Residential Wood Combustion Consultation

Response of the Wood Heat Organization Inc. to the pre-consultation questionnaire
September 16, 2002

Background

The Wood Heat Organization (WHO) was formed 1999 to support the public in the responsible use of wood energy in the home. Its volunteer-supported work predated its federal non-profit incorporation in the form of a web site put on line in 1996. WHO fulfills its mandate by providing reliable information, by conducting research into wood heating-related issues and by working to articulate the public interest in discussions of policies that affect woodburning.

At present WHO cannot claim the views it expresses are representative of the Canadian public's because it lacks the resources to sponsor regular survey research on the subject and has been unable to attract as members a substantial number of wood burners. We have concluded that our failure to become a truly representative organization is due to the reticence of wood burners to be public actors in relation to this private, personal and family-scale activity – it is clear that wood burners are not joiners.

However, we do track all research related to the use and attitudes towards wood burning, respond to about two thousand email requests for non-commercial information each year and host an active email discussion group on the subject. As such, we are confident that WHO is in a better position than other organizations to gain insights into the thinking, objectives and sensitivities of people who heat their houses with wood. We do our best to articulate those insights.

Wood is by far the most economical and accessible of all renewable energy resources to Canadians. Our view is that wood heating has value beyond the displacement of fossil fuels and reduction of greenhouse gas emissions. It is practiced on a small scale, the fuel is derived usually from a local resource and the practitioners get a better understanding of the causes and effects of their environmental impacts than users of other energy sources. As many environmentalists have suggested, these are some of the very features needed for environmental sustainability. Canadians who heat their homes with wood responsibly should be recognized for their contribution to reducing greenhouse gas emissions and a sustainable energy future.

Before responding to the questionnaire, we wish to put on the record the general position we take on the main issue at hand. WHO supports an initiative to regulate the emissions from residential wood burning equipment at the manufacturing/sales stage.

Two paragraphs from the WHO mission statement summarize the general approach we promote to the visitors to our web site at www.woodheat.org:

1. WHO recognizes wood as an effective renewable energy source for household heating and cooking when sustainable forestry methods are used for fuel supply and when the fuel is burned using appropriate technologies and techniques.
2. WHO recognizes that wood is most sustainably and economically used as an energy source at the urban fringe and beyond, and that one household’s wood burning activities can be considered appropriate only if they do not interfere with another household’s enjoyment of their home and property.

We know from the experience of the US EPA regulation that this form of regulation is the necessary catalyst for technology development that serves the interests of those who use wood burning equipment. That is, the technologies that have produced a roughly 90 percent reduction in particulate emissions and a 30 percent increase in net efficiency were developed and commercialized as a direct consequence of EPA's regulation. Proof that the regulation was responsible is the fact that within the categories of wood burning appliance exempt from the EPA regulation – central furnaces and boilers, cooking ranges and conventional fireplaces – there has been little technological development in decades. The same type of high emission, low efficiency appliances in these categories that were state of the art thirty years ago are still sold today. Advanced technology options in these categories are not generally available.

The advanced technology stoves, fireplaces and fireplace inserts that meet EPA's regulation are easier to use, safer and save time and money on fuel each heating season. Our view, with some reservations, is that the numerous advantages of advanced equipment justify regulatory intervention and the higher initial cost of the appliance.

Response to the Questionnaire

1. Are there any other issues or options that you would like to see addressed during the consultation workshop?

This first stakeholder consultation meeting should endeavour to define the key issues that will animate the subsequent discussions. It is likely that some issues will be dealt with easily and quickly, while others will become the core issues for research, debate and the need for consensus-building.

·        Rural, remote and first nations impacts  At present it is generally accurate to say that members of remote First Nations communities do not select advanced, EPA certified appliances, preferring instead conventional stoves purchased through building supply outlets that are usually hundreds and in some cases a thousand or more kilometres distant. This preference is probably based on a number of practical considerations such as initial cost, shipping weight, firebox size, general configuration, size of cooking surface, durability, access to repair parts and so on. Once a regulation is enforced, will market forces alone produce products that can meet the special needs of rural, remote and First Nations communities? Some analysis of this important issue is warranted.

·        Previously unregulated appliance categories  The emissions standard CSA B415 which would form the technical basis of the regulation does not cover decorative and site-built fireplaces with a minimum burn rate in excess of 5 kg/h. It does, however, apply to cook stoves and central furnaces and boilers, appliance categories not covered by the EPA regulations. As indicated, the EPA exemption for these categories has resulted in an almost complete stagnation in technological innovation. If the Canadian regulation does not include exemptions for these categories, will Canadians have access to wood-fired cook stoves and furnace/boilers that can meet their needs? To be clear, WHO supports regulating these categories, but we think some discussion is needed around timing and economic impacts.

·        The public reaction  There is reason to suspect a strongly negative public perception of this regulatory initiative, particularly if it is introduced in what is perceived as a patronizing or heavy-handed manner.  To illustrate the potential problem, here is a brief excerpt from an NRCan consultant's report Wood Burning Focus Groups, A Draft Report to Wood Burning Steering Committee, January 31, 2001

Focus group participants were asked to provide their reaction to the following statement, attributed to the Canadian Lung Association:

Breathing wood smoke emissions is like breathing in second-hand cigarette smoke. Wood smoke pollutants can be very harmful to the development of young children’s lungs.

A number of participants said they did not believe this statement, particularly the English-speaking groups.  They said, “Prove it to me.”  This statement was read to participants after a short break in the focus group.  While the first part of the groups were congenial, after this statement was read, the tone of the group was more hostile.

Obviously the quoted statement is entirely accurate and quite bland, yet it elicited strongly negative responses from focus group participants. The reaction of average Canadian wood burners hints at the underlying sensitivities surrounding this most personal of home heating options. To expect Canadians to accept the government's word that their wood stoves, which they depend upon and many will claim they love, should be defined as hazardous products, is to invite a negative backlash. The entire matter of public acceptance requires more investigation and consideration, as is suggested by the findings of the quoted research commissioned by NRCan.

·        Fireplaces could remain unregulated  In the Options Paper one of the key questions asked is whether there is a need to develop an emissions regulation for fireplaces. We note that a little more than twenty percent of the firewood consumed each year is burned in fireplaces. Not only is this wood largely wasted from an energy efficiency point of view considering the very low efficiency of conventional fireplaces, but these units tend to put out high emission levels. More importantly, these fireplaces are overwhelmingly used in urban settings where population density is high, so more people are likely to be exposed to fireplace emissions than to those from wood stoves. This raises a key question for the stakeholders participating in this consultation: If fireplaces were not regulated, would this initiative imply a policy bias against rural Canadians? Clearly, this is a thorny question and one that should be considered carefully. We don't see sufficient time given in the agenda for questions as difficult as this one.

·        Unintended consequences  While the U.S. experience in regulating wood burning system emissions is useful in providing insights into the likely impacts of such a regulation, this is a different country, with different climate zones and different population distribution characteristics. To avoid the problem of unintended consequences, some consideration of potential impacts different from those experienced in the U.S. should be undertaken.

2. What changes, if any, would you make to the draft agenda to ensure that there is an adequate focus on issues of concern to you?

We have a number of concerns, not just with the agenda, but with the process for this consultation.

·        Is this meeting the only opportunity for consultation? The following excerpt from the Options Paper implies that this 11.5 hour meeting over two days will be the only opportunity for stakeholder consultation.

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.

While there has been a vague suggestion in an email exchange that further consultation opportunities are possible, we cannot plan our participation until the entire process is clarified.

·        Meaningful consultation requires stakeholder engagement  Effective consultation requires that a representative group of stakeholders be engaged well in advance to help design the process itself. When we received in January 2002 the invitation to participate in this consultation, we understood that participation could include collaborating with other stakeholders to develop an effective consultation process. We received this understanding from the following paragraph that appeared on the application form.

The Annex to the [CCME] Accord on Environmental Harmonization states that "Those who have an interest in an issue should be given the opportunity to identify themselves and to participate in the process, including the development of the stakeholder participation process itself."

We had high hopes that a regulatory initiative on RWC emissions could be completed in a collegial environment without major conflicts between governments and non-governmental stakeholders, particularly considering that some of the key stakeholders appear to be generally supportive. However, that does not mean that we assumed this initiative could go forward without serious consideration of the issues, costs and other consequences. We have been asking that some form of consultation be initiated for several years, since before the ministers announced the Joint Initial Actions and the Inter-Governmental Working Group on Residential Wood Combustion was formed in 1999. Our concern about the looming deadline of 2005 has increased with each passing month without communication from the Working Group or EC/CCME about when it would begin consultation and how it would be conducted. Initially we were told that there was nothing to consult about, then that there was no budget for consultation, then the file was moved from the Ottawa to the Montreal office of EC, which meant an entirely new group of people with whom to collaborate. It is with much disappointment that we now find the consultation appears to be compromised by a process that, as currently defined, is consultation in name only, preventing stakeholders from taking any meaningful part.

·        The CCME has established an effective consultation model  We have clear ideas on what an effective consultation process should look like and have experience as stakeholders in such a process. The CCME has established a good model for effective stakeholder consultation. Our organization participated on the Core Advisory Group (CAG) for the Dioxins and Furans Canada Wide Standards consultations. Our tasks were to work with the process organizers and other interested stakeholders to review and comment on discussion documents, to agree on effective meeting agendas, to ensure that all stakeholders had the opportunity to state their initial views on the matter of the d&f CWS, to ensure that key issues for discussion and resolution were properly defined and that sufficient time was available to build a consensus on a way forward. Despite some differences in view, the d&f consultation process was conducted in a collegial, respectful way and when it was completed it was apparent that all stakeholders agreed that they had been heard and their views had been taken into consideration. The process extended over a two year period and consisted of three two-day national stakeholder meetings and numerous CAG meetings. We wish the same process and the same outcome for the consultations on the establishment of an emissions regulation for RWC. In fact, an effective consultation process is all the more important for this file because the issues are far more complex than those confronting the d&f CWS process in that the wood burning emissions regulation will directly affect Canadian families in their private affairs and in their bank accounts.

·        The agenda is too crowded  The agenda attempts to cover more content than is reasonable considering the time offered. The core issue that will affect Canadians is the establishment of the regulation and it is only given about two hours of the agenda. The regulation should be the sole focus of consultation until the governments and stakeholders have explored the issues and implications and, ideally, have reached a consensus on a path forward. Discussions of public information and appliance changeout projects should be set aside until consultations on the regulation are completed.

·        The wood stove as a hazardous product  It is reported in the Options Paper that CEPA contains some wording that prevents is use in regulating a product that does not emit a toxic substance directly, but does so only when used. The fact that CEPA is not due for review until after the ministerial deadline of 2005 for a wood heat regulation, has resulted in the recommendation that wood burning appliance emissions be regulated under Environment Canada's Hazardous Products Act. This approach sends an unfortunate message to the public. The Options Paper contains the following paragraph.

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. [emphasis quoted accurately]

However, the agenda does not include a specific item and time frame in which to discuss this preferred approach. Given that RWC had been identified as an important source of air pollution in Canada and discussions of an emission regulation had occurred long before CEPA was proclaimed in 1999, the fact that the wording of CEPA was not adjusted in anticipation looks on the surface to be the result of bureaucratic error. And further, the selection of the Hazardous Products Act as an alternative to provide the necessary authority looks on the surface to be one of simple expediency. The absence of this specific issue by name in the agenda suggests, perhaps inadvertently, that regulation under the Hazardous Products Act is not really up for discussion or review. The option of requesting an emergency amendment to CEPA or some other option would appear to be a valid subject for serious discussion at the stakeholder meeting.

3. What additional background information do you require?

The package of information distributed to stakeholders on August 14 contains only a limited amount of useful information.

The package contained a copy of the U.S. EPA regulation of 1988 but, curiously, did not contain a copy of CSA B415-2000 which would form the technical basis for the Canadian regulation. Also, it contained a copy of Health Canada's Hazardous Products Act, but notably omitted a copy of Environment Canada's CEPA so stakeholders could see for themselves the wording that prevents its use. Both of these omissions should be corrected.

To understand the impact of this regulation on the public, it would be useful to know if  wood burning appliance manufacturers will be able to respond to specialized product needs, such as large, durable stoves for the North, cooking ranges, and central furnaces and boilers for large spaces and multiple buildings. There is much information needed from the stakeholders themselves to enable the other stakeholders to fully understand the issues and participate effectively. Perhaps the other stakeholders have had insufficient time to react in writing.

The NRCan report Wood Burning Focus Groups, A Draft Report to Wood Burning Steering Committee, January 31, 2001 should be distributed to help stakeholders who are not specialists in the wood energy field to better understand how Canadians view their use of wood as a heating fuel.

It would also be useful for the Working Group to communicate with the stakeholders by email, reserving the use of surface mail for those without access. The use of email for all communications is the standard in CCME consultation processes and would be useful in this case to enhance the speed and effectiveness of information transfer. This is particularly true considering the limited time before the meeting.

4. Are there any developments or other relevant news that should be shared with workshop participants?

To fully appreciate the potential impacts of this regulation, both positive and negative, the stakeholders need an economic and social analysis of wood burning's place in Canadian society. To give one superficial indication of what such an analysis might reveal we have done a quick calculation of one aspect of economic impact.

From Environment Canada's 1995 Criteria Air Contaminants Emissions Inventory Guidebook we find that Canadians burn about 622 million cubic feet of wood per year, which, assuming 80 cubic feet of solid wood per full cord, equals about 7.8 million cords per year. At a commercial value of $150 per cord (which is at the low end of fire wood costs) the estimated value of residential wood fuel is about $1.17 billion each year. This is a significant amount of economic activity, particularly since most of it occurs in our rural communities where employment opportunities are often limited. To put the environmental costs of wood burning into context, it is important to examine its environmental, social and economic benefits. Can the stakeholders participating in this consultation come to consensus in the absence of such an analysis?

5. Are there any other organizations that you think should attend the consultation workshop or at least be provided with the consultation materials and invited to submit written comments?

As mentioned, we are concerned that there may be insufficient representation from Canada's First Nations, considering the possible impact of the proposed regulation on rural and remote FN communities. At least the Assembly of First Nations should be contacted to determine what FN agencies should take part in the consultation in order to state their concerns, if any, and report to their constituencies on possible impacts.

Pollution Probe has made an effort in the past to promote environmentally appropriate wood burning while balancing the positive environmental qualities of wood as an energy source. Pollution Probe would make an effective and well-informed stakeholder in this process.

One of our concerns is that this regulatory initiative, as proposed, will have a disproportionate impact on rural Canadians. For this reason, it would be useful to have someone from Agriculture Canada's Rural Secretariat involved in this consultation process.

We continue working to identify other agencies that could provide useful input to this process and will advise you of them as they are contacted.