Tuesday, May 20, 2014

A Response to "Best Practices in Change Out Programs"

This is a response by Sylvia Shultz of the non-profit Clean Air Fairbanks to our Blog Post on Best Practices in Change out Programs.  Sylvia takes issue with our assertion that Fairbanks employs a strategy that we consider a "best practice." Her thought provoking response is reproduced below. If others have substantive responses, please send them and we will consider reprinting them.

"Thanks for sharing your blog post and asking for feedback.

In your blog, you wrote that "Fairbanks may be the best example of effective prioritizing based on location instead of using a first-come, first-serve model."  

The only "best example" of practices for the Fairbanks PM2.5 non-attainment area is the City of Fairbanks ban on hydronic heaters. Other than that, "best" at wasting public money is all the change-out program can claim. $7.8 million has been spent on change-outs, with $1 million more in the 2015 Capital Budget (expected to be signed by the Governor). It is a unique among change-out programs in a PM2.5 non-attainment area as there is little to prevent rolling back to the most polluting heaters and boilers.
The Fairbanks North Star Borough (FNSB) and the State of Alaska continue to allow any solid fuel or other heating device to be installed in this serious PM2.5 non-attainment area. However, in 2009, the City of Fairbanks banned new hydronic heaters. Outside the city limits, without controls, PM2.5 levels are far higher. But other than that single provision in city code, installation of coal, wood, pellet, biomass, or waste oil burners for residential and commercial use is unrestricted. New devices of every flavor, from $50 barrel stove kits to $20,000+ coal hydronic heaters, continue to be installed. FNSB paid residents to install wood boilers, the State paid for $20,000 coal boilers (it won't say how many), and schools were converted to wood (although that didn't work, and now are converting to natural gas with state funding). State funding also paid for unreliable and ineffective ClearStak catalyst retrofits on wood and coal boilers.

So, while it is correct that FNSB uses location-based prioritization for the voluntary change-out program to target air pollution hot zones, any type of heater or boiler may be installed in these areas, as long as it is outside the City of Fairbanks. Highly polluting heaters can be installed by owners who been paid $11,000 to replace a hydronic heater. It is nonsense to herald Fairbanks' prioritization method as a "best practices" model when there is no restriction on new installations, even in hot zones. PM2.5 measured in the cleanest area, the City of Fairbanks, rank among the worst in the nation. Monitors from neighborhoods outside the city limits rank among the worst in the world.

A survey in 2010 for the State estimated a total of 3,360 uncertified woodstoves, coal heaters, and outdoor wood boilers in the PM2.5 nonattainment area. After $7.8 million has been spent, that is over $2,300 per uncertified heater. Spending another $1 million would bring the total per uncertified heater to over $2,600. Yet, many uncertified heaters remain and more continue to be installed. Ineffectively throwing money at a serious problem should not be held up as a best practice. Most communities could not afford to undertake such an expensive approach that demonstrates such poor results.

Please review the Case Study on two Central Boiler 2300, Phase 2 qualified, in Fairbanks AK. It was submitted to EPA as part of our NSPS comments. EPA seems unaware of the problems and the judge's order in Alaska v. Straughn that declared the operation of the boilers to be a "public nuisance." EPA's proposed Step 1 emission standard would allow hydronic heaters that have even higher emission levels than those in Alaska v. Straughn.

The FNSB change-out program paid Straughn $10,000 to remove one boiler, and agreed to pay $10,000 for the second. This was after the judge ordered the owner to cease operation of the boilers and later a settlement restricted the properties to oil or gas heating. Paying to remove and destroy devices that can't even be used at those properties serves only to prevent them from being sold and installed elsewhere in the PM2.5 nonattainment area, even next door.

Thanks for your reporting and attention to detail.

Sylvia Schultz

Collaborative Stove Design Workshop Announcement

Rebecca Trojanowski of Brookhaven
National Lab is one of Organizers of
 the November Stove Design Workshop.
The Collaborative Stove Design Workshop held Nov. 4 – 7, 2014 was a gathering of stove professionals to study, test, and discuss advanced wood stove designs.  The Workshop was held at Brookhaven National Laboratory in New York and involved hands-on stove testing, daily review of test data, and a series of presentations by participants and other experts.

(The next competition, the Fourth Wood Stove Design Challenge will be hold on the National Mall in Washington DC in November 2018. It will focus on automated controls for cord wood stoves and stoves that make electricity.  Check back for more information in Spring 2017 or contact info@forgreenheat.org. )

The final outcome and stove rankings of the 2014 event showed innovation is key for high performance. See the test results, presentations and photos from the event  here.

"We are extremely excited about this Workshop and already more than 10 companies and institutions are planning to submit automated stoves or stove prototypes, including some from Europe, China and New Zealand," said John Ackerly, President of the Alliance for Green Heat. "We are also very pleased that representatives from federal agencies and states will be attending not just to learn about automation, but to better understand wood stove testing and to network with industry," Ackerly said.

Stoves must have some type of automation that significantly reduces operator error, use of unseasoned wood, and/or start-up emissions.  To apply, stove designers must agree to share test data obtained during the Workshop with other participants and allow participants to inspect their technology to learn how it works. 

The Workshop was designed for participants to share their knowledge, learn from each other, and explore advanced stove designs that may help significantly reduce particulate emissions and meet potential strict emission standards set by the EPA.  The Workshop also developed an alternative test method for automated stoves, as allowed under the existing NSPS.

The finalist stoves were tested in a dilution tunnel and with other particular matter testing technology, using cord wood. Testing was done by Brookhaven staff, Ben Myren of Myren Consulting, and others.  The first prize winner received $1,000.

Participants:  Due to space limitations, there is only room for 40 participants in addition to the Organizing Committee and technicians.  We are looking for specialists from the stove industry, the international cookstove community, universities and government agencies as well as inventors.  Click here for the Participant Application form. Participant applications must be submitted by Sept. 1.

Stoves:  Stoves must include innovative, automated features that pre-empt the operator from controlling air intake, or some other technology that can significantly improve real world performance by reducing chances of misuse or extended smoldering.  Mitigating the impact of using unseasoned wood is also important. Click here for the Stove Application form. Stove applications must be submitted by July 1.

Logistics:  The Workshop will be held at the Brookhaven National Lab in Upton, New York, 1.5 hours east of New York City on Long Island.  There will be a $250 fee per participant to cover administrative and other   Lodging will be available in the Indigo hotel and participants must cover their own travel, lodging and meals.
costs.

Background: The Collaborative Stove Design Workshop is the second phase of the Wood Stove Design Challenge, following last year’s Wood Stove Decathlon on the National Mall in DC.   The Workshop will be a more collaborative event with some of the country’s top stove specialists.  It is partially modeled after an annual “Stove Camp” hosted by Aprovecho Research Center in Oregon, which uses an interdisciplinary approach to designing stoves that are often not patented, but open-sourced so that anyone can build them and improve upon them.  The Workshop is being sponsored by the Alliance for Green Heat and Brookhaven National Lab.

Organizing Committee:
The Organizing Committee oversees the Workshop, including selecting the stoves to test and the participants. Primary funding comes from NYSERDA, the US Forest Service and the Osprey Foundation.

John Ackerly, Alliance for Green Heat
Ellen Burkhard, NYSERDA
Tom Butcher, Brookhaven National Lab
Prof. Phil Hopke, Clarkson University
Craig Issod, founder of Hearth.com
Ben Myren, Myren Consulting, Inc.
Robert Rizzo, Mass. Department of Energy
Norbert Senf, Masonry Heater Association
Dean Still, Aprovecho Research Center
Rod Tinnemore, Washington Department of Ecology
Rebecca Trojanowski, Brookhaven National Lab

More updates on the Workshop will be posted on our website and blog and a monthly summary in our newsletter.  For questions or suggestions, please contact us at info@forgreenheat.org.

Monday, May 19, 2014

Best Practices in Change Out Programs (and Why Some Programs Underperform)

Nov. 2016 update: An updated list of "best practices" for stove change-out programs is available here.

Change-out programs are now commonplace in the wood stove community, particularly in the Northwest, with Libby, MT being the highest profile one.  In Libby and elsewhere, changing out old uncertified stoves to new EPA certified stoves has demonstrably contributed to cleaner air quality.  Typically, wood stove change-out programs start with government funding, and then leverage in-kind donations from wood stove manufacturers, stove retailers and others. 


However, change-out programs sometimes provide fewer air quality benefits than expected.  And, per ton of particulate matter removed from the environment, they can be very expensive.  Raw numbers from Washington State based on money they spent versus estimated emission reduction came to nearly $50,000 per ton of particulate.  When Washington State uses the EPA methodology for calculating cost per ton, the mean cost was between $14,000 and $19,000 per ton


In addition to the classic change out program designed to reduce excessive smoke in particular town, valley or region, change out programs can simply help rural households more efficiently use a local renewable energy source.  Also, manufacturers and retailers can undertake them in the slow, summer season.


In assessing the effectiveness of change-out programs, the Alliance for Green Heat found a lack of rigorous analysis or debate about how to best achieve air quality improvements. Some states are starting to develop more innovative features in incentive programs instead of following the pattern set by the EPA and HPBA. Here are eight strategies that will improve change out programs.  Virtually none of these strategies, that many consider key parts of change outs, can be found on the EPA or HPBA change out pages.  Expect push back from local government agencies, HPBA and/or retailers on some of these points, but all of them are becoming more and more accepted.

1. Controlling future installations of uncertified appliances
Too many change out programs occur in places were people are still allowed to install old, second hand stoves or even unqualified outdoor boilers.  Reports touting the success of change-outs in Pennsylvania, Indiana and the Great Lakes states don’t even mention that while old stoves are being removed, traditional outdoor wood boilers are being installed in the very same communities.  In Vermont and Keene, NH, more uncertified wood stoves may have been installed since their programs ended than were removed.  Before spending limited dollars on change-outs, funds should be focused in areas where the locality has enough commitment to clean air to stipulate that old, uncertified stoves and unqualified outdoor boilers cannot be installed in the future.

2.  Prioritize which stoves get changed out first
We believe that some programs inappropriately used a first-come, first-served approach when stoves used as a primary of sole heating source in more densely populated areas could have been targeted first.  While this does not apply to valleys with inversions like Libby, where every stove is equally important, in places like Massachusetts and southern New Hampshire, where funds can run out quickly, stoves in the middle of towns which are used as a primary heating device should be given priority.  Some new epidemiology research is coming out saying that stove change-outs do not necessarily improve indoor air quality and the main benefit is to improve outdoor air quality that impacts the community at-large.  In change-outs that cover multi-county areas, or even statewide, as in Vermont's program, we think focusing on stoves in towns is warranted.  Last priority should be stoves in isolated houses that only use wood as a secondary heat source.  Fairbanks may be the best example of effective prioritizing based on location instead of using a first-come, first-serve model.  A related best practice that has been implemented by HPBA, EPA and others is giving priority or higher rebates to low income households. While this is a practical necessity in order for them to participate, it also helps the program ensure that they are getting more stoves that are primary heating appliance of the house.
3.  Focus on wood, not just stoves
Some experts are now wondering if a $150 rebate to help build a wood shed to keep wood dry may produce similar air quality results as a $1,000 rebate for a stove.  It’s well known that the equipment is only half the battle, and the other half is the fuel and the operator.  Requiring firewood dealers to bring a moisture meter when delivering wood and writing down moisture content on the sales receipt may also be a good strategy. Change out programs could prioritize homes with woodsheds, to help ensure that subsidizing a new stove will result in reduced smoke from the home.  Or homes with woodsheds could receive a higher rebate, which incentivizes proper storage and educates people about its importance.

4. Right-size the rebate and require partial payment
When rebates disappear in a few hours or even a few weeks, it likely means the rebate was too generous and a lesser rebate could have resulted in more change outs.  Also, rather than provided a fixed amount, programs that provide 50% or even 35% of the new stove should be considered, where possible.  When smaller, more targeted populations are involved like Keene, NH, larger rebates are required, as they also are with low-income populations.

5. Require that new stoves meet stricter emissions and efficiency standards
Almost all change-out programs now require that the new EPA certified stove be 4.5 grams or less, but some are starting to require 3 or 2.5 grams an hour or less. Pellet stoves, which operate in the field much more like they did in the testing lab than wood stoves, should be held to 2.5 or 2 grams an hour at the most.  Some states, with varying degrees of success, are starting to experiment with minimum efficiency requirements and this is likely to be a standard requirement sometime in 2015.  Oregon provides a greater rebate level for stoves made by companies who agree to share verified efficiencies with their customers.  Most stove manufacturers will not release this information, preferring to use unverified and often exaggerated numbers.  Maryland requires a maximum of 3 grams for wood stoves and 2 for pellets. (The Maryland program is a renewable energy program and does not require the change out of an old stove, but about half the old stoves are disabled and destroyed anyway.)

6. Require both wood and pellet stoves be EPA certified
Few programs have required that pellet stoves be EPA certified although there are substantial benefits of this.  EPA certified pellet stoves are usually more efficient than their exempt counterparts because exempt pellet stoves often use the 35 to 1 air to fuel ratio loophole to avoid certification but all that air reduces efficiency.  Some pellet stoves are as low as 40% efficient, and many are in the 50s and 60s, when they easily can be in the 70s.  Households should not be unwittingly subsidized to buy a low-efficiency pellet stove that will saddle them with much higher fuel costs for years to come.  Unfortunately, large and small pellet stove manufacturers currently self-report efficiencies and are notoriously adept at exaggerating and inflating their efficiency numbers.  The EPA and DOE have done little to counteract this and have at times contributed to the problem.

7. Integrate wood stove inspections in energy audit process
If your state is particularly interested in retiring older stoves, it is important that state subsidized energy audits require that the auditor inspect the wood stove, just like they check other HVAC equipment.  Auditors can educate homeowners about the importance of upgrading to safer, more efficient equipment, spot dangerous installations, assist in removing dangerous stoves and sometimes help get stove upgrades to be subsidized through low interest loans or other programs.  The Building Performance Institute (BPI) is taking the lead to develop guidelines for energy auditors to inspect wood stoves.  In recent years, energy auditors have failed to include wood stoves in hundreds of thousands of homes.

8. Ensure big box stores are included in the program
As long as professional installation is being required in a change out or incentive program, including stoves from big box stores can make funding go much further and enable more low and middle-income households to participate.  Allowing purchases from hardware chain stores can make all the difference for lower income families to trade out that old stove and afford a new one.  Good quality stoves can start at $700 and one of the most popular stoves in the country sells for $900.  Professional installation can be done by CSIA accredited chimney sweeps if local NFI trained staff at specialty hearth stores will only install their own products.  Especially if larger rebates are not provided to low-income families, this is a vital way to help them overcome high upfront costs and help stretch program funding and change out more stoves.

Background
Based upon an informal survey of 10 change out programs, we found the average rebate for a new wood stove was $627 dollars, but ranged from $300 to $1,050 per stove and much more for low-income change outs. The median rebate was $670.  Nine out of the ten programs surveyed offered additional assistance to low -income applicants, and three out of ten offered full rebates.

Change out programs, depending on their size and scope, can cost a great deal of money to run and advertise. Buy back or bounty programs that just pay to remove stoves and do not replace them, are increasing in popularity and should be considered alongside change outs.  They are far cheaper, require much less administration, and can be run on a year round ongoing basis.  The average cost per change out varies greatly between programs. Libby, Montana had a large budget and was servicing a low-income population so the cost per stove was higher.  Pittsburgh program’s average cost was relatively low, at $770 per change out.   Higher costs per stove do not necessarily mean they were less efficiently run, as there are so many variables and so much need for costly educational programs that target homeowners who are not changing out stoves, but may be emitting a lot of excess smoke. 

[Afterward: Sylvia Shultz of Clean Air Fairbanks took issue with part of this blog and you can read her response here.]


Click for larger version.

Friday, May 16, 2014

One Chapter of Polluting Legacy of Outdoor Boilers Coming to Close

One chapter of the fight over outdoor wood boilers is on the verge of ending, as EPA regulations are prepared to ban the sale of unregulated boilers in the 38 states that still allow them.  And virtually all the  main stakeholder groups, from industry to air quality agencies, agree that this will be one of the best things about the upcoming residential wood heater regulations set to take effect in the spring of 2015.

A decision by the EPA in the mid 1980s to not regulate residential wood-fired boilers, also referred to as hydronic heaters, seemed reasonable at the time.  Fossil fuels were cheap and our nation was turning away from wood heating and quickly adopting electricity and gas as heating sources. But starting around the turn of this century, a boiler design emerged that became increasingly popular, spawning a few dozen small businesses, some running out of garages and barns.  The design appeared brilliant: put the boiler in the backyard next to your woodpile and pipe the hot water underground.  But they had one big drawback.  They had a water jacket around the firebox that continually cooled the fire, keeping it from reaching temperatures that combustion needs to be clean and efficient.

Outdoor wood boilers are one of the reasons that states and non-profits are demanding stricter EPA emission limits not just for boilers, but also for stoves and furnaces, which are all coming under more scrutiny.  In the absence of federal regulations, a dozen states either effectively banned them, or only allowed models that met stricter voluntary emission standards.  Vermont was the first state to require this in 2005 and Utah was the last in 2013 before federal regulations, known as New Source Performance Standards (NSPS) will take effect in 2015.

These regulations will close the chapter on installing new, unregulated boilers in the US, but the hundreds of thousands of existing boilers already installed still cast a pall over the wood heating community, reducing neighbors property values and forcing some families to leave their home, rather than breathe the dense smoke that often comes from these boilers.

New battles are already looming around outdoor boilers, as the Hearth Patio and Barbecue Association (HPBA) fights for a one- year period to sell off existing inventory of the unregulated boilers.  States and air quality groups oppose this additional year and the EPA will decide by February 3, 2015 whether to allow the additional year of sales, as well as how many pounds of particulate matter the boilers can emit in 2015, and how much tighter the standard should be by 2020.

Litigation is likely, but relief is not likely to come soon enough for companies like Central Boiler, the leading manufacturer of both unregulated boilers and the cleaner models.  Central Boiler has fought regulations in state after state to continue selling their unregulated models, while at the same time building cleaner EPA Phase 2 models for the dozen states that ban their unregulated ones. Their most popular models are the unregulated ones and currently, their dealers do not know if they can sell them after next spring.  Many dealers are telling customers to buy and install now, while they still can.

The outdoor wood boiler industry is also pitted against the importers of more sophisticated European technology, with the US importers fighting for test methods and emission standards that are geared towards European technologies, which are more likely to include oxygen sensors, thermal storage and high temperature combustion.

The battle over the future of outdoor boilers is a microcosm of many similar battles about our energy future.  More than a dozen Republican lawmakers are demanding that the EPA drop these regulations that they say will make this age-old American tradition of heating with wood prohibitively expensive.  Democrat lawmakers are more focused on reducing pollution.  Both sides claim they are they are supporting the future of a low carbon fuel source. 

But many battles will remain with the states, as property line set backs and stack heights are still considered vital by many states who don’t want outdoor boilers in suburban neighborhoods or where a neighbor’s house in only 100 or 200 feet away.  While the cleaner models are cleaner when used properly, they still can be misused by operators who load them with un-split wet wood, or even worse, with household garbage that cause plumes of smoke to blow through valleys shared by other families.


Update: In August 2014, Connecticut announced a outdoor wood boiler buy-back or replacement program. (The program is now closed.) What makes it significant is that they are only allowing boilers that emit no more than .06 lbs of particulates per MMBBTU, which is far lower than the current EPA voluntary standard of .32 lbs/MMBTU.  Woodmaster is one of the only company that makes boilers that clean, along with a number of European pellet boilers such as Maine Energy Systems and others.  The state does not require the replacement boilers to be part of the EPA voluntary program, but only requires that they meet the low emission requirement.