I received the following e-mail in response to the post about regulating wood furnaces....
TECHNICAL BULLETIN
On January 1, 2003 the New York State, Department of State, Division of Code Enforcement and Administration issued a Technical Bulletin to "clarify to what extent outdoor wood boilers for heating buildings are regulated by the Uniform Fire Prevention and Building Code." I have attached a copy of the Technical Bulletin for your review. The Technical Bulletin was issued over 5 years ago. The Hamlet of Gasport should have an established permitting process for outdoor wood furnaces, based upon the Technical Bulletin.
The Technical Bulletin clearly defines the requirements on how an "outdoor wood boiler" can be installed in New York State. The outdoor wood furnace must be listed and labeled for outdoor installation otherwise it cannot be installed within New York State.
The location of the furnace on a person's property is a zoning issue because the Uniform Codes do not address the location of an outdoor appliance on a property, only the listing requirements for clearance to combustibles. The Technical Bulletin is still valid today as demonstrated by the memo issued by the New York State, Department of State, Division of Code Enforcement and Administration on June 27, 2007.
OUTDOOR WOOD FURNACE INDUSTRY
I would like to invite you to review: www.outdoorfurnacefacts.com . Here you will be able to review US EPA reports relative to the outdoor wood furnace industry, air dispersion modeling, a guide to creating responsible regulations, a sample ordinance and other important information on the outdoor wood furnace industry.
The outdoor wood furnace industry is exempt from 60 CFR (Code of Federal Regulations) 40, Subpart AAA, which apply to the indoor wood stove industry. The NSPS (New Source Performance Standards) was developed for an entirely different class of wood burning appliances (indoor wood stoves), and imposed limits were rigorously derived from demonstrated emission control technologies for that class of appliance.
In 1998, the US EPA published testing of two outdoor wood furnaces which is attached. EPA report 600/SR-98/017 states that, "Compared to a wide range of residential heating options, these furnaces' emissions were of the same order as other stick wood burning appliances." The US EPA bases their finding on a test done on a Central Boiler outdoor furnace, which is furnace B in their report. Comparing EPA report 600/SR-98/017 to EPA report 600/SR-00/100 shows that particulate emissions from a properly operated outdoor wood furnace are similar to indoor wood stoves.
The US EPA did not regulate outdoor wood furnaces in 1998 for several reasons. One of the reasons is the size of the outdoor wood furnace industry. The outdoor wood furnace industry makes up a very small percentage of the wood heating industry and because tests showed that the emissions were comparable to other wood heating appliances, the US EPA did not regulate. Roughly 44 Million (44,000,000) indoor wood heating appliances including fireplaces, fireplace inserts, indoor certified and uncertified woodstoves (most of which are uncertified 75-80%), indoor wood furnaces, barrel stoves, etc. dominate the wood heating industry compared to approximately 220,000 outdoor wood furnaces. Outdoor wood furnaces make up approximately .004% of the wood heating appliance industry.
Outdoor wood furnaces are not a new source of emissions. Many times outdoor wood furnaces are installed to replace multiple indoor uncertified wood heating appliances such as fireplaces and uncertified indoor wood stoves.
On January 29, 2007, the US EPA announced a voluntary emission reduction program for the outdoor wood furnace industry. This is the first program that has ever been developed and made available for this class of wood heating appliance. The EPA OWHH (Outdoor Wood-fired Hydronic Heater) Phase 1 Program includes a test method (Test Method 28 OWHH) and an emissions limit that must be met in order to participate in the program. The Outdoor Wood-fired Hydronic Heaters that meet the program requirements will be referred to as “Program Compliant” and they will receive a permanent “qualifying label” and “hang tag”.
Within the next couple of months there will be the EPA OHH (Outdoor Hydronic Heater) Phase 2 Program that will include ASTM (American Society for Testing and Materials) E2618 - a recently passed standard that will allow for "automatically fueled heating appliances" such as outdoor wood-pellet furnaces and indoor pellet boilers to be tested for emissions and efficiency. The name change between the Phase 1 and Phase 2 Programs will occur because of the addition of "automatically fueled" heating appliances.
Two very important issues should be considered when looking at outdoor wood furnaces.
1.) SAFETY: In 1983/1984 when home heating costs rose dramatically, home fires caused by indoor wood stoves also rose dramatically because of the increased use of wood to help supplement home heating. By taking away the safe choice of an outdoor wood furnace, indoor wood burning would again increase the risk of home fires that could result in millions of dollars of property loss. Outdoor wood furnaces remove the threat of devastating chimney fires and the dangerous carbon monoxide buildup or oxygen depletion associated with burning wood indoors. There is a reason that insurance companies have a "rider" policy for indoor wood burning. Over the period from 1980-1998, indoor wood burning was responsible for 1,541,800 fires; $1.024 billion dollars in property loss; and 3,275 deaths (The (NFPA) National Fire Protection Association Fire Analysis and Research, U.S. Home heating Fire Patterns, June 2001).
2.) EMISSIONS: Burning wood has environmental advantages over fossil fuels because heating with wood is "carbon neutral". Wood is a renewable energy source, which, when burned results in no net CO2 increase. CO2 is part of the natural plant-growth cycle and occurs naturally when trees are allowed to rot on the forest floor. Fossil Fuels, when burned, release CO2 which otherwise would stay trapped in the earth. Wood, when burned produces less sulfur dioxide (SO2) and nitrous oxides (NOX) than fossil fuels - EPA emission document AP-42.
Another reason to consider responsible regulations regarding outdoor furnaces is because of other products that have been made available to consumers looking for alternatives to foreign oil and fossil fuels. Also manufactured are units which use wood pellets or corn.
TECHNICAL BULLETIN
On January 1, 2003 the New York State, Department of State, Division of Code Enforcement and Administration issued a Technical Bulletin to "clarify to what extent outdoor wood boilers for heating buildings are regulated by the Uniform Fire Prevention and Building Code." I have attached a copy of the Technical Bulletin for your review. The Technical Bulletin was issued over 5 years ago. The Hamlet of Gasport should have an established permitting process for outdoor wood furnaces, based upon the Technical Bulletin.
The Technical Bulletin clearly defines the requirements on how an "outdoor wood boiler" can be installed in New York State. The outdoor wood furnace must be listed and labeled for outdoor installation otherwise it cannot be installed within New York State.
The location of the furnace on a person's property is a zoning issue because the Uniform Codes do not address the location of an outdoor appliance on a property, only the listing requirements for clearance to combustibles. The Technical Bulletin is still valid today as demonstrated by the memo issued by the New York State, Department of State, Division of Code Enforcement and Administration on June 27, 2007.
OUTDOOR WOOD FURNACE INDUSTRY
I would like to invite you to review: www.outdoorfurnacefacts.com . Here you will be able to review US EPA reports relative to the outdoor wood furnace industry, air dispersion modeling, a guide to creating responsible regulations, a sample ordinance and other important information on the outdoor wood furnace industry.
The outdoor wood furnace industry is exempt from 60 CFR (Code of Federal Regulations) 40, Subpart AAA, which apply to the indoor wood stove industry. The NSPS (New Source Performance Standards) was developed for an entirely different class of wood burning appliances (indoor wood stoves), and imposed limits were rigorously derived from demonstrated emission control technologies for that class of appliance.
In 1998, the US EPA published testing of two outdoor wood furnaces which is attached. EPA report 600/SR-98/017 states that, "Compared to a wide range of residential heating options, these furnaces' emissions were of the same order as other stick wood burning appliances." The US EPA bases their finding on a test done on a Central Boiler outdoor furnace, which is furnace B in their report. Comparing EPA report 600/SR-98/017 to EPA report 600/SR-00/100 shows that particulate emissions from a properly operated outdoor wood furnace are similar to indoor wood stoves.
The US EPA did not regulate outdoor wood furnaces in 1998 for several reasons. One of the reasons is the size of the outdoor wood furnace industry. The outdoor wood furnace industry makes up a very small percentage of the wood heating industry and because tests showed that the emissions were comparable to other wood heating appliances, the US EPA did not regulate. Roughly 44 Million (44,000,000) indoor wood heating appliances including fireplaces, fireplace inserts, indoor certified and uncertified woodstoves (most of which are uncertified 75-80%), indoor wood furnaces, barrel stoves, etc. dominate the wood heating industry compared to approximately 220,000 outdoor wood furnaces. Outdoor wood furnaces make up approximately .004% of the wood heating appliance industry.
Outdoor wood furnaces are not a new source of emissions. Many times outdoor wood furnaces are installed to replace multiple indoor uncertified wood heating appliances such as fireplaces and uncertified indoor wood stoves.
On January 29, 2007, the US EPA announced a voluntary emission reduction program for the outdoor wood furnace industry. This is the first program that has ever been developed and made available for this class of wood heating appliance. The EPA OWHH (Outdoor Wood-fired Hydronic Heater) Phase 1 Program includes a test method (Test Method 28 OWHH) and an emissions limit that must be met in order to participate in the program. The Outdoor Wood-fired Hydronic Heaters that meet the program requirements will be referred to as “Program Compliant” and they will receive a permanent “qualifying label” and “hang tag”.
Within the next couple of months there will be the EPA OHH (Outdoor Hydronic Heater) Phase 2 Program that will include ASTM (American Society for Testing and Materials) E2618 - a recently passed standard that will allow for "automatically fueled heating appliances" such as outdoor wood-pellet furnaces and indoor pellet boilers to be tested for emissions and efficiency. The name change between the Phase 1 and Phase 2 Programs will occur because of the addition of "automatically fueled" heating appliances.
Two very important issues should be considered when looking at outdoor wood furnaces.
1.) SAFETY: In 1983/1984 when home heating costs rose dramatically, home fires caused by indoor wood stoves also rose dramatically because of the increased use of wood to help supplement home heating. By taking away the safe choice of an outdoor wood furnace, indoor wood burning would again increase the risk of home fires that could result in millions of dollars of property loss. Outdoor wood furnaces remove the threat of devastating chimney fires and the dangerous carbon monoxide buildup or oxygen depletion associated with burning wood indoors. There is a reason that insurance companies have a "rider" policy for indoor wood burning. Over the period from 1980-1998, indoor wood burning was responsible for 1,541,800 fires; $1.024 billion dollars in property loss; and 3,275 deaths (The (NFPA) National Fire Protection Association Fire Analysis and Research, U.S. Home heating Fire Patterns, June 2001).
2.) EMISSIONS: Burning wood has environmental advantages over fossil fuels because heating with wood is "carbon neutral". Wood is a renewable energy source, which, when burned results in no net CO2 increase. CO2 is part of the natural plant-growth cycle and occurs naturally when trees are allowed to rot on the forest floor. Fossil Fuels, when burned, release CO2 which otherwise would stay trapped in the earth. Wood, when burned produces less sulfur dioxide (SO2) and nitrous oxides (NOX) than fossil fuels - EPA emission document AP-42.
Another reason to consider responsible regulations regarding outdoor furnaces is because of other products that have been made available to consumers looking for alternatives to foreign oil and fossil fuels. Also manufactured are units which use wood pellets or corn.
