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HPBA Response to NESCAUM Report

Are the new, ultra clean woodstoves just as bad for air quality as your grandparents’ ancient woodstove? That’s what you might think if you read the recent report released by NESCAUM. Of course, it’s utter nonsense to suggest that this is true. Any woodstove available in a store today meets the very high standards set by the Obama Administration in 2015. 

A very brief history of the woodstove: Prior to 1988, the government did not certify woodstoves. Really anyone could build a metal box with a chimney and burn wood in it. However, in 1988 the EPA implemented the first New Source Performance Standards (NSPS) that targeted woodburning appliances. This regulation resulted in much cleaner-burning stoves and better air quality. In 2015, the EPA updated that NSPS to bring us the familiar Step 1 and Step 2 appliances. The Step 2 requirements have been mandated since May of 2020. The difference between a non-certified stove, a 1988-certified stove, and a 2020-certified stove is extraordinary and a credit to the industry for fully embracing technological advancements to produce these incredible appliances.

We take seriously any allegation that the testing and certification process is not adequate, but we haven’t seen – nor does this report expose – any indication that the regulatory process doesn’t work. The report does show that different labs can get different results, especially when using different types of wood (firewood versus lumber). In addition, fire is variable! A log may settle in a different way in one test to the next, resulting in slightly different results. This does not mean the process doesn’t work – it means that there will always be some variability between labs. A fully resourced EPA could track that.

A properly funded and staffed EPA could also conduct field testing of woodburning stoves. They haven’t done that since the early 1990s. That means the EPA and NESCAUM have no idea how the newest certified stoves perform in the home. All we have to go by are lab results, which do show significant improvement from pre-2015 stoves and the stoves today that meet the standards set by the Obama Administration in 2015. And remember that the vast majority of stoves in homes today are pre-1988, uncertified (which is to say unregulated) models.

So, what is going on in Alaska? There is a significant air quality issue in Fairbanks that the Alaska Department of Environmental Conservation (ADEC) is struggling to address. ADEC initially raised concerns that there is a problem in the EPA certification process. From what we have heard from member companies, part of ADEC’s problem could be that they aren’t fully reading the stove test reports. We all know how cumbersome it can be to read an EPA test report, let alone find information that you’re looking for.

We’re aware of many of ADEC’s concerns and found that most of them are due to a modest data omission or a small mistake in a test report – nothing that would indicate a problem with the actual emissions level from a certified stove. However, the data they are looking for is there, just not where ADEC expected it to be. HPBA and the industry has been calling on the EPA to develop a standard template for the test labs and manufacturers to use for test reports and certification. Perhaps with a template it would be easier to report and understand what is in these reports.

In recent years, communities all over the country are doing change outs to encourage consumers to get rid of their outdated woodstoves and replace them with a new, cleaner version. This must continue.

In many parts of the country, a woodstove is a key part of heating a home. In some places, it is the only viable option. Changeouts and tax credits like the new federal section 25(D) make it easier for a home owner to obtain a new woodstove. It is critical that every stove in use today that predates EPA certification be replaced with a newer, cleaner option.

This report from NESCAUM is an unfortunate result of individuals looking to find a problem so that they can push for their desired outcome. An outcome that will not help the public or the development of the wood and pellet heater industry. The industry has done everything that EPA has asked of it. Sometimes a little grudgingly, but ultimately, we follow the rules. If there is a problem with how EPA is certifying products, we need more than lab variability and an anti-woodstove agenda to force the removal of clean and excellent products from the store shelves. Consumers in North America deserve to have access to the heating source that best works for them and our industry will fight for that right.