1 INTRODUCTION
This document is intended to serve as a basis for discussion at a stakeholder workshop on initiatives to reduce emissions from residential wood burning appliances. It was developed by the Intergovernmental Working Group on Residential Wood Combustion, comprised of representatives from municipal, provincial, territorial and federal governments. The Working Group was formed in 1999 to promote and coordinate government actions on the sustainable development of residential wood combustion. Its first priority was to address four components related to residential wood combustion under the Joint Initial Actions on the Canada-wide Standards for fine particulate matter (PM2.5) and ozone. These standards were endorsed by the Canadian Council of Ministers of the Environment, except Quebec, in June 2000.
Under the Joint Initial Actions, governments committed to "participate in new initiatives to reduce emissions from residential wood burning appliances, including:
· an update of the CSA standards for new wood burning appliances;
· development of a national regulation for new, clean burning residential wood heating appliances;
· national public education programs; and
· an assessment of the option of a national wood stove upgrade or change-out program."
This document outlines the options and/or proposed courses of action for each of the above initiatives. This workshop is the first opportunity for stakeholders at a national level to provide feedback on the options for reducing emissions from residential wood burning appliances. The results of this workshop will be taken into consideration by the Working Group in developing its recommendations to CCME.
Background information that may be helpful to readers is included in the annexes to this document:
Annex 1: Market and User Profile - describes the extent of wood-burning appliances in use in Canada, regional wood consumption, new sales of appliances, and imports and exports.
Annex 2: Industry Profile - describes the industry associations as well as the manufacturers, importers, and distributors of wood stoves in Canada.
Annex 3: Benefits of Certified Stoves - compares emissions, energy efficiency, and costs between certified and non-certified stoves.
Annex 4: Existing Management Programs - describes the existing regulations, certification and other programs aimed at wood stoves in Canada, the United States, and Europe.
Annex 5: Tools not Feasible as a National Regulation - in support of Chapter 4, this annex describes the options for a national regulation that were assessed as being not suitable to meet the objectives of a national regulation.
Annex 6: List of Accompanying Documents - lists background materials that accompany this discussion document.
2 Background
2.1 Health Effects of Particulate Matter
Air pollution affects the health of all Canadians, especially children, the elderly and those with respiratory and cardiac conditions. Particulate matter less than or equal to 10 microns (PM10) is a key component of smog, along with ground-level ozone. PM10 can be released directly into the atmosphere or formed secondarily in the atmosphere from precursors as a result of physical or chemical transformations. The four primary precursors to PM10 are sulphur dioxide, nitrogen oxides, ammonia and volatile organic compounds. Ozone is formed in sunlight and warm, stagnant air from the precursor gases of nitrogen oxides and volatile organic compounds (VOCs).
The people most at risk from smog are elderly people, those with heart or lung disease as well as children, because they breathe faster and spend more active time outdoors. Even healthy young adults breathe less efficiently on days when the air is heavily polluted. Sensitive people may experience symptoms after only one or two hours outdoors.
Of greatest health concern are fine particulate matter (PM2.5) that can penetrate deeply into the lungs and interfere with the functioning of the respiratory system. These fine particles have been linked to increases in asthma symptoms, hospital admissions and even premature mortality.
PM-related health effects are being seen at ambient concentrations that currently occur in Canada. Effects include daily mortality, respiratory and cardiovascular hospitalizations, impaired lung function, adverse respiratory symptoms and medication use, restricted activity days, and higher frequency of reported chronic respiratory disease. Federal studies show that thousands of deaths a year can be attributed to air pollution. The Ontario Medical Association says that air pollution costs Ontario citizens more than $1 billion a year in hospital admissions, emergency room visits and absenteeism. The Toronto Public Health Department says that that air pollution causes 1,000 deaths a year and numerous health-related problems.
Based on a scientific assessment conducted by Environment Canada and Health Canada, PM10 has been declared toxic under the Canadian Environmental Protection Act, 1999 (CEPA 1999). PM10 was added to the List of Toxic Substances in Schedule 1 of CEPA 1999 on April 26, 2001.
2.2 Canada-wide Standards for PM2.5 and Ozone
Two of the key management initiatives to address smog in Canada are the Canada-wide Standards for PM2.5 and ozone. On June 5, 2000, the Canadian Council of Ministers of the Environment (CCME), except Quebec, endorsed Canada-wide Standards (CWSs) for PM2.5 and ozone. CWSs are developed under the 1998 Canada-wide Accord on Environmental Harmonization and its Canada-wide Environmental Standards Sub-Agreement. The agreements are available online (www.ccme.ca).
The CWS agreement recognizes that PM2.5 and ozone negatively effect human health and the environment and establishes the need for nationally coordinated, long-term management toward minimizing risk from these pollutants.
In agreeing to the CWSs, federal, provincial and territorial jurisdictions across Canada have made strong commitments to implement the CWSs, to share information respecting implementation, and to be accountable to their respective publics.
The numerical targets and timeframes for the CWSs are:
For PM2.5:
30 mg/m3, 24-hour averaging time, achievement to be based on the 98th percentile ambient measurement annually, averaged over 3 consecutive years, by 2010.
For ozone:
65 ppb, 8-hour averaging time, achievement to be based on the 4th highest measurement annually, averaged over 3 consecutive years, by 2010.
Governments have committed to undertake a number of Joint Initial Actions towards meeting these CWSs, which are to be completed by 2005. The Joint Actions Implementation Coordinating Committee, comprising representatives from CCME jurisdictions, is overseeing these initial actions. Sectors included in the Joint Initial Actions have been selected because:
· based on current emission inventories, they are significant emitters of the precursor pollutants that cause PM2.5 and ozone;
· they are common to most jurisdictions and affect many communities across Canada;
· effective action requires a multi-jurisdictional approach; and
· effective action can be initiated in the near-term.
One of the components of the Joint Initial Actions is the commitment to participate in new initiatives to reduce emissions from residential wood burning appliances, including:
· an update of the CSA standards for new wood-burning appliances;
· development of a national regulation for new, clean burning residential wood heating appliances;
· national public education programs; and
· an assessment of the option of a national wood stove upgrade or change-out program.
The Inter-Governmental Working Group on Residential Wood Combustion, formed in 1999 by interested municipal, provincial, territorial and federal governments to promote and coordinate government actions on the sustainable development of residential wood combustion, was given the task of addressing these initiatives and presenting recommendations to CCME. The CWSs and Joint Initial Actions are included in the accompanying documents.
2.3 Emissions from Residential Fuel Wood Combustion
Emissions from residential fuel wood combustion contribute significantly to PM10, PM2.5, and VOC emissions in Canada. According to the revised 1995 Criteria Air Contaminants (CAC) Emissions Inventory[1] (including open sources), residential wood combustion is:
· the fourth highest source of PM2.5 emissions in Canada (behind forest fires, dust from unpaved roads, and dust from paved roads);
· the seventh highest source of PM10 emissions in Canada (behind dust from unpaved roads, tilling and wind erosion, forest fires, construction, dust from paved roads, and agriculture); and
· the sixth highest source of VOC emissions (behind forest fires, upstream oil and gas industry, light duty gasoline vehicles, general solvent use, and light duty gasoline trucks).
Much of the VOCs emitted probably very quickly condenses to PM as well. This and the fact that it emitted primarily in the winter means that it does not contribute much to ozone formation.
Figures 1 through 3 show the contribution of PM10, PM2.5, and VOC emissions from residential wood burning compared to total emissions from other sectors, excluding open sources such as forest fires and dust from unpaved roads.
Figure 1: PM10 Emissions (excluding open sources)
Figure 2: PM2.5 Emissions (excluding open sources)
Figure 3: VOC Emissions (excluding open sources)
Table 1 shows the emissions from residential wood burning compared to total emissions from all sectors, excluding open sources.
Table 1: Source Comparison of 1995 (revised version) PM10, PM2.5, and VOC Emissions in Canada
|
|
PM10 |
PM2.5 |
VOCs |
|||
|
Category/Sector |
tonnes |
% total |
tonnes |
% total |
tonnes |
% total |
|
Total Industrial Sources |
287 996 |
51.7 |
174 368 |
44.2 |
934 030 |
39.4 |
|
Total
Transportation Sources |
95 503 |
17.1 |
83 260 |
21.1 |
734 334 |
31.0 |
|
Total
Incineration |
1 573 |
0.3 |
1 195 |
0.3 |
6 738 |
0.3 |
|
Total
Miscellaneous |
14 370 |
2.6 |
9 234 |
2.3 |
552 965 |
23.3 |
|
Total
Non-Industrial Fuel Combustion (excl. residential wood combustion) |
63 117 |
11.3 |
31 337 |
7.9 |
7 242 |
0.3 |
|
Residential Wood
Combustion |
95 006 |
17.9 |
94 896 |
24.1 |
137 236 |
5.8 |
|
National Total |
557 565 |
100.0 |
394290 |
100 |
2 372 545 |
100.0 |
Another joint study, conducted by the Communauté urbaine de Montréal, Environment Canada, and the Direction de la santé publique de Montréal-Centre, assessed the impacts of wood-burning during the winter of 1998-99[2]. The study compared levels of air pollutants at Rivière-des-Prairies (an area considered to be highly influenced by residential wood combustion) to levels in downtown Montreal (not influenced by residential wood combustion). The study showed a link between residential wood combustion and increased levels of air pollutants in Rivière-des-Prairies compared to downtown Montreal: The results show
· a 45% increase in polycyclic aromatic hydrocarbons (PAHs);
· up to 200% increase in some VOCs;
· from 40 to 100% increase in PM2.5; and
· a 40% increase in some metals.
3 CSA Standard
3.1 Overview
In December 2000, the Canadian Standards Association (CSA) completed the second edition of CSA Standard B415.1, Performance Testing of Solid-Fuel-Burning Heating Appliances. It supersedes the previous edition published in 1992 under the title Performance Testing of Solid-Fuel-Burning Stoves, Inserts, and Low-Burn-Rate Factory-Built Fireplaces. It now includes cook stoves, indoor and outdoor central and small commercial systems, and space heaters.
This standard was developed at the request of government authorities in order to regulate appliances in new installations and to assist manufacturers in the development of solid-fuel-burning appliances with improved combustion characteristics.
This standard describes a test procedure for measuring the emissions, heat output, and efficiency of solid-fuel-burning furnaces, boilers, stoves, low-burn-rate factory-built fireplaces, and inserts and automatically fuelled stoves having a minimum air-fuel ratio less than 35:1. Site-built decorative fireplaces or fireplaces with a minimum burn rate above 5 kg/h are excluded.
The development committee made every effort to make the methodology of this standard consistent with the US EPA's regulations. The test procedure described in this Standard is based on Method 5G-1 of the US EPA Code of Federal Regulations, Title 40. The interpretation of the US EPA regulations is periodically updated by the issuance of Applicability Determinations. Anyone using this standard who also intends to seek US EPA product approval should be fully conversant with all US EPA requirements.
3.2 Issues for Discussion
1- Is there a need and adequate rationale to develop a CSA standard for site-built decorative fireplaces or fireplaces with a minimum burn rate above 5 kg/h?
2- What factors and parameters need to be taken into account in the development of such a standard?
3- What concerns are there about the development of such a standard? How might these concerns be addressed?
4- What other complementary or alternative options or approaches should be considered to achieve comparable results?
5- What outstanding issues and questions need to be addressed, either now or over the longer term?
4 national regulation
4.1 Background
In Canada, only British Columbia has a provincial regulation prohibiting the sale or manufacture of wood heating appliances that do not comply with the CSA standard or the US EPA standard; however, the regulation could be circumvented by consumers who choose to purchase a non-certified appliance from another province, and use it in British Columbia.
Other countries are also addressing emissions from wood stoves. In 1995, the US EPA revised its regulations restricting emissions of contaminants from residential wood stoves. Some states have adopted regulations that are more stringent than the EPA standard. Scandinavian countries have a certification mechanism for manufactured products establishing their compliance with existing manufacturing standards in each country, as well as a certification program. Switzerland has a seal of quality for wood combustion appliances. Efforts are also underway in France and the European Commission to develop emission standards for wood stoves.
A more detailed description of the management programs and regulations in Canada and other countries is contained in Annex 4.
4.2 Objectives of a National Regulation
A national regulation is needed at the manufacturer, importer, and distributor levels to ensure a level playing field across Canada. The price differential between certified stoves and conventional wood stoves is in the range of $300 to $700 according to the model, which is likely to have a major influence on consumer purchasing behavior.
A national regulation would apply to all stoves addressed by the CSA standard, including solid-fuel-burning furnaces, boilers, stoves, low-burn-rate factory-built fireplaces, and inserts and automatically fuelled stoves having a minimum air-fuel ratio less than 35:1. Site-built decorative fireplaces or fireplaces with a minimum burn rate above 5 kg/h may be addressed in the future if further CSA standards are developed.
Major suppliers of wood stoves and industry associations, including the Hearth, Patio & Barbecue Association of Canada (HPBAC) and the Association des Professionnels du Chauffage (APC) are supportive of a national regulation. The Wood Energy Technical Training Association (WETT), as well as the New Brunswick Lung Association are also supportive. Although many major manufacturers in Canada are already building and selling US EPA certified stoves, most manufacturers continue to also build conventional wood stoves to remain competitive.
4.3 Assessment of Options
Over the last several years, Environment Canada, in consultation with provinces and territories, has been identifying the options for a national regulation. The most obvious option – a regulation under CEPA 1999 – is not feasible at this time. It has been determined that CEPA 1999 does not provide the authority to regulate the manufacture, import, or sale of residential wood stoves because they are not "substances" that are toxic, nor do they contain or release a toxic substance at the time of manufacture, import, or sale. Therefore, it is not possible to use the regulation-making powers under Section 93 of CEPA 1999 to control their manufacture, import, or sale.
Since wood stoves can be sources of a toxic substance (PM10) when wood is burned, Section 93 of CEPA 1999 can be used to regulate the release of PM10 from individual wood stoves by referencing the CSA standard. However, this would mean the regulation would target users of wood stoves. Regulating users of these residential appliances would be impractical, and the resulting regulation would be extremely difficult and costly for Environment Canada to enforce.
Although it is expected that the ability to regulate the manufacture, import and sale of such products will be addressed when the review of CEPA 1999 is initiated in 2005, there is a commitment to complete the Joint Initial Actions for the CWSs by 2005. Therefore, other options for developing a national regulation were examined, such as other tools under CEPA 1999, provincial/territorial regulations, and voluntary approaches. Through analysis of these options, it was determined that none would achieve the objectives of a national regulation. The analysis of these options is described in Annex 5.
Following discussions with Health Canada to identify feasible alternatives, Environment Canada identified the Hazardous Products Act (HPA) as the most feasible tool to establish a national regulation governing the manufacture, import, or sale of residential wood stoves. A copy of the HPA is included in the accompanying documents. The proposed approach is further discussed in the next section.
It should be emphasized that although a regulation under the HPA was identified as the preferred approach based on the analysis of options, it is a proposal for the purposes of consultations with stakeholders. Input from stakeholders on the proposed approach as well as the other options that were analyzed are critical to the process and will be taken into consideration in determining the path forward.
4.4 Proposed Prohibition or Restriction under the Hazardous Products Act
Based on an analysis of all possible options, including tools under CEPA 1999, a prohibition (s.4(1)) or a regulation (s.4 (2)) under the Hazardous Products Act (HPA) is the most effective option for a national approach to regulating residential wood stoves in Canada by 2005. An HPA regulation would meet the objectives of a national regulation: to provide a level-playing field and ensure the manufacture, import, and sale of CSA-certified wood stoves. Health Canada would be legislatively responsible for this regulation while Environment Canada would be responsible for its development and full implementation, including compliance promotion, and enforcement. The following sections describe the operational approach.
4.4.1 Activities that can be Controlled
The HPA applies to advertising, selling and importing. These words are defined in section 2 of the HPA:
· advertise - in relation to a prohibited product or restricted product, includes any representation by any means whatever for the purpose of promoting directly or indirectly the sale or other disposition of the product;
· import - means to import into Canada;
· sell - includes offer for sale, expose for sale and distribute.
Section 4(1) of the HPA authorizes the Minister to prohibit the advertising, sale and importation of products listed in Part I of Schedule I. Section 4(2) authorizes the Minster to restrict the advertising, sale and importation of products listed in Part II of Schedule I except as authorized by regulations made under section 5. Such regulations could set out the conditions under which the advertising, sale, or import of a product could take place.
4.4.2 Scope of Application
A prohibition or regulation would apply to new solid-fuel-burning heating appliances addressed in the CSA standard:
· manually and automatically fuelled stoves and fireplace inserts;
· factory-built fireplaces with a minimum burn rate less than 5 kg/h; and
· furnaces and boiler with outputs up to 2 megawatts designed to have the useful heat produced by the appliance conveyed to areas remote from the appliance by ducting or plumbing.
Solid-fuel-burning appliances include manually and automatically fuelled systems, as well as add-ons and combinations.
It would not apply to appliances not covered by the CSA standard, including:
· site-built masonry fireplaces;
· site-built masonry heaters;
· decorative fireplaces; and
· fireplaces with a minimum burn rate above 5.0 kg/h.
4.4.3 Labeling Requirements
Any person who imports, sells or advertises must not import, sell for use or for resale, or advertise an appliance manufactured after a specified date unless, at the time of import, sale or advertising the appliance bears a permanently affixed label that:
· is readily visible or accessible;
· conforms to the labeling requirements under the Canadian standard; and
· indicates that the appliance conforms to the particulate emission requirements of the Canadian standard.
4.4.4 Record-keeping
Any person who imports, sells or advertises is required to keep, for a period of at least five years at their place of business in Canada, all sale and imports records and submit an annual record or report of sales and imports to the federal government.
4.4.5 Offences and Penalties
Section 28 of the Hazardous Products Act describes the offences under the Act and provides for penalties and fines.
4.4.6 Enforcement
The process of CSA certification includes accreditation of laboratories that are authorized to carry out the testing of manufactured stoves. Manufacturers pay an annual fee to retain their CSA certification. Accredited laboratories test an appropriate sample of the stoves being manufactured and carry out four inspections a year on the manufacturer to check if the design accepted is still the same and if the labels are being used appropriately. Where deviations or non-compliance is encountered, the manufacturer must repeat the testing for modifications and must also pay an additional annual fee in order to keep its certification.
For monitoring the compliance of retail sales and offers to sale, Environment Canada would prepare an annual inspection plan that identifies the priority target areas and the rationale. Imports could be inspected upon entry to Canada by customs agents.
4.4.7 Cost-Benefit Analysis
A Regulatory Impact Analysis Statement would be prepared at the time of the drafting of the regulation and would consider the following:
Costs
· costs to consumers - the price difference between CSA-approved and non-CSA approved products, the overall impact on consumers by examining information on market penetration of the various products and projected sales (this data should be available at a minimum at the national level, but to establish regional impacts, would be preferred on a provincial basis);
· costs to the federal government - the costs to implement and enforce the regulation;
· alternatives considered - an analysis of alternatives, rationale for selecting proposed approach – at a minimum, qualitative statements on the selection of the “best” instrument;
· costs to industry - impacts of a regulated market to industry.
Benefits
· benefits from improved air quality - to environment and human health;
· benefits to consumers - for example, increased energy efficiency of wood burning will result in lower wood costs; and
· benefits to industry - for example, harmonization with standards in the United States, good environmental citizenship.
4.5 Issues for Discussion
1- What factors and parameters need to be taken into account in the development of such a national regulation?
2- What concerns are there about the development of such a regulation, as proposed? How might these concerns be addressed?
3- More specifically, what concerns and what suggestions are there with respect to the proposals regarding:
a) The overall objectives of a national regulation?
b) The scope of the regulation, including the range of appliances and related activities/factors to which the regulation should apply?
c) Specific terms of such a regulation?
d) Enforcement/compliance strategies and mechanisms?
e) The scope of, and approach to, the design, conduct and use of the proposed Regulatory Impact Analysis Statement for the draft regulation (i.e., analysis of costs and benefits) ?
4- What other complementary or alternative options or approaches should be considered to achieve comparable results?
5- What outstanding issues and questions need to be addressed, either now or over the longer term?
5 public education Campaign
5.1 Overview
Natural Resources Canada has been leading a campaign called "Burn it Smart!", to promote safer, less polluting and more efficient wood burning practices for those who heat their homes with wood, or use it for recreational purposes. Knowing that wood-smoke is a pollutant often caused by the inefficient combustion of fuel wood, the campaign provides tips and proposes actions to help the public reduce wood-smoke pollution, while economizing on the wood they use. An exchange program – the Neighbourhood Woodstove Change-out Project – is a component of the education campaign. The Burn it Smart! brochure is included in the accompanying documents
The Intergovernmental Working Group on Residential Wood Combustion had endorsed this campaign as meeting the commitments in the Joint Initial Actions under the Canada-wide Standards for PM and ozone, however due to funding restrictions, the campaign will not continue past the 2002-03 heating season (refer to section 5.3 for more information on the path forward). The Working Group oversees the implementation of this campaign in conjunction with a Steering Committee. Government members of the Steering Committee include Environment Canada, Health Canada, Canada Mortgage and Housing Corporation, Nova Scotia Ministry of Natural Resources, Quebec Ministry of the Environment, Alberta Environment, Yukon Development Corporation, and the Montreal Urban Community. Along with the hearth industry, represented by the HPBAC and the Association des professionnels du chauffage, the following national partners have committed to the campaign: Fire Prevention Canada, WETT, the Canadian Environmental Network, and the Canadian Lung Association.
The campaign was piloted by way of change-out projects from January to March, 2002 in seven communities:
· Annapolis Valley, Nova Scotia;
· Sackville, Nova Scotia;
· Fredericton, New Brunswick;
· Moncton, New Brunswick;
· Thunder Bay, Ontario;
· Okanagan Valley, British Columbia; and
· Whitehorse, Yukon.
The objectives of the pilot season were to:
· conduct pilot exchange programs in seven communities across Canada via the Neighbourhood Woodstove Change-out Project;
· encourage those who heat with wood to improve their burning practices;
· encourage those who heat with wood or are contemplating doing so, to purchase an energy efficient wood stove;
· test all messages, focusing on two key messages and two social marketing approaches (health/environment, and safety, with cost, convenience and aesthetics as secondary messages), along with collateral materials, to determine their effectiveness with various elements of the target population; and
· evaluate the campaign and determine the most effective approaches and messages for the national campaign.
5.2 Components of the Pilot Season
5.2.1 Website
An extensive website, hosted by Natural Resources Canada, was launched in January 2002 (www.burnitsmart.org or www.chauffageaubois.org). The website provides information on the Burn it Smart! campaign, the seven pilot change-out projects, how to burn smarter, and high efficiency products. It also features frequently asked questions, a quiz, and a reader survey.
5.2.2 Promotional Materials
A range of promotional materials has been produced:
· brochure, for distribution to customers;
· fact sheets, for distribution to those looking for more detailed information;
· posters, for display at the store, trade shows and other marketing opportunities (a small format poster will be developed, to accommodate space limitations at retail outlets);
· banners;
· point-of-purchase displays;
· decals, for display on appliances;
· ad templates, to be customized by the retailers to promote the campaign and their involvement; and
· survey to consumers who purchase an advanced technology stove.
The materials were distributed during the public workshops that were held during the pilot season. Materials were also available at hearth products dealers and, in some cases, at public malls and other public areas.
5.2.3 Community Workshops
Community workshops provided an opportunity for one-on-one discussion between householders and experts in wood heat and safety. Workshops tended to be about two hours long and were hosted by project managers representing local community groups, with input provided from the local fire chief or fire prevention officer, wood stove retailers, WETT technicians, and other wood heat experts. Presentations were made about efficient wood heating practices and appliances, and the change-out options being offered. Brochures and other written materials were made available to those who attended.
Another popular feature of the workshops were outdoor displays that clearly demonstrated the difference between older stoves and advanced technology models. While the older stove produced a plume of smoke from its chimney, observers saw no visible smoke from the advanced stove’s chimney. They also saw that the advanced technology stove produced a more beautiful fire. Media were invited to attend the workshops, and played a strong role in carrying the message to the community.
5.2.4 Household Audits
Some communities conducted home visits by a WETT technician to assess a household’s wood stove. The materials provided at the workshops were also provided to technicians for discussion with householders. These audits provided an excellent opportunity for one-on-one advice by a qualified expert in wood heat. A total of 16 home visits were conducted, with some alarming safety issues identified.
5.2.5 Incentives
Incentives, both financial and social, can play a large role in motivating people to change behaviours. Both new appliances and more efficient practices benefit consumers financially, through savings in wood, and the time saved in cutting and stacking it and maintaining the stove. On the other hand, the high cost of purchasing a new appliance is clearly seen as a cost disincentive. People participating in the pilot programs were surveyed to determine how the costs and benefits weighed into their decision. Pilot projects have proposed various incentives, including:
· financial incentives towards the purchase of a new stove;
· removal of the old stove at a reduced rate or for free;
· gift certificate towards wood stove inspection and cleaning;
· a free cord of wood;
· an EnerGuide audit; or
· a free wood stove and free installation.
5.3 Path Forward
Following the pilot season, an evaluation tool was developed to assess the results and make improvements in the program. The educational materials were revised according to the results of the evaluation. The final evaluation report is expected by the end of March 2003.
Natural Resources Canada is leading the launch of the campaign for the 2002-03 heating season. Project managers are expected to host at least 12 public Burn-it-Smart! workshops in each of 20 regions across Canada from September 2002 to March 2003.
Since expected federal funding did not materialize due to increased federal government spending on security, Natural Resources Canada will not be able to continue the Burn It Smart! Campaign past the 2002-03 heating season, although they will maintain the website for a few years and will make the templates for the promotional materials available. The Intergovernmental Working Group is looking at ways to build upon the momentum of the Burn it Smart! campaign and to find other ways to deliver a longer-term national public education program beyond this fiscal year.
5.4 Issues for Discussion
1- How prominent a role should a public education campaign play in overall efforts to encourage reduction in emissions?
2- What factors and parameters need to be taken into account in the design and implementation of such a public education campaign?
3- What concerns are there about such a public education campaign? How might these concerns be addressed?
4- More specifically, what concerns and what suggestions are there with respect to the proposals regarding:
a) The overall objectives and scope of a public education campaign?
b) The types – and suggested typical contents – of educational and promotional materials that would be developed and disseminated?
c) The role and subject matter of community workshops or equivalent?
d) The rationale for, and potential approaches to voluntary household audits?
e) The scope, nature and feasibility of potential incentive regimes?
f) Funding and delivery options for public education initiatives pending/following the phase-out of the “Burn it Smart!” program?
g) The specific roles or different stakeholder groups (governments, industry, NGOs and others) in the design, funding and/or delivery of public education measures.
5- What other complementary or alternative options or approaches should be considered to achieve comparable results?
6- What outstanding issues and questions need to be addressed, either now or over the longer term?
6 ASSESSMENT OF OPTIONS FOR A NATIONAL CHANGE-OUT PROGRAM
6.1 Overview
An evaluation of the various change-out programs that have occurred across Canada, during the last 10 to 15 years, including the change-out programs of the Burn it Smart! Campaign, is planned for the fall of 2002. The objectives of the assessment are to:
· determine the success and benefits of the various programs;
· determine whether a change-out program is effective and efficient compared to other programs (e.g., advertising, education); and
· if effective, develop a template for a national change-out program.
The evaluation will be based on the template that was designed for the evaluation of the Burn it Smart! Campaign. A copy of the blank template is included in the accompanying documents.
6.2 Issues for Discussion
1- Is there a need and adequate rationale for a national change-our program?
2- What factors and parameters need to be taken into account in the design and implementation of such a change-out program?
3- What concerns are there about such a change-out program as it has been proposed? How might these concerns be addressed?
4- More specifically, what concerns and what suggestions are there with respect to:
a) The content of the proposed evaluation template for the program?
b) The scope of change-out programs to which the proposed template (or equivalent) should be applied?
5- What other complementary or alternative options or approaches should be considered to achieve comparable results?
6- What outstanding issues and questions need to be addressed, either now or over the longer term?
ANNEX 1: MARKET AND USER PROFILE
Wood-burning Appliances in Use
According to Canadian Facts' Omnibus Survey, over three million Canadian households report having burned wood either at their principal residence or at a vacation property[3]. This is consistent with Natural Resources Canada's 1997 Survey of Household Energy Use (SHEU '97), which indicates that an estimated 5.4% of homes, or over 500,000 Canadian dwellings use wood as the principle heating fuel, with a further 26% of homes using wood as a supplementary heating system[4].
According to a study conducted by Environment Canada and the HPBAC[5], wood stoves represent about 37% of the wood-burning appliances used in Canada, fireplaces make up about 54% and furnaces and other equipment make up the remaining 9%. Although stoves make up just over one-third of all wood-burning appliances, their use accounts for about 55% of the wood burned because stoves are the most common appliance for wood heating as opposed to fireplaces, which are used more casually.
It is estimated that the conventional technology wood-burning appliances account for more than 90% of all residential wood stoves currently in use5. Conventional wood stoves employ modest or no emission reduction technology. These stoves represent the majority of the Canadian wood stove inventory, many of which were installed during the 1980s “off oil” era.
According to Natural Resources Canada, wood is used most frequently as a main heating fuel in Atlantic provinces (15% of households) and Quebec (11%), where it is also most often used as a supplementary heating system4.
Wood Consumption
Table 2 below, taken from the National Emissions Inventory and Projections Task Group report, compares data on fuel consumption from the Canadian Facts survey, the SHEU '97 survey and provincial surveys conducted in Quebec and New Brunswick.
Table 2: Comparison of average provincial fuel consumption data from various sources
|
|
Canadian
Facts |
SHEU
1997 |
Provincial
Surveys |
|||
|
|
Average cu. ft. |
Average full cords |
Average cu. ft. |
Average full cords |
Average cu. ft. |
Average full cords |
|
NF |
746.9 |
5.8 |
512.5 |
4.0 |
|
|
|
PE |
521.7 |
4.1 |
480.6 |
3.8 |
|
|
|
NS |
479.4 |
3.7 |
353.2 |
2.8 |
|
|
|
NB |
512.7 |
4.0 |
404.7 |
3.2 |
537.6 |
4.2 |
|
QC |
624.6 |
4.9 |
428.8 |
3.4 |
281.6 |
2.2 |
|
ON |
316.6 |
2.5 |
161.2 |
1.3 |
|
|
|
MB |
321.9 |
2.5 |
195.6 |
1.5 |
|
|
|
SK |
298.7 |
2.3 |
123.4 |
1.0 |
|
|
|
AB |
173.4 |
1.4 |
119.0 |
0.9 |
|
|
|
BC |
301.6 |
2.4 |
221.4 |
1.7 |
|
|
|
CA |
429.75 |
3.4 |
300.0 |
2.3 |
|
|
While there is a significant difference in reported fuel consumption between the surveys, the rankings between provincial consumption figures are preserved. The average household wood consumption is far lower in provinces to the west of the Ontario/Quebec border than in provinces to the east. The report cites two reasons to explain this difference:
· The majority of homeowners in Ontario and provinces to the west have had access to low cost natural gas and generally lower oil and electricity costs for over 30 years and this reduces the incentive to use wood as their principal heating fuel; and
· Conventional fireplaces are more than twice as prevalent in Ontario and provinces to the west (average of 58% of all appliances) than in Quebec and provinces to the east (average of 26% of all appliances). According to SHEU '97 results, 54% of fireplaces are used once per week or less and a further 27% are used three times per week or less. At this average rate of use, annual fuel consumption for fireplaces would be significantly less than a full cord of wood. This factor reduces average consumption in provinces where fireplaces predominate.
Sales of Wood-burning Appliances
Figure 4 shows the number of residential wood heating appliances sold in Canada from 1989 to 2000.
Figure 1: Number of units sold between 1989 and 2000 (Statistics Canada7)
Table 3 shows statistics on the buyers of these products.
Table 3: Buyers of Hearth Products Sold in Canada (1999[6])
|
Sales |
|
Buyers
(%) |
|
|
|
Retail customers |
New housing contractors |
Remodeling contractors |
|
Wood fireplace |
75 |
15 |
10 |
|
Wood heater |
82 |
10 |
8 |
|
Gas fireplace |
65 |
28 |
7 |
Imports and Exports
According to Statistic Canada's reports on shipments7, the value of exports of all categories of wood heating appliances in 2000 was $27.7 million for a total production of $69.1 million, that is 40% of the production of Canadian manufacturers. The proportion of the total production exported appears to be on the increase; in 1992, exports represented 17% of the total, in 1993, 21.8%, and in 1996, 30%. Exports were stable from 1997 to 1999 at roughly 35%7.
With respect to imports, it seems that Canada presented a trade balance surplus in the area of wood heating appliances. Imports represented a relatively small portion of the total market, while American and European products occupied specialized niches. For instance, advanced technology cast iron stoves probably constituted the most important product category to be imported, and these products are largely available in points of sale throughout Canada. In fact, imports probably dominated this product category, given that at the time, there were no or few advanced technology cast iron stove manufacturers in Canada. There are no reliable statistics on the number of wood heating appliances imported in Canada. However, observers in these industrial sectors, questioned during the study published in 1997, estimated their number at between 5,000 and 15,000 units per year. In addition, various types of pellet stoves were imported from the United States, but the total market for pellet stoves was small, estimated to be from 3,000 to 5,000 units per year.
Industry Associations
The Hearth, Patio and Barbecue Association (HPBA) is an international trade association first established in 1980 to represent and promote the interests of the hearth products industry in North America. The Hearth Products Association of Canada (HPAC) is a trade association for industry professionals who manufacture, sell, install and service hearth products in Canada, regardless of fuel type. In 2001, the HPAC merged with the Barbecue Industry Association to form the Hearth, Patio and Barbecue Association of Canada (HBPAC). The Association includes manufacturers, retailers, distributors, manufacturers' representatives, service and installation firms, and other companies and individuals - all having business interests in and related to the hearth, patio, and barbecue products industry. (http://hpba.org)
HPBA's members manufacture, import, distribute, sell, service, and represent products that include:
· factory-built fireplaces, gas logs, inserts, and accessories;
· wood, pellet, coal, and gas stoves;
· barbecues, grills, and accessories; and
· patio furniture and accessories.
Wood Heat Organization Inc., is a nonprofit, non-governmental agency dedicated to the responsible use of wood as a home heating fuel. The Wood Heat Organization was formed to support the public in the responsible use of wood energy in the home. It fulfills its mandate by providing reliable information, by conducting research into wood heating-related issues, and by representing the public interest in discussions of policies that affect woodburning. (http://www.woodheat.org)
The Association des Professionnels du Chauffage (APC) was founded in 1983 for industry professionals who manufacture, sell, install, and service hearth products in Quebec. APC is a non-profit organization affiliated with the HPBAC. It acts as a general and specialized information and training center. (http://www.poelesfoyers.ca)
Wood Energy Technical Training Incorporated (WETT) is a non-profit training and education association managed by a volunteer board of directors elected by holders of valid WETT certificates. Through its administrative designate, WETT Inc. functions as the national registrar of the WETT program. Through professional training and public education, WETT Inc. promotes the safe and effective use of wood burning systems in Canada. The WETT system consists of several courses recognizing the various types of work done by wood energy professionals. Certification is achieved by completing courses to earn educational credits. A technical reference manual has been prepared to assist trainees in preparing for courses and as a reference manual for certificate holders. WETT has 1600 members across Canada, 1300 of which are certified WETT installation or inspection technicians. (http://www.wettinc.ca/wettweb/contentshell.html)
Manufacturers
Table 4 lists the 29 major manufacturers of solid fuel burning heating products in Canada, as reported by Statistics Canada in December 20007. These manufacturers account for approximately 80% of the total value of shipments of these products. Of the 29 manufacturers, 8 are listed as members in the 2000 HPAC Directory.
Table 4: List of Reporting Manufacturers, December 2000[7]
|
Name |
Products |
|
Nova
Scotia |
|
|
Acadian Woodstoves Inc. |
Heating stoves (circulating, pellet) |
|
Newmac Manufacturing Inc. |
Heating stoves (circulating, other), heating stoves (radiant), furnaces (wood or coal), add-on furnaces, combination furnaces (solid fuel with oil or gas) |
|
Parrsboro Metal Fabricators Ltd. |
Furnaces (wood or coal), add-on furnaces, residential boilers |
|
New
Brunswick |
|
|
Enterprise Fawcett |
Heating stoves (circulating, other), heating stoves (radiant), cooking stoves, furnaces (wood or coal), add-on furnaces |
|
NY Thermal Corp. |
Furnaces (wood or coal) |
|
Quebec |
|
|
Compagnie de
Cheminée Industrie Inc. |
Pre-fabricated fireplaces |
|
Cheminées
Sécurité International Ltée. |
Heating stoves (circulating, pellet), pre-fabricated fireplaces |
|
Drolet Poêles
et Foyers Inc. |
Heating stoves (circulating, other) |
|
Foyers Supreme
Inc. |
Pre-fabricated fireplaces, fireplace inserts |
|
J.A. Ruby Inc. |
Heating stoves (radiant), combination furnaces (solid fuel with oil or gas) |
|
P.S.G. Distribution Inc. |
Heating stoves (circulating, pellet and other), heating stoves (radiant), pre-fabricated fireplaces, furnaces (wood or coal), add-on furnaces, combination furnaces (solid fuel with oil/gas and electricity) |
|
Produits
D'Acier Nordic |
Heating stoves (circulating, other), steel liners for masonry fireplaces, pre-fabricated fireplaces, fireplace inserts |
|
Thermo 2000 Inc. |
Furnaces (wood or coal), residential boilers |
|
Valcourt & Frère |
Pre-fabricated fireplaces |
|
Ontario |
|
|
Anvil Fireside Accessories Ltd. |
Steel liners for masonry fireplaces |
|
Atlantic Pool Inc. |
Heating stoves (radiant) |
|
Decaro Manufacturing Ltd. |
Heating stoves (circulating, pellet), pre-fabricated fireplaces |
|
Heartland Appliances Inc. |
Cooking stoves |
|
Heritage Energy Systems Inc. |
Heating stoves (circulating, other), fireplace inserts |
|
Ka-Heat
kachelopen Ltd. |
Heating stoves (circulating, other) |
|
Selkirk
Metalbestos Inc. |
Fireplace inserts |
|
Wolf Steel Ltd. |
Heating stoves (radiant), pre-fabricated fireplaces, fireplace inserts |
|
Manitoba |
|
|
Falcon Machinery (1965) Ltd. |
Combination furnaces (solid fuel with electricity) |
|
British
Columbia |
|
|
Archguard Industries Ltd. |
Steel liners for masonry fireplaces, pre-fabricated fireplaces, fireplace inserts |
|
FPI Fireplace Products Intl. Ltd. |
Pre-fabricated fireplaces, fireplace inserts |
|
Northern Fireplace Ltd. |
Steel liners for masonry fireplaces |
|
Osburn Manufacturing Inc. |
Heating stoves (radiant), fireplace inserts |
|
Pacific Energy Fireplace Products Ltd. |
Heating stoves (radiant), fireplace inserts |
|
Valley Comfort Systems Inc. |
Heating stoves (circulating, other), heating stoves (radiant), add-on furnaces |
ANNEX 3: BENEFITS OF CERTIFIED STOVES
Emissions Comparison
Table 5 presents the emission factors for the criteria air contaminants for different categories of wood burning appliances.
Table 5: Criteria Air Contaminant Emission Factors for Residential Wood Combustion (kg/tonne of dry fuel)[8]
|
Appliance |
TPM |
PM10 |
PM2.5 |
SOx |
NOx |
VOC |
CO |
Notes |
|
Conventional
Fireplaces |
|
|
|
|
|
|
|
|
|
· Without glass doors |
19.3 |
18.5 |
18.4 |
0.2 |
1.4 |
6.5 |
77.7 |
1 |
|
· With glass doors |
13.5 |
13.0 |
12.9 |
0.2 |
1.4 |
21.0 |
98.6 |
1 |
|
Fireplaces
with Inserts |
|
|
|
|
|
|
|
|
|
· Conventional |
14.4 |
13.6 |
13.6 |
0.2 |
1.4 |
21.3 |
115.4 |
2 |
|
· Advanced Technology |
5.1 |
4.8 |
4.8 |
0.2 |
1.4 |
7.0 |
70.4 |
2 |
|
Advanced
Tech. Fireplaces |
5.1 |
4.8 |
4.8 |
0.2 |
1.4 |
7.0 |
70.4 |
3 |
|
Conventional
wood burning stoves |
|
|
|
|
|
|
|
|
|
· Not air-tight |
24.6 |
23.2 |
23.2 |
0.2 |
1.4 |
35.5 |
100 |
4 |
|
· Air-tight |
14.4 |
13.6 |
13.6 |
0.2 |
1.4 |
21.3 |
115.4 |
4 |
|
Advanced
technology wood burning stoves |
5.1 |
4.8 |
4.8 |
0.2 |
1.4 |
7.0 |
70.4 |
4 |
|
Central furnaces/boilers |
14.1 |
13.3 |
13.3 |
0.2 |
1.4 |
21.3 |
68.5 |
5 |
|
Pellet
stoves |
1.2 |
1.1 |
1.1 |
0.2 |
1.4 |
1.5 |
8.8 |
6 |
|
Other
equipment |
14.4 |
13.6 |
13.6 |
0.2 |
1.4 |
21.3 |
115.4 |
4, 5 |
Notes.
1. Assistance in the identification and review of documents and recommendations for the development of emission factors was provided by Dr. James E. Houck, Vice President of Research, OMNI Environmental Services Inc., Beaverton, Oregon.
2. The emission factors for conventional fireplaces with and without doors were developed from an analysis of a large number of studies, since no single definitive study exists. There is no widely recognized test protocol for conventional fireplaces, so different fuels, load configurations and test procedures are used in various studies. As a result, each of the studies analyzed provides only emission results under specific conditions, and may only provide context for findings from other studies.
3. Emission factors for fireplace inserts are the same as for the corresponding free standing wood stoves. See note 5 below for discussion of data used in the development of these emission factors.
4. Advanced technology fireplaces may be treated the same as advanced wood stoves since they meet the same emission standard and their emission control technologies are similar. See note 5 below.
5. Emission factors for conventional and advanced wood stoves, fireplace inserts and advanced fireplaces were developed from an analysis of a large number of studies. Although different emission factors are sometimes reported in the literature, the emissions for catalytic and non-catalytic advanced wood stoves are combined in a single average factor to reflect the long-term performance profiles of these two emission reduction technologies. Correcting to account for differences in test methods and adjusting for higher burn rates recorded during field testing, the particulate matter emission factor for new catalytic stoves would be 3.2 g/kg of fuel burned and for non-catalytic stoves the factor is 5.1 g/kg. Therefore, to avoid the potential for distortion of total emissions for the entire population of advanced stoves, and to account for the fact that the majority of advanced stoves used in Canada are of the non-catalytic type, the single emission factor for non-catalytic stoves is used.
6. The emission factors for central furnaces and boilers were based on the analysis of the few available studies. One of the referenced studies reported on testing of two outdoor boilers. Therefore, the emissions performance of these systems is reflected in the average emission factors for central furnaces and boilers.
7. The emission factors for pellet stoves were developed from the analysis of several studies.. However, because of the relatively small number of pellet stoves in use in Canada and because the surveys used did not specifically ask respondents if their appliances burned pellets, it was not possible to develop a useful estimate of the number of pellet stoves in use. The emission factors are provided here for information only and may be useful in the future if a better estimate of the number of pellet stoves in use is developed.
A joint study, conducted by Environment Canada and the HPAC in December 2000, compared the releases from a conventional wood stove and a US EPA certified (non-catalytic, advanced technology) wood stove for a number of pollutants5. The study found that releases of PM, VOCs and PAHs from the certified stove were significantly less than those from the conventional stove. The emissions of dioxins and furans were not conclusive--more research is required to better determine how dioxins and furans are formed in residential wood-burning equipment. On average, releases of substances from the certified stove compared to those from the conventional stove are:
· 94% less for PM;
· 80% less for VOCs; and
· 85% less for PAHs.
Energy Efficiency
Certified wood stoves are also more energy efficient than conventional wood stoves. Table 6 presents the different levels of efficiency measured according to studies by the US EPA.
Table 6: Net efficiency of various wood heating appliances
|
Type of wood stove |
Net
efficiency (%) US
EPA[9] |
|
Wood stoves conventional non-catalytic |
54 68 |
|
Pellet stoves certified non-certified |
57.6 to 75.2 33.4 to 70.5 |
|
Masonry heaters |
54 to 65 |
Note: Net
efficiency rests on combustion efficiency and heat transfer efficiency.
Price Comparison
Prices vary by retailer, but generally, costs for a certified stove range from $500 to $700 more than a conventional wood stove.
ANNEX 4: Existing Management Programs
Canada
Federal Government
There are no federal regulations of an environmental nature to limit the emissions or the type of wood stoves sold, imported, or manufactured in Canada.
Atlantic Provinces (New Brunswick, Nova Scotia, Newfoundland, Prince Edward Island)
There are no regulations specifically targeting the emissions or the type of wood stoves sold or manufactured in Atlantic Canada. Ambient air sampling programs were conducted during the eighties in Nova Scotia and New Brunswick. As a general rule, regulatory authorities in the Atlantic provinces act on a case basis only when a complaint has been filed. An air pollution regulation in Newfoundland specifically excludes emissions stemming from residential heating. Likewise, Nova Scotia farms and homes are exempted from provincial regulations on air pollution.
Campaigns aimed at educating the public and encouraging the population to replace stoves with high-efficiency models were conducted in Nova Scotia and New Brunswick in the fall of 1997.
Quebec
Quebec has no regulations restricting the emissions or the type of wood stoves sold or manufactured. Several studies on ambient air quality have been conducted (Rivières-des-Prairies, Sept-Iles, etc.), while a number of awareness campaigns (fact sheets) have been conducted since the end of the eighties. In 2001-2002, l’Association Lanaudière pour l’Air Pur, a non profit organization, conducted a successful change-out program and education campaign in Lanaudière. They conducted several education workshops. In association with a hearth retailer, Environment Canada, and the fire department, Quebec conducted a change-out program where a $200 refund on a new certified wood stove was given to the buyer.
A meteorological alert program in the event of temperature inversion was implemented in Sept-Iles in 1993. Messages urging the restriction of wood heating were transmitted to evening television news programs when inversion conditions occurred. A winter program for predicting unfavorable air dispersion conditions, referred to as winter ventilation, enforced in Montreal since December 2000, hopes to achieve the same goal. When unfavorable conditions of dispersion into the atmosphere occur, messages are broadcast to encourage the population to restrict their use of fireplaces, wood stoves, and snowblowers, and to use the mass transport system rather than their automobiles.
The Département de santé publique de Montréal-Centre (DSP), along with Environment Canada and the Montreal Urban Community, conducted a survey in 1999 on wood heating in the Montreal area They also conducted a pilot project on the impact of wood burning on population exposure to emitted pollutants. Indoor and outdoor air samples were analyzed for PAHs, aldehydes, PM2.5, total particulates, and others such as potassium, iron, and carbon monoxide. Urine samples were also analyzed for various PAH metabolites. The study indicated that a wood heated residence has more indoor air contaminants than outdoor air.
Article 5.65 of the Montreal Urban Community’s regulation 90-4 prohibits burning treated wood residues or other residual matter, with the exception of virgin wood, in residential combustion appliances. Several municipalities have similar regulations.
With respect to the use of outdoor stoves and fireplaces, article 20 of the Quebec's Environment Quality Act allows for intervention when pollution is observed resulting from outdoor burning.
Ontario
Ontario does not have any regulations restricting the emissions or the type of wood stoves sold or manufactured. Since the eighties, several public awareness initiatives in the area of wood heating pollution were implemented. Between January and March 1999, the province conducted a pilot program for the replacement of wood stoves (Greater Eastern Ontario Wood Change-Out Program). This program, conducted in partnership with manufacturers, sales outlets, Environment Canada, Environment Ontario, and other community bodies, targeted areas in Eastern Ontario (Cornwall, Kingston, Ottawa, etc.). Up to $400 was granted for each old stove, to be used as credit for the purchase of a certified appliance.
Between February and April 2001, the Great Woodstove Change-out and Education Program in the Georgian Bay Watershed was carried out. The program's goal was to improve air quality by encouraging greater public awareness of cleaner and safer wood burning practices and the availability of the new cleaner-burning appliances. The program was supported by the province, the federal government, HPBAC, and individual manufacturers and retailers. A series of 12 public evening workshops were conducted around Georgian Bay from Sault Ste. Marie to Owen Sound, with attendance of over 1000 people. Eighty-five woodstove appliances were changed-out during the course of the program.
Prairie Provinces (Alberta, Saskatchewan, Manitoba)
These provinces do not have any regulations restricting the emissions or the type of wood stoves sold or manufactured. The regulatory authorities act on a case basis only when a complaint has been filed. The number of complaints appears to be higher in Manitoba.
British Columbia
British Columbia has a regulation prohibiting the sale or manufacture of wood heating appliances that do not comply with the CSA or US EPA standards. However, the regulation could be circumvented by consumers who choose to purchase a non-certified appliance from another province, and use it in British Columbia. A copy of the regulation is included in the accompanying documents.
British Columbia has conducted several ambient air studies since 1990. In the Cranbrook area, a volunteer program not only samples ambient air, but also provides alerts in the event of unfavorable weather (newspapers, radio and television), along with a telephone information service.
A change-out program aimed at the replacement of non-certified wood stoves in support of legislation on air quality enhancement in British Columbia was implemented in the spring of 1995. A total of 213 old stoves were replaced by new technology wood, gas, and pellet stoves. The change-out was spread almost equally between gas and wood stoves plus two pellet stoves. A rebate of $50 to $200 was given to the customer depending on the technology chosen. The retailer also took care of the old stove, dismantling it and recycling the metal.
United States
United States Environmental Protection Agency
In 1988, the US EPA adopted a regulation setting out the performance standards for new residential wood heating equipment. A copy of this regulation, revised in 1995, is included in the accompanying documents.
The major elements of this regulation are summarized as follows:
· the regulation applies to appliances manufactured after July 1, 1988, and sold after July 1, 1990;
· the regulation does not apply to open masonry fireplaces built on the site itself;
· the regulation applies to fireplaces and wood stoves, and does not apply to open fireplaces, boilers, furnaces and cooking stoves;
· the standards are verified following a certification program and tested in a laboratory;
· certification is valid for 5 years and may be renewed; and
· the emissions limit for particles is 4.1 g/h for catalytic appliances, and 7.5 g/h for non-catalytic appliances.
Fireplaces and masonry ovens are not included in the standards, but the US EPA has developed procedures for testing these on site.
Oregon
The state of Oregon has its own certification program for new wood stoves. Given air quality problems caused largely by PM10, certain areas have adopted specific programs. Thus, as a general rule, in periods during which the air quality is good (green code), wood heating is permitted. In periods during which the air quality is moderate (yellow code), only the use of certified wood stoves is allowed. Lastly, in periods during which the air quality is bad (red code), the use of any type of wood stove is prohibited. The city of Bend has a by-law requiring the removal or replacement of old wood stoves when a house is sold. A program has also been implemented to ensure the replacement of old wood stoves with certified models.
Colorado
In addition to having adopted a regulation respecting the certification of wood stoves, the state of Colorado has implemented various initiatives when local issues warrant it. Among these are a ban on using wood stoves under certain conditions, a ban on wood heating on given days, the replacement of non-certified wood stoves with certified models, etc.
Washington
The state of Washington has adopted the US EPA standards and the Oregon certification program as an integral part of its own regulation. The regulation prohibits advertising, selling, exchanging or donating non-certified wood stoves.
In 1993, particle limitations more stringent than that of the US EPA were adopted. Thus, since January 1, 1995, the limit in terms of particle emissions is 2.5 g/h in the case of catalytic appliances and 4.5 g/h in the case of non-catalytic appliances. Since January 1997, all fireplaces except masonry fireplaces must meet the US EPA standards for wood stoves.
Local authorities and the state of Washington may prohibit the use of wood stoves if certain air pollution levels are reached. Two banning phases are possible. During the first phase, the use of non-certified fireplaces and wood stoves, as well as the use of fireplace inserts, is prohibited. During the second phase, it is prohibited to use any wood heating appliance.
Alaska
The state of Alaska legislates smoke from wood combustion in fireplaces and wood stoves on the basis of a 50% opaqueness standard. It also prohibits their use during alerts (Juneau Valley).
Michigan
In the Spring of 2000, the environmental department of the state of Michigan, in association with the US EPA and the Hearth Products Association, launched a pilot project aimed at replacing wood stoves. Sellers offer a discount on the purchase of a new wood stove in exchange for old wood stoves to be recycled. Following an agreement, this pilot project is expected to be extended to the states bordering the Great Lake and to Ontario.
New England States
Like most of the United States, the states of Maine, Connecticut, Vermont and New York apply the US EPA regulation respecting new wood stoves.
Europe
Basic research has been undertaken to observe the situation in Northern Europe regarding the control of air pollution stemming from residential wood combustion. The goal was to determine whether or not the approach adopted in the United States for controlling the quality of the appliances sold as a means of controlling all related emissions of contaminants could also be implemented in Europe.
This research targeted Scandinavian countries. Some information was also obtained regarding Iceland, Switzerland and the European Common Market.
Scandinavian Countries
As is the case in the majority of developed countries, Denmark, Sweden, Iceland, Finland, and Norway have a certification mechanism for manufactured products establishing their compliance with existing manufacturing standards in each country. There is also a "Northern" certification for the five countries.
With respect to fireplaces and wood stoves, Norway enforces specific regulations restricting the emissions of wood combustion appliances. This regulation is the Norwegian standard NS 3059, which limits maximum PM emissions to 10 g/kg (catalytic models) or 20 g/kg (non-catalytic models), while limiting average emissions to 5 g/kg (catalytic models) or 10 g/kg (non-catalytic models). A specific protocol allows the calculation of emissions in kg/hr on the basis of two categories of appliances according to their possible combustion rates, thereby allowing to compare with the environmental certification standards of the US EPA.
Sweden has a "P" certification approach which was developed for various products such as pellet stoves, solar panels, heat exchangers, etc. Sweden’s national research and certification institute is currently developing a "P" certification for boilers and wood stoves. Certification for combustion appliances includes safety, emission, reliability and efficiency testing. Requirements for "P" certification are more stringent than the national requirements. There is currently a "P" certification for pellet stoves. It underlines that organic carbon emissions must be less than 100 mg/m3 of dry gas at 10% of oxygen, while carbon monoxide emissions must be less than 3000 mg/m3 of dry gas at 10% of oxygen. In addition, efficiency must be at least 75%.
Moreover, a "Cygne" certification label is currently being developed for Scandinavia for combustion appliances that use biofuels. Consultations are ongoing in the framework of the "Cygne" and "Northern" certifications regarding residential boilers using biofuels. Criteria are being developed for biofuel stoves.
Other Countries
Switzerland has a seal of quality for wood combustion appliances. This seal is managed by the Association suisse pour l’énergie du bois (Schweizerischen Vereinigung für Holzenergie). The certification approach is described in a document entitled "Schweizer Qualitätssiegel für Holz-Feuerstätten im Wohnbereich –Reglement für die Zertifizierung" and is based on European, German, Austrian, and Swiss testing standards. It sets efficiency rates and concentration limits for carbon monoxide and particles until 2003, and others beginning in 2004.
A draft mandate of the European Commission was adopted on February 8, 2000, in Brussels, during a meeting on solid fuels of the European Committee for Standardization. This mandate solely concerns the work on clean biofuels and excludes waste (contaminated treated wood) and peat. A work group has determined the sphere of activity and the work program of the future technical committee. Five themes were retained: terminology, definitions and descriptions; specifications, classification and quality control of combustible; sampling and sample reduction; physical and mechanical testing; and chemical testing. For these themes, twenty-four work issues have already been identified.
In France, a standardization commission was created at the beginning of 2000. Steps are currently being taken to determine whether or not the work committee will address the issue of certification for fireplaces and wood stoves, or if this issue will eventually be handed over to another committee.
One may expect, once the "Cygne" certification is completed in the Scandinavian countries, which should be in the short term, that member countries of the European Commission will also complete a certification for wood stoves and other appliances. This certification would take the shape of an Ecolabel applicable on a European scale for heating appliances using biofuels.
In addition, the Global Ecolabelling Network addresses ongoing efforts in North-European countries involving heating systems that use solid biofuels.
ANNEX 5: TOOLS NOT FEASIBLE AS A NATIONAL Regulation
The following are the options that were assessed and deemed inappropriate to meet the objectives of a national regulation.
CEPA Tools
Regulation
The most obvious option – a regulation under CEPA 1999 – is not feasible at this time. It has been determined that CEPA 1999 does not provide the authority to regulate the manufacture, import, or sale of residential wood stoves because they are not "substances" that are toxic, nor do they contain or release a toxic substance at the time of manufacture, import, or sale. Therefore, it is not possible to use the regulation-making powers under Section 93 of CEPA 1999 to control their manufacture, import, or sale.
Since wood stoves can be sources of a toxic substance (PM10) when wood is burned, Section 93 of CEPA 1999 can be used to regulate the release of PM10 from individual wood stoves by referencing the CSA standard. However, this would mean that the regulation would target users of wood stoves. Regulating users of these residential appliances would be impractical, and the resulting regulation would be extremely difficult and costly for Environment Canada to enforce.
Although it is expected that the ability to regulate the manufacture, import and sale of such products will be addressed when the review of CEPA 1999 is initiated in 2005, there is a commitment to complete the Joint Initial Actions for the CWSs by 2005.
Environmental Quality Guidelines
Environment Canada could issue a guideline adopting the CSA standard. However, as a stand-alone tool this option is ineffective as it relies on voluntary adoption, which is unlikely to be effective in ensuring a level playing field.
Economic Instruments
The only economic instruments provided for under CEPA 1999 are deposit-refund systems in s.325 and tradeable unit systems (such as tradeable emission permits) under s.326. Each must be tied to a regulation. Deposit-refund systems and tradeable unit systems can be enacted in conjunction with regulations made under s.93; however, since it has already been determined that a regulation under s.93 of CEPA 1999 would not be a feasible option for residential wood stoves, an economic instrument under CEPA 1999 is not useable in this case.
Pollution Prevention Plans
Part 4 of CEPA 1999 provides the authority to require pollution prevention plans. These could be requested of manufacturers, sellers, and importers for the phase-out of wood burning appliances that do not meet the CSA standard. Since there is no ability to enforce compliance with pollution prevention plans, this option would not ensure a level playing field.
Federal Energy Efficiency Act
The Energy Efficiency Act can be used to regulate international and inter-provincial trade and prohibits the leasing, shipping, or importing of an energy-using product into Canada unless it complies with the prescribed energy efficiency standard. While wood stoves can be considered to be a product designed to operate using a form or source of energy, the intent of the regulation would be to control the release of PM10 into the atmosphere, not as an energy efficiency standard and thus, does not fall under the authority of the Act.
Provincial/Territorial Regulations
In Canada, only British Columbia has a provincial regulation prohibiting the sale or manufacture of wood heating appliances that do not comply with the CSA standard or the US EPA standard. In the absence of a national regulation, a template for a regulation could be developed for subsequent adoption by provinces and territories; however, it would require 15 jurisdictions to undertake lengthy regulatory processes.
Furthermore, not all provinces have the legislative authority to enact regulations to control the sale, manufacture and import of a product; therefore, national coverage would not be provided using this approach. The following provinces are able to regulate:
· British Columbia;
· Quebec;
· New Brunswick;
· Nova Scotia; and
· Prince Edward Island.
Municipal By-laws
In the absence of a national regulation, a template for a by-law could be developed, for subsequent adoption by municipalities. It is obvious however, that this option would apply to users of wood stoves, not importers, manufacturers, or sellers and would not ensure a level-playing field across Canada.
Voluntary Agreements
The use of voluntary approaches as a cost-effective alternative to regulation has been emphasized in government policy and accepted by most government regulators as one of the tools to be considered when examining the most appropriate approach to achieving policy objectives. However, they are not appropriate under all circumstances. It has been found that they are most effective when there is a potential regulatory backstop and where the industry is readily identifiable.
Given the extent of the wood stove industry, it is not likely that a voluntary approach would meet the objectives of creating a level-playing field. Voluntary agreements would need to be made with industry associations or manufacturers, since it is not feasible to reach agreements with the hundreds of retailers or importers of wood stoves across Canada. As the associations are professional in nature there is no mechanism to ensure compliance by individual members. Furthermore, not all major manufacturers are members of these associations (of the 29 major manufacturers listed, only eight are members of HPAC). It is also not likely that agreements could be reached individually with all manufacturers (29 major manufacturers of solid fuel burning heating products in Canada account for approximately 80% of the total value of shipments of these products). There are no data on the numbers of smaller manufacturers. It is for these reasons that the residential wood stove industry has lobbied for the development of a national regulation.