brenndatomu
Hey you woodchucks, quit chucking my wood!
I hear an Owl...Who?? Who's that?? Who??
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The not-so-difficult to run EPA stove
- Thread starter Steve NW WI
- Start date
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Vermonster
ArboristSite Operative
edit
I stand corrected.
page 37 of 354...
"...we propose to allow a transition period so that heaters/stoves with EPA certification currently in effect can continue to be manufactured and sold until the current certification expires (5 years from date of certification) or is revoked..."
and this..
"... it is also important to avoid unreasonable economic impacts on those manufacturers (mostly small businesses) who need additional time to develop a full range of cleaner models."
So, if a manufacturer certifies a new model in 2014 he could still produce and sell it until 2019... but it the model was certified in, say, 2010 then he would have to stop making it in 2015, or get it certified under the new regulations. Although, the EPA has also stated something termed the "Alternative Approach" in which all stoves would need to be in compliance within 3 years (by the year 2017 provided the "final" comes down in 2015). At this time the EPA has not determined which "approach" it will set.
page 38-39 of 354...
"We are also asking for comments on a three-step compliance approach (referred to herein as the “Alternative Approach”) for all adjustable rate wood heaters, single burn
rate wood heaters and pellet heaters/stoves. Under this Alternative Approach, the Alternative Step 1 emission limits would apply to each source: (a) manufactured on or after the effective date of the final rule, or (b) sold at retail on or after the date 6 months from the effective date of the final rule. (Step 1 under the Alternative Approach is the same as Step 1 under the Proposed Approach.) The Alternative Step 2 emission limits would apply to each source manufactured or sold on or after the date 3 years after the effective date of the final rule. The Alternative Step 3 emission limits would apply to each source manufactured or sold on or after the date 8 years following the effective date of the final rule (thus providing 5 years between the Alternative Step 2 and Alternative Step 3)."
and this...
"Our current preference is the Proposed Approach, but we intend to finalize a single compliance approach after fully considering the comments received during the public comment period on this proposed rulemaking."
Also interesting... page 41-42 of 354...
"We are also proposing to require emission testing and reporting based on both crib wood and cord wood for the proposed Step 1 compliance, and allowing manufacturers to choose whether to certify with crib wood or cord wood for the proposed Step 1 upon the effective date of the final rule. For the proposed Step 2 compliance 5 years after the effective date of the final rule, we would require certifying with cord wood only."
and this..
"Although we lack sufficient data to propose a separate CO emissions standard at this time, we propose to require that the manufacturer determine CO emissions during the compliance test and report those results to the EPA. We specifically request emission and cost data for systems that reduce CO emissions. If those systems warrant inclusion in the final rule, we would consider doing so. In addition, we ask for specific comments on whether the final rule should explicitly require indoor CO monitors as a critical safety component for heaters installed in occupied buildings or other buildings or enclosures in which the operator would enter to add fuel..."
I guess CO emissions will be the next big move against wood-fired appliances... but only after they force manufacturers to do the research and data gathering for them.
And here we have the out-with-the-old and in-with-the-new test procedures; previous 1988/90 testing no longer qualifies‼ All stoves will need to re-certify using a completely different test procedure from what it was designed around. Pretty much setting as many up for failure as possible.
page 48-49 of 354
"The manufacturers, laboratories, states and the EPA have more than 25 years of experience with Method 28... ...to address some of these concerns, ASTM has used a “consensus-based” process to develop E2515-10 “Standard Method for Determination of Particulate Matter Emissions in a Dilution Tunnel.” The EPA is proposing that this sampling and analysis method be used for all of the appliances in this rulemaking."
By the way, the new procedure requires passing the "low" burn rate testing
Anyway, page 55 ends the summery section on stoves and begins the summery section for forced air furnaces and OWB's... and I don't feel like post all that crap... err... stuff.
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page 37 of 354...
"...we propose to allow a transition period so that heaters/stoves with EPA certification currently in effect can continue to be manufactured and sold until the current certification expires (5 years from date of certification) or is revoked..."
and this..
"... it is also important to avoid unreasonable economic impacts on those manufacturers (mostly small businesses) who need additional time to develop a full range of cleaner models."
So, if a manufacturer certifies a new model in 2014 he could still produce and sell it until 2019... but it the model was certified in, say, 2010 then he would have to stop making it in 2015, or get it certified under the new regulations. Although, the EPA has also stated something termed the "Alternative Approach" in which all stoves would need to be in compliance within 3 years (by the year 2017 provided the "final" comes down in 2015). At this time the EPA has not determined which "approach" it will set.
page 38-39 of 354...
"We are also asking for comments on a three-step compliance approach (referred to herein as the “Alternative Approach”) for all adjustable rate wood heaters, single burn
rate wood heaters and pellet heaters/stoves. Under this Alternative Approach, the Alternative Step 1 emission limits would apply to each source: (a) manufactured on or after the effective date of the final rule, or (b) sold at retail on or after the date 6 months from the effective date of the final rule. (Step 1 under the Alternative Approach is the same as Step 1 under the Proposed Approach.) The Alternative Step 2 emission limits would apply to each source manufactured or sold on or after the date 3 years after the effective date of the final rule. The Alternative Step 3 emission limits would apply to each source manufactured or sold on or after the date 8 years following the effective date of the final rule (thus providing 5 years between the Alternative Step 2 and Alternative Step 3)."
and this...
"Our current preference is the Proposed Approach, but we intend to finalize a single compliance approach after fully considering the comments received during the public comment period on this proposed rulemaking."
Also interesting... page 41-42 of 354...
"We are also proposing to require emission testing and reporting based on both crib wood and cord wood for the proposed Step 1 compliance, and allowing manufacturers to choose whether to certify with crib wood or cord wood for the proposed Step 1 upon the effective date of the final rule. For the proposed Step 2 compliance 5 years after the effective date of the final rule, we would require certifying with cord wood only."
and this..
"Although we lack sufficient data to propose a separate CO emissions standard at this time, we propose to require that the manufacturer determine CO emissions during the compliance test and report those results to the EPA. We specifically request emission and cost data for systems that reduce CO emissions. If those systems warrant inclusion in the final rule, we would consider doing so. In addition, we ask for specific comments on whether the final rule should explicitly require indoor CO monitors as a critical safety component for heaters installed in occupied buildings or other buildings or enclosures in which the operator would enter to add fuel..."
I guess CO emissions will be the next big move against wood-fired appliances... but only after they force manufacturers to do the research and data gathering for them.
And here we have the out-with-the-old and in-with-the-new test procedures; previous 1988/90 testing no longer qualifies‼ All stoves will need to re-certify using a completely different test procedure from what it was designed around. Pretty much setting as many up for failure as possible.
page 48-49 of 354
"The manufacturers, laboratories, states and the EPA have more than 25 years of experience with Method 28... ...to address some of these concerns, ASTM has used a “consensus-based” process to develop E2515-10 “Standard Method for Determination of Particulate Matter Emissions in a Dilution Tunnel.” The EPA is proposing that this sampling and analysis method be used for all of the appliances in this rulemaking."
By the way, the new procedure requires passing the "low" burn rate testing
Anyway, page 55 ends the summery section on stoves and begins the summery section for forced air furnaces and OWB's... and I don't feel like post all that crap... err... stuff.
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Oh yeah, I forgot this...
"Under Proposed Step 2, manufacturers would be required to show compliance testing with cord wood.
We are also proposing to revise the test methods to require the addition of 1-hour filters for each test run to gather data regarding startup and anticipated peaks. Further, we
are proposing new compliance requirements for Step 2 with emissions limits at the lowest burn rate (Category 1) and the maximum burn rate (Category 4), not a weighted average of the four burn rates, as in the current 1988 NSPS."
Chances become very real that "adjustable burn rate" wood-fired appliances will become very difficult to find... especially in "larger" sizes... and you can be sure they won't be cheap. It will be very difficult to make an "adjustable" appliance that can pass testing at both extreme ends of the firing rates... much easier to make a "single burn rate" stove that passes. Likely the ability of the user to "crank it up" when he's cold, and "damp it down" for overnight burns will be gone... basically just on or off will be the options.
So, Del_, as you see by reading my last two posts... there ain't a single stove manufactured today that is guaranteed to pass the new standards. Some may be able to... but there ain't any way possible to use the old testing procedures to predict anything. The simple fact is... nobody friggin' knows.
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"Under Proposed Step 2, manufacturers would be required to show compliance testing with cord wood.
We are also proposing to revise the test methods to require the addition of 1-hour filters for each test run to gather data regarding startup and anticipated peaks. Further, we
are proposing new compliance requirements for Step 2 with emissions limits at the lowest burn rate (Category 1) and the maximum burn rate (Category 4), not a weighted average of the four burn rates, as in the current 1988 NSPS."
Chances become very real that "adjustable burn rate" wood-fired appliances will become very difficult to find... especially in "larger" sizes... and you can be sure they won't be cheap. It will be very difficult to make an "adjustable" appliance that can pass testing at both extreme ends of the firing rates... much easier to make a "single burn rate" stove that passes. Likely the ability of the user to "crank it up" when he's cold, and "damp it down" for overnight burns will be gone... basically just on or off will be the options.
So, Del_, as you see by reading my last two posts... there ain't a single stove manufactured today that is guaranteed to pass the new standards. Some may be able to... but there ain't any way possible to use the old testing procedures to predict anything. The simple fact is... nobody friggin' knows.
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Vermonster
ArboristSite Operative
I think the takeaway from all this discussion is that it's really not that cool to pollute our environment, whether it be air, soil or water.
Anyone who thinks otherwise please chime in, and be prepared to be hoist by your own petard.
brenndatomu
Hey you woodchucks, quit chucking my wood!
Hey, I'll give Spidey the credit he's due here, he's been doing his homework and sharing the cliff notes with all of us, any of the rest of y'alls actually read through this crap?
brenndatomu
Hey you woodchucks, quit chucking my wood!
Apparently I need to clarify..."This crap" referring to the latest EPA novel crap
Jesus Christ Del_,
Why is it when someone presents you with actual facts... even the actual verbatim of facts... that differ with your perceived notions, you revert to character assassination of the presenter. I didn't make that stuff up, those are direct quotes from the proposed rules.
I've read the complete thing twice, all 354 pages, and skimmed through it several other times... have you even looked at it??
Sure, I added my personal opinions on what they mean, or could possibly mean... but that don't make the verbatim facts any less factual.
Maybe you'd like to hear my opinion of the Constitutionality of it?? I can guarantee you won't like those facts I present...
Listen, I read a lot of things... I read Senate and House bills being voted on, both Federal and State... I read all sorts of proposals from all sorts of regulatory bodies... I monitor the SCOTUS website intently. I don't get my news from TV, papers, radio, talking heads, and certainly not from "special interest" groups... I haven't even looked at a TV in weeks, and I ain't read a newspaper in years. I go directly to government websites, download the latest, friggin' read it, and form my own opinions... and I do it nearly every friggin' day.
As a citizen of these United States I believe it's my duty to be informed, I learned long ago that I'll never be informed by media such as TV, radio, papers and whatnot... but it appears you believe it's your duty to discredit anyone who is truly informed.
I feel sorry for you... it must be a miserable existence.
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Why is it when someone presents you with actual facts... even the actual verbatim of facts... that differ with your perceived notions, you revert to character assassination of the presenter. I didn't make that stuff up, those are direct quotes from the proposed rules.
I've read the complete thing twice, all 354 pages, and skimmed through it several other times... have you even looked at it??
Sure, I added my personal opinions on what they mean, or could possibly mean... but that don't make the verbatim facts any less factual.
Maybe you'd like to hear my opinion of the Constitutionality of it?? I can guarantee you won't like those facts I present...
Listen, I read a lot of things... I read Senate and House bills being voted on, both Federal and State... I read all sorts of proposals from all sorts of regulatory bodies... I monitor the SCOTUS website intently. I don't get my news from TV, papers, radio, talking heads, and certainly not from "special interest" groups... I haven't even looked at a TV in weeks, and I ain't read a newspaper in years. I go directly to government websites, download the latest, friggin' read it, and form my own opinions... and I do it nearly every friggin' day.
As a citizen of these United States I believe it's my duty to be informed, I learned long ago that I'll never be informed by media such as TV, radio, papers and whatnot... but it appears you believe it's your duty to discredit anyone who is truly informed.
I feel sorry for you... it must be a miserable existence.
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Vermonster
ArboristSite Operative
Using the Lord's name in vain will earn you scorn from the bible belters.....................et al.
That's not taking the Lord's name in vain... but you may have been taught it is.
Read this...
http://www.reclaimingthemind.org/bl...t-really-mean-to-take-the-lords-name-in-vein/
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jrider
Addicted to ArboristSite
You read government websites then bash the science that our government often supports? Seems logical to me. I mean I wouldn't want only one side of things being presented whether I form my own opinions or not.
Vermonster
ArboristSite Operative
I'm a GD pagan Norseman!!! 
If I have to 100% honest... no, I didn't see it that way at first (likely because I expected some sort of comment).
But after looking at it again... in context... yeah, my bad.
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I don't want any "sides"... I just want the... well... verbatim.
I'll form my own opinion from there... and I really could not care any less which "side" it comes down on.
Government (in this country) is not provisioned a "side", it isn't even provisioned wrong or right... it only has the Constitution, and nothing more.
This idea that Government should, or needs to do something because it's the "right" thing to do is seriously flawed... it flat ain't allowed to do anything for that reason. Do you know why?? Because not all of us see right and wrong the same way... what may be "right" for you, may very well be "wrong" for me. There is a strict set of rules government is supposed to follow in this country... it's call the Constitution... anything outside of those rules is in fact... "wrong".
Personally I do not see "sides" when it comes to government, especially Federal Government... I only see what they are doing in relationship to what the Constitution allows them to do. Personally... I BELIEVE in the Constitution, all of it, as it is written... not how it has become twisted.
Anyway... enough of that...
I wonder if Steve NW WI has made it to his destination yet??
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Well... here'a another challenge...
Show me where it is written in scripture that I did... in the context I used it...
Oh... yeah... I've read the bible also, cover-to-cover, several times... different versions even.
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Thank you for looking it up. I didn't have time to do that today. I'm still not concerned. If I decide to sell my house, the wood stove isn't that important. It's kind of a spendy way to get a woodstove--to buy a house. Don't you agree? Or did you pick your house simply because it came with a non-certified stove?
I don't plan on trying to sell my stove nor am I interested in buying a used stove. I also believe that the cheap cast iron stove was a factor in burning down the house. A heavier duty stove might have held up better. I guess I'm making a statement about a stove being unsafe in the same context as when some on here make a blanket statement that new stoves are no good. Apparently what is good for the gander is not good for the goose.
And yes, I'm not a manly man. If that bothers you, too bad. Apparently you are running out of wind, you've started with the personal stuff and are getting all huffy.
You can keep your wood stove. I've no interest in you losing it. It just is quite boring to read about how our woodstoves are no good, when that is simply not true. And, I'll run through the woodstove brands I've heated with again, Earthstove (anything wrong with that?) Schrader (got any comments?) Fisher (which was installed in a rental not quite to code, but worked), a Schrader fireplace insert (was missing some parts so ate a lot of firewood withouth throwing much heat out--also in a rental) and my current Quadrafire. I've also had a couple of pellet stoves, and a propane fake woodstove. The Quadrafire is the only certified stove of the bunch, and it isn't much different, other than keeping the chimney cleaner than all the others.
That's it. That's all. 'Nuff said. I've got better things to do.
I don't plan on trying to sell my stove nor am I interested in buying a used stove. I also believe that the cheap cast iron stove was a factor in burning down the house. A heavier duty stove might have held up better. I guess I'm making a statement about a stove being unsafe in the same context as when some on here make a blanket statement that new stoves are no good. Apparently what is good for the gander is not good for the goose.
And yes, I'm not a manly man. If that bothers you, too bad. Apparently you are running out of wind, you've started with the personal stuff and are getting all huffy.
You can keep your wood stove. I've no interest in you losing it. It just is quite boring to read about how our woodstoves are no good, when that is simply not true. And, I'll run through the woodstove brands I've heated with again, Earthstove (anything wrong with that?) Schrader (got any comments?) Fisher (which was installed in a rental not quite to code, but worked), a Schrader fireplace insert (was missing some parts so ate a lot of firewood withouth throwing much heat out--also in a rental) and my current Quadrafire. I've also had a couple of pellet stoves, and a propane fake woodstove. The Quadrafire is the only certified stove of the bunch, and it isn't much different, other than keeping the chimney cleaner than all the others.
That's it. That's all. 'Nuff said. I've got better things to do.
slowp,
I have repeatedly asked, even made a couple flat out challenges, for someone to point out exactly where I have made such a "blanket" statement. I have never said your stove, or anyone else's stove is "no good"... EVER‼ ... EVER‼
Neither have I ever slammed anyone for their choice, I haven't even told someone not to get something. On the other hand, there are a few here, one in particular, that has done nothing but repeatedly state how bad and "no good" my appliance is and what a horrible person I am for using it. Not just the current appliance, and not just the one before it. Gander and goose?? That glass slipper don't fit my foot... but I can tell you who's it does.
Personal stuff?? I haven't made any personal attacks... but I have responded to a few (just look at the childish post above yours if you want to see what "personal stuff" is... I still ain't figured out what that has to do with the lord or his good book).
Don't you worry none girl... I got lots more wind.
I do find the "huffy" accusation interesting though... just curious, if I'm "huffy", what do you call your post then??
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Chris-PA
Where the Wild Things Are
Balance people. I deal with standards and testing all the time in designing products for a different field. Some of these are safety standards, some of them performance standards, written by both government and private industry groups, both European and US standards. A well designed and written standard can be a great thing to have, as it gives the designer a clear target to shoot for, reduces liability (compared to making up the rules yourself), and eliminates the shoddy competition that makes crap and undercuts you.
European standards tend to be more "prescriptive", basically telling you how you must make something rather than what you must achieve, while US standard traditionally were more "descriptive" and just gave you the target. But that is a generalization and does not hold in every case. By and large I like to have a performance target, as it lets us be innovative in how we approach it rather than a standard that forces everyone to use the same approach - otherwise you are stuck just trying to do the best implementation instead of inventing new solutions.
I've seen standards that are very well written, and others that are terrible. One thing that tends to happen with big standards in an industry is that it becomes a career path for those on the standards committees, and then the standards are under constant revision and the designer has to spend a lot of time trying to keep up, lots of money getting re-certified, and you are trying to hit a moving target. Plus you get change for change sake. I note this standard has not been revised for 25 years.
So the fact that there is a new performance standard is not alarming to me, but neither would I assume right off that it is well done either. I'll have to take the time to read it completely. On the plus side it looks like it is a standard written around a performance test. I think the change to cord wood is positive and more realistic. Things that concern me are that it sounds a little vague, at least in terms of the time of implementation. Vague is not cool in standards. I'm hoping it does not force manufacturers into overly complex solutions or exotic materials (cats, basically).
I also hope they do not get into controlling CO or CO2 emissions, although these could be driven from completely different reasons. As someone who considers himself to be an environmentalist, I'm not sure what I think about the focus on directly toxic particulate emissions from woodstoves. The big environmental problems we face are from burning of fossil fuels, and from associated carbon releases that have nothing to do with the directly toxic particulate emissions that were long the primary focus of efforts to clean up the air. Basically, that danger was missed and other directly toxic emissions were overemphasized. Wood stoves cannot be a problem in regard to carbon emissions, because all the carbon in the fuel was taken from the environment in the last few decades - it has zero net effect in the local environment. Focusing on it distracts from the real carbon issue which is fossil fuels. Wood heat is not and cannot be an appropriate solution in every place or for everyone - there is not enough wood and some communities or environments won't support it.
I don't know how to gauge how severe these rules are - one of my concerns is if they are trying to make every stove suitable for use in every area, like towns and denser residential areas. Another approach is to simply let local communities ban them, or to deal with local offenders (like the smoke from the OWB I drove through the other day, which blocked the whole road and surrounded about 5 other homes nearby). In lower density rural areas like mine, the existing standards may be fine. Wood heat is simply not appropriate everywhere.
Here I have to point out that I am an environmentalist suggesting that letting local regulation ban the appliances might be a better solution than a national standard to modify all stoves, which is a profoundly conservative approach (based on the definition of traditional US conservatism, not Faux news conservatism). Still, if that was done there would be people on here complaining about how the socialists had taken away their right to burn wood in town.
We don't know yet were these new rules sit in relation to the state-of-the-art - basically in relation to what to the designers have up their sleeves? The new chainsaw emissions rules got solved elegantly with strato engines, which have ZERO negative impact and in fact improve performance, yet people are still complaining.
European standards tend to be more "prescriptive", basically telling you how you must make something rather than what you must achieve, while US standard traditionally were more "descriptive" and just gave you the target. But that is a generalization and does not hold in every case. By and large I like to have a performance target, as it lets us be innovative in how we approach it rather than a standard that forces everyone to use the same approach - otherwise you are stuck just trying to do the best implementation instead of inventing new solutions.
I've seen standards that are very well written, and others that are terrible. One thing that tends to happen with big standards in an industry is that it becomes a career path for those on the standards committees, and then the standards are under constant revision and the designer has to spend a lot of time trying to keep up, lots of money getting re-certified, and you are trying to hit a moving target. Plus you get change for change sake. I note this standard has not been revised for 25 years.
So the fact that there is a new performance standard is not alarming to me, but neither would I assume right off that it is well done either. I'll have to take the time to read it completely. On the plus side it looks like it is a standard written around a performance test. I think the change to cord wood is positive and more realistic. Things that concern me are that it sounds a little vague, at least in terms of the time of implementation. Vague is not cool in standards. I'm hoping it does not force manufacturers into overly complex solutions or exotic materials (cats, basically).
I also hope they do not get into controlling CO or CO2 emissions, although these could be driven from completely different reasons. As someone who considers himself to be an environmentalist, I'm not sure what I think about the focus on directly toxic particulate emissions from woodstoves. The big environmental problems we face are from burning of fossil fuels, and from associated carbon releases that have nothing to do with the directly toxic particulate emissions that were long the primary focus of efforts to clean up the air. Basically, that danger was missed and other directly toxic emissions were overemphasized. Wood stoves cannot be a problem in regard to carbon emissions, because all the carbon in the fuel was taken from the environment in the last few decades - it has zero net effect in the local environment. Focusing on it distracts from the real carbon issue which is fossil fuels. Wood heat is not and cannot be an appropriate solution in every place or for everyone - there is not enough wood and some communities or environments won't support it.
I don't know how to gauge how severe these rules are - one of my concerns is if they are trying to make every stove suitable for use in every area, like towns and denser residential areas. Another approach is to simply let local communities ban them, or to deal with local offenders (like the smoke from the OWB I drove through the other day, which blocked the whole road and surrounded about 5 other homes nearby). In lower density rural areas like mine, the existing standards may be fine. Wood heat is simply not appropriate everywhere.
Here I have to point out that I am an environmentalist suggesting that letting local regulation ban the appliances might be a better solution than a national standard to modify all stoves, which is a profoundly conservative approach (based on the definition of traditional US conservatism, not Faux news conservatism). Still, if that was done there would be people on here complaining about how the socialists had taken away their right to burn wood in town.
We don't know yet were these new rules sit in relation to the state-of-the-art - basically in relation to what to the designers have up their sleeves? The new chainsaw emissions rules got solved elegantly with strato engines, which have ZERO negative impact and in fact improve performance, yet people are still complaining.
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