1. Issues with Wood & Pellet Stove Efficiency John Ackerly President A minimum efficiency standard will help consumers and industry National Educational Forum on the Residential Wood Heater NSPS, Minneapolis, MN November 8, 2012

2. Alliance for Green Heat 501c3 nonprofit funded by foundations & grants A national voice for wood heat consumers Work for more incentives for the cleanest & most efficient biomass heaters Call on government to provide R&D funding for ultra-clean “next generation” stoves Work for more common-sense regulation of wood stoves, including No new installs of unqualified outdoor boilers No new installs of uncertified stoves in densely populated areas

3. Every Gram of PM Matters If neighborhoods like this are to have 10 – 20 pellet stoves, the difference between 3 grams and 1 gram is huge. If industry and the renewable energy community want more widespread deployment of pellet stoves, we need them to be be consistently and significantly cleaner than wood stoves. EPA should propose 2.5 gr/hr in the NSPS and propose as an alternative going to 1.5 several years later.

4. Wood Stoves Must be Part of Energy Audits BPI Solid Fuel Working Group Alliance for Green Heat – Chair EPA National Fireplace Institute Chimney Safety Institute of America Washington State Dept. Ecology Hearth, Patio BBQ Association DOE funded programs have resulted in millions residential energy audits that resulted in upgrading hundreds of thousands of furnaces and boilers. Wood stoves have been completely left out, indicating a widespread lack of interest in government about this technology, and its impacts.

5. The Grandfather of the US Wood Stove Chose Viewing the Fire Over Efficiency 271 years ago, in 1741, Ben Franklin assembled a stove far less efficient and dirtier than many other stoves on the market. Somehow, it is still hailed as a tremendous advance in wood burning. It undermined the deployment and development of far more efficient stove designs. Why? Anglo culture, led by scores of opinion leaders, believed an open fire was more civilized than the closed “Germanic” stoves.

6. 271 Years Later, Low Efficiency Outdoor Wood Heaters Plague our Countryside Wisconsin: Wood smoke PM2.5 capital of the US

7. What are the efficiency challenges? Most wood and pellet stove manufacturers do not report reliable efficiency numbers There are no national minimum efficiency performance standards (MEPS) for wood and pellet stoves Fuel calculators use a wide range of efficiency assumptions with little documentation. The IRS approved sidetracking B415 and using LHV. There is no EnergyStar program for wood or pellet stoves ?

8. Minimum Efficiency Performance Standards are Widely Accepted MEPS are widely supported by the general public Many consumers buy appliances based on purchase price and do not consider long term fuel costs MEPS save consumers billions each year in reduced fuel costs MEPS will bolster the reputation of hearth appliances, giving consumers confidence that they are all reasonably efficient MEPS will help conserve wood and pellets, a valuable resource MEPS are especially important for HVAC systems as annual fuel costs can exceed purchase price in several years MEPS will ultimately even help consumers know that a second hand stove is efficient, even when hang tag is long gone MEPS do not necessarily raise price of appliances

9. Minimum Efficiency Standards (MEPS) are rapidly proliferating

10. Energy Use & Price Decline as Efficiency Rises

11. Efficiency of wood appliances As tested at High Heating Value (HHV)

12. Out of the top 24 pellet stove companies retailing in the U.S. The following is based on a review of manufacturer websites: 7 listed some stove efficiencies 7 make general efficiency claims, i.e. “our stoves achieve up to 77% efficiency” 10 do not mention any efficiency numbers None specified LHV or HHV, that we saw

13. Pellet Stove Advertising - Emissions Of the top 24 pellet stove companies retailing in the US, 16 do not list their emissions 8 provide emissions numbers in grams per hour This may indicate that the market does not easily enable consumers to buy cleaner stoves, or avoid dirtier ones. This may indicate consumers do not know about or care enough about emissions.

14. Efficiency Confusion Reigns and No One Tries to Dispel it Which website explains that stoves today are usually advertised using LHV and report efficiency in any number of ways, usually not B415? o HPBA o EPA o NESCAUM o WESTAR o NYSERDA o Dept. of Ecology, WA o Alliance for Green Heat Answer: None of the above. None of these institutions attempts to explain how manufacturers advertise efficiency.

15. Whose Role is it to Protect the Consumer? Last week’s Headlines: “Hyundai/Kia to Correct Overstated MPG Claims as Result of EPA Investigation” How many consumers counted on getting a 75% efficient stove with the IRS tax credit? How many actually got a 75% LHV stove? “The IRS sponsored wood stove tax credit program allows manufacturers to use a different method of determining efficiency. IRS allows laboratories to use greater flexibility in determining the thermal efficiency rating for tax credit purposes.” http://www.combustionportal.org/woodstoves.cfm http://www.combustionportal.org/woodstoves.cfm

16. Fuel Calculators in Disarray EPA links to a calculator that doesn’t use EPA default efficiencies Maine appears to use LHV figure for pellet boilers US Forest Service uses extremely high numbers Many exaggerate pellet efficiencies Calculator Name EPA Certified Non-cat Pellet Stove EPA default63%78% Actual average – OMNI 72%68% Actual average – Ferguson 71% EIA72%78% Hearth.com70% HBPA70%78% Building Green.com 70%80% Maine63%80% PFI60%80% Oregon Extension60%80% Jotul70% US Forest Service77%83% Range60 – 77%70 – 83%

17. What Consumers Need to Know: Pellet Stoves Myth #1: Advertised efficiency numbers can be relied on. Advertised efficiency numbers are calculated in many different ways and are not reliable. They are almost always in LHV, even though EPA uses HHV. We urge consumers to make sure stove is over 70% HHV or 80% LHV using the B415 method. Myth #2: Pellet stoves tend to be more efficient than wood stoves. Many pellet stoves are fuel-guzzlers with low efficiency numbers. Expected savings may never materialize.

18. Solutions – Long Term Minimum efficiency requirement for biomass heaters An Energy Star-like program that includes both emissions and efficiency.

19. Solutions – Short Term HPBA should urge all members to use B415 and tell consumers if they are using HHV or LHV Stakeholders should take a position on extension of tax credit and urge Congress to require B415 efficiency test Catalytic Stove Caucus request fuel calculators to add default efficiency for cat stoves EPA should urge manufacturers to send B415 efficiency numbers to add to EPA list of certified stoves Manufacturers who provide B415 efficiencies could be recognized on the EPA list EPA & States should educate consumers on stove efficiency and warn about misleading advertisements

20. Thank you! John Ackerly www.forgreenheat.org john@forgreenheat.org 301-841-7755