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REGIONAL— The Environmental Protection Agency’s testing program for wood stoves and other wood-burning devices is ineffective and is putting the public’s health at risk. That’s according to the EPA’s Office of Inspector General, which issued a scathing indictment of the EPA’s missteps as it attempted to implement strict new emission controls beginning back in 2017.
The public health wasn’t the only thing to suffer from flaws in the program. Tower-based Lamppa Manufacturing had flirted with bankruptcy late last year after the EPA rescinded its certification to sell its Kuuma wood furnaces, despite test results that repeatedly demonstrated it was the cleanest-burning wood furnace on the market.
The company, which was the first to meet the strict new emissions standards that took effect in 2020, had seen its sales grow steadily in the wake of their certification. By the summer of 2022, with the upcoming heating season and a new federal grant program for the purchase of certified wood furnaces, the company was poised for sales like they’d never experienced before. In anticipation, the company ramped up its workforce and spent hundreds of thousands of dollars on materials.
In June of 2022, with their five-year certification period coming due, the company sent the EPA a letter indicating its wish to renew. That’s when the EPA delivered their bombshell. Due to two minor issues, neither of which was the fault of Lamppa Manufacturing, the company would need to repeat the entire testing program before the EPA would renew its certification. What’s more, the company’s certification would expire on Sept. 1, preventing them from either selling or advertising their wood furnaces.
It was the worst possible timing, noted Garrett Lamppa, now the fourth generation of the Lamppa family to run the company. “Business was booming,” said Lamppa, given that the company had geared up for its biggest year ever. And, suddenly, just as the heating season was getting underway, the EPA pulled the rug out. “They were willing to put us out of business. They made that clear,” said Lamppa.
At the same time, notes Lamppa, the EPA continues to allow companies that had failed to meet the standards for certification to sell their stoves as certified products.
Emissions a critical issue
For years, wood stoves reduced heating costs for many homeowners, but created an enormous public health hazard due to their emissions, which include extremely fine particulates, known as PM 2.5, as well as carbon monoxide and volatile organic compounds. Air quality concerns are most acute in communities in the northern U.S., where a significant percentage of homeowners burn wood. The EPA estimates that the estimated 340,000 tons of fine particulates emitted by wood-burning devices nationwide account for 10,000 to 40,000 excess deaths due to heart disease, lung cancer, and other ailments.
The Clean Air Act required the EPA to take steps to reduce those emissions and the result was a certification program which, at least on paper, appeared designed to do just that. Under new rules adopted in 2015, any wood furnace sold beginning in 2020 would need to meet standards that many manufacturers argued could never be met.
That is until Lamppa Manufacturing met the standard in 2017, becoming the first wood furnace to be certified under the new program. Since then, the EPA has certified two other wood furnace manufacturers, in part because of a testing effort that EPA’s inspector general describes as “dysfunctional.”
Inconsistencies and lack of oversight
The findings of the EPA’s inspector general came as no surprise to Daryl Lamppa, who had overseen development of Lamppa Manufacturing’s exceptional wood furnaces. He had also overseen testing at the certified laboratory in Madison, Wis., which became the go-to laboratory for wood furnace makers seeking EPA certification.
Daryl had seen firsthand the many problems that plagued the testing program, in large part because of unclear directions and oversight from the EPA, as well as unannounced changes in the standards.
Daryl had complained bitterly to EPA officials for years about flaws in their testing program and took issue with the agency’s certification of two other wood furnace manufacturers. He had reviewed their test results and was convinced that neither had actually met the standards for certification.
He wasn’t the only one with concerns. “Flawed test methods and a lack of EPA oversight of the wood heater program have created uncertainty for states,” wrote the inspector general in his Feb. 28, 2023 report. “State regulators from Alaska and California said that they are concerned about relying on the EPA’s certification process to identify wood heaters to sell in their states or for their changeout programs.”
In New England, the Northeast States for Coordinated Air Use Management, a regional regulatory body issued its own analysis of the EPA’s program, which highlighted deficiencies in lab testing and reporting that neither the EPA nor the third-party certifiers identified through the certification process or their oversight.
Among the concerns was that the EPA had established alternative testing methods that state regulatory agencies argued created unrealistic conditions that allowed passage of wood-burning devices that would never achieve emissions targets in real world circumstances. The EPA, under pressure, withdrew those alternative testing methods in early 2022.
The inspector general’s report faulted the EPA on several fronts. “For example, the EPA lacked policies and procedures detailing how to review certification test reports, did not conduct compliance audit tests, did not have standard templates for certification test reports, did not use staff with the appropriate subject-matter technical expertise, and did not exercise regulatory or oversight authority,” wrote the inspector general. “This lack of internal controls resulted in deficiencies in certification testing and certification test reports that the third-party certifier or the EPA should have caught during the certificate-of-compliance process.”
Millions of dollars potentially wasted
At the state level, many regulators were under political pressure to improve air quality in communities, particularly in mountainous regions, where winter inversions often trapped wood smoke for days. Those states often invested millions of their own tax dollars to provide incentives for wood stove users to change out their old, polluting wood stoves and furnaces for cleaner, more efficient models. As the EPA inspector general noted, those states often depend on the EPA certification process to determine which wood-burning devices should qualify for rebate or tax credit programs.
The federal rebates are also dependent on the EPA’s conclusions.
Yet, notes the EPA inspector general: “If the EPA’s certification process is not reliable, the EPA and states involved in changeout programs may be wasting millions of dollars by subsidizing new appliances that may not be substantially cleaner in real-world conditions compared to the older appliances.”
Vindication for Lamppa
Representatives of Lamppa Manufacturing have been making similar arguments for years, and have been frustrated at the way the EPA has ducked any kind of accountability, at least until now. “It’s been frustrating that they’ve been able to skirt responsibility for the problems,” said Garrett Lamppa. “As soon as anything comes up, they put it on the manufacturer or the test lab.”
In the end, it was the EPA’s lack of transparency that created most of the problems for Lamppa Manufacturing, including the requirement that the company go through an expensive and time-consuming testing procedure yet again. While the manufacturers weren’t supposed to have to test with every five-year recertification, the EPA required that Lamppa do exactly that, for one very technical discrepancy in the original test.
On one of the four original test burns conducted on the Lamppa wood furnace, the device had emitted 0.147 pounds of soot for every million BTUs, an amount of heat equivalent to about two-and-a-half weeks of burning. The standard set by the agency was 0.15, so the burn would appear to have been a success. Yet, without changing the standard, the EPA quietly began requiring manufacturers meet a limit of 0.14 pounds, to provide an extra margin to reflect real-world circumstances.
“We’ve done everything we’re supposed to do,” said Daryl Lamppa. “It’s been a nightmare,” he added, noting that because of that one minor discrepancy, he nearly lost the company.
And the toll was more than financial. Both Lamppa and his plant manager, Dale Horihan, describe the testing process itself as incredibly stressful and time consuming. In addition, it takes time to schedule a slot at most test labs, and it wasn’t until November that Horihan could line up a test window, but it took two more week-long trips to the facility to complete the four burns required under the testing regimen. That’s in part because of a new EPA requirement that the testing lab use a Teflon filter, a requirement that had apparently never been tested for compatibility. Horihan said the new filter was initially a disaster, absorbing enormous amounts of water vapor and halting testing. Since each test can take as much as eight hours when all goes right, every glitch in the process wastes an entire day.
By the time of the first round of testing, Lamppa Manufacturing had been unable to take new orders for wood furnaces for more than two months. Workers had been put on reduced hours and everyone there understood that the very future of the company rested on the success of the tests. Horihan said the pressure and stress was intense.
While that first round of testing made progress, problems with the filter prevented the testing lab from completing all four of the burns within the week. In the end, Horihan was forced to make two other trips to Intertek to finally complete the tests.
As it had back in 2017, Lamppa’s Kuuma wood furnace proved that its wood furnace is the cleanest and most efficient wood furnace on the market— and it’s the only one that’s met the 0.14 pounds per million BTU rule. Daryl Lamppa notes that the three other manufacturers currently certified have never met that new rule, yet are allowed to continue to sell their furnaces, at least until they’re up for renewal.
Lamppa Manufacturing received its official green light to begin sales again on March 1, but the impact of losing six months of sales during the heart of the heating season has left the company strapped. Besides lost sales, Garrett Lamppa figures the company spent close to $100,000 for the latest round of testing.
And the company is likely to have to retest in five years, because of an error made by the testing lab. While the lab was supposed to conduct certain test burns with 40 pounds of wood, the test lab had granted the manufacturers a ten-percent margin either way, which was based on their understanding of the EPA’s testing guidelines. At least one of Lamppa’s most recent tests was conducted with slightly less than 40 pounds of wood, although it was well within the ten-percent margin. But because of the discrepancy, the company expects it will have to retest in five years.
EPA changes its tune
While the EPA has yet to issue a response to the inspector general’s report, officials at Lamppa say they’ve already noticed a change in the agency’s attitude. “They completely changed their tune after the report came out,” said Garrett Lamppa. While the EPA had initially been resistant to suggestions for improvements, he said the agency is now making many of the changes that the company had recommended, such as better communication with the manufacturers. With only three wood furnace manufacturers in the country, it made no sense to keep manufacturers in the dark about the changing regulatory landscape. “They made all these changes and never let anyone know,” said Garrett Lamppa.
Meanwhile, notes Garrett Lamppa, the EPA is allowing companies that likely can’t meet the latest standards remain certified and on the market, “which means tax credits are being flushed.”
Those companies, which were initially certified two years after Lamppa’s Kuuma wood furnaces, will need to re-test before they can be recertified in 2024. And that could provide Lamppa Manufacturing with the window for dramatic growth down the road… provided they can avoid the vagaries of the federal EPA.
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