As everyone in our industry now knows, the EPA is deep into the process of reviewing their program that certifies clean burning wood stoves, which is formally known as the New Source Performance Standards (NSPS) for Wood Heaters. A lot of retailers and reps have questions about how these changes might affect their business, so HPBA has produced a short Q&A piece for the affiliate newsletters.
What is NSPS?
The NSPS is the EPA's wood stove certification program. It is the rule which was adopted in 1988 that requires that all wood stoves manufactured or imported in the U.S. be certified by the EPA. This current review is the first revision of this rule in 20 years.
What will this review cover?
The EPA is at least considering covering everything that burns solid fuel in this review;
- A lower passing grade for wood stoves
- Certification process for pellet stoves and boilers, as well as corn stoves
- Removal of the exemption for single burn rate heaters and furnaces
- Factory built and masonry fireplaces
- Masonry heaters
- Outdoor hydronic heaters
How will everything get certified and will there be enough time?
This is one of the key issues for HPBA. Some of these products will need more time than others to get all of the models certified. How long the passing grades are for each product will also impact how long it takes to recertify the line. It's quite possible that there will be seasons where not all of your favourite models have completed the new certification. There will be many detailed changes to both the wood stove and the pellet stove test, and it's impossible to know which units will be easy to recertify and which will be difficult.
What is HPBA doing about the NSPS process?
HPBA has retained the very best professional assistance available to us: Mr. David Menotti, of the law firm of Pillsbury, Winthrop, Shaw Pittman. David has represented our industry on air quality issues since 1985 with the state regulation in Colorado, and he was instrumental in the negotiations that lead to the first NSPS in 1988. David is now a well-known air attorney and has represented many industries (such as the American iron and steel industry) on issues with the EPA.
HPBA is also using the services of Bob Ferguson, who was once the lead engineer at Vermont Castings, and is now a private consultant. Bob is working very hard on the details of the new pellet stove test method, and on a new ASTM test process for stick stoves, which may remove some of the 'busy work' in the certification testing process, which in turn will lower those costs. Bob is also assembling blinded data for all the test runs for all the existing certified stoves, which will help determine the new passing grade. In addition, many members have volunteered extraordinary amounts of time in meetings and strategy sessions, with the full support of their companies.
This sounds expensive; are the manufacturers paying for this?
The HPBA board of directors voted to assess solid fuel hearth manufacturers for half of the costs of this effort and match that with funds from our Government Affairs budget. Every company whose product depends on solid fuel has been assessed each quarter for their share of actual expenses. All appliance manufacturers and importers, as well as all chimney, hearth pad, and accessory members have been invoiced. In the two invoices sent in 2009 almost $50,000 was raised from Manufacturers above and beyond their dues. This is being matched from the HPBA Government Affairs budget. Of course, existing HPBA staff assets are being used wherever possible, and many key volunteers have contributed hundreds of hours of their time gratis.
I've donated to my affiliate's NSPS effort; on what will my donation be spent?
Our team is in frequent contact with the EPA staff, including face to face meetings in North Carolina, Oregon, and Georgia. In addition, the ASTM working groups are meeting twice a month, generally by phone, to plan the new test methods. In 2009 our legal bills and meeting expenses exceeded $200,000. Affiliate contributions are being used to support the general program and to minimize the disruption to our industry.
Your donation and sacrifice is very much appreciated!
2010 will be the cusp, the key moment, of this whole process.
What wood stoves and pellet stoves look like and how well they operate (heat) for the next 10-20 years, may well be determined over the next 12 - 18 months. Even though this is a tough year for all of us, we can't let up.
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