1

MEMORANDUM To: Gil Wood , US EPA

David Cole, USEPA From: Jill Mozier, EC/R Inc. Date: November 2 7 , 2012 Subject: **Notes from the November 9**  **, 2012 Synthesis Discussion of the National**  **Educational**

**Forum on the Residential Wood Heater NSPS in Minneapolis, MN**

____________________________________________________________________________________ **Synopsis of**  **Discussion Focus (topics discussed most) :**  **C ertification**  **T est**  **P rocedures**  **:** Th e Multi
- Jurisdictional Organizations ( MJ Os) and state stakeholders present (together “the states”) recommend ed a two - phase approach to certification test improvements which addresses short
- term fixes for this NSPS revision while collecting data for longer
- term improvements to be made in the next NSPS revision
. The states noted that their primary concern is protection of human health and air quality , and that these concerns are motivating their suggested changes. Among other changes, the states support : a mov e to cord wood while allowing either cord or crib wood during a transition period ; limiting the time the door is open during start - up to ensure capture of start
- up emissions ; requiring more filter pulls to better characterize variations in emissions and reduce loss of semi
- volatiles ; and eliminating Category 2 and 3 burn rates in favor of 3 run s at the higher emission rate of Category 1 or 4 (for a total of 4 emission measurements with no averaging between C ategory 1 and 4 , and at similar cost) in an effort to better characterize maximum emission rates
. While unanimously supporting a switch to cord wood, the Hearth, Patio, and Barbecue Association (HPBA) industry delegation present (“ HPBA delegation ”) w as co ncerned that there is not enough data to determine the risk to the industry in the near
- term and that some states might require cord wood testing rather than just allowing it as an option (a.k.a. “the cord wood off
- ramp”). The HPBA delegation w as generall y opposed to limiting the start - up time during the test , stating that longer start
- up burn times are necessary

in the real world to start successful fires and EPA should consider longer times for better replication in the lab (or at the very least that 5 minutes already represents worst - case and a shorter time is not practical) , and that start
- up emissions are already being captured in any

event. The HPBA delegation was opposed to frequent filter pulls, claiming that the testing cost would greatly increase and that the imprecision of the test method would be amplified with each additional filter weighing. The HPBA delegation , with some exception, w as also generall y opposed to the changes in Category burn rates due to a claimed lack of data to ga u ge risk to the industry in the near
- term , and generall y opposed to testing stoves in worst case Category 1 or 4 conditions rather than at “sweet spot” Category 2 and 3 burn rates more ty

pical in the real world. The HPBA delegation expressed support for collec ting CO measurements , although not for having a CO emission limit in the NSPS proposal (with some exception)
. All i ndustry stakeholders noted the importance of a bridge to cord wood and also expressed support for ASTM methods , including state participation in the ASTM process . The HPBA delegation noted the ir concern about the imprecision of the test method and questioned its accuracy relative to the real world ( related especially to the use of crib wood and the variable nature of wood burning) and that2

therefore tightening of the standard based on Method 28 is not defensible in their view and will unnecessarily

keep some good stoves off the market
. Overall, while there was agreement that greater precision and a transition to cord wood is needed ; there was no t agreement on how to best improve the precision or how/when to make the switch to cord wood
. A lso, there was disagreement regarding Category burn rate s and start
- up time changes
. The group agreed to continue discussing a way forward in a work group. **L evel and form of the standards**  **:** The states presented a straw proposal which included combining wood burning devices into 3 categories based on function (room heaters, central heaters, and thermal storage devices), and emplo yi ng 2 mandatory

Bins (with Bin 1 sunsetting into Bin 2 at as yet unspecified years ) and an aspirational Bin 3
. All 3 categories in each of the 3 Bins include proposed PM emission standard s and cap s , as well as proposed efficiency

minimums, and to - be
- determined CO limits. The straw proposal was favorabl y received b y the pellet boiler and catal ytic device manufacturers but the HPBA delegation claimed that the emission limits were arbitrary due to their belief that the test method is not precise enough to distinguish 3 Bins and that such lumping and emission limits would shut down some of the industry (e.g., hydronic heater manufacturer s). The HPBA counsel argued that the lumping together of functions was not in keeping with the CAA but rather that EPA must group by device commonalities and best demonstrated technologies , that the cost effectiveness anal ys is would fail for several of the proposed standards , and that the industry would litigate such issues and push for a rigorous defense b y EPA . Some i ndustry members opposed efficiency standards, claiming the data does not exist , a full third of the models would be excluded by an efficiency standard (a point disputed by Washington S tate), and that combustion efficiency should merely

be reported on the hang tag which would then allow market driven forces to select the most efficient models over time. Notwithstanding the general opposition by the HPBA del e gation , some other industry members and citizen group representatives expressed support for th e technology driving nature of the states’ straw propos al , including the device grouping and even the most stringent Bin 3 option, which some claimed could be a boost to the industry by offering EPA certification of better performing stoves. Regarding cate gories, some industry members expressed support for the states grouping catal ytic with non
- cataly tic and pellet with wood
. Most industry representatives suggested splitting the central heaters group into air
- based versus water - based. Overall, there was ind ustry agreement on the concept of using a time
- line d binning approach, but disagreement regarding the specific device categories, most of the states’ emission numbers, and even the existence of an aspirational Bin 3. The states noted that they were not surprised b y industry’s reaction to their straw propos al , that these numbers would change if based on cord wood, and that industry had not suggested an alternative to the 50% best performing stove metric (used in Bin 2). **I n**  **- use durability**  **:** Oregon proposed some options for the NSPS and/ or for state programs including warranties, incentives for proper consumer upkeep of stove s including modular/replaceable parts , tests by manufacturers to simulat e aging, decreasing the ability (via stove design) for consumers to operate the stove improperly , and perhaps an auto
- shutdown of the stove if it i s out of specification (e.g., O 2 sensors). In general,3

Oregon proposed that EPA/states and the manufacturers work together on this issue of shared concern
. The HPBA delegation ’s general response was that in
- use durability regulations were not necessary because manufacturers were already t aking such steps to protect their own interests (against warranty claims and bad reputations) , and that in any event the states were in a better position to control consumer behavior in this regard. The states expressed an interest in pursuing the durability issues further in a work group
. **Participants & Observers of Synthesis Discussion :**  **Participant Name**  **Organization** Andy Ginsberg Oregon Department of Environmental Quality Arthur Marin NESCAUM Bob Ferguson Ferguson, Andors & Company (consultant to HPBA) Carol Cenci PSCAA Chris Neufeld Blaze King/Travis Industries Dan Johnson WESTAR David Thornton MPCA David Menotti Crowell & Moring (counsel to HPBA) Dick Valentinetti Air Quality, DEC, Vermont Dutch Dresser Maine Energy Systems Eric Merchant M ontana DEQ Gil Wood US EPA Gregory Green US EPA Jim Hodina Linn County Air Quality Division, Iowa John Ackerly Alliance for Green Heat John Crouch HPBA John Dupree USEPA Larry Sorrels USEPA Lisa Rector NESCAUM Martin Lunde Garn Inc. Nathan Russell NYSERDA Rick Curkeet Intertek Testing Services NA, Inc. Rod Tinnemore Washington State Department of Ecology Tom Morrissey Woodstock Soapstone Company Tomas Carbonell Environmental Defense Fund **Observer Name Organization**  Beth Friedman EC/R Inc Bob Lebens WESTAR Jill Mozier EC/R Inc Lisa Herschberger Minnesota Pollution Control Agency Nancy Kruger National Association of Clean Air Agencies (NACAA) Rachel Sakata Oregon Department of Environmental Quality Rob Kaleel LADCO Susan Wierman MARAMA4

**Discussion Details: Goals and Process for the Meeting**  **:** Dan Johnson of WESTAR opened the sy nthesis meeting b y expressing that representatives from the various state Multi
- Jurisdictional Organizations (MJOs) were at the forum to learn so that the representatives could better inform their respective MJOs on the complexity of the issues involved in the woodstove NSPS . He hoped that by the end of the forum the MJOs would understand everyone’s position

– consensus/agreement would be ideal

– but realistically consensus may

not be possible. In response to EPA confirming that a draft proposal to EPA management b y the end of the calendar ye ar was the goal, Dan said that such a date would be “light speed” for the MJOs but he would nonetheless make recommendations to his members, and furthermore requested comments in the on
- line “Basecamp” discussion by De cember 9, 2012. One week after December 9 , the MJOs would craft a letter to EPA. EPA clarified that they

would like to complete by mid
- January

those things in the current draft woodstove NSPS that could be changed quickly , in order to get a new draft proposal to OMB b y February or March. Note: ** below indicates an attempt at summarizing points of agreement and/or areas where more detailed discussion to reach an understanding is needed. **Certification Test Procedures :**  Rod Tinnemore of Washington State Department of Ecology ( ECY ) explained that the states recommend a two
- phase approach to certification test improvements involving a short
- term fix for this NSPS with additional revisions for the next NSPS revisions (hopefull y no more than 8 years away). Th e goals are:  Improve precision;  Limit “gaming” the test;  Eliminate elements that don’t add value;  Characterize maximum emission rate; and  Obtain information to inform new test method development and potentially new emission limits
. Regarding efficiency , there seems to be general agreement to better define which pieces of CSA B415 to use (e.g., high heating value (hhv) versus low heating value (lhv)) and that the lack of low burn rate in B415 needs to be addressed. Regarding the test method, the states pro pose:  Requiring a filter pull every 60 minutes;  Requiring that filter weight be measured and reported at 12 hours, 24 hours, and 48 hours due to concern about potential loss of VOCs during “drying
. ” Regarding device operation changes, the states propose:  Move to cord wood or allow both crib
- and cord wood during a transition period;  Report density

of wood instead of wood species;5

 Limit start
- up time so that start
- up emissions are not missed;  Base coal bed weight on % of fuel load with ±1% deviation;  Elimin ate Category 2 and 3 burn rates and require only Categories 1 and 4, perform 3 runs at the highest emission rate (in Cat 1 or Cat 4), and set emission standard for each Category with no averaging between Categories
.  For h ydronic heaters, determine actual m ax heat output by test; and  For woodstoves, willing to consider change from max of < 1 kg/hr to < 1.15 kg/hr for low burn rate . David Menotti representing HPBA commented that the (above) basic ideas are sound regarding a short
term versus long
- term fix, but cautioned that tweaks can’t be so substantial as to remove EPA from the available database

– that some of these elements raise concern in this respect. Gil Wood of EPA clarified that this is a 2
- phase process being proposed and that the additional data (e.g., from the 60 minute filter pulls) are not for this NSPS revision . HPBA is concerned about dropping Categories 2 and 3 and replicating test runs on Categories 1 and 4 , because limited data is there yet

– therefore the category revision should be a 2 nd tier change not 1 st tier. When EPA asked in what way the data was missing, HPBA responded that they haven’t tested the stoves with th e new proposed approa ch, with replicate runs and with out weighting Category 1 most heavil y – that while they do have Category

1 and Category 4 data, industry

does not know what would result from the 3 proposed replicate test runs ( “ which puts all the risk on industry” ). Chris Neufeld of Blaze King asked that if we’re tryingto represent real
- world burning and if the consumer uses stove in low or medium
- low burn rate 80% of time, wh y eliminate this “sweet spot” representing most of the real
- world use? Andy Ginsburg of the Oreg on Department of Environmental Quality (DEQ) responded that from a public health perspective there is concern about short
- term high emissions that will occur. So from a public health perspective, stoves should be designed so that they ’re engineered to be c ontrolled under the worst operating mode

– hence the focus on Categories 1 and 4. Minimizing emissions in the worst mode may

also offer clues to oversizing. Rod Tinnemore commented that this would also put all manufacturers at an “ equal disadvantage, ” so for example cataly

tic and non
- catal ytic stoves are treated equal ly with no unfair advantage. Rick Curkeet of Intertek Testing commented that emissions in g/hr are different than in g/heat
- delivered

– that actually

the highest burn rate is not the cleanes t but has the highest g/hr

– so units need to be discussed. Arthur Marin and Li sa Rector of NESCAUM responded that they don’t assume the highest burn rate is the cleanest, but they

parsed data by

lb/MMbtu and by

g/hr and hence propose testing Categories 1 and 4 where worst emissions happen. Furthermore , they commented that the NSPS is not about averaging but rather supposed to be computing maximum emission rates. Dan Henry

of 5G3 Consulting commented that it’s a mistake to assume that if stove is control led under Categories 1 and 4 then Categories 2 and 3 will fall into place. Tuning the stove to air:fuel ratios is complex and manufacturers would have to go back and ensure that Categories 2 and 3 were not messed up by the design focused on Categories 1 and 4. So EPA shouldn’t just look at Cats 1 and 4 and leave6

out most ty

pical burn rates. Furthermore, regarding right sizing, the average cons umer has been educated that bigger isn’t better and stove manuals focus on right sizing and climate. Andy Ginsburg asked industry if, with the proposal for separate Category 1 and 4 standards (no averaging between Cat 1 and Cat 4 ), would they also like separate Category 2 and 3 standards? David M enotti responded that the discussion was mixing standard and test method issues, and it may be better to average and cap emissions. John Crouch of HPBA further commented that filter pulls every 60 minutes will inc rease testing cost. Bob Ferguson representing HPBA commented that having more than 1 test run is probably

good for increasing precision, but HPBA need s to discuss weighting impact on level of standard. Bob Ferguson commented that i f three runs are done in 1 category , then the standard should not be a weighted average , as it would be too heavily weighted on low end. Lisa Rector commented that there is onl y 1 data point for 4 different burn rates in the current test method
. She believes that the test method ideally n eed s to go to N of 3 for each burn category , but it is unrealistic to ask for 12 runs (that is, 3 runs for each of 4 tests) . So the states’ propos al is to improve the precision but not increase the cost , and no longer use a weighted average for the standard. Dutch Dresser of Maine Energy Sy stems commented that for pellet boilers he likes the different standards based on different burn rates, but pellet stoves heaters should not be tested down in a dirty range where they

aren’t designed to perform anyw ay . ** For group, it was noted that there appears to be consensus that greater precision is needed but all don’t necessarily

agree on burn rates . There is some possible agreement regarding different standards for different burn rates. Dan Henry

comm ented that the ASTM method approach of 40 % low/ 40 % medium/ 20 % high for weighted average of 3 runs is comparable for most EPA - certified stoves (very little difference with current weighting of 4 runs), so it is possible to do something with the spare 4 th run. Bob Ferguson commented that the impacts of a change like this would need to be anal yz ed, because it would be getting away

from the current database. Changing something that’s been done this way for 25 ye ars carries significant risk to industry . Ins tead, all stakeholders should share the risk. Andy Ginsburg commented that, regarding short
- term versus long
- term goals, he recognizes that an incremental process is required to improve test precision to help discuss more stringent standards

– agrees there is a tension here

– but that there is risk of better test method to states and industry alike. Nonetheless, the test method needs improvement. Bob Ferguson agreed with this, but commented that it’s too late to change the test method “5 minutes before EPA goes to OMB”. John Ackerly

of Green Heat Al liance expressed support for comments by Dutch Dresser regarding woodstoves using ox ygen sensors and that test methods should accommodate this. There needs to be an alternative test method so there’s no barrier to innovation.7

Tom Morrissey of Woodstock So apstone commented that it would be less radical a change to have 4 tests: high, low, another test at whatever produced worst emissions, then last test at combined Categories 2 and 3. Weighted averages are meaningless to consumers, so he likes new approach. Need to publish burn rate emissions in a transparent way

– that is, 3 columns of numbers not just 1 weighted average. Then consumer can decide which column is most applicable to them and on which to base purchasing decision. This will trigger innovation. Gil Wood commented that EPA had previousl y considered using approach of 3 runs plus extra run at “worst case” , similar to the fireplace program
. Lisa Rector commented that N of 3 is crucial. Gil Wood further commented that 3 runs at each burn rate is being considered now . Rick Curkeet commented that product performance precision is what is being discussed, but that there is already a provision to throw out outliers and re
- run. So what would happen to outlier provision? What would count and what wouldn’t? Burning w ood is unpredictable. EPA asked how many times outlier provision was used, but the response from Rick and from Bob Ferguson was that this data is not available. ** Dan Johnson commented that regarding the burn category discussion, the states have straw ideas , not a firm proposal. The discussion should not be closed, if there are better ideas. There is agreement on need for a more precise test method and that this new method not be much more expensive . Rod Tinnemore and Lisa Rector have proposed a more precise test. If HPBA disagrees with this test, then what should the test look like? Greg Green of EPA added that EPA wants to address test method precision and would like HPBA/industry to offer thoughts. Tom Morrissey commented that labs never run test without multiple filters

– so it’s not a multiple filter issue, but rather about number of runs. It can already be determined where max emissions occur. Andy Ginsburg confirmed for John Crouch that yes, the states are suggesting doing away with weighted averages. Dan Henry

commented that the 5G emission measurement method has been agreed upon unanimously and that his experience when running 5G dual train filters is that it’s impossible to capture enough on filters to weigh catch. A dual filter dual s ample train already has audit features . Imprecision will be increased b y additional weighing and will require someone weighing non
- stop (including tare weights and sample weights). This will double or triple the cost. Rick Curkeet added that this is not specific to woodstoves but also applies to hydronic heaters. The first catch is significant and uncertainty increases when trying to weigh multiple filters with smaller catches on each . He recommended looking at CO when trying to determine peak emissions, rather than doing multiple runs. Lisa Rector asked if testing was needed over full charge, and if a shorter test was possible in next round (not this round). Not only should precision be improved, but data should be collected for future test. Rick Curkeet commented that a full test is needed for efficiency any way . CO and CO2 should be measured , and that to partition particulate one could look at area under CO curve (e.g., what % of area comes in first 1⁄2 hour) so that we can get to what we’re looking for in a less expensive way , with data8

already available. Dan Henry further commented that filters are not run during thousands of product development tests

– rather industry knows that opacity
- free is achieved when the ratio of O2:CO hits 10:1. The highe r that ratio is, the cleaner the burn. If that occurs in 15 to 30 minutes, industry knows it’s a successful test and will run to the end to determine burn rate. A ratio of 200:1 is achieved near end because CO drops off so much. Bob Ferguson commented that all stakeholders want data and generating data for the future is a good thing b ut there are no available short cuts in certification labs. Multiple runs are not necessary , as the point of max emission is well known (e.g., in 1 st hour for woodstoves, when transitioning from on to off for h ydronic heaters) . Should not deal with dozens of sets of filters; more pragmatic solution exists. Dick Valentinetti of Air Quality , Vermont DEC, asked if industry was suggesting no particulate standard but only a CO standard. Dan Henry responded that if the data were mined, one would find that CO and PM track perfectl y. Dick noted that he’s most concerned with consistency and if CO is a better way , then it should be considered . David Menotti commented that the precision issue is most profound due to the inherent variability

of burning wood, and that Dick’s CO idea is too bold a change at this point. Lisa Rector noted the states’ concern about using filters too long (potential loss of semi
- volatiles). HPBA responded that too many filters are needed for once
- per - hour pulls. Lisa responded that perhaps labs could do several pulls in the first hour and then at max duration. Bob Ferguson noted that they aren’t concerned about the primary filter because there is a secondary filter, but in any

event it’s been shown that the primary

filter catches all. Bob further noted that filter pulls and weighing need to be mini mized due to increase of imprecision (he likes single filter catch). Li sa noted that some of PM evaporates and back
- up filter doesn’t catch that loss

– some semi
- volatiles will be lost on filter so 12
- hr, 24 - hr, 48
- hr measurements will help determine that loss (without that accounting cleaner units will be penalized because semi
- volatiles come off dirty units)
. Bob noted that the method starts with a dry (desiccated) filter

– that a wet filter catch is not possible since much of the weight in burning is fro m moisture. Lisa recommended continuing this discussion with George Allen. David Thornton of Minnesota PCA noted that CO data is not available now, so may be use for Phase 2. Andy Ginsburg commented that enough short
- term samples should be collected for the future standard, but that such data should also be used for the current NSPS in some way

– that a combination approach is needed . Hydronic heaters are a concern and a test method is needed that captures variability (likewise for pellet stoves)
. Gil Wood noted that this is a proposal, not a final rule being crafted and EPA will explain all issues and illustrate potential multiple options in the proposed rule to allow fine tun ing for the final rule
. Gil Wood asked Rick Curkeet whether all labs collect CO . Rick responded that his lab has CO data, but not necessaril y all labs do since CO is not currently required. David Menotti commented that there is not a robust CO data set, so HPBA is not ready to switch to CO standard. Bob Ferguson further noted that CO and particulate don’t track perfectl y, although there are strong trends. John Ackerly asked if EPA could be transparent during this time before sending to OMB. Gil noted that EPA will be as transparent as possible and explained about 90 day public comment period.9

** There appears to be general agreement about a two
- tiered approach to get to bolder steps eventually and that a work group will continue to discuss details and areas of disa greement. John Crouch commented that tweaks should not add to cost. Andy Ginsburg commented that with this two
- tier approach tweaks could be made in the short term that will improve precision and obtain short
- term emission data (taking into account good po ints made about pulling more samples) for the next NSPS

– thus tweaks should inform the current NSPS revision while g athering data for future NSPS revisions
. Lisa Rector asked for feedback on low burn rate. David Menotti commented that the most important issue for industry

is making a bridge to cord wood
. Andy Ginsburg commented that limiting start
- up time is important. Bob Ferguson commented that all start - up emissions are captured in testing. Regarding low burn rate, Dan Henry commented that when you force a stove to be built such that it can operate at < 1 kg/hr under non
- cataly tic technology , then b y design you are giving consumers license to smolder. The 1988 NSPS requires a non - removable stop at its lowest burn rate , e.g., at the 1 kg/hr position. Raising the minimum burn rate would reduce consumer
- caused stove smoldering, allow arrival at the sweet spot quicker, and also address stove forgiveness for wet wood. If a model can burn clean at a lower setting, e.g., many catal ytic stoves, then still allow it for that model. Martin Lunde of GARN noted that movement to cord wood is the single best way to replicate the real world. David Menotti gave history of crib wood testing noting that industry agreed to crib because the thought was there’d be better precision; but there i sn’t . So industry has been designing stoves around crib wood , not real
- world cord wood

– and SIP planners are not even using crib test data , but rather are using cord wood data . The risk is too high to industry to switch imm ediately after so many years of designing around crib wood , so a certification off
- ramp is needed

– that is, manufacturers should be given the option (not the requirement) to test with cord
- instead of crib wood to determine the passing grade. There’s currently

an ASTM test method for cordwood but it needs more refinement. ** There is general agreement about transitioning from crib
- to cord wood , but HPBA comments that the devil is in the details especiall y with limited database. There is agreement to discuss the transition from crib
- to cord wood more off
- line in a work group
. David Menotti comments further regarding the risk to industry of switching to cord wood

– that is, that some states will see the optional off
- ramp and make this their more stringent standard . Industry approached EPA for a consistent standard in 1988 because industry c ould not tolerate different state standards. Thus industry

would like to negotiate with states now and ensure cord wood testing i s not a deal breaker
. Arthur Marin noted that they cannot commit that every state/local government won’t use the authority granted to them in the CAA to be more stringent. David responded that industry is not looking for a sue
- able contract but is rather looking for go od faith understanding. Dick Valentinetti noted that half of the states cannot be more stringent than the federal government/EPA any way , and although he cannot speak for New York, he thinks he can bring the other states to a good faith understanding. David noted again that industry doesn’t want to be sandbagged. Greg Green commented that perhaps the first step is to agree on a range of options for proposal

– that the options don’t need to be nailed down yet, rather give EPA options.10

Dan Henry

commented that at every conference European technology is extolled and yet Europe doesn’t use cribs nor require testing at minimum burn rates and their tests are run exactly as burned in a ty

pical home. Consequently

European stoves work in lab ju st like they work in the home. If the US goes to cord wood , we need to replicate the real world

– stoves operate at different burn rates

– it is what it is. That’s what wrong with the US standard today
. Andy Ginsberg noted that Austria has database and NYSERDA has paid for the database. Can we use this database? Bob Ferguson responded that European models often have to be re
- designed to meet US test method standards

– the test method s are not comparable. Gil Wood noted that the best European hydronic heaters are typically designed to avoid operation at the low burn rates and poor combustion conditions that have been so common and so problematic for US hydronic heaters. Regarding start
- up time and Paul Tie gs’ (now deceased) contentions, Bob Ferguson noted that stoves should be run for a full hour on pre - test load before load ed for the test so that the coal bed is full y charco alized . Bob Ferguson noted that no emissions should be missing (i.e., not captured by testing) during th e start - up . Andy Ginsburg commented that the issue is how consumers , who are not necessarily as skilled as manufacturers, will use stove (e.g., all about getting hot fast). Too much optimization will measure too sophisticated a start
- up than is ty picall y practiced by consumers. Bob Ferguson commented that the manuals tell wood stove consumers to burn for > 15 minutes for start
up, so 5 minutes is a reasonable worst
- case. Very short start
- up times by

consumers are not wanted by industry. In addition, limiting the start
- up time further (less than 5 minutes) is practicall y difficult to accomplish in terms of how long it takes to load. Finally , Bob doesn’t see improvements from changing the 5 minute start
- up time as this is over whelmed by the random nature of burning wood. Bob and Rod Tinnemore agree to discuss this topic more off
- line. Chris Neufeld commented that he discussed with Paul Tiegs the point that how long the door is open affects the interior temperature, and that limiting how long the door is open during fuel loading decreases the interior temperature. Chris himself keeps his personal wood stove door open < 60 seconds but nonetheless agrees that 5 minutes is a good worst case real world estimate. Rick Curkeet commented that Europe assumes consumers follow the manual. The door is one issue, but air control is more important

– operators need to let the start
- up wood burn for 10 to 15 minutes before adjusting the air control. Five minutes is barel y on the edge of getting a fire going; many stoves will not even light in 5 minutes. This is a totally arbitrary number; start
- up time needs to be increased. ** There is an agreement to move start
- up time discussion off
- line. Greg Green commented that everyone present has probably gott en an appreciation of industry ’s knowledge regarding the test methods. Thinking outside of the box for discussion purposes, what if EPA were to propose an X kg/hr operating standard that 8 out of 10 stoves must meet and then allow industry to determine tes t method? (In other words, start with the standard and develop test method around the standard to ensure device operates at that level

– this would take pressure off test method.) David11

Menotti responded that this turns standard setting on its head and is potentially a suicide pact for industry

– data from testing is needed to set standard , in his opinion
. ** Dan Johnson concluded that stakeholders need to re
- visit real
- world discussion. The s tates are being informed today

and a work group needs to drill d own further on specific test method issues. Dan asked if there were any

other issues regarding test methods
. David Menotti responded that the work group should be open
- ended so that issues may be brought back to it, and also that state participation is nee ded in the ASTM process . Industry and ASTM have created 5 different test methods , and states’ lack of participation needs resolution . Rod Tinnemore and Lisa Rector confirmed for Dan that this request by industry for state participation in the ASTM process is not a new issue. **NSPS Proficiency Test Data and Certification Values versus Real World Data**  Presented b y Carole Cenci of the Puget Sound Clean Air Agency (PSCAA) , who noted that HBPA gave data to PSCAA
. Carole noted with help of graph that proficienc y data is not normally distributed based on fact that regression was not linear (her presentation graph show s burn rate weighted emission in g/hr on y axis versus EPA certification value in g/hr on x axis). Carole further noted that lab deviation seems consistent across all stoves and years indicating that there is variability but not bias

– i.e., test results are not random and variability not linked to stove or y ear. Deviation from lab mean is ±1.8 g/hr per test. David Menotti commented that this is the first time he is seeing this graph, but it seems to support a ± 3 g/hr deviation . Lisa Rector responded however that it’s unclear which data is based on Category 1, 2, 3 and 4 burn rates and so these individual test runs are attempting to compare apples and oranges. David commented that standards are not based on means but rather on 95% confidence interval s . Gil Wood agrees that discussion of this graph is too technical for purposes of today ’s meeting and will follow up with EPA statistician. Dan Henry

commented the point is that from one test to the next, the variability has a wide spread. David Menotti commented that the graph indicates the random nature of bur ning wood and that there is not much sense in tightening standard based on Method 28. Rick Curkeet commented that the spread in any one of 4 data points is ±3 g/hr. Carole Cenci continued presentation and commented that anal ys is shows that real world dat a versus EPA certified values are non
- normal ly distributed (not linear) but rather are lognormall y distributed. Thus, lognormal statistical tools are needed rather than normal statistical tools. David Menotti commented regarding two ty pes of data: in
- home and ( Dennis Ja s man’s ) lab which simulated in
- home conditions in lab but didn’t use Method 28. The burn rates of real world data don’t conform with Method 28 and are binned into low, medium, and high certification values with linear emission factors. David noted that this analy sis points to a seminal issue. Lisa Rector responded that there are huge issues with such field studies to the extent that the comparison is akin to comparing apples and cars (e.g., whole host of methods used in generating real world data).12

Carole Cenci concluded that the anal ys is shows labs can differentiate between good, better, and best. **Level and Form of Standards** Overview presented b y Lisa Rector who noted that uniform standards are needed for devices with common purposes, and that variable timelines can be added using a binned approach (of good, better, best bins). Thus :  Collapse all devices into 3 basic categories for emission standards : o Room heaters o Central heating devices o Thermal storage devices  Employ

a “bin” concept for e mission standards  CO emissions o Modeling analy sis using EPA emission rate data shows that Phase 2 HHs can create exceedances of CO standard (anal ys is using AERMOD showed CO NAAQS was exceeded 80% of time, 50 meters away from HH stack). States’ Straw Proposal for emission levels: Bin Concept for Emission Standards (emission rate s based on current weighted average s, will change if just Cat 1 and Cat4 )
Category Standards Bin 1

Transitional effective upon promulgation with sunset dates consistent with current draft rule Bin 2 Based on average emission rate of top 50% of units Bin 3

Alternative average emission rate for top 12% of units Room Heater  PM

 CO  Efficiency  < 4.0 g/hr; no run > 7.5 g/hr  CO TBD  70%  < 2.5 g/hr; no run > 4.5 g/hr  CO TBD

– Cat 4  75%  < 1.3 g/hr; no run > 2.5 g/hr  CO TBD  75% Central Heating  PM

 CO  Efficiency  < 0.32 lb/MMbtu; no run > 18 g/hr  CO TBD  70%  < 0.15 lb/MMbtu; no run > 7.5 g/hr  CO TBD  75%  < 0.06 lb/MMbtu; no run > 3.0 g/hr  CO TBD  75% Thermal Storage  PM

 CO  Efficiency  < 0.32 lb/MMbtu; no run > 18 g/hr  CO TBD  70%  < 0.15 lb/MMbtu; no run > 7.5 g/hr  CO TBD  75%  < 0.06 lb/MMbtu; no run > 3.0 g/hr  CO TBD  75% Note that Bins 1 and 2 (crib or cord) are mandatory ; Bin 3 (cord) is aspirational
. David Menotti commented that category standards are not the basis according to CAA, rather supposed to look at best technologies and start with commonalities of devices. Including catal ytic, non
- catal yti c,13

pellet and utility

/ single burn rate stoves (which are new and have no data basis ) is akin to including apples, oranges and pears. The numbers are being force
- fed. Gil Wood noted that EPA has alway s had leeway / discretion with categories and sub
- cate gorization. EPA can legall y approach it this way . David Menotti responded that justification for sub
- categorization in past has been different best demonstrated technology (BDT) , not functionality
. Andy Ginsburg commented that for the states the fundamental function of being a room heater is what’s important and industry

can compete to make that solution happen. The distinction is the function

– all are using wood and all are heating rooms, so all sh ould compete on an equal footing. The need is to drive device technology

based on standard. Chris Neufeld commented that catal ytic industry wants equal playing field so catal ytic industry favors elimination of separate categories. Martin Lunde confirmed with Lisa Rector that it was based on loadside heat output measurements and crib data. Martin commented that since it was done with crib wood the data is questionable. David Menotti commented that it’s arbitrary to achieve these numbers given the precisi on issues, so numbers will eliminate some better performing devices in real world unnecessarily . I f optimization of combustion efficiency

is wanted, then choose CO or PM and not also efficiency . David is completely opposed to efficiency

standard s because d ata doesn’t exist for this ; i.e., i t’s been demonstrated that 1/3 of wood stove models would be excluded by this efficiency standard and the cost effectiveness analy sis doesn’t support requiring new designs , according to David. Rod Tinnemore noted that HP BA must be using a different dataset because his data ha s 67 data points and those units that met 70% efficiency didn’t exclude a third. David Menotti responded that only EPA or CSA weighted average reference method data counts. Lisa Rector noted that bas ed on CO data for central heaters there is not a 1:1 correlation for PM reduced and CO reduced. States cannot have significant CO emissions in background (while regulating PM). John Ackerly

commented that these standards could be good for industry and engender confidence in consumers. He can see Bins 2 and 3 as akin to Energy Star ratings. It could be great for industry to let consumers know that EPA certifies these units at thes e better performance levels
. Martin Lunde commented that 3 bins are not problematic, but the emission standards proposed are problematic. He also noted that he does not trust crib data compared to cord wood data . Lisa Rector responded that if you have alt ernative data that can be binned, the states are open to using it. Martin wondered if a bad protocol is better than no protocol. Dan Henry

commented that with these proposed emission standards “ the industry would be wiped out. ” David Menotti commented th at if EPA goes with Bin 3 he will insist on rigorous justification for cost effectiveness and demonstrated technologies.14

Andy Ginsberg noted that earlier David Menotti expressed concern that some states will want to be stricter than the standards. An aspirational standard such as Bin 3 will serve industry ’s purpose of reigning in the states. There is some benefit here in creating demand, but Andy agrees that the data needs to be made more robust. Tom Morrissey said that conceptuall y the binning is great and asked if Bin 3 is a fixed/proposed standard. (The answer given by the states was – no; it’s voluntary .) In response to Tom Morrissey ’s question regarding how Bin 3 would appear in the rule, Gil Wood explaine d that it would be listed in the rule and would be described in the preamble that manufacturers c ould decide at which level to certify their models. Gil Wood clarified that rather than “voluntary , ” the correct terminology is “alternative means of emissio n limitation.” Both Bins 1 and 2 would be mandatory (with Bin 1 sunse tting) and thus would require full anal ys is. But Bin 3 as an alternative means (non
- mandatory) would not need a cost effectiveness anal ys is since the NSPS would not be making industry mee t these numbers. OG C has already reviewed this binning concept and confirmed that it is legal for NSPS
. Andy Ginsburg commented that no organization or state can control what other states will do, and no one is suggesting that Bin 3 be mandatory . But in the interest of full disclosure, there will be a Bin [3] out there which some states would like to see supported with tax credits and change
- out money if at all possible. In response to John Crouch’s question, Gil Wood confirmed that EPA is prepared to “mi x” forced air furnaces with atmospherically vented designs (i.e., category standards according to function not design). Andy Ginsburg responded to industry question regarding whether the draft proposed standard was optimizing around crib wood by explainin g that initially

there would be optimizing around crib wood , but Bin 3 could be certified based on cord wood or a Bin 4 could be added for cord wood
. Chris Neufeld commented that the format is what the catal ytic stove manufacturers are looking for but wanted to confirm that the actual numbers proposed are merel y placeholders

– that the draft NSPS numbers could be different. Lisa Rector responded that yes, the numbers could change, but the format would still be good, better, best. Andy Ginsburg further res ponded that the state authors have some justification/methodology for the numbers but are open to discussion regarding them. Andy further commented that there is the idea that Bin 1 would transition into Bin 2 in a certain number of ye ars (number of ye ars not pinned down yet). In response to Martin Lunde’s question regarding does industry need to test with crib wood , Lisa Rector commented that Bins are based on crib
- or cord wood , although may be Bin 3 could just be cord wood
. Gil Wood expressed staff level agreement with Lisa’s response although he was careful to note that he is not the EPA Administrator who will make the ultimate decision. John Crouch commented that this proposal will have big small business impacts and will have to pass the Sm all Business Regulatory Enforcement Fairness Act (SBREFA). Gil Wood noted that EPA has already gone through the SBREFA process and received input that is incorporated into EPA’s decision making.15

In response to Greg Green’s clarification question regarding that industry ’s concern appears to be the categorization rather than the binning concept, David Menotti commented that the concern regards improper lumping of devices and the emission standards in each bin, as well as concern over Bin 3. Industry does not have a problem with phasing
- in standards like was done in 1988 , and industry does like the idea of 0.32 lb/MMbtu being “Phase 1”, which he noted was the original draft proposal, not the later co - proposal with 0.15
. Dan Henry

commented that in the Klamath Valley study an EPA stove at 2.1 g/hr was the best performer based on crib wood (which would be ~ 3.0 g/hr in real world) . The 3100F certification values were improved b y improved air:fuel ratio , but the stove does mo re poorl y burning cord wood . Dan’s point i s that technology

should drive standards, but these draft proposal numbers are driving industry in the opposite direction [from where the states and EPA sh ould want it to go for reduced real world emissions]. When asked by Andy Ginsburg if this is also true for [numbers if based on] cord wood , Dan responded that a bigger number [standard] is need for cord wood as well as incentives to get to cord wood . A bridge needs to be built because industry cannot get to 2.5 g/hr based on cord wood [without changing air
- fuel ratios] , and industry needs 7 ye ars for the return
- on - investment (ROI), according to Dan. David Menotti commented that in the central heaters category (of state straw proposal ) there is an inappropriate lumping of forced air furnaces with hydronic heaters. There is hardly any data set for forced air furnaces (e.g., value of 0.92 lb/MMbtu not robust). Furthermore, there is no database for hydronic heater efficiency

– EPA has disqualified database on efficiency , according to David. Currently David knows of one cycling hydronic heater unit that meets the 0.15lb/MMbtu. The hydronic heaters cannot meet this standard and the HH industry will be shut down by

these numbers (which is upse tting to David because he himself pushed the industry to do better and they

have made remarkable improvements including reducing emissions by 90%). Gil Wood responded that 10% of a huge number is still a huge number, and people are being impacted by HH emi ssions. In response to a question from Gil Wood regarding whether the straw proposal numbers are achievable by forced air furnaces, Chris Neufeld commented that a forced air furnace model was at 3.8 g/hr with 83% or 84% efficiency

based on B415.1. So th e technology exists, but he cannot comment precisely how this would translate to lb/MMbtu . (Gil converted number and it’s better than 0.32 lb/MMbtu. ) Bob Ferguson noted that a Canadian woodstove model with an air jacket would not meet 0.32 lb/MMbtu. In response to industry

claim that the data doesn’t exist to support the standard, Dick Valentinetti commented that this has been discussed for two years, so he is wondering where industry ’s data is. Dick further commented that credible personal air monitors are currentl y in development and will be ready for widespread use in about 3 to 4 years [at which time the pollutant levels near high
- emitting devices will be deemed completel y unacceptable b y public]. Regarding lack of data, Bob Ferguson commented that in dustry does not have more forced air furnace data because the Canadian Standards Association (CSA) standards went into effect in spring 2010 and manufacturers have been working to bring products into compliance with CSA

– the products have not been finaliz ed yet, thus there’s no data yet. David Menotti commented that it’s okay to regulate forced air furnaces but not with Phase 1 hydronic heaters because the data doesn’t exist, since there was no voluntary program for forced air furnaces.16

Andy Ginsburg commented that no central heaters or hydronic heaters can meet Oregon standard. These devices are competing against natural gas units which are hundreds or thousands times cleaner. Oregon cannot justify

going from clean to dirty. Fifty percent of states have to accept federal standards, but other states may

be more stringent (e.g., NY). David Menotti responded that industry knows it needs to accommodate the states, but the states should understand that these proposed numbers will shut down the industry . Andy c larified that Oregon’s goal is to protect air quality and to drive technology

in this direction

– as such, Bin 1 will not fly in Oregon. Dutch Dresser commented that he represents an industry [pellet central heating s ys tems], categorized as central heater s under the states’ proposal, that can already meet the Bin 3 standard. ** Dan Johnson confirmed with industry that numbers aside, at least a 2
- Bin approach (if not 3) makes sense. A remaining question then is how to determine numbers

– for example, in th e Bin 2 straw proposal, does it make sense to look at the average of the current best 50%? David Menotti responded that the precision problem is more fundamental, that without confidence in the numbers the imprecision is being perpetuated. Dan Henry commented that more discussion time is needed

– for example, we don’t have answer regarding how long to get from Bin1 to Bin 2. Dan Johnson responded that Bin 3 will not be mandatory , but that the states accept the angst from industry nonetheless, and also recognize industry ’s significant concern about grouping. David Menotti commented about the “wild card” nature of the proposal, that there must be a cost effectiveness anal ys is, and that Bin 2 will not pass that CE anal ys is. Dan Johnson further questione d that i f we can get to cost effectiveness, is the 50% conceptuall y good? Bob Ferguson cautioned that industry reps at meeting are not able to accuratel y represent all of their members’ interests because the members aren’t yet aware of these proposals and haven’t all met

– HPBA will need input from their members [before answering such questions]. Andy Ginsburg responded that that’s what the public comment period is for. Dan Henry

commented regarding the voluntary low mass fireplace program having an original limit of 7.1 g/kg which was good for 5 years and then dropped to 5.2 g/kg , but EPA created 3 rd category at 3.1 g/kg

– which killed the program. Industry had not enough time from 7.1 to 5.2 to 3 rd category , and no state adopted it. So Bin 3 will become default f or states that want a lower standard. ** Moderator noted that timing of phasing in of Bins needs to be considered. Regarding categories, Martin Lunde commented that air
- based s ys tems versus water - based s ys tems have very basic property and engineering dif ferences, and the proposal should therefore split the central heater category

into air
- and water
- based. The HPBA delegation agreed. Martin further responded to Lisa Rector that yes, thermal storage should remain in its own category [or at least have separate test method]
. Rod Tinnemore noted that states are looking for way s to simplify by lumping devices together

– they are not lumping because they don’t understand the differences in devices. Dutch Dresser commented that he liked the categories and sees Bin 3 as technology
- forcing which is good for [his] industry
. David Menotti commented that efficiency is already

written into the standard if using units of lbs/MMbtu, and this gets around lack of efficiency database.17

Chris Neufeld commented that, as Dutch Dresser noted earlier [presumably about being lumped in and forced to perform in a way the device is not meant to], water
- based and air
- based furnaces should be separated. Rick Curkeet commented that Europe would like to introduce hy brid s ys tems here but there is not a good fit in the standard for these units, so they are not able to enter US market. Lisa Rector wondered if there should be an “other” Bin. Rick responded that the standard should go to emissions per heat output (to which Lisa commented that this happened to be her original proposal ye ars ago ). Lisa attempted to confirm that Rick would like handfed versus automatic feed categories and an emission per heat output, which are basicall y the classification use d by Europe. David Menotti interjected that such a switch would have to be for the future since industry does not have enough data on heat output to support the change . Rick commented that some data exists and that some can be calculated. Martin Lunde comm ented that consumer’s number one concern is efficiency ; emissions are an afterthought. In response to question from Gil Wood regarding pellets and non
- pellet woodstoves being lumped together, John Ackerl y responded that he is okay with the lumping but doe sn’t like the term “room heater” from a consumer point
- of
- view. Regarding thermal storage units, David Menotti commented that masonry heaters cannot be regulated based on lb/MMbtu because there is no overall efficiency test method and no overall efficienc y data, so these can onl y be regulated based on combustion efficiency (g / kg
- of

- wood
- burned). Therefore the thermal storage unit category should be subdivided into (1) partial thermal storage hydronic heaters and (2) masonry

heaters. David further comment ed that there is no [official] data for partial thermal storage hydronic heaters because the test method is still being developed (EN305 won’t work because it leaves off cold start). These units look a lot like better
- controlled cycling heaters which are c oming in at 0.2 to 0.3 lb/MMbtu so Bin 2 (at 0.15 lb/MMbtu) would eliminate these units. Andy Ginsburg commented that a goal is to build a database for room heaters based on lb/MMbtu. Bob Ferguson commented in response that HPBA has been promoting efficiency data collection to report on the hang tag rather than to use in the standard directly

– so they are okay with collecting data for future but don’t want efficiency requirements in the standard [now] . Arthur Marin asked Gil Wood if voluntary reporting o f efficiency

precluded EPA from setting a mandatory

[efficiency
- based] standard with in the 8 year NSPS cycle
. Gil explained that this would be a regulatory

change and the package would need to go through the regulatory process, but no, EPA would not be precluded from doing so. Jim Hodina of the Linn County Public Health Department in Iowa asked Gil Wood about the regulatory timeframe and whether the preamble could state the timeframe in some way as the NAAQS does [to avoid the next NSPS taking longer than 8 years]. Gil noted that there is nothing legall y preventing EPA from re
- visiting the NSPS in less than 8 ye ars. Andy Ginsburg would like the current NSPS to build
- in a transition to the next NSPS

– e.g., include a deadline (6 or 7 ye ars) or a process for collecting data for creation of new test method. Rick Curkeet suggested using an ASTM method, commenting th at an ASTM method must be reviewed every 5 years in an open process

– that the methodology is a living document that goes away after 8 ye ars if not18

reviewed. ASTM could set a minimum efficiency , for example. Andy asked if efficiency

% would need to be stat ed by

EPA, and Rick responded that ASTM can set the test standard without EPA. In - Use Durability Overview was presented by Andy Ginsberg of the Oregon Department of Environmental Quality, who noted that in
- use durability is important because of its impac t on air quality (i.e., old stoves are a big part of inventory), because of the long
- life and cost [of stoves], and because of consumer behavior. Stoves deteriorate with age , older units may emit at higher levels than when new, and an estimated 50% of stov es in Oregon are [older] uncertified models ( i. e. . , Phase 2 stoves will be around for many ye ars). Furthermore, central heaters are expensive and thu s not amenable to change
- out programs. So stakeholders need to keep in mind that the stoves that get put in circulation today will likel y impact airshed quality for a long time. Therefore Oregon [and presumably some other states] would like a durability standard. Andy Ginsberg presented the following draft regulatory options for consideration, but was careful to note that these options do not necessaril y represent any other state’s proposal and that the other states had not yet seen this table : Options for NSPS or State Programs

Design Maintenance Education Components & Warranties Service contract with initial sale (e.g., business opportunity for chimney sweeps) Value of maintenance Test to simulate aging Warranty void if not maintained per specifications Manufacturer’s instructions Modular / replaceable parts Periodic tune
- up requirement (by state, no t NSPS) Proper burning techniques Less consumer control In - use testing with follow
- up as needed (e.g., 10 ye ars after installation) Auto shut
- down if out of specifications (e.g., O2 sensors) Chris Neufeld commented that if there’s a catal ys t, the manufacturer must give a 3
- ye ar warranty . But the question is who will void the warranty (i.e., is manufacturer off
- the
- hook if consumer misuses product by

for example burning house down after putting diesel fuel in stove ? )
. Andy Ginsberg commented that incentives should be created for consumer to follow warranties (could be carrots and sticks). Arthur Marin commented that it could be thought of as akin to a consumer using wrong fuel in their car and v oiding their warranty. Chris further commented that he had previously suggested defining a list of tolerances for manufacturing materials

– that manufacturers could voluntarily test for this data and the product would consequently be more predictable

– thi s would support building of a quality product that would tolerate prescribed use. Dan Henry

commented that warranty issue s bankrupt companies and most companies already give “lifetime” warranties (7 years). The hydronic heater industry , for example, already requires 99% of19

Oregon’s proposed durability standards. A warranty

rate of >1% is unacceptable to manufacturers. Andy commented that minimum durability levels would help ensure that progress in industry continues. Bob Ferguson commented that accelerate d stress tests have merely shown that if you put your mind to it, yo u can break anything. Manufacturers will test [without being told to] to ensure product won’t have warranty problems. Regulation is not necessary here. John Ackerly

commented that routine maintenance is a good idea but it needs to be data
- driven. Missoula did a good job requiring certification technicians to go out and check gaskets every third year. Manufacturers don’t have leverage once they sell product. Rick Curkeet commented that req uired safety tests already include stress test s and overfiring for a long period of time. But labs don’t conduct emission test s after safety test, or vice versa [because NSPS requires certified stove to be sealed for potential NSPS audit tests later]
. The b ottom line is that all devices get safety tested for way above what consumer would do (i.e., ULs of the world)
. Arthur Marin wondered whether any m anufacturers have recruited consumer volunteers to give back stove for manufacturer to test. Bob Ferguson r esponded that this had been done, but he’s not sure how common the practice is and that industry didn’t learn what they

thought they

would
. Bob noted that the manufacturer will alway s get stove back for a warranty claim however. Rick Curkeet commented that it’s common for employees of manufacturer to bring stove home and real
- world
- test. ** Moderator noted that some state stakeholders would like minimum [durability] standards to control bad actors. Bob Ferguson noted that when industry reviewed warranties it was remarkable how very similar warranties were across products. He also noted that “lifetime” has different meaning for different states. Chris Neufeld commented that consumers quickl y communicate any dissatisfaction to each other via the internet an d that manufacturers must respond immediatel y. Consumer dissatisfaction reporting is akin to a fast moving virus and is therefore self
- enforcing for industry
. John Ackerly

commented that there is nothing stopping towns from requiring chimney sweeps every ye ar, as in Germany

(using a testing device called a Moeller). Lisa Rector further commented that chimney sweeps in Germany

are like OSHA here in authority to lock
- out/tag
- out. Andy Ginsberg commented that research has shown that idiot lights alone don’t incentivize people to fix cars, onl y performance issues incentivize consumer action . Unless stoves are dramatically malfunctioning ( i.e., not heating), people will likely not be motivated to fix stoves. Chris Neufeld responded that on the contrary evidence shows that consumers do replace catal ys ts because they ’ve spent a lot on stove (notwithstanding John Ackerly ’s comment that his own father had a catal ytic stove and didn’t know it was cataly tic). Dan Henry

commented that manufacturers can put any thing yo u want in their manuals but manufacturers have no ability to control consumer/user behavior once stove is out there. States however do have this power. Andy Ginsberg responded that states do have some power but looking for states and20

manufacturers to work together (e.g., incentives from manufacturers to encourage stove maintenance by consumer, like discount on product if replaced in time, etc). Tomas Carbonell of the Environmental Defense Fund asked if service contracts are bundled with warranties. Dan Henry

responded that it depends on the dealer (some pellet dealers do, for example), but most manufacturers don’t bundle . Gil Wood noted that legally it could be required in the NSPS but such a provision probabl y could not be enforced effectively. Tom Morris sey commented that his small company sells direct to consumers and it’s only been in the last several ye ars that they ’ve been asked about service contracts. Rather , his company contacts consumers in the summer about catal ys ts or service kits (he noted that he wasn’t sure consumers would contact the company). Tom further noted that it is clear from this meeting that stove lifespans are long. His company does their own change
- out campaigns and gets 100
- ye ar - old stoves sometimes, and sometimes their own 30
- ye ar - old stoves. The company keeps a database of customers as well as a photo library of every component of stoves being serviced to catalog wear and tear, etc. Martin Lunde commented regarding oversizing of stoves that manufacturers can’t deal with this iss ue – rather sizing needs to be put in building code like Minnesota did. Building code is answer, not manufacturer. Chris Neufeld suggested a state tax credi t to get stove inspected, with DOE review. John Ackerly

commented that manufacturers should not s ell equipment, like screens [so doors could be left open] , that should not be used . Dan Henry commented that screens could only be legally sold for stoves that passed emission test with screen on. **Summary and Next Steps** The major components of the wrap
- up expressed by Dan Johnson of WESTAR were: (1) Test method

– Stakeholders are looking for ways to improve precision but in cost effective way
. There is no answer yet as to timeline. More intense (work group) discussion needs to take place regarding nature and timeline of transition from crib
- to cord wood
. (2) Level and Form of Standard

– The states are not surprised b y industry ’s reaction to the proposed numbers, but Dan noted that if NSPS were to move to cord wood those numbers would change. There appears to be agreement about moving to two Bins (and for some to Bin 3 even)
. Regarding next steps, Dan did not hear an alternative suggestion to 50% best performing stove metric, and noted that there is not agreement on this metric. (3) In - Use Performance

– There appears to be some shared interest in emission and warranty claims. The states would like to talk about this issue more in the work group. Arthur Marin asked EPA if there was merit to spending next two weeks on cord wood off
- ramp. Gil Wood and Greg Green responded affirmatively that it was worth EPA time and they ’d be involved. Gil would work with John Crouch. John commented that HPBA is interested but its members are still thinking about this. Lisa Rector asked ind ustry to put its cards on the table regarding this issue and others. Bob Ferguson commented that manufacturers are still chewing on cord wood idea, but they are21

burning wood and collecting data

– just don’t want to jump off cliff blind. David Menotti comme nted that he took this issue to his caucus but didn’t get a quick response. Gil Wood asked Greg Green how hard the end
- of
- ye ar deadline is. Greg responded that EPA will move on a rule to protect public health and that there’s a narrow window with which to move since this is not a court - ordered deadline. Rod Tinnemore noted that the state and industry stakeholders are closer today on some issues than they were a year ago. Tomas Carbonell noted appreciation to attend meeting and explained that the Environm ental Defense Fund has received numerous complaints from citizens and grassroots groups, which is why EDF is involved and would like to see a protective standard quickly
. Dan Henry

commented that the data on certified stoves ranges from 3 g/hr to 30 g/hr burning cord wood on every model multiple times. The p resident of HHT said he’d switch to cord wood certification testing if it would make stove better and reduce emissions because that’s the right thing to do

– but it will cost the company millions and cannot be done quickly. EPA should set higher real
- world numbers

– that a more lenient standard should be promulgated based on cord wood , rather than a tighter standard based on crib wood
.