A War on Wood Heat? – EPA Proposes Tough New Emission Standards

Recently I’ve seen a number of alarming posts on new changes to regulations coming down from the EPA regarding wood stoves. One such blog is titled, EPA Takes an Axe to Self-Sufficiency; another, Off Grid Attack: EPA To Outlaw Many Wood Burning Stoves. The EPA’s proposed changes (you can read all 354 pages here) are certainly aggressive, with a call for an 80% reduction in fine particulate matter from wood stoves by 2019. These changes will have implications for wood stove manufacturers and those heating with wood…and for Canadian’s too, as regulators here have been quick to adopt the new EPA guidelines in the past. So what are we to make of these changes?

I’m not entirely sure what the real motivation is for these aggressive targets (one source cites lawsuits directed at the EPA from seven states and the American Lung Association for not updating standards to align with the Clean Air Act), though the EPA would have you believe it all has to do with improving human health and saving lives.

But while the EPA takes a swing at wood stoves, North American’s are consuming more energy than ever before, mostly fossil-fuel based, in more outrageous and conspicuous ways than anyone thought possible.

Upon walking into a Rona store the other day I noticed an 8 person hot tub displayed near the entrance. This hot tub sold for $18,000 and when I asked the clerk what it would cost to operate he said, “Well, first you have to fill thing. I think it’s 4,000 litres. There’s a 5,500 watt heating element and a 1 horsepower motor for the jets. You also have all the chemicals and the filters, so yeah, it’s not exactly cheap.” It occurred to me that if what I was reading on some blogs was correct, that in just a few years it may not be possible to heat your home with wood but as long as you were flush with cash the possibilities for shrouding oneself in a world of energy devouring luxury items would go unabated.

To impose tough regulations on a minority of people heating with wood (just 4.5% of Canadians in 2005, down from 4.7% in 1998; source), while ignoring the global-scale damages to land, air and water due to an increasingly rapacious appetite for consumer electronics, luxury goods and automobiles, and large, inefficient, resource intensive homes, is simply Draconian.

Full Page Lexsus advertisement from The Globe and Mail.

It also got me thinking that if governments actually cared for the wellbeing of its citizens, they’d first impose meaningful regulations on the industry, and the automobile and housing sectors (which together account for 84% of all energy used in Canada). What if Ottawa or Washington said to automakers, “Hey guys, by the way, you’re going to have to increase the fuel economy of cars by 80% by 2019.” Are you kidding me?! My 2009 Toyota Corolla had just 3% better fuel economy than the 1980 model and that’s with 30 years of ‘innovation’. What if they said to home builders, “By 2019 all new homes will have to face the sun, be super-insulated and passively heated, and be free of any materials that off-gas noxious chemicals.” And then there are the energy companies, but I don’t think I need to go there.

I’m certainly a proponent of using resources more responsibly and I believe we each have a right to breathe fresh, clean air but I also believe we have the right to a certain degree of autonomy over our lives. When governments (like the Government of Quebec) urge people to “avoid burning wood as your main source of heat, [as] other heating methods such as electricity, natural gas, and fuel oil pollute less”, it’s not difficult to see the stupidity and shortsightedness in these recommendations. Encouraging people to shift from wood (a renewable, carbon neutral fuel) to non-renewable fossil fuels does nothing but force humanity further into a deepening progress trap.

But with wood heating comes responsibility.

This means we should be aiming to 1) convert the wood to heat in the most efficient way possible and 2) make sure the heat doesn’t just leak out into the environment. This second point can be referred to as effectiveness marked by sufficient insulation in the space you’re heating balanced with ample thermal mass, which acts to first temper the heat from a hot fire, storing, then slowly releasing it as its needed. An “efficient” metal box may reduce certain emissions but if it is installed in a poorly insulated home, lacking any thermal mass to store the heat, it does little to reduce the amount of wood consumed by the stove.

It’s true that EPA-certified wood stoves have a fraction of the emissions wood stoves once had, which I’d suggest is a good thing. There’s a good chance the new measures will have further benefits to air quality. What I struggle with, however, are efficiency claims that fail to address context. Wood stoves are assigned ratings based on laboratory testing, in near-perfect conditions, but rarely, if ever, is a stove operated under such conditions. Ratings on wood stoves are similar to the fuel-efficiency ratings for new vehicles. They don’t seem to hold up in the real world.

Fine particulate emissions from various sources, though there are certainly other impacts assoicated with the burning of fossil fuels that are not captured by this graph.

Some of this has to do with ignorance or poor behaviours – burning wet wood, not burning the stove hot enough, burning treated wood, etc. – but these things are avoidable if people are receptive to a little education. In other situations people are simply trying to make their stove more effective – making up for a lack of mass to store the generated heat and/or because they have a poorly insulated house (though, ironically, probably built to code). We see this as people head into the bedtime hours. You see, it’s difficult to make it through the 8 hours of night on a single firing in the wood stove. So rather than burning a stove the way it’s intended (hot and fast), people dampen down their stove, starving it of oxygen, or they burn wet wood. Both force the wood to burn more slowly, meaning they don’t have to get out of bed part way through the night. Neither approach does anything to promote cleaner burning, but they are the common way to burn wood to make up for what lacks in the design.

More stringent emission standards are not likely to solve these more systemic problems.

This leads me to this point – what is happening around wood heating in the amazingly collaborative environment of masonry stove builders, rocket mass heater enthusiasts, and natural builders is truly exciting. Thousands of people are putting their heads together to build better wood heaters, with a goal of getting more heat from less wood with less pollution. And with the new EPA guidelines coming down the pipe, folks are already suggesting novel solutions   to make the rocket mass heater even more efficient than the current configuration. Even Popular Mechanics featured some of the incredible work happening in this area, reporting on the first-ever Wood Stove Design Challenge, which not only featured a rocket mass heater, but other interesting and promising mass-heater designs.

It’ll be interesting to see where these developments go and I hope the new EPA regulations take a balanced and reasonable approach to masonry heaters, which were exempt from previous guidelines but are proposed for the new ones.

They will, however, be handled differently than standard wood stoves, with the EPA stating that the new standards will most likely align with ASTM method E2817-11 for masonry heaters. My understanding is that masonry stoves are given more leeway around particulate emissions than wood stoves, for reasons which are highlighted by this point in the ASTM standard:

Warning—Use of masonry heater emissions rate reporting numbers (grams per hour) for comparative purposes with other solid fuel burning appliances will require careful study of each of the appliance’s comparative operating characteristics in the given application. Intermittently fired appliances such as masonry heaters and continuously fired appliances such as wood and pellet stoves are not accurately compared by their respective emissions rates.

This point highlights an explicit understanding that efficiency and effectiveness are different things and we should be encouraged by this.

Heating with wood is a way of life for a small number of Canadians wishing to live a simpler, more examined life. The process of cutting a tree, bucking, chopping, stacking, drying, and finally heating with the wood is an honest and sustainable way to heat your home, domestic water, or for use in cooking. Many would-be homesteaders dream of a small holding, complete with a big garden, chickens, a cozy handmade house, and a wood stove. Let’s hope the EPAs new regulations do not have the consequence of forcing people to use fossil fuels over wood for their heating needs. If it does, it will have failed in serving the public good.

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