August 23, 2021
Wood Burning Issues and What Retailers Need to Know
John Crouch - Director – Public Affairs
Retailers:
Have your suppliers been telling you their hot new products are stalled waiting for approval from EPA?
They are not just spinning a yarn, there is a reason that virtually ALL of the manufacturers are waiting to hear on their certifications.
Earlier this year the Northeast States for Coordinated Air Use Management (NESCAUM) published a review of the Environmental Protection Agency (EPA) program to certify new woodstoves. This group made some pretty bold assertions about a new, EPA-approved test method used by many companies and accused EPA of dropping the ball on oversight of the entire certification program. This has led to EPA reviewing all renewal and new certification requests, as well as all existing certifications. With the review process conceivably taking several months, the net effect has been a significant slowdown on receiving new and renewed certifications right before the industry’s important selling season.
The good news is that the bulk of the so-called “deficiencies” cited in the review were either trivial or simple omissions by the laboratories or manufacturers. Most of the controversy surrounding the NESCAUM review, however, revolves around the use of the new method for testing woodstoves, which calls for actual firewood to be used as the fuel. This consensus-based test method was an attempt to improve upon the decades-old reliance on 2x4s and 4x4s of Douglas fir lumber. The review challenges the new test method for not being precise enough and allowing for too much variability in, for instance, the species of firewood.
Our industry’s perspective is different and it is simple. What will the consumer be burning in their woodstove? Of course the answer to that is firewood. Consumers don’t burn lumber from Home Depot. Any woodstove must be able to burn all kinds of firewood, not just one or two species. Why should manufacturers design stoves that burn lumber cleanly when that is not reflective of real-world experience? Testing with normal firewood is called the ASTM method and it was developed using input from the EPA, industry, and other regulators. Over the past five years, we’ve developed reams of data from testing being done at labs all over the country. The test method absolutely has its variabilities – all firewood has variabilities – but ASTM testing does show when a newly-designed woodstove is meeting its obligations with respect to emissions.
Unfortunately, aside from the criticism of this test method, the review also attacked the EPA for not doing an adequate job of reviewing all test reports. This has naturally resulted in the EPA taking more time to go back and review all the existing test reports. This has significantly slowed the certification of new stoves.
The timing for this is unfortunate as many companies want to release new units to take advantage of the new tax credit [link] during this fall’s selling season. It is also possible that some certificates may be revoked once EPA finishes up the review. More likely, a few stove models will need to be retested – with a suspension of sales of those stoves until any issues are resolved. As retailers, you need to stay vigilant to this threat and react appropriately to any decisions by the EPA. HPBA is a great resource to keep you up to date.
The NESCAUM review goes even further. It actually claims that new stoves today are probably no cleaner than unregulated (sometimes referred to as “uncertified” or “conventional”) stoves from the 1980s. Of course this is nonsense. The historical data is clear: even stoves certified using the old method – those 4x4s of Douglas fir – are significantly cleaner than those uncertified stoves. This holds true not just in the laboratory, but in the homes of your customers – where it really counts. And it certainly stands to reason that stoves designed to burn real firewood, with the testing to prove their worth, will do an even better job in the real world.
HPBA member manufacturers strongly support the use of actual firewood to test and certify woodstoves. This is the closest we get to real-world conditions. Our interest is getting clean-burning woodstoves into every home that wants one. We think the EPA should develop a standard template for certification applications to minimize the mistakes. Create a form that the manufacturers and labs fill out – that will eliminate many of the simple mistakes that NESCAUM identified. We agree with NESCAUM that the current application process needs to be improved.
We look forward to a time when EPA will once again begin to test stoves in actual homes, fueled and operated by families, not technicians. That will be the real test of this new test method and any other test methods that may be proposed.