Residential Wood Heater NSPS:Improving Wood Technologies in theResidential Heating MarketPresented to the White House Office of Management and Budget1Mark Torpey, Director of R&D, New York State Energy Research and Development Authority (NYSERDA)Mark Watson, Program Manager for Environmental Researchand Energy Resources R&D, NYSERDAEllen Burkhard, Ph.D., Senior Project Manager, NYSERDAMark Odell, Vice President, Econoburn, LLCDale Furman, Managing Member, Hydronic Specialty Supply LLCLou Okonski, COO, Evo World Inc.Arthur Marin, Executive Director, Northeast States forCoordinated Air Use Management (NESCAUM)Lisa Rector, Senior Policy Analyst, NESCAUMDrew Wayne, Office of Congressman Tom ReedJanuary 26, 2015• Residential heating markets account for about onequarter of New York’s wood harvests• Biomass central heating units have the highest PMemissions• ~560,000 wood heating units in NYS• In NYS, PM emissions from residential wood combustionare greater than those from electric generation ortransportation, yet wood is used in <2% of NY homes• New York is currently home to five advanced technologywood boiler manufacturersBiomass Heating: an important issue in NYS23• 8 years of research, development and demonstrationof biomassheating• $8 million of NYSERDA funds, plus $7 million for new projects– product development, evaluation, and demonstration– test method development for residential and commercial biomass boilers– fuel characterization and regional consensus building for fuel standardization– air quality and health effects research• New generation of biothermal technology has dramatically improvedthe efficiency performance and emissions profile ofwood heatingequipment but without a high standard, these companies will suffer.• Wood Heat Roadmap– understanding of the importance of proper sizing,the use of thermal storage, andproper test methods to assess actual performance inthe field.• Many states outside of NY rely on information fromNYSERDANYSERDA’s Biomass Heating R&D program4• Governor’s initiative• Multi-pronged market development strategy tostimulate growth in the high-efficiency, low-emitting biomass heat industry• $20 million, long-term commitment• Fuel production and distribution, sustainableforest management, equipment manufacturing,sales and installation, workforce training anddevelopmentRenewable Heat New York5Air Quality6• Wood smoke dominates PM in rural NYS• Wood smoke contributes 30% of the wintertime PM inRochester, NY• Sub-daily concentrations of wood smoke PM are measured at healthrelevant levels, even in rural areas• NYS has a goal to reduce exposure to wood smoke pollution• New York is looking to support high-efficiency andlow-emissionwood boiler heating systems, with increasing standards over time.• New York is also providing incentives to retire outdoor wood boilers,indoor wood boilers, whole house wood furnaces, andwood stoves.• We have learned much about the technical capabilities andrequirements to help us attain our energy and environmental goals.Air Quality715,9681,509127802,9302,6522,46565011,76302,0004,0006,0008,00010,00012,00014,00016,00018,000Annual Tons PM2.5PM2.5 Emissions by Key Source TypesWood: heats 1.2% NY homes primary heat &~453,000 stovesNatural gas: heats 51.7% NY homes (>3.6million)Home heating oil: heats 33.1% of NY homes (>2.3 million)8Results of Modeling a Phase 2OWB based on emissions fromM28HH with backgroundModeling 24-hr ImpactsResults of Modeling a Phase 2 OWBbased on emission profile from EPA ORDtesting w/out background9Emission ScenarioConcentration (μg/m3)EPA NAAQS35 12Neighborhood Scenario - ValleyScenario 1: Growth with Step 1 technology 58.8 11.6Scenario 2:Growth with Step 2 technology 27.4 8.7Neighborhood Scenario - MountainScenario 1: Growth with Step 1 technology 66.4 10.7Scenario 2:Growth with Step 2 technology 24.6 7.1Neighborhood Scenario – Urban/suburbanScenario 1: Growth with Step 1 technology 62.9 12.9Scenario 2:Growth with Step 2 technology 30.5 10.1The Future: Step 1 vs Step 210Technologies & Test Methods11Important advances in wood boiler technologyOutdoor Wood Hydronic Heater Two-stage, downdraft gasification heater(low-mass boiler) with thermal storage• Completely different design principals from the outdoor wood hydronic heater.• Low mass technologies – advanced technologies - cannot be evaluated using EPAMethod 28 WHH• Lack of a test method became a significant marketbarrier• Barriers from traditional avenues for test methodcreation so NYSERDA requestedassistance from Brookhaven National Lab12More rigorous evaluation yet simpler and more costeffective to conduct• 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 rigorousthan stack loss measurement used in several proposedtest methods• PM and CO measurements provide emissions at differentphases of the burn [start-up, steady-state, and endphases(critical for future design improvements)]Anticipated reduction in testing costs from $25K to$10K• Commercial labs have refused to test using the BNL–PTSmethod even though EPA and states accepted its useas atest method in regulatory and voluntary programsBrookhaven National Lab (BNL) Partial Thermal Storage (PTS)Test MethodDevelopment supportedfinancially by NYSERDAand EPA.Great support from stateair regulators, BiomassThermal Energy Council,NY Bioenergy Allianceand manufacturers ofadvanced cordwoodboilers13**Device Test Method PM Emissions Efficiency**Froling EN303-5 0.06 lb/mmBtug/hr cannot be calculated86%Froling BNL PTS 0.18 lb/mmBtuMax run 7.3 g/hrAnnual average 70%HSS BNP PTS 0.28 lb/mmBtuMax run 14 g/hrAnnual average 60%Comparing Test ResultsIn order to better serve the consumer:• Eliminate comparison of emissions across differenttest methods• Adjust the g/hr cap from 7.5 to 18 g/hr for devices that use test methods including start-up emissions• Outlaw the use of hang tags and use of emissions and efficiency data in marketing materials for unitstested by methods that do not use cord wood or include start-up emissions. Only allow these units tobe sold as “certified”• Allow the use of hangtags and marketing of emissions and efficiency data for units tested withcordwood by methods that include start up emissions14101.510.220.080.00004024681012**lbs of PM per day**lbs of PM per dayPerformance Comparison Across a Common Duty CycleResearch projects conducted by EPA ORD and BNL15Commercial Test LabCapacity16• Reviewed 23 test reports• 90% (21 of 23 reports) found missing or questionable data• Issues included deviations from test protocol, unreported data,and basic math errors• Testing was conducted by labs that were EPA-certified and ISOaccredited• Issues continue as states review test reports fortheir regulatoryprograms• Significant questions remain about capabilities, capacities andimpartialityReview of EPA Accredited Labs Test Reports17New York Manufacturers18Mark Odell, Vice PresidentEconoburn– Made-in-the-USA• Econoburn of Brocton, NY is a manufacturer of a Made-in-the-USAdown-draft wood boiler.• The EPA Voluntary method has depended solely on M28 WHH andhas created a market barrier for our superior technology because M28WHH cannot evaluate low mass boilers like the Econoburn.• Some state regulations have used the EPA Voluntarylist or dependedon M28 WHH to develop regulations. The lack of a test methodappropriate for our units effectively blocked Econoburn from keymarkets.• Consumers have had the perception that if Econoburn is not listed byEPA it isn’t clean and efficient. EPA ORD’s own research showed thiswas not the case and in fact our unit was cleaner than EPA qualifieddevices19Market 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 comprehensivetest for our boiler type.• Econoburn is proud to finally be approved by the NYSDEC and NYSERDA’sRenewable Heat NY program.• We are frustrated that while EPA accepts the BNL-PTS, and recognizes BNL as anaccredited test lab, EPA cannot accept our test result because of a conformity issue,which is impossible for a government laboratory to obtain• Barriers created by the accredited labs have resulted in a significant loss of marketshare. Without being listed on EPA’s voluntary program, we have not been able toenter key markets.• Our future appears to hang in the balance of fourEPA accredited test laboratories thatare refusing to test by the EPA accepted BNL-PTS method.Econoburn– Made-in-the USA20Recommendations:• EPA accredited test labs must not be allowed to dictate what test methods are used.• Labs appear to be blocking markets by refusing toconduct tests, this raises questionsabout impartiality of the commercial labs. The rulemust ensure that the labs who testare impartial evaluators without perceptions of financial conflict of interest.• While we can easily meet the weighted annual output emissions rate of 0.32lb/MMBtu, we respectfully request a limit of 18 g/hfor any burn category for unitstested by the BNL PTS method.• Econoburn has gone to great effort to make improvements to our technology – bettercombustion chamber geometry, the addition of an oxygen sensor and smart controls –all to optimize combustion, increase efficiency andminimize emissions. We makeclean burning technology.• Other companies have not made the investments thatwe have. Who do you wish toreward?EconoburnMade-in-the-USA21Final comment:• If you make a weak rule, you will reward those whomade no effort to improve theirproducts and continue to sell dirty technology. This will further hurt Econoburn, asmall business that has worked hard to produce efficient and clean burning units.• The longer you delay implementing good test methods and achievable emissionsstandards, the longer we have an uneven playing field.• Consumers need to know which units will perform better in the field. The rule shouldseek to provide special hangtags to units that testwith cordwood and start-upemissions so they can easily be identified by the consumer. These units should alsoreceive special recognition on EPA’s website.• Who should really benefit? Those who innovate orthose who refuse to do so?Econoburn– Made-in-the-USA22Dale Furman, Managing MemberHydronic Specialty Supply- Made-in-the-USA• HSS is a new Made-in-USA manufacturer of an advancedcord wood boiler located in Western NY.• HSS saw the need in the market for better technology andhas invested heavily to commercialize this efficient andclean down-draft wood boiler technology.• HSS has been tested at BNL on the BNL PTS method.We passed and those results are now under review byNYSDEC.• HSS echoes the comments made by Econoburn. Do notreward dirty technology, reward innovation.• Do not allow the accredited test labs to dictate what testmethods are used and seek to make them impartialevaluators without perceptions of financial conflict ofinterest.• Set a realistic category maximum emissions rate of18 g/hper Category for units tested in start-up conditions.Anything less is too low at this time and will block goodtechnologies from the market.23Lou Okonski, COOEvoWorld Made-in-the-USA• Evo World is a Made-in-USA manufacturer resultingfrom a new partnership of a third-generation familyboiler manufacturer based in Troy, NY and anAustrian pellet boiler manufacturer.• Evo World manufactures high-efficiency pellet boilersthat perform best with thermal storage. Evo Worldhas been accepted by the RHNY program only withthe use of thermal storage.• Pellet boilers will not be as clean or efficient if usedwithout thermal storage. If the unit is not installedwith storage, it must be tested with EPA M28WHH,anything else will not be representative of actualperformance.• Shortly we will have data that compares performancewith and without thermal storage. While we areconfident that we can test and be passed on the EPAM28 WHH method, it is not the way we wish for ourunit to be installed.24• We urge the use of the BNL PTS test methodand requirement that those who test by itinstall their pellet boiler with thermal storageso there is no confusion for the customer.• All others wishing to install without thermalstorage should test by EPA’s M-28 WHH.• Hangtags must provide clear performanceinformation for consumers. If units are testedwith real world tests, they should havehangtags• EvoWorld also echoes the comments byEconoburn– Reward innovation, not dirty technology.– Do not allow the accredited test labs todictate what test methods are used– ISO and EPA certified labs must becomeimpartial evaluators without real orperceived financial conflict of interest.EvoWorld Made-in-the USA25• New York is committed to supporting high-efficiency and low-emissions wood boilerheating systems.• We must not reverse any recent improvements in airquality, nor create new healthrisks associated with wood combustion. A major goal is to reduce exposure to woodsmoke pollution and prevent non-attainment of the NAAQS.• Not all test methods are equal. The use of the ASTM test method, and refusal of theEPA acredited test labs to use the BNL-PTS test method, are barriers to advancingU.S. biomass technologies.• Approved test methods must include the efficiencyand emissions measurements ofthe full operation of the unit, not just best case.This is the only way to accuratelycharacterize in-field use.• Accept only the BNL-PTS for down-draft units, it allows the necessary information forfurther innovation.• Allow maximum 18 g/h of PM in Category run for units that include start-up emissions.• CO needs to be measured and reported as part of any approved test method.Summary26• We need access to emission reports so data can bescrutinized. The only viable pathforward for a vibrant wood heat industry is one which optimizes both energy efficiencyand environmental performance.• Provide a hang tag only for those units tested oncord wood or pellets withcomprehensive start-up, steady-state and end-phaseemissions testing.• Remove confusion in the marketplace, do not allowmarketing of efficiency oremissions performance determined on any test methodother than one using cordwood or pellets and measuring all phases of the burn.• Remove market barriers created by test labs and void accreditation for labs refusing totest 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 burn.• To effectively support a vibrant wood fuel heatingindustry, we must reward innovationrather than dirty, poor performing technologies.Summary, continued