# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

501 Eastowne Dr., Suite 250  Chapel Hill, North Carolina 27514

Telephone: (919) 484

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# MEMORANDUM

TO: Gil Wood, USEPA

David Cole, USEPA

FROM: Jill Mozier, EC/R Inc.

DATE: September 2 7 , 2013

SUBJECT: Notes from September 1 9 , 2013 presentation by Hearthstone, Jotul, and Stove Builder

International (SBI) to EPA regarding wood stove consumer expectations and likely

behavior in response to NSPS , and concerns from non

- catalytic manufacturers

.

Attendees (at EPA, RTP, NC) :

EPA Non

- Cat alytic Manufacturer EC/R

Gil Wood Dav id Kuhfahl, Hearthstone Jill Mozier

Greg Green Marc

- Antoine Cantin, SBI

Kimber Scavo Roger Purinton, Jotul

Larry Sorrels

David Cole

Mike Toney

David Kuhfahl from Heathstone led the presentation ( “The Future of Wood Heat

– 2013 and Beyond”,

attached) . He noted that after last year’s trade group his company and others formed an informal group

which represents ~37% of total non

- pellet cordwood industry (manufacturers in this informal group are

listed in the attached) . He further noted that non

- catalytic stoves represent 73% of sales , which include

non

- cat cordwood woodstoves and forced air furnaces ( this group does not includ e hydronic heaters

which t he y consider part of the problem for the industry).

This informal non

- cat cordwood group of manufacturers agree with the NSPS initiative, but wants EPA

to set “reasonable, real world” emission limits. He noted that industry should do its part, that the real

efficiency of appliances should be reported. He noted that uncertified stoves emit 5 to 20 times what

certified stoves do and that this group of manufacturers he’s speaking on behalf of only manufactures

certified stove s . Part of the problem, according to this group, is that exempt units are imported f rom China for example. These importers don’t report their numbers to HPBA, but there are many of them.

[Gil Wood noted that EPA is attempting to close th is loophole with the proposed NSPS.]

Roger Purinton noted that Jotul is willing to give up making parts for old stoves because it’s the right

thing to do. He agreed that there are lots of rebuild & replace; that the sale of uncertified stoves needs to

stop. [Gil noted that while he personally agrees, and hopes EPA will continue to educate consumers, this

piece is not part of the NSPS regulatory package

– it’s not under NSPS’ purview.] Marc

- Antoine Cantin

said that no one should forget that homeowners have a choice, that it’s too easy for consu mers to buy

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u ncertified stoves. [Greg Green encouraged the manufacturers to continue to give this message. Gil

noted there has been some success in Oregon with removal of old stoves when homes are re

- s old .]

Roger noted that Europe has been very successful in getting ri d of old, dirty stoves in homes.

David noted that part of the decline in woodstove sales happened after the 1988 NSPS and consumers

could no longer find stoves for < $200. David further noted that the group does not necessarily see

catalysts as a good thing. When Greg Green asked what their issue is with catalysts, David noted that

they have many issues and the presentation will address those.

David said he’d provid e a copy of the consumer survey upon which his presentation is based entitled

“Wood Stove/Fireplace Emissions Study

– Impact on Product Replacement & Consumer Opinions

Supplemental Report

– Products Combined” conducted by the Stevenson Company. He presente d his

power point slides (attached to this memo ), noting that what consumers are looking for has changed in

the last 10 years

– that is, while price is still the #1 concern, efficiency is now the #2 concern and this

concern for efficiency was not so import ant 10 years ago. He also noted that the lower cost steel stove

market has grown, while the more expensive cast iron stove market has declined due partly to the lower

natural gas prices. (Gas burning, in his observation, tends to be based on discretionary income, including

especially burning in decorative gas appliances.)

Roger noted that wood heaters, unlike other appliances, have efficiencies that are significantly impacted

by human factors. [Gil noted that there are a number of efficiency calculators ou t there, but they may not

be providing much payback

– it’s unclear to what extent the average consumers are paying attention to

how to operate their wood heaters.] Roger noted that in his observation the efficiency questions come

from engineers and the lik e, not necessarily from the average homeowner. Marc noted that people

[ including manufacturers, labs, countries] measure efficiency differently so that there exists different

numbers for the same or similar stoves

– this is confusing to customers. [Gil not ed that the proposed

NSPS will hopefully clarify the situation of LHV versus HHV, 8

- hour burn rates, and CSA B415.10.]

Roger noted that because he works for Jotul, he’s familiar with the European test method and mentioned

an example of one European lab in particular that gets amazingly high efficiency numbers. In general,

Roger has noticed that the efficiencies of European stoves are much lower when tested with non

European test methods and he generally concludes therefore that European technology is not su perior to

North American technology; they are merely using a different test method. Marc agreed, noting that in

the Czech Republic the efficiency is calculated over one burn rate

– the sweet spot essentially

– so the

efficiencies look great

– but in North America, manufacturers get penalized by burn rate categories that

aren’t typical (eg., low burn rates that cause smoldering). Marc later noted that , on the other side of the

spectrum, in Australia, 60% is a good number since the efficiency has to be calcul ated over 3 burn rates

– so Australian efficiencies are lower than Europe or Canada.

David noted that the reason efficiency is now the #2 concern is due largely to internet pre

- shopping and

reading of Alliance for Green Heat articles. David further noted the confusion over the hang tag default

numbers, which the manufacturers never certified to, the confusion caused by hang tag versus marketing

brochure numbers, and the confusion caused by combustion efficiency versus thermal efficiency versus

a hybrid of the two. David concluded that manufacturers have never had an “efficiency pond” to play in,

so agreed upon test methods and uniform reporting requirements need to be determined . [Gil noted that

this is EPA’s aim/hope in the draft NSPS proposal.]

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David an d Roger noted that some consumers are in principle opposed to pellet stoves because they want

to be off

- grid and don’t want a wood heater that requires electricity.

Regarding the problem with catalytic stoves, David noted that a non

- cat stove is designed to pass the

Washington standards with one easy

- to

- use air control lever. A cat stove has a minimum of one air

control lever plus a bypass damper. [ Personal anecdote

- David owned a cat stove in his home years ago

and the catalyst never, over many years, e ngaged properly. ] David highlighted t hat 79% of cat alytic

stove owners do know why the cat alyst exists but they still often operate the stove with the damper open

without the cat engaged

– because the stove can smoke if the damper is prematurely closed b efore

catalyst “light

- off”

– so the design isn’t working well for some consumers

– therefore there’s no net

improvement in air quality when that occurs . In the end, the cat stove can be dirtier than the non

- cat

stove when the operat or fails to engage the catalyst properly (e.g., may attain 2.5 g/hr with the damper

closed / engaged on a cat, but when it’s open the emissions are ~21 g/hr). Marc further highlighted that

for cat stove owners of < 5 years, 63% have replaced the catalyst. (Note: in answer to an e arlier

question, Marc clarified that the consumers who participated in the survey were educated before each

question

– so, for example, they did know what a catalyst was.) David concluded that the average life of

a catalyst is 5 years

– and that after 5 y ears the lab numbers are 4.5 g/hr for non

- cat stoves but

~ 8. 1 g/hr

for cat stoves.

Thus the non

- cat manufacturers have a concern that people believe cat alytic stove s are a panacea, when

they are not. [Gil noted that the NSPS proposal is getting away fro m 2 different emission standar d s for

cat and non

- cat stoves. Manufacturers will be able to figure out how to best get to the emission

standard.] Marc responded that the difficulty in the non

- cat manufacturers figuring it out is that the

number is low due t o cat alytic numbers. [Gil noted that some non

- cat stoves can already achieve these

numbers.] Marc continued that the manufacturers will take a short

- cut, have a panic reaction, and turn to

production of catalytic stoves, but this will cause a worse environ mental situation (due to issues noted

above), plus higher prices will drive consumers away from purchasing new stoves and encourage them

to keep their old stoves

. Roger noted that even if given 5 years to get a non

- cat stove to achieve lower

numbers, getti ng those lower numbers with a cat stove is a sure thing and can occur in 1 year

– so

industry will naturally move in that direction. David noted that cat stoves are hard to operate and that the

efficiencies according to the Catalytic Hearth Coalition are n ot necessarily real. David noted that the

consumer survey revealed that >40% of cat stoves were burned in bypass of the catalyst mode.

T he non

- cat manufacturers represented at this meeting concluded that they want the Washington

Standard (2.5 g/hr for ca t stoves; 4.5 g/hr for non

- cat stoves) and want the market to force emissions

down with better technology. David stated that they also want a standardized method for efficiencies,

but not a regulating efficiency level , so that they could build the dataset

. [Gil earlier noted that the draft

proposal is requiring the reporting of efficiencies, but not setting an efficiency standard.] David further

noted that manufacturers need 5 years to transition to cordwood. Marc expounded that manufacturers

can go from crib to cord, or can go to a lower emission number but cannot achieve all of these things at

once, especially not at the prescribed burn rates, and definitely not at fireboxes > 3 cubic feet. Marc

later noted that it is unrealistic of WESTAR and NESCAUM to push for 1.3 g/hr and for cordwood and

across all burn rates. David and Roger agreed that they have no idea if they can achieve 4.5 g/hr with

cordwood. [Gil noted that Rick Curkeet has said c ribs are just as variable as cordwood.] Marc said he

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agrees with Rick’s basic argument which is to design the unit based on how homeowners will actually

use it. [Gil agreed this is a persuasive argument and wanted labs to replicate real

- world home use as

m uch as possible.] Marc further suggested that the minimum burn rate with cordwood should be a

percentage of the maximum burn rate

– that a 1 k g /hr burn rate will never work, since a hot start is

required. SBI opens 25% of air intake, otherwise stove choke s and doesn’t light, especially with dense

wood. Thus the minimum burn rate “ is a killer ” , especially for the bigger fireboxes. David concluded

that the non

- cat manufacturers represented would like EPA to consider the minimum burn rate issue, and

re

- iterat ed that they want market pressure to drive industry. He further noted that anything < 4.5 g/hr is a

crap shoot and just luck of the draw.

Gil expressed thanks for the data in the survey (which the manufacturers noted cost > $20,000). Gil

further concluded that EPA is looking at the best systems of emission reduction

– that there is lots of

pressure to get to the truly best performance level s . While only a handful of models and manufacturers

may be there now, EPA is giving 5 years for everyone to get there. Marc responded that 5 years is not a

lot of time. He explained that it takes 1 year to get a model under 4.5 g/hr but then his company also

needs to get 14 other models there. Even the certification testing of so many mode ls is problematic

because humidity in the air matters, for example. Ben Myren has suggested not testing during high

humidity

– so everyone is choosing labs out west. [ Gil assured everyone that this is a proposal, not the

final rule, and that there will be a public comment period. ]

Roger noted that Jotul is transparent and that while BDT is not focussed only on clean air, he frankly

sees potential for proposed stricter standards to create a safety concern. He noted that he is not yet ready

to provide data o n this, but will first need to confirm his suspicions and then provide information to Gil

related to this potential safety concern.

In answer to a question from Greg regarding how different are the design s of the 14 models SBI would

reportedly need to per form R&D on, Mark explained that SBI produces strictly solid fuel heaters (3

pellet units, 3 fireplace insert firebox designs, and 3 FAF designs). SBI needs 3 fireboxes in each

application of FAF, fireplaces, and pellet stoves and the company cannot accomp lish that for all of these

models in 5 years. Marc further noted that while the 1.3 g/hr looks sexy on paper, there is no true

environmental benefit, i n his opinion (due to issue of driving industry towards catalytic stoves and

c onsumer s leaving damper s op en on cat stoves, note d above). Marc later expounded that the 14 units use

the same technology throughout but are “ different enough ” , and that 1 to 1.5 years per unit are needed

for R&D at $300,000 per unit/model (steel design). David noted that the costs for cast iron stoves are

nearly twice that, or ~$600,00 0 for R&D per model.

Roger noted that the old stoves will be around for another 30 years and that until we get rid of the old

stoves, there will be no measurable improvement in airshed. [Gil noted th at the NSPS will not be an

immediate fix and that nationwide changeouts could give a bigger health benefit quicker than the NSPS

and that is why EPA has encouraged and is continuing to encourage changeout as quickly as possible .]

Roger noted that Jotul is doing a “cash for clunkers” program that is quite successful

– people can get

$500 out of the deal. He also noted that there are encouraging units out there

– for example, a pressed

vermiculite stove design that gets very good numbers, but it’s too fragil e for in home use

– the loading

of wood cracks the unit.Wood stovefmanuacturers askingfor a common senseapproach to the future.Concerningthe“StandardsofPerformanceforNewResidentialWoodHeaters,NewResidentialHydronicHeatersandForcedAirF rnacesandHeaters‐Furnaces,NewResidentialMasonryHeaters”ResidentialMasonryHeaters.Who are we?We are a group of manufacturers that make anddistributefreestandingandbuilt-inEPACertifieddistributestandingCertifiedwood fired products in North America:JtlNAouSBIHearthStonePacific EnergyNapoleon – Wolf SteelICC – RSFRegency–FPITogether, we represent 37% of the total industry 2012 USshipments of EPA certified appliances.NSPS 2013EPA states that this proposal “updates the 1988 NSPS toreflect significant advancements in wood heater technologiesand design, broadens the range of residential wood-heatingappliances covered by theregulation, and improves andt li i l t ti d ”streamlinesimplementation procedures.”EPA further states that the rule “is expected to requiremanufacturers to redesign wood heaters to be cleaner andlower emitting” and that these changes would provide forbetter and more efficient performance.We agree with the NSPS initiative1.EPA is tasked to regulate emissions for wood burningappliances2.EPA should set forward reasonable emissions limits3.The industry must do its part at improving air quality whileproviding wood burning appliances to homeowners for primaryor supplemental heat4.We should be reporting our appliances’ real efficiency5.New, uncertified wood burning appliances should be a thing ofthe past6.The sale of any used uncertified stoves should be stoppedWhat is right to do?We believe thatencouraging locallysourced, renewableb tlTimenear carbon neutralheat is beneficialto everyone’s future.CleanCombustionWhat is right to do?When a tree rotsnaturally or burns,the carboncontained in thedi l dwoos releasedback to theatmosphere.How Can We Do It?We, as manufacturers; want to be able to continue offeringldb ilitllcean woournng appanceso a:Clean burning heaters, from compact simple stoves for asmaller budget / need tolargersophisticated fireplaces forsmallerbudget/needtosophisticatedfireplacesforbigger budgets / need and anything in betweenWith or without catalystWe, as an industry must:Consider consumer preferences: price, efficiency and userfriendlinessAlways respect EPA regulationsWhat do weKnow?We sought out an independent surveyfirm topyreveal consumer preferences and help usunderstand their likely behavior.This 15 minute survey conducted in June of 2013This15minutesurveyconductedinJuneof2013is the most recent survey conducted in ourindustry.Wood Stove/Fireplace Emissions StudyImpact On Product Replacement & Consumer Opinions7/11/2013What do WeKnow?610 relevant consumers as a data base:○539 were currently hearth product owners○71 were purchase “intenders”This significant data set gives us insight into consumerpreferences and expectationsto help us then understand thelikelybehavior of thegeneralpopulation.g ppSample size precision is estimated at ± 4.0 percentage points ata 95% confidence level.a95%confidencelevel.Note: The survey excluded decorative fireplace owners. It strictly concentratedon wood heater owners,includingthose usingfreestandingstoves,built-in stoves,g g g,and stoves inserts.Who Answered our Survey?Location of the AppliancesOwnership and intentPurpose and frequency of useWhat do consumers care about?The #1 Decision Making Reason toS l tNWdBi A liieecaewoourningAppliances:Price $$1.The Stevenson Company Survey was clear.Price$$2.In 2012 sales, HPBA manufacturer’s data shows anoverall decline (-23.7%) in higher cost Cast IronEPA wood stove volume with an average wholesaleof $1230, while the lower cost Steel EPA woodstoves with an average wholesale of $752 enjoyedi f 20 6%anincrease of20.6%.Are Homeowners Likely to Spend 500$Premium for Catalytic or “New Technology”?gyAre Owners more Likely to Fix Their Current ApplianceorFindaUsed “Previous Technology”Appliance?Previous Technology”Appliance?The #2DecisionMakingReasontoSelectaNewDecisionWood Burning Product is:Efficiency!Currently reported efficiencies are confusing toCurrentlyreportedefficienciesareconfusingtoconsumers;Industry needs and supports the idea of a simplestandardized method of calculating and reportingffi iecency.Natural Draft Appliances and EfficiencyOur consumers want energy independenceand power free reliability.Wood heaters are natural draft appliances:They continue to work during power failure.They generate theirown powerto create andmaintain draft.The#3 Consumer preference is:User Friendly Controls and Ease of Use!A non catalytic wood stove is designed to pass thei ti t i t W hi t St t t d d ithexisting stringentWashingtonState standardwithone air control lever, “Low to High” with a passivenon-cat secondaryburn system. Easyto use.yA catalytic wood stove can also be designed topass the existing Washington State standard but ithas at minimum one air control lever and a bypassdamper that needs to beproperlyoperated to burnpp ypclean.Catalytic Stove Owners say...What Happens if a Typical Cat Appliance isNot Operated Properly?pyOpen Closed BurnedOpen BurnedClosedDamperAlwayswithdamperopen 21%100% 0% 21% 0%Oftenwithdamperopen 22%75% 25% 17% 6%Sometimeswithdamperopen 29%50% 50% 15% 15%Rarelywithdamperopen 19%25% 75% 5% 14%Nithd9%0%100%0%9%21.0013.00Neverwithdamperopen9%0%100%0%9%Average 57% 43%Cat emissions assumptionCat Emissions vs. Non Cat2.50Emissionswithdamperclosed4.5OverallaverageemissionsforatypicalcatapplianceEmissionswithdamperclosedEmissionswithdamperopenypppEmissionsofnon‐catapplianceAssumptions:All appliances have a catalyst in working condition and are at 2.5g/h, as per the currentWashington State limit.Catappliance emissions with the damper open are equivalent to the emissions of an uncertifiedstove at 21 g/h from reference (1)applianceemissionswiththedamperopenareequivalenttotheemissionsofanuncertifiedstoveat21g/hfromreference(1)Reference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models with U.S. EPACertification Emission Values anda Comparison with Emissions from UncertifiedWood Stoves, James E. Houck, 2011-10-31, Figure10Catalytic stove age and expectedMaintenanceWhat Happens if Cat Appliances are NotM i i d P l ?Maintained Properly?Yes No Working NotWorking CatWorking CatNotWorkingCatreplaced UnreplacedCat LikelyfunctionalCatsCatAppliance<5yrs32% 63% 37% 100% 0% 100% 0%5‐10yrs25% 48% 52% 80% 20% 90% 10%10‐20yrs15% 42% 58% 20% 80% 54% 46%20+yrs13% 36% 64% 0% 100% 36% 64%A70%30%8.0874.521.00Average70%30%Cat Emissions assumptionCat Emissions vs. Non CatOverallaverageemissionsforatypicalcatapplianceEmissionsofnon‐catappliance2.50EmissionswithcatworkingEmissionswithcatnotworkingAssumptions:All appliances with a catalyst inworking condition and are at2.5g/h, as per the currentWashington State limit.Cat appliance emissions with the catalystnot working are equivalent to the emissionsof an uncertified stove at 21 g/h from reference (1)EmissionsofnoncatapplianceEmissionswithcatnotworkingReference: (1) Comparison of Particulate Emission Rates from the In-Home Use of Certified Wood Stove Models with U.S. EPACertification Emission Values anda Comparison with Emissions from UncertifiedWood Stoves, James E. Houck, 2011-10-31, Figure10What are dealers saying aboutC l i h ?Catalyticheaters?From a dealer web site:“...Among the disadvantages is that learning to how to usethe catalyst to get the best efficiency is a bit more tricky thana non-catalytic stove, and many manuals for catalytic stovesarenotveryhelpfulWeatCustomFireplaces&Morehavehelpful.Fireplaceswritten our own "Catalytic Woodstove 101" guide, whichexplains how to get the best out of the catalyst step by stepwhen breaking in a new stove. We also make ourselvesavailable to answer any questions a new stove owner mayhave. Eventually, the catalyst willhave to be replaced....“From: http://www.customfireplacesandmore.com/hearth-articles/catalytic-non-catalytic.htmlCatalytic wood heatersThe Catalytic Hearth Coalition said:Regarding Efficiency: “....catalytic stoves are more efficientthen their non-catalytic counterparts. As you know, this hasbeen recognized for some time as manifested in the defaultefficiencies of 72% for catalyst stoves compared to 63% fornon-catalyst woodstoves in the current NSPS.”The default efficiency were derived based on a smallnumber of appliances 25 years ago.It was annumberofappliances25yearsago.Itwasanacceptable average back then, probably not veryrelevant today.Catalytic CombustorsThe Catalytic Hearth Coalition said:“A longevity study ontwocatalytic appliances was performed andconcluded that after 9 years those cats were still in workingcondition.”Omni tests on the two cats justconfirmed that those two catsare in the average for longevity.Our survey revealed that morethan 40% of appliances areburned always or often on bypass. In fact, these cats may onlyhave the equivalent of 4.5 years of usage or no use at all.By comparison, the Stevenson Company survey interviewed atotal of 610 consumers. Sample size precision is estimated at± 4.0 percentage points at a 95% confidence level.Catalytic CombustorsThe Catalytic Hearth Coalition showed a home heatingcomparison between a Washington 4.5g/h non-cat stove with75% efficiency and a 1.76g/h cat stove with 82.5% efficiency.A tE l tirecentvauationof Overall Efficiencyfor EPA CertifiedNon-catalytic WoodHeaters showed nocorrelation betweenemissions andoverall efficiencyoverallefficiency.Ferguson, Andors & company, July 2011Catalytic CombustorsSome thoughts:Cat appliances burn without flames. Some people are lessthan enthusiastic about the flameless fire.Catalytic stoves work well in a laboratory but it ismisleading to believe that the air quality will be protectedwhen the homeowner hasthe very simple choice of notwhenthehomeownerhastheverysimplechoiceofnotengaging the catalyst at all, or ignoring maintenanceneeds.○The Stevenson survey revealed over 40% of homeownersuse their catalytic appliance with the bypass “always” or“often” open.What do We Want?We want the EPA:To continue to regulate wood-heater performance bypromulgatingthe current Washington emission limitsgg gwhich will have a better impact on the emissionsinventory than forcing higher prices and “userunfriendly” technology:e dyo ogy2.5 g/h for catalytic appliancesto offset the risks of not replacing the catalytic combustorand not using the bypass properly4.5 g/h for non-catalytic appliancesWhat do We Want?We want the EPA:To select a standardized method ofmeasuringandreportingefficiency for wood burningappliances that reflect the way homeowners usetheir wood heater.To measure and report efficiency,not regulateit.What do We Want?We want the EPA:To consider realistic minimum burn rates toaccommodate larger stovesWhat do We Want?We want the EPA:To allowmarket pressuresto direct manufacturersto come up with cost effective, user-friendlytechnologies to reduce the emissions of theirappliances. EPA needs to recognize that bysettingg y gthe target for non-cat wood heaters at 4.5g/h, manymanufacturers will end-up with better results.Simply Clean CombustionThank You!