Residential Wood Heater NSPS:

Improving Wood Technologies in the 

Residential Heating Market

Presented to the White House Office of Management and B

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Mark Torpey, Director of R&D, New York State Energy Research and Development Authority (NYSEMark Watson, Program Manager for Environmental Research and Energy Resources R&D, NYSEREllen Burkhard, Ph.D., Senior Project Manager, NYSERD

A

Mark Odell, Vice President, Econoburn, LLCDale Furman, Managing Member, Hydronic Specialty Supply LLCLou Okonski, COO, Evo World Inc.Arthur Marin, Executive Director, Northeast States for Coordinated Air Use Management (NESCAUMLisa Rector, Senior Policy Analyst, NESCAUMDrew Wayne, Office of Congressman Tom Reed

January 26, 2015
• Residential heating markets account for about on

quarter of New York’s wood harvests

• Biomass central heating units have the highest P

emissions

• ~560,000 wood heating units in NYS • In NYS, PM emissions from residential wood com

are greater than those from electric generation otransportation, yet wood is used in <2% of NY ho

• New York is currently home to five advanced tec

wood boiler manufacturers

Biomass Heating: an important issue in 

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• 8 years of research, development and demonstration of bio

heating

• $8 million of NYSERDA funds, plus $7 million for new proje

– product development, evaluation, and demonstration– test method development for residential and commercial biomass boil– fuel characterization and regional consensus building for fuel standard– air quality and health effects research

• New generation of biothermal technology has dramatically 

the efficiency performance and emissions profile of wood hequipment but without a high standard, these companies w

• Wood Heat Roadmap

– understanding of the importance of proper sizing, the use of thermal s

proper test methods to assess actual performance in the field. 

• Many states outside of NY rely on information from NYSER

NYSERDA’s Biomass Heating R&D prog
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• Governor’s initiative• Multi-pronged market development strate

stimulate growth in the high-efficiency, low

emitting biomass heat industry

• $20 million, long-term commitment• Fuel production and distribution, sustaina

forest management, equipment manufactsales and installation, workforce training adevelopment

Renewable Heat New York 
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Air Quality
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• Wood smoke dominates PM in rural NYS• Wood smoke contributes 30% of the wintertime PM in Roc• Sub-daily concentrations of wood smoke PM are measure

relevant levels, even in rural areas 

• NYS has a goal to reduce exposure to wood smoke polluti

• New York is looking to support high-efficiency and low-em

wood boiler heating systems, with increasing standards ov

• New York is also providing incentives to retire outdoor woo

indoor wood boilers, whole house wood furnaces, and woo

• We have learned much about the technical capabilities an

requirements to help us attain our energy and environmen

Air Quality 
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15,968

1,509 127 80 2,930 2,652 2,465 650

0

2,0004,0006,0008,000

10,00012,00014,00016,00018,000

Annual Tons PM2.5

PM2.5 Emissions by Key Source Ty

Wood: heats 1.2% NY homes primary heat &~453,000 st

Natural gas: heats 51.7% NY homes (>3.6million)

Home heating oil: heats 33.1% of NY homes (>2
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Results of Modeling a Phase 2 OWB based on emissions from M28HH with background

Modeling 24-hr Impacts

Results of Modeling a Phbased on emission profile testing w/out background
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Emission Scenario ConcentratiEPA NAAQS 35 Neighborhood Scenario - ValleyScenario 1: Growth with Step 1 technology 58.8 Scenario 2:Growth with Step 2 technology 27.4 Neighborhood Scenario - MountainScenario 1: Growth with Step 1 technology 66.4 Scenario 2:Growth with Step 2 technology 24.6 Neighborhood Scenario – Urban/suburbanScenario 1: Growth with Step 1 technology 62.9 Scenario 2:Growth with Step 2 technology 30.5 

The Future: Step 1 vs Step 
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Technologies & Test Me
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Important advances in wood boiler technolo

Outdoor Wood Hydronic Heater Two-stage, downdraft gasifica

(low-mass boiler) with therma

• Completely different design principals from the outdoor wood hydronic he• Low mass technologies – advanced technologies - cannot be evaluated 

Method 28 WHH

• Lack of a test method became a significant market barrier• Barriers from traditional avenues for test method creation so NYSERDA 

assistance from Brookhaven National Lab
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More rigorous evaluation yet simpler and more cost effective to 

• Test fuel: cord wood NOT dimensional lumber• Measurements of cold start (Cat I) and hot start (Cat IV) • Efficiency is measured by thermal output, more rigorous 

than stack loss measurement used in several proposed test methods

• PM and CO measurements provide emissions at different 

phases of the burn [start-up, steady-state, and end phases (critical for future design improvements)]

Anticipated reduction in testing costs from $25K to $10K• Commercial labs have refused to test using the BNL –PTS 

method even though EPA and states accepted its use as a test method in regulatory and voluntary programs

Brookhaven National Lab (BNL) Partial Thermal Storage 

Test Method

Develofinancand EPGreat air regThermNY Bioand madvanboilers
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Device Test Method PM Emissions EfficienFroling EN303-5 0.06 lb/mmBtu

g/hr cannot be calculated

Froling BNL PTS 0.18 lb/mmBtu

Max run 7.3 g/hr

Annual 

HSS BNP PTS 0.28 lb/mmBtu

Max run 14 g/hr

Annual 

Comparing Test Results

In order to better serve the consumer:• Eliminate comparison of emissions across different test methods• Adjust the g/hr cap from 7.5 to 18 g/hr for devices that use test methods including s• Outlaw the use of hang tags and use of emissions and efficiency data in marketing m

tested by methods that do not use cord wood or include start-up emissions. Only allobe sold as “certified”

• Allow the use of hangtags and marketing of emissions and efficiency data for units te

cordwood by methods that include start up emissions
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10

1.51

0.22 0.08 0.00004

02468

1012

lbs of PM per day

lbs o

Performance Comparison Across a Common Dut

Research projects conducted by EPA ORD and BNL
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Commercial Test Lab Capacity
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• Reviewed 23 test reports• 90% (21 of 23 reports) found missing or questionable da• Issues included deviations from test protocol, unreported 

and basic math errors

• Testing was conducted by labs that were EPA-certified a

accredited

• Issues continue as states review test reports for their reg

programs

• Significant questions remain about capabilities, capacitie

impartiality

Review of EPA Accredited Labs Test R
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New York Manufacture
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Mark Odell, Vice President

Econoburn – Made-in-the-U

• Econoburn of Brocton, NY is a manufacturer of a Made-in-the-USA 

down-draft wood boiler.

• The EPA Voluntary method has depended solely on M28 WHH and 

has created a market barrier for our superior technology because M28 WHH cannot evaluate low mass boilers like the Econoburn. 

• Some state regulations have used the EPA Voluntary list or depended 

on M28 WHH to develop regulations. The lack of a test method appropriate for our units effectively blocked Econoburn from key markets.

• Consumers have had the perception that if Econoburn is not listed by 

EPA it isn’t clean and efficient. EPA ORD’s own research showed this was not the case and in fact our unit was cleaner than EPA qualified devices
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Market Barriers – EPA accredited test laboratories• Econoburn is the first Made-in-the USA technology to pass the BNL-PTS• The BNL-PTS is the most complete and comprehensive test for our boile• Econoburn is proud to finally be approved by the NYSDEC and NYSERD

Renewable Heat NY program.

• We are frustrated that while EPA accepts the BNL-PTS, and recognizes 

accredited test lab, EPA cannot accept our test result because of a confowhich is impossible for a government laboratory to obtain

• Barriers created by the accredited labs have resulted in a significant loss 

share. Without being listed on EPA’s voluntary program, we have not beenter key markets.

• Our future appears to hang in the balance of four EPA accredited test lab

are refusing to test by the EPA accepted BNL-PTS method. 

Econoburn – Made-in-the U
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Recommendations:

• EPA accredited test labs must not be allowed to dictate what test metho• Labs appear to be blocking markets by refusing to conduct tests, this ra

about impartiality of the commercial labs. The rule must ensure that the are impartial evaluators without perceptions of financial conflict of intere

• While we can easily meet the weighted annual output emissions rate of 

lb/MMBtu, we respectfully request a limit of 18 g/h for any burn category tested by the BNL PTS method.

• Econoburn has gone to great effort to make improvements to our techno

combustion chamber geometry, the addition of an oxygen sensor and small to optimize combustion, increase efficiency and minimize emissions. clean burning technology. 

• Other companies have not made the investments that we have. Who do 

reward? 

Econoburn Made-in-the-US
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Final comment:• If you make a weak rule, you will reward those who made no effort to imp

products and continue to sell dirty technology. This will further hurt Econsmall business that has worked hard to produce efficient and clean burni

• The longer you delay implementing good test methods and achievable e

standards, the longer we have an uneven playing field. 

• Consumers need to know which units will perform better in the field. The 

seek to provide special hangtags to units that test with cordwood and staemissions so they can easily be identified by the consumer. These units receive special recognition on EPA’s website.

• Who should really benefit? Those who innovate or those who refuse to d

Econoburn – Made-in-the-U
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Dale Furman, Managing Member

Hydronic Specialty Supply- Made-in-the-

• HSS is a new Made-in-USA manufacturer o

cord wood boiler located in Western NY. 

• HSS saw the need in the market for better 

has invested heavily to commercialize this clean down-draft wood boiler technology.

• HSS has been tested at BNL on the BNL P

We passed and those results are now undeNYSDEC. 

• HSS echoes the comments made by Econo

reward dirty technology, reward innovation.

• Do not allow the accredited test labs to dict

methods are used and seek to make them evaluators without perceptions of financial cinterest.

• Set a realistic category maximum emission

per Category for units tested in start-up conAnything less is too low at this time and wiltechnologies from the market.
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Lou Okonski, COO 

Evo World Made-in-the-US

• Evo World is a Made-in-USA manufact

from a new partnership of a third-geneboiler manufacturer based in Troy, NY Austrian pellet boiler manufacturer.

• Evo World manufactures high-efficienc

that perform best with thermal storagehas been accepted by the RHNY progthe use of thermal storage. 

• Pellet boilers will not be as clean or eff

without thermal storage. If the unit is nwith storage, it must be tested with EPanything else will not be representative performance.

• Shortly we will have data that compare

with and without thermal storage. Whilconfident that we can test and be passM28 WHH method, it is not the way we unit to be installed. 
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• We urge the use of the BNL PTS test method 

and requirement that those who test by it install their pellet boiler with thermal storage so there is no confusion for the customer. 

• All others wishing to install without thermal 

storage should test by EPA’s M-28 WHH.

• Hangtags must provide clear performance 

information for consumers. If units are tested with real world tests, they should have hangtags

• EvoWorld also echoes the comments by 

Econoburn

– Reward innovation, not dirty technology. – Do not allow the accredited test labs to 

dictate what test methods are used 

– ISO and EPA certified labs must become 

impartial evaluators without real or perceived financial conflict of interest. 

Evo World Made-in-the US
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• New York is committed to supporting high-efficiency and low-emissions w

heating systems.

• We must not reverse any recent improvements in air quality, nor create n

risks associated with wood combustion. A major goal is to reduce expossmoke pollution and prevent non-attainment of the NAAQS. 

• Not all test methods are equal. The use of the ASTM test method, and re

EPA acredited test labs to use the BNL-PTS test method, are barriers to U.S. biomass technologies.

• Approved test methods must include the efficiency and emissions measu

the full operation of the unit, not just best case. This is the only way to acharacterize in-field use. 

• Accept only the BNL-PTS for down-draft units, it allows the necessary inf

further innovation.

• Allow maximum 18 g/h of PM in Category run for units that include start-u

• CO needs to be measured and reported as part of any approved test me

Summary
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• We need access to emission reports so data can be scrutinized. The only 

forward for a vibrant wood heat industry is one which optimizes both eneand environmental performance. 

• Provide a hang tag only for those units tested on cord wood or pellets wit

comprehensive start-up, steady-state and end-phase emissions testing.

• Remove confusion in the marketplace, do not allow marketing of efficienc

emissions performance determined on any test method other than one uwood or pellets and measuring all phases of the burn.

• Remove market barriers created by test labs and void accreditation for la

test by EPA approved methods such as the BNL-PTS.

• Require boilers testing with thermal storage to include it in the installation

• Manufacturers must test on all fuel types that they claim the unit can bur• To effectively support a vibrant wood fuel heating industry, we must rewa

rather than dirty, poor performing technologies.

Summary, continued