Can the EPA Do Its Job?
As the wood and pellet stove and boiler industry gets closer to facing new EPA regulations, there is a striking disconnect between industry expectations and the EPA’s mandate. For industry, the concept of “technology-forcing” regulations is anathema, a clear example of a government agency running amok. For many air quality agencies, technology-forcing regulations are the only way to move forward.
This won’t be a technology-forcing rule, even though most stoves will likely be forced to change by 2020. For it to be technology-forcing, the technology needed to achieve the mandated emission standard would not yet exist on a commercial scale. However, some catalytic stoves on the market show that it’s already possible to meet the strictest standard proposed by the EPA.
The wood stove industry has issued hundreds of pages of detailed analysis showing more than 90 percent of stove models would not survive the regulations. However, forcing 90 percent of stoves to change is precisely the goal, not an unintended side effect. They want our country to move to a new generation of cleaner stoves.
The Alliance for Green Heat agrees that 90 percent of stoves need redesigning. But unlike many air quality agencies and environmental groups, we are a pro-wood heating organization. We believe that the biomass stove and boiler industry can do this and still be profitable, while ensuring its own long-term survival and growth.
Many stoves may only need minor redesigns. There are plenty of R&D consultants who can help manufacturers if they don’t have the internal capacity. Some models may have to be scrapped and redesigned entirely, a pretty expensive process for what are mostly small businesses that don’t deal in large quantities. This is why the EPA proposed staggering the implementation of the new rules—so that companies have time to get cleaner models ready. Some manufacturers may go out of business, especially ones that only make traditional outdoor wood boilers and do not have the capacity to make cleaner units. Other manufacturers will benefit and profit from the rules.
We agree with the industry that it’s too soon to require all stoves to be certified with cordwood, and that such a change could probably not happen for three to five years. We also agree that regulations forcing industry to put catalysts on all stoves are not the answer. This worked for automobiles, but the technology is not yet ready for stoves.
There is one fundamental question both industry and air quality agencies share: “Is the EPA up to the task of regulating wood and pellet heaters?”
Northeastern air agencies have said that the compliance and enforcement office of the EPA is “ineffective,” and questioned the agency’s ability to manage existing stove regulations, much less any new ones. They also cite the private, EPA-certified test labs as having a “lack of capacity to independently conduct and certify results” of emission tests, the linchpin of ascertaining whether a stove meets EPA requirements. The industry questions the fundamental capacity of the EPA to sufficiently understand and address a broad array of very technical issues.
We share concerns of both air agencies and industry, but are aware that government agencies are often in this bind. In this case, they appear to be working toward a compromise of stakeholder interests. Their proposal is extremely lenient with cleaner appliances like pellet stoves, and pretty tough for unregulated wood stove and outdoor wood boiler manufacturers. We expect all major players will criticize the regulations for going too far, or not far enough. It’s too early to tell if they will strike the right balance.
The best context to understand this rulemaking comes from the 1990 regulations when EPA first regulated wood heaters. Yes, prices rose modestly. Yes, some manufacturers went out of business and the number of companies shrunk. Yes, millions of old, polluting stoves were grandfathered and are still there. But we ended up with a vibrant industry that makes some of the best and cleanest wood stoves in the world and helps millions of Americans affordably heat their homes using a renewable resource. Those regulations were a lifeline to an industry that was making many very polluting appliances and would have otherwise faced a more complex regulatory landscape at the state level.
The 1990 regulations may have required a more drastic overhaul of stove designs than this one. Back then, the solution was secondary combustion technology. This time, there will likely be a variety of ways to meet stricter emissions standards, and some automation of air control may be one of the solutions. Ultimately, to get a new fleet of cleaner stoves deployed, we need an EPA that can put in the resources to adequately oversee the process.
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