Should emissions from decorative fireplaces, wood-fired cook stoves, and central systems be regulated?

The pros and cons of category exemptions

The B415.1 standard applies specifically to heating appliances like stoves, fireplace inserts and central systems. The scope of the standard specifically excludes site-built and decorative appliances. The excluded categories are described as:

•  site-built masonry fireplaces

• site-built masonry heaters

• decorative fireplaces and

• fireplaces with a minimum burn rate higher than 5.0 kg/h. 

The exemptions are based on the technical limitations of the test protocol. The emissions from site-built and decorative fireplaces could be measured and regulated, but it would require a different approach to testing.

A second standard in the series (B415.2) to cover fireplaces was discussed by the technical committee, and a proposal to investigate the technical issues to be addressed during its development was submitted to CSA, but funding was not available to pursue development.

The pros and cons of regulating fireplaces

The U.S. EPA did not include fireplaces under its emissions regulation. The usual reasons given for the exemption are:

1. Infrequent use:  Decorative fireplaces are not used as frequently or for extended periods the way heating devices are.
2. No smouldering:  Fireplaces are not usually 'airtight' so they are not as likely to produce thick smoke caused by smouldering.

Another possible reason for exempting fireplaces, although it is not often cited, is that regulating them could produce a public uproar. Fireplaces tend to be favoured by higher income people for their decorative/aesthetic qualities. The probable effect of regulating fireplace emissions would be the need for glass doors and limitations on the size of the hearth opening in order to reduce emissions. But glass doors and small hearths are not popular among connoisseurs of open fireplaces. Of all wood burning user groups, this could be the most vocal and influential.

There are, however, good arguments for regulating fireplaces and doing so at the same time that emissions from other classes of wood burning appliance are regulated. These could include:

1. Urban use:  According to Environment Canada figures, about 20 percent of all firewood burned in Canada is burned in conventional fireplaces. But fireplaces tend to be used more often in urban settings where population density is high and where more people are exposed to the smoke. 
2. High emissions:  The smoke emissions from fireplaces per kilogram of fuel burned are more than three times higher on average than from wood-fired heating equipment that meets the EPA emission limits – 16.4 grams per kilogram of dry fuel compared to 5.1 g/kg. Note that fireplaces have far higher burn rates than stoves, so during each hour of operation, fireplaces pump out much more pollution than clean burning stoves.
3. Low efficiency:  Conventional fireplaces have low efficiency, so most of the wood burned in them is wasted from an energy use perspective. This also means that the main macro benefit of using wood fuel – as a greenhouse gas-neutral option to fossil fuels – is lost. Without the GHG mitigating benefits of fossil fuel displacement to offset emission impacts, the arguments for not regulating fireplaces are rendered weak indeed.
4. Avoiding an anti-rural bias:  It could be argued that regulating heating appliances and not fireplaces favours well-off urban polluters over lower income rural households. A full-coverage regulation might not achieve universal approval, but it would at least be seen as fair.
5. Ignite a debate:  An initiative to regulate fireplaces could prompt an enlightening public debate about the pros and cons of wood fuel use, its place in Canada's energy use mix, and what constitutes appropriate use. Considering Canada's excessive per capita energy consumption (by international standards), the energy-related environmental damage and projected future shortages, such a debate is overdue.

The issue of whether or not to regulate fireplaces is one reason why the delay by government officials in initiating public consultation is so unfortunate. Three years ago Environment Canada unilaterally decided not to pursue the development of a fireplace emission standard. (It should be noted that CSA requires external funding for standards development and government is the only practical source of such funding in this case. Therefore, not funding the development of the fireplace standard was a government policy decision.) During the consultation process, it will likely be argued that there is now insufficient time to develop the standard before the ministers' 2005 deadline for implementing the regulation. Does this mean that EC has already decided not to regulate fireplace emissions?

The pros and cons of regulating cook stoves and central heating appliances

In addition to fireplaces, EPA also provided exemptions for cook stoves and central heating appliances. Both exemptions were established on the basis that the number of units involved was too small to be of significant concern.

There is no technical reason why cook stoves and furnaces cannot be tested under the CSA B415.1 emissions test procedure. As a result, the technical committee responsible for the standard provided no exemption for these classes of wood burning appliance on the basis that such exemptions are political, not technical, in nature.

It would be a simple matter for the Canadian government to provide exactly the same exemptions that EPA did so that the regulations would be identical in each country. Here are the arguments for the same exemptions:

1.      Canada and US - one market:  Providing the same exemptions would support the idea of a common market between the U.S. and Canada, so it could not be argued that Canada had constructed a non-tariff trade barrier.

2.     Market too small to be viable:  It is argued that the market in Canada for products in these categories, and specifically cook stoves, is too small to justify the R & D, tooling and promotional expenditures needed to bring them to market. Theoretically, certified low emission cook stoves wouldn't find a market in the U.S. because of the EPA exemption. The worst-case scenario is that no manufacturer would successfully develop and market a cook stove, therefore depriving Canadians of this type of product. Some people say that regulating cook stoves amounts to a ban on the product.

3.      Small manufacturers would disappear:  Wood furnaces and boilers are usually made by smaller companies that have found a niche not occupied by the large companies that export a significant amount of their production. Regulating central heating appliances could put these companies out of business.

Here are some arguments in favour of a blanket regulation that covers all categories of equipment.

1.      Exemptions inhibit innovation:  The EPA exemptions for central appliances and cook stoves resulted in the stagnation of innovation in these categories. Many of the cook stove models still offered for sale are reproductions of antiques, the designs of which are more than 50 years old. Most wood furnace designs are more than 20 years old. This lack of progress is the direct result of market forces that penalize technological development because of the incremental costs of low emission technology. Even though the EPA regulation on wood stoves and fireplace inserts has now been in place 14 years, technical improvements continue to be made and manufacturers compete on the basis of low certified emission performance.

2.      No clean burning products available:  Canadians have been deprived of reasonably efficient, low emission central appliances and cook stoves. The result is that people who purchase these appliances to meet their particular needs must put up with high fuel consumption and higher maintenance costs because of faster creosote accumulation in chimneys, as well as a greater risk of chimney fire. An environmentally enlightened household that needs a cook stove has no option but to use dirty technology.

3.      Design problems not insurmountable:  Although some manufacturers will claim that meeting B415 emission limits is a practical impossibility in their product category, there is already evidence to the contrary. For example, two Canadian wood furnace manufacturers are currently working on low-emission products in anticipation of the planned regulatory initiative. These manufacturers are investing in technology in the firm belief that their company will not only survive, but thrive in an environment in which smoke emissions are regulated. In the case of cook stoves, there is evidence that their characteristically small fireboxes can be adapted easily to meet the B415/EPA limits. The evidence is in the form of small free-standing wood stoves, with simple combustion systems, that are now EPA certified. Since the EPA/B415 test protocol is biased towards small fireboxes, these small stoves can meet the requirements with simple, inexpensive pollution-control features. The same could be achieved with cook stoves.

There are certainly difficulties to overcome, but we don't see any compelling technical or policy reasons why the emissions from all classes of woodburning equipment should not be regulated. From the experience gained in the US it is clear that emission regulations are effective in reducing pollution impacts while significantly improving appliance efficiency. The US experience also demonstrates that category exemptions introduce distortions to the market and more negative impacts than advantages.

On balance, the Wood Heat Organization supports a level playing field among all wood burning appliance categories. We think the public and the environment will gain in the long run.