E-mail

From: "cneufeld" <cneufeld@bmi.net>

To: Gil Wood/RTP/USEPA/US@EPA

Date: 04/09/2012 10:26 AM

Subject: RE: CHC Concerns

Gil:

You are correct. Engineering time required to develop a catalytic wood stove is far less than a non 

catalytic. In fact, since the fall of 2010, we developed, tested and received EPA approval for two different 

catalytic fireboxes. We have a single engineer, Mr. Ivo Hoovers, who developed both fireboxes.

As for patents, ours expired many, many years ago. In fact, the hybrid wood stove patent that another 

manufacture has applied for is somewhat interesting. In 1983, Blaze King built, by current definitions, a 

hybrid wood stove. It used both secondary air tubes and a catalytic combustor. We have advised the 

patent office of this fact.

In 2011, at our industry Expo (you were present as I recall) major players did not display catalytic wood 

stoves. One year later, Travis, Regency and others are all now promoting the catalytic models they have 

made and that are coming to market. One of the most outspoken manufacturers, with solid political 

connections, does not even know that his anti-catalytic statements in past are about to cause some 

awkwardness. Their corporate offices and engineering labs overseas are buying combustors for their 

new catalytic prototypes!

As for the old R & C (research and copy) it is indeed far more prevalent that you might ever imagine. As 

far as catalyst suppliers, they will sell without restriction. In fact, in the past year, several new US 

suppliers have really picked up on the market potential and have approached wood stove manufacturers.

There are at least 7 manufacturers, Blaze King, Woodstock Soapstone, Vermont Castings, Kuma, Buck, 

Regency, Travis, and others currently making or introducing catalytic models. I would expect that a 

single standard would encourage manufacturers to make cleaner burning stoves, both catalytic and non 

catalytic;ytic alike.

What I feel is important, as you know since I have said this so many times in the past three years, testing 

requirements and standards should both reflect and be based upon how wood stoves are used in a home 

not a test lab. Wood stoves spend 80% of their time on low settings. Catalytic wood stoves shine on 

the lowest settings and even on high burn are cleaner than most non catalytic models.

Keep in mind that if a catalytic wood stove is certified at 1.0 gr/hr., that is the average based on the four 

burns. In fact, since 80% of the time the stove is actually burned on a lower setting, the emissions are 

much, much lower than 1.0 gr/hr.

In a non catalytic model, you have the inverse scenario. A non catalytic model certified at 3.5 gr/hr, 

spending 80% of the time on low, is actually producing more than 3.5 since low is where they burn 

dirtiest.

Now you can see why industry wants to increase the low burn rate by 15% to 1.15kg/hr. It's just out right 

game playing.

I was on a call two weeks ago with most of the industry executives and they were complaining about the 
70% HHV efficiency requirement stating that 30% of the stoves on the market would not make that 

number. I spoke up and said, " In the pest two years you have all beat your chests and said your stoves 

were more than 75% efficient so your products would qualify for the tax credit. Now, the HHV efficiency 

gets introduced, which is more reflective of real world use and you're all worked up about it."

They met with EPA staff last week to raise their concerns over the matters and I hope EPA stays the 

course! I will loose two models, but that's o.k., we'll just innovate, build cleaner and more efficient 

models. Isn't that what the NSPS is all about?

Thanks

Chris

PS I am off to by a bullet proof vest for my next industry wide meeting.

From: Gil Wood [mailto:Wood.Gil@epamail.epa.gov] 

Sent: Monday, April 09, 2012 6:19 AM

To: cneufeld

Subject: RE: CHC Concerns

Thank you for the confidential cost info Chris!

A continuing issue for having one emission limit for both catalytic and noncatalytic stoves is the cost for 

R& D for noncatalytic manufacturers to develop catalytic stoves [or other low emission systems] that meet 

the tighter emission limits that catalytic stoves can already easily meet...

To me, it seems like a manufacturer or consultant that has experience developing EPA-certified 

noncatalytic stoves could also develop a new catalytic stove a lot cheaper than what it took for them to 

develop their EPA-certified noncatalytic stove... since presumably they already know a lot about 

combustion and materials and the catalyst will do a lot of the additional work to get the emissions even 

lower... Would one engineer for a year seem reasonable?

How solid are the stove patents for BlazeKing and other companies that make catalytic stoves? I 

presume some competitors will try to reverse engineer from what they see from your stoves... 

Do you sell licenses for your stove catalyst integration technology?

I presume there are no limits by the catalyst manufacturers on buying/using their catalysts, right?

How long do you think it would take to meet the total stove demand mostly by catalytic stoves instead of 

mostly noncats?

Thanks again.

Gil