After the Smoke Clears: A close look at the tightening of EPA emission standards

Transcription

1 After the Smoke Clears: A close look at the tightening of EPA emission standards Consumers and the NSPS Presented by John Ackerly Alliance for Green Heat Thursday, April 16, :00 2:30

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 Push for more transparency from manufacturers and EPA about testing and efficiencies. Integrate stoves into work of energy auditors and home energy professionals.

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4 Wood Smoke in the US

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6 Will Consumers Notice the NSPS? Most consumers don t know there was a first NSPS in 1988 and most won t know about this one either. But, they do experience the changes in stove technology and price. $500 stove in 1978 would cost $1,800 in today s dollars. By that measure, costs have done down since the first NSPS. Industry is not messaging to media the biggest impacts on consumers: exempt stoves and unqualified OWBs.

7 What consumers will notice Unregulated residential OWBs off the market in the 40 or so states that still allow them. But, the exact same units can still be sold by same dealers for commercial applications: greenhouses, auto shops & garages, stores, farm buildings, etc. Recent YouTube post by a Woodmaster dealer says OWB retailers will start having consumer pledge not to install unit on residence before selling them unit. Exempt wood stoves will also go away.

8 Technology Changes in 1988 vs Was 7.5 harder in 1988 than 2.0 will be in 2020? Adding secondary air tubes and getting ratios of primary and secondary air adjusted was a significant R & D investment and challenge Cleaner & more efficient is better, but what are downsides for consumers? There is a cause for concern that a 83 or 84% efficiency stove could backpuff more that a 70% efficient stove. Will stoves get smaller? More finicky? Will gaming in test labs be reduced?

9 Second hand market continues EPA considered regulating 2d hand market Any new installation is a new source Could have banned install of uncertified stoves Craigslist Maine had about 225 wood stoves CL does not allow any good, service, or content that violates the law but will not bar sale of uncertified stoves in states that don t allow it. About 20% were EPA certified, $400-$1,500. Many EPA certified stoves do not advertise that they are certified. Lots and lots of old, uncertified Vermont Castings, Jotul, Fishers for $250-$650.

10 2d hand EPA Certified Stoves in ME Castle Serenity Pellet, $750 New Century, $450 Regency Insert, $895 Lopi Patriot, $375

11 Old, uncertified stoves Atlantic 20, $200 Fishers, $400 - $900 Ideal All Nighter, $1,250

12 Antique pieces of art Moreso $500 Scandia $175 Jotul Trolla 108, $250 Amity $280

13 Stoves that won t die, but should Homemade, $150 Federal airtight, $100 Potbelly, $125 Double barrel, $175

14 The NSPS does not impact installation While EPA can ban install of uncertified stoves, it cannot require professional installation. The best things a state can do to improve wood smoke is 1. Require prof. installation and 2. Require safety (UL) listing. 4 states (MA, OR, WA & WI) require permits to install stoves Results in cleaner & safer installs Can help prevent installs of dangerous or uncertified stoves

15 Efficiency in New EPA Rules Manufacturers have to start testing and publicly reporting efficiency using B415 & HHV. Manufacturers have to disclose efficiency when stoves are tested for certification or recertification. Most stoves don t have to be retested for years, so efficiency numbers likely to come out very slowly. Manufacturers can voluntarily submit efficiency numbers at any time. (Industry is not encouraging this.) The estimated default efficiencies (63, 72 and 78) will be phased out soon. Efficiency measured by a stack-loss measurement

16 NSPS & Misleading Advertising * Exempt coal stoves cannot advertise they can burn wood. Fireplace cannot advertise as a stove. Can t advertise to sell a stove that is not certified and/or doesn t have a permanent label Can companies still advertise LHV efficiency numbers based on in-house testing of the best run they got?

17 Efficiency of wood appliances As tested at High Heating Value (HHV) 90% 80% 70% 60% 50% 40% 30% Best Known Default (EPA) Average Worst Known 20% 10% 0% Pellet Catalytic Non-catalytic

18 Owner s Manuals The NSPS requires a lot of changes to Owners Manuals (OM) by May 15. All old and new OMs must be on company website. Must include information to adequately enable consumers to achieve option emission performance. Info must be consistent with instructions provided to test lab. I would argue that manual should include emissions from all 4 burn rates and alert the operator that to get a cleaner and consistent smokeless burn, you cannot use lowest air setting.

19 Multi- Fuel stoves Coal and corn only stoves are exempt, provided that all advertising and warranties clearly denote that wood burning is prohibited. FR, p / Multi-fuel stoves allowed as long as pellet fuel meets emission standards and corn emission results are tested and reported. Irony: Stoves are not tested with cordwood, so if you follow the letter of the law in the NSPS, the operator should be instructed to use crib wood.

20 Wood bricks The NSPS should encourage, not discourage innovation that makes stoves cleaner. But the NSPS may discourage alternative fuels like wood bricks, if a fuel like bricks has to go through same process as pellet fuel certification. We predict that bricks will grow rapidly in the northeast and that they will be a big benefit to clean air. Cost is similar to cord wood per BTU. ~13 different brands and ~20 different products sold in the Northeast region

21 Catalytic stoves may come back in a huge way Currently, cat stoves make up only about 15% of the market. Some experts estimate they could make up 40% of market in 5 years. Is this a good thing? Some catalytic stove manufacturers are worried about a repeat of the 1990s, in which scores of very poorly designed cat stoves flooded the market.

22 State bans on enforcement Missouri, Michigan and Virginia passed laws saying their state agencies could not enforce provisions of the NSPS. Those states could face consequences, such as Potential sanctions under the Clean Air Act Loss of permitting authority Pending bills in Wisconsin & Minnesota HPBA has played behind the scenes role; not formally stated a position on these state initiatives

23 Pellet Fuel Pellet fuel quality assurance ensures the appliances operate properly and meet the certified emission limits. Operators must only burn pellets that have been specified in the owner s manual (OM) and graded by The Pellet Fuels Institute, ENplus and CANplus are initially deemed to be approved. What does this mean for the consumer? Greater security that they are buying a quality pellet Technically, consumers should only use fuel that stove was tested with and approved in owner s manual Owners manuals could specify PFI, Enplus and/or CANplus Manufacturers unlikely to void warranties if consumers use unapproved fuel, but the OM says they can

24 Consumer Labels in New Rules Stoves that test with cordwood in next 5 years and can meet 4.5 grams an hour can use a special EPA approved label to alert consumers that stove is designed and tested as it will be used by consumer. Stoves that meet Step 2, 2020 emission limit of 2 grams an hour (or 2.5 with cordwood) can also use a special label alerting consumers that they meet strictest standards. These are good steps, but if EPA and Industry don t make these work, a more comprehensive green label may be needed.

25 What industry is saying... Regency: Catalytic may be only way to achieve 2.0 g/hr Vermont Castings: Our long term concern is what the EPA will do about efficiencies and carbon monoxide. Jotul: We will probably have to use catalytic combustors on all our models.... Let s hope the industry can compromise with the EPA [on Step 2 standards]. Kuma: We re not terribly concerned about the 2.0 gph limit. IHP: Step 2 will be difficult to get to, and it may put larger wood-burners at risk.

26 HPBA Litigation Details will be filed by May 15 Will presumably challenge Step 2 standards and probably the alternative, optional certification with cord wood. BNA reported HPBA is likely to challenge: EPA's inclusion of a yet to be finalized test method to certify products. Agency decision to finalize emissions limits that will be in place in five years despite acknowledging the lack of data.

27 Thank you! John Ackerly

28 NSPS 2015 Lisa Rector Northeast Biomass Heating Expo April 16, 2015

29 NSPS and State Regulations State hydronic heater regulations are not impacted in by the NSPS States with certification programs will still need to review and certify results Massachusetts, New York, Vermont Setback requirements still apply 2

30 What you measure matters Modeling Steady State emissions Modeled Duty Cycle emission 3

31 New Test Methods Matter Typical test methods measure steady state but not representative of in use emissions Need new data points Short term emissions Start up emissions Need real world fuel Need to be able to verify in the field 4

32 New Data Points Incorporating start emissions changes emissions profile how to we identify top performers for start up Efficiency over various loads Device Test Method PM Emissions Efficiency Froling EN lb/mmbtu g/hr cannot be calculated Froling BNL PTS 0.18 lb/mmbtu Max run 7.3 g/hr 86% 69-77% Avg 70% 5

33 Wood Heat Impact on Air Quality Wood: heats 1.2% NY homes primary heat &~453,000 stoves Natural gas: heats 51.7% NY homes (>3.6million) Home heating oil: heats 33.1% of NY homes (>2.3 million) 6g

34 The Future: Step 1 vs Step 2 Emission Scenario Concentration (μg/m 3 ) EPA NAAQS Neighborhood Scenario - Valley Scenario 1: Growth with Step 1 technology Scenario 2:Growth with Step 2 technology Neighborhood Scenario - Mountain Scenario 1: Growth with Step 1 technology Scenario 2:Growth with Step 2 technology Neighborhood Scenario Urban/suburban Scenario 1: Growth with Step 1 technology Scenario 2:Growth with Step 2 technology

35 Creating A Cleaner Energy Future For the Commonwealth COMMONWEALTH OF MASSACHUSETTS Charlie Baker, Governor Matthew Beaton, Secretary Daniel Burgess, Acting Commissioner Northeast Biomass Heating Expo Portland, Maine April 16, 2015 After the Smoke Clears Biomass in Massachusetts Energy Portfolio Rob Rizzo Renewable Thermal Program Manager

36 Biomass in Massachusetts Partners Policies, Initiatives, and Programs Regulations Creating A Greener Energy Future For the Commonwealth

37 Biomass in Massachusetts Creating A Greener Energy Future For the Commonwealth

38 Commonwealth 2015 Woodstove Change-Out Program $900,000 Stove Type Max PM 2.5 emissions Rebate Standard Rebate Low-Income Rebate Pellet Stove 2.0 g/hr 1,250 2,250 Catalytic Wood Stove 2.0 g/hr 1,000 2,000 Non-Catalytic Wood Stove >3.0 and <3.5 g/hr 750 1,750 Non-Catalytic Wood Stove <3.0 g/hr 1,000 2,000 EPA 2015 NSPS Rule g/hr g/hr cribwood 2.5 g/hr cordwood Creating A Greener Energy Future For the Commonwealth

39 Residential Pellet Boilers Rebates available from the Massachusetts Clean Energy Center Particulate Matter 2.5 <0.10 lb PM2.5/MMBTU1 at nominal output. thermal efficiency of 80% or greater. capable of automatic startup in response to a demand for heat (electronic ignition). automatically modulate to lower output and/or turn itself off when the heating load decreases or is satisfied. have a multi-pass heat exchanger. Creating A Greener Energy Future For the Commonwealth

40 Residential Pellet Boilers Thermal Storage is REQUIRED All Projects must incorporate thermal storage unless they have submitted and had approved by MassCEC independent third party test results documenting that the heating system is designed for and capable of: Modulating below 20% of full capacity; Maintaining a Particulate Matter 2.5 emissions rate of no greater than 0.10 lb PM2.5/MMBTU3 at minimum capacity; and Maintaining thermal efficiency of 80% or greater at minimum capacity. Creating A Greener Energy Future For the Commonwealth

41 Residential Pellet Boilers The thermal storage system must have a minimum of 80 gallon capacity and an additional one (1) gallon of capacity per 1,000 BTU/hr of nameplate heating capacity being installed over 80,000 BTU/hr up to 119 gallons. must be designed to meet at least 80% of the annual heating load of the building it is serving (kbtu). may not be sized with a peak heating capacity (kbtu/hr) greater than 110% of the Manual J heat load calculation. Creating A Greener Energy Future For the Commonwealth

42 Biomass in Massachusetts SAPHIRE Schools and Public Housing Integrating Renewables and Efficiency energy efficiency and renewable heating 20% energy reduction Open for Public Schools Closed for Public Housing DOE: $715,000 DOER: $3.1 million schools $2 million public housing PM 2.5 limit of 0.03 lb/mmbtu >80% efficiency thermal storage capacity must be at least 20 gallons per 10,000 BTU/hr. of boiler capacity. Creating A Greener Energy Future For the Commonwealth

43 Biomass in Massachusetts LIHEAP Low Income Home Energy Assistance Program DOER: $1,258,000 No Cost to eligible families New Wood Pellet Stove round 1 allowed stoves up to 4.05 g/hr- no longer eligible PM 2.5 < 2.5 gr/hr (next round <2.0 g/hr) Installation 1 ton of Premium Pellets First year service contract To Date: 201 stoves installed 201 tons of Premium pellets Creating A Greener Energy Future For the Commonwealth

44 Biomass in Massachusetts Business Development Grants Biomass Thermal Energy Council - Statewide Development of efficiency test procedures for commercial-sized solid biomass boilers $ 75, Cook Forest Products, Inc. - Upton Purchase CBI wood chipper to manufacture micro-chips from clean unprocessed wood waste for industrial end users $250, T. Jepson & Son, LLC - Spencer Expansion of wood chip production with procurement of Peterson 4300 chipper $250, Rocky Mountain Wood Company - Wilbraham Development of a wood pellet manufacturing facility $1,000, Maine Energy Systems - statewide Develop loose, bulk pellet distribution facility in MA and introduce a pellet boiler showroom $806, $3 million solicitation and $2,381,598 supported biomass projects Creating A Greener Energy Future For the Commonwealth

45 Biomass in Massachusetts Mohawk Trail Renewable Heat Initiative renewable wood pellet manufacturing, distribution and heating in 20 towns in northwestern Massachusetts Phase 1 -five studies Forest Resource Assessment DOER Currently seeking proposals under COMMBUYS Bid#: BD ENE01-ENE Community Outreach/Market Analysis Carbon Impact Study Business Plan Development Regional Economic Impact Study Phase 2 Support a pellet manufacturing and distribution facility Support municipal fuel switching Creating A Greener Energy Future For the Commonwealth

46 Biomass in Massachusetts Development of a Regional Wood Pellet Standard Harvard University Emmett Environmental Law and Policy Clinic working with the Department to identify any legal barriers to developing a regional wood pellet standard: develop strategic recommendations for achieving a Massachusetts-specific or multi-state solution; The Clinic will also identify options for implementation in Massachusetts. DOER will seek a qualified consultant(s) to assist in developing a regional wood pellet standard Develop a regional workgroup public and private forestry, energy and wood pellet industries Creating A Greener Energy Future For the Commonwealth

47 Regulations Biomass in Massachusetts Alternative Portfolio Standard Acts 2014, Ch CMR Renewable Thermal Technologies in the Alternative Portfolio Standard Eligible Technologies by Statute any facility that generates useful thermal energy using: Sunlight, biomass, biogas, liquid biofuel or naturally occurring temperature differences in ground, air or water Creating A Greener Energy Future For the Commonwealth

48 Biomass in the APS Air Emissions Pollutants Pellets Chips Cordwood Small Scale < 3 MMBtu/hr heat input) PM lb/mmbtu heat input 0.10 lb/mmbtu heat input reserved CO 270 7% O % O 2 reserved Large Scale (equal to or >3MMBtu/hr heat input) NOx, CO, PM 2.5 MassDEP permit required DOER will review air emission requirements every 2 years, with MassDEP 14 Creating A Greener Energy Future For the Commonwealth

49 Creating A Cleaner Energy Future For the Commonwealth COMMONWEALTH OF MASSACHUSETTS Charlie Baker, Governor Matthew Beaton, Secretary Dan Burgess, Acting Commissioner Rob Rizzo Renewable Thermal Program Manager robert.rizzo@state.ma.us

50 Standards of Performance for New Residential Wood Heaters, New Hydronic Heaters and New Forced-Air Furnaces: Final Rule A l i s o n S i m c ox, P h D A i r Q u a l i t y P l a n n i n g U n i t U S E PA, R e g i o n 1 N o r t h e a s t B i o m a s s H e a t i n g E x p o P o r t l a n d, M E A p r i l 1 6,

51 What will this presentation cover? Statutory basis of New Source Performance Standards (NSPS) Background Differences between the 1988 rule and the final rule Benefits and costs What this final rule does not require Specifics about the final rule standards, sell-through of inventory, requirements for forced-air furnaces NSPS response to comments and PM Advance Impact on New England Next steps 2

52 What is the statutory basis of the NSPS? Section 111(b) of Clean Air Act Federal Program for New Sources The Administrator shall establish Federal standards of performance for new sources within [the] source category. Standard of Performance A standard for emissions of air pollutants which reflects the degree of emission limitation achievable through the application of the best system of emission reduction, which (taking into account the cost of achieving such reduction and any non-air quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated. 3

53 What is the background for this rule? On February 3, 2014 EPA proposed rules to make new residential wood heaters significantly cleaner than currently required. We received about 8,000 public comments. The final rule includes changes EPA made in response to these comments The original NSPS was promulgated in 1988 and set emission limits for New adjustable burn-rate stoves New fireplace inserts (wood stoves that fit into fireplaces) Minor amendment made in 1998 did not change emission limits Today, new technologies and types of heating devices are available 4

54 How do the 2015 and 1988 rules differ? 1988 rule only regulated adjustable burn rate wood heaters (wood stoves and some pellet stoves) 2015 rule regulates: Adjustable stoves Single burn-rate stoves Pellet stoves Fireplace inserts Hydronic heaters Forced air furnaces Sets new certification requirements 5

55 What are benefits and costs of the 2015 rule? Estimated emissions reductions: 8,300 tons of fine particles, a 68 percent reduction over estimated emissions without rule. 9,300 tons of VOCs, a 68 percent reduction over estimated emissions without rule. 46,100 tons of CO, a 62 percent reduction over estimated emissions without rule. Benefits of $3.4 billion to $7.6 billion annually, including value of: Avoiding asthma attacks, non-fatal heart attacks, emergency room visits for asthma, lost work days, and premature deaths, among other benefits. Estimated cost of $46 million annually $74 to $165 in health benefits for every dollar spent 6

56 What is not regulated or required by this final rule? Doesn t regulate: Masonry heaters Existing heating devices Heaters fueled solely by oil, gas, or coal Fireplaces, pizza ovens, barbecues, chimeneas, fire pits Doesn t regulate efficiency or carbon monoxide (CO), but does require testing and reporting Doesn t require temporary hangtags 7

57 Final Rule Summary of Standards Wood-Fired Heating Device Step Effective Date *after F.R. Notice Wood stoves & Pellet Stoves (both adjustable and single burn rate) (both catalytic & non-catalytic) Hydronic Heaters days (May 15, 2015) 5 years (May 15, 2020) 60 days (May 15, 2015) Particulate Matter Emission Standard 4.5 g/hr Test Fuel Cribwood or Cordwood 2.0 g/hr Cribwood 2.5 g/hr Cordwood 0.32 lbs/mbtu weighted average AND 18.0 g/hr individual test run cap OR EPA Phase 2 Qualified Cribwood or Cordwood 2 5 years (May 15,2020) 0.10 lbs/mbtu for each burn rate Cribwood 0.15 lbs/mbtu for each burn rate Cordwood Forced Air Furnaces 60 days (May 15, 2015) New work practice & operational standards, including providing information on best operating practices in owner s manual N/A 1 Small: 1 year (May 16, 2016) Large: 2 years (May 15, 2017) 0.93 lbs/mbtu weighted average Cordwood 8 2 All: 5 years (May 15, 2020) 0.15 lbs/mbtu for each burn rate Cordwood

58 Change from proposal: Sell-through of inventory EPA proposed to allow 6 months for retail sell-through for wood stoves, but not hydronic heaters (HHs) and forced-air furnaces made before compliance deadline. Commenters esp. small businesses raised concerns that manufacturers could have large stranded inventory. In final rule, EPA providing longer sell-through period for wood stoves and cleaner HH models. Wood stoves certified under 1988 standards and current qualified HHs may be sold until Dec 31, No sell-through for forced-air furnaces because they aren t required to comply with emission limits until May 16, 2016 (small furnaces) or May 15, 2017 (large furnaces). 9

59 Change from proposal: Compliance certification Conditional one-year certification for wood stoves, pellet stoves, and forced-air furnaces Must submit certification application that includes full test report by EPA-accredited laboratory and that meets other application requirements 10

60 Change from proposal: Forced-air furnaces EPA proposed to set emission limits for Step 1 for forced-air furnaces (FAF) immediately on effective date of May 15, Commenters raised concerns about meeting compliance deadline and needing more transition time In final rule, work practice/operational standards become effective May 15, Emission limits become effective May 16, 2016 for small FAF and May 15, 2017 for large FAF 11

61 EPA Response to Comments on NSPS and PM Advance Response to Comment (RTC) on proposed NSPS: PM Advance program: 12

62 New England - Winter 2015 USG = Unhealthy for Sensitive Groups (above health-based standard) PM 2.5 Standard = 35 ug/m 3 on a 24-hour average basis

63 Next steps Implementation assistance Public outreach Amplify voluntary efforts to replace existing wood-burning devices Focus on developing new cordwood test method 14

64 More information Final rule website: Burn Wise website: EPA Office of Air Quality Planning & Standards: (919) (919) (919) EPA Region 1 Air Quality Planning Unit: simcox.alison@epa.gov (617)