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Friday, June 18, 2021

More About the Cordwood Test Method War

        Almost concurrent with the release of our “Review Part 1” statement on May 15th, nine State Attorney Generals (from states VT, MA, RI, NY, NJ, MD, WA, OR, and AK) sent a letter to the EPA.  The letter urged the EPA to revoke the current cordwood test method (ASTM E-3053) and adopt the new method (IDCTM) proposed by NYSERDA. 

The EPA is currently using two labs (one in OR, one in CT) to test the proposed new method.  Three different stoves will be run through multiple tests to ascertain (1). If test results can be replicated over subsequent burns in the same lab, and (2). If test results can be replicated in two different labs.  

We expect these results to be slowly forthcoming over the next two months.

Linked below is part 2a from Tom Morrissey’s review of the “Assessment” and proposed new test method (IDCTM).  This part of the review delves into the “low” and “medium” burn rate measurements used in the current EPA certification process, a focus of NESCAUM’s criticism.

Also discussed at length in this review is how the NESCAUM test method proposes to measure efficiency.  Stove efficiency results reported thus far by NESCAUM for tests using its proposed method are unexpectedly low, likely to be attributed to the test protocol having different beginning and end points (discussed in “Part 2a” of Tom Morrissey’s review).  

Another point of concern is the lack of test calculation transparency.  Test developers (NESCAUM/NYSERDA) refuse to disclose the data and sample calculations so that their method of calculating efficiency can be explained and verified.  This is very odd behavior for “public servants”.

Thursday, June 17, 2021

A New War Over the Accuracy of Cordwood Test Methods

    In March of this year the Northeast States for Coordinated Air Use Management (NESCAUM) published an attack on the EPA wood stove certification process.

The document, entitled “Assessment of EPA’s Residential Wood Heater Program”, claims that the EPA process is dysfunctional and a systemic failure.  In addition, the document attacks test labs that perform the wood stove certification tests, the third-party reviewers who certify these test reports for the EPA, and alleges collusion between manufacturers and test labs.  In short, it attacks every entity in the wood stove testing and certification process.

Almost simultaneously with the publication of the “Assessment”, NESCAUM released its own new woodstove test method.  Their “Integrated Duty-Cycle Test Method (“IDCTM”) is alleged to solve all problems NESCAUM had identified with both the current EPA test methods and also with the participants in the certification process: manufacturers, test labs, third-party certifiers, and the EPA itself.

In the “Assessment,” NESCAUM makes various claims that are deeply colored by bias and conflict of interest, untrue, or factually incorrect.  Appended to this blog post is a response to NESCAUM’s “Assessment” by Tom Morrissey, President of Woodstock Soapstone Company.

Tom’s response, “Review Part 1”, is the first of what will likely be a number of posts on this topic.

At issue are the accuracy of NESCAUM’s claims, the way both emissions and efficiency are measured going forward, the accuracy of cordwood test methods, the cost of compliance testing and regulatory approval, and the barriers to both entry and innovation in this market.  Stay tuned.

Click Here to Read Tom Morrissey’s Response