EPA-450/2-92-002
TECHNICAL INFORMATION DOCUMENT
FOR RESIDENTIAL WOOD COMBUSTION
BEST AVAILABLE CONTROL MEASURES
U.S. Environmental Protection Agency
Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
September 1992
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Disclaimer
This document reflects" the latest information that the
Environmental Protection Agency (EPA) has obtained on measures
for control of residential wood combustion. As additional
information becomes.available, the document will be updated, as
appropriate. Mention of trade names or commercial products is
not intended to constitute endorsement or recommendation for use.
Copies
Copies of this document are available through the Library -
Services Office (MD-35), U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina 27711; or, for a fee, from
the National Technical Information Services, 5285 Port Royal
Road, Springfield, Virginia 22161.
ii September 1992
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CONTENTS
Section
1.0 Introduction 1-1
1.1 Purpose of Document . . . . . . . . 1-1
1.2 Statutory Background 1-2
1.2.1 Designations . 1-2
1.2.1 Classifications 1-2
1.2.3 Serious Area Attainment Dates ...... 1-4
1.2.4 Key Serious Area SIP Requirements . . - . . 1-4
1.2.5 RACM and BACM Issuance 1-5
1.3 Document Organization . . , 1_6
1.3.1 Available Control Measures for RWC BACM . 1-6
1.3.2 RWC BACM Economic Feasibility Methodology 1-7
2.0 Integral Measures Available for RWC BACM. .... . 2-1
,.2.1 Public Awareness and Education . . 2-1
2.1.1 Program Effectiveness and Tracking .... 2-2
2.1.2 Key Public Awareness and Education
Program Elements 2-2
2.1.3 Communication Strategy 2-3
2.2 Mandatory Curtailment Program . . . . . . . . . . 2-3
2.2.1 Public Awareness 2-4
2.2.2 Forecasting and Prediction ........ 2-4
2.2.3 Public Notification • 2-5
2.2.4 Exemptions . . ......... 2-5
2.2.5 Enforcement ..... 2-6
2.2.6 Tracking - 2-7
2.3 Measures to Improve Wood Burning Performance . . 2-7
2.3.1 Control of Wood Moisture Content . .... 2-7
2.3.2 Weatherization of Homes with Wood Stoves . 2-8
2.3.3 Educational Opacity Program ........ 2-9
2.4 All New Wood Stove Installations EPA-Certified,
Phase II Stoves or Equivalent 2-10
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i Page
3.0 Flexible Measures Available for RWC BACM 3-1
3.1 Emissions Reduction or•Elimination -
Existing Installation „ 3_2. -
3.1.1 Conversion of Existing Wood Burning
Fireplaces to Gas Logs 3-1
3.1.2 Changeover to EPA-Certified Phase II
Stoves or Equivalent 3-3
3.1.3 Changeover to Low-emitting Devices . . . 3-5
!
3.2 Emission Reduction or Emission Increase
Prevention — New Installations 3_6
3.2.1 Gas Fireplaces or Gas Logs for New
Wood-Burning Fireplace Installation . . 3-5
3.2.2 Upgrade Offset 3_6
3.2.3 Restriction on Number ashd. Density of
New Wood-Burning Stove and/or Fireplace
Installations .; 3_g
3.2.4 Requirement that New Wood Stove
Installations be Low-Emitting 3-9
3.3 Emissions Reduction — New and Existing
Wood Stove Installations 3-9
3.3.1 Device Offset .; 3-10
3.3.2 Upgrade Offset ; .* 3-11
4.0 RWC BACM Economic Feasibility Methodology 4-1
4.1 Introduction 4_1
4.2 Integral Measures 4-1
i
4.2.1 Public Awareness, and Education 4-1
4.2.2 Mandatory Curtailment Program 4-2
4.2.3 Measures to Improve Wood
Burning Performance 4-7
4.2.3.1 Control, of Wood Moisture Content 4-7
4.2.3.2 Weatherization of Homes
with Wood Stoves 4-8
4.2.3.3 Educational Opacity Program . . . 4-9
4.2.4 All New Wood Stove Installations EPA-
Certif ied, Phase II Stoves or Equivalent . 4-10
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Section **
4.3 Flexible Available Measures . 4-12
4.3.1 Emissions Reduction or Elimination -
Existing Installations 4-12
4.4.1.1 Conversion of Existing Wood Burning
Fireplaces to Gas Logs -4-12
4.3.1.2 Changeover to EPA-Certified Phase II
Stoves or Equivalent ...... 4-15
4.3.1.3 Changeover to Low-emitting
Devices . . . 4-17
4.3.2 Emission Reduction or Emission Increase
Prevention — New Installations 4-20
4.3.2.1 Gas Fireplaces or Gas Logs for New
Wood-Burning Fireplace
Installations 4-20
4.3.2.2 Upgrade Offset '. 4-23
4.3.2.3 Restriction on Number and Density of
New Wood Burning Stove and/or Fireplace
Installations 4-25
4.3.2.4 Requirement that New Wood Stove
Installations be Low Emitting . . 4-33
4.3.3 Emissions Reduction — New and Existing
Wood Stove Installations *4-36
4.3.3.1 Device Offset ..... 4-36
4.3.3.2 Upgrade Offset 4-39
APPENDIX A RWC BACM Task Force Membership A-l
APPENDIX B Methodology for Calculating Device
and Upgrade Offset Ratios B-l
September 1992
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TABLE
Table No. Page
1-1 Measures Available for RWC BACH . ! . . . 1-8
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SECTION 1.0 .
INTRODUCTION
1.1 PURPOSE OF THIS DOCUMENT
The purpose of this document is to provide technical
information for the development of best available control
x^
measure (BACM) strategies for residential wood combustion
(RWC) in areas that are designated serious nonattainment for
PM-10 (particles with an aerodynamic diameter less than or
equal to a nominal 10 micrometers). The information is needed
by States to develop control strategies for their serious
PM-10 nonattainment area State•implementation plan (SIP)
submittals.
Note that while the guidance presented herein lists
available measures which the Environmental Protection Agency
(EPA) is recommending as BACM, and is intended to be
comprehensive, it is by no means exhaustive. It also does not
establish any binding requirements. Consequently, the State
is encouraged to consider other sources of information and is
not precluded from selecting other measures and demonstrating
to the public and EPA that they constitute BACM.
1.2 STATUTORY BACKGROUND
1.2.1 Designations
Section 107(d) of the Clean Air Act (Act), as amended in
1990, provides generally for the designation of a--r..as of each
State as attainment, nonattainment or unclassifiable for each
pollutant for which there is a national ambient air quality
1-1 - September 1992
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standard (NAAQS"). Certain areas meeting the qualifications of
section 107(d)(4)(B) of the amended Act were designated
nonattainment for PM-10 by operation of law upon enactment of
the 1990 Amendments to the Act (initial PM-10 nonattainment
areas). A Federal Register notice announcing all of the areas
designated nonattainment for PM-10 at enactment and classified
as moderate was published on March 15, 1991 (56 FR 11101). A
follow-up notice correcting some of these area designations
was published August 8, 1991 (56 FR 37654). The boundaries of
the nonattainment areas were formally codified in 40 CFR
Part 81, effective January 6, 1992 (56 FR 56694, November 6,
1991). All those areas of the country not designated
nonattainment for PM-10 at enactment were designated
unclassifiable [see section 107(d)(4)(B>(iii) of the amended
Act].
1.2.2 Classifications
Once an area is designated nonattainment, section 188
outlines the process for classification of the area. In
accordance with section 188(a),: at the time of designation,
all PM-10 nonattainment areas are initially classified as
moderate by operation of law. ;A moderate area can
subsequently be reclassified as a serious nonattainment area
under two general conditions. First, EPA has general
discretion under section 188(b)'(l) to reclassify a moderate
area as a serious area at any time the Administrator of EPA
determines the area cannot practicably attain the NAAQS by the
statutory attainment date for moderate areas. Second, under
section 188(b)(2) a moderate area is reclassified as serious
by operation of law after the statutory attainment date has
passed if the Administrator finds that the area has not
attained the NAAQS. The EPA must publish a Federal Register
notice identifying the areas that have failed to attain and
were reclassified, within 6 months following the attainment
date [see section 188(b)(2)(B)].
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.. • .
Section l88(b)(l)(A) mandates an accelerated schedule by
which EPA is to reclassify appropriate initial PM-10
nonattainment areas. The EPA proposed on November 21, 1991
(56 FR 58656) to reclassify 14 of the 70 initial moderate
areas as serious. The final decision to reclassify the areas
proposed will be based on the criteria utilized in the
proposal, comments received in response to the proposal and on
information in the moderate area SIP's that were due on
November 15, 1991 for each of the areas.
In the future, EPA anticipates that, generally, any
proposal-to reclassify an initial PM-10 nonattainment area
before the attainment date will be based on the State's
demonstration that the NAAQS cannot, practicably be attained in
the area by December 31, 1994 [the statutory attainment date
specified in section 188(c)(l) for initial PM-10 nonattainment
areas].
In addition to EPA's general authority under section
188(b)(l) to reclassify as serious any area the Administrator
determines cannot practicably attain the PM-10 NAAQS by the
applicable date, for areas designated nonattainment for PM-10
subsequent to enactment of the 1990 Amendments, subparagraph
(B) of section 188(b)(l) mcindates that appropriate areas are
to be reclassified as serious within 18 months after the
required date for the State's submission of a moderate area
SIP.1 Taken together with the statutory requirement that PM-
10 SIP's are due within 18 months after an area is designated
nonattainment [see section 189(a)(2)(B)], the statute thus
requires that EPA reclassify appropriate moderate areas as
serious within 3 years of the nonattainment designation.
Any decision by EPA to reclassify such a future
nonattainment area as serious will be based on facts specific
'•This directive does not restrict EPA's general authority
but simply specifies that it must be exercised, as
appropriate, in accordance with certain dates.
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to the nonattainment" area at issue and will only be made after
providing notice in the Federal Register and an opportunity
for public comment on the basis for EPA's proposed decision.
1.2.3 Serious Area Attainment
The amended Act specifies that the initial moderate
nonattainment areas (those designated nonattainment upon
enactment of the 1990 Amendments) reclassified to serious are
to attain the PM-10 NAAQS as expeditiously as practicable but
no later than December 31, 2001. Areas designated
nonattainment subsequent to enactment that are reclassified as
serious must attain the PM-10 NAAQS as expeditiously as
practicable but not later than: the end of the tenth calendar
year after the area's designation as noriattainment [see
section 188 (c) (2)].
1-2.4 Key Serious Area SIP Requirements
As discussed above, States must develop and submit SIP's
providing for the attainment of the PM-10 NAAQS for every area
designated nonattainment and classified as moderate or serious
for PM-10 under the amended Act. New revisions must be made
to the PM-10 SIP in accordance ' with section 189(b) of the
amended Act for areas that are Declassified as serious
nonattainment areas. First, provisions must be adopted to
assure that BACM (including BACT) will be implemented in the
area [see section 189 (b) (1) (B) j . Second, a demonstration
(including air quality modeling) must be submitted showing
that the plan will attain the NAAQS either by the applicable
attainment date or, if an extension is granted under section
188(6), by the most expeditious alternative date practicable
[see section 189(b) (1) (A) ] .
The SIP revisions to require the use of BACM must be
submitted to EPA within 18 months after an area is •
reclassified as serious [see section 189(b)(2)]. The BACM are
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.*'.' • 7% ' . . •
to be implemented no later than 4 years after an area is
reclassified [see section 189(b)(1)(B)].
The serious area attainment demonstration required under
section 189(b)(l)(A) must be submitted to EPA within 4 years
after an area is reclassified based on a determination by EPA
that the area cannot practicably attain by the statutory
deadline for moderate areas. It is due within 18 months after
an area is reclassified for actually having failed to attain
by the moderate area attainment date [see section 189(b)(2)].
1.2.5 RACM and BACM Issuance •
Section 190 of the amended Act requires EPA to issue
technical guidance for RACM and BACM no later than 18 months
from enactment of the 1990 Amendments to the Act for three PM-
10 source categories: urban fugitive dust, RWC, and
prescribed silvicultural and agricultural burning. In
conjunction with publication of the "General Preamble for
Title I of the Clean Air Act Amendments of 1990," EPA
discharged the section 190 requirement to issue RACM technical
guidance for each of these three source categories [57 FR
13541, April 16, 1992; 57 FR 18070, April 28, 1992]. The
General Preamble provides a policy for how to utilize the
available RACM technical guidance to develop area-specific
RACM strategies. For RWC, the available RACM technical
guidance cited is the existing RWC control measure document
issued by EPA in September 1989, "Guidance Document for
Residential Wood Combustion Emission Control Measures"
(referred to as "RWC Guidance Document" in this document, see
Ref. 1). As frequently suggested in this document, the 1989
RWC document should be consulted for background information on
the available measures described in this document.
The issuance of this RWC BACM technical guidance document
(and its fugitive dust and prescribed burning companion:
documents), together with-EPA's previous issuance of RACM
technical guidance, wholly fulfills EPA's statutory obligation
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to issue RACM and BACM technical guidance for urban fugitive
dust, RWC, and prescribed silyicultural and agricultural
burning under section 190 of the amended Act. similar to the
manner in which EPA provided guidance on Act requirements
applicable to moderate PM-10 nbnattainment areas in'the
General Preamble, including a policy or how to utilize the
RACM technical guidance documents, the EPA is planning to
provide guidance on Act requirements and provisions applicable
to serious PM-10 nonattainmenti areas, including BACM, in an
addendum to the General Preamble. [EPA made a draft of the
addendum available for public comment on July 16, 1992 (57 FR
31477).] The portion of the addendum that addresses BACM
provides a policy for how to utilize today's RWC BACM
technical guidance (and companion technical guidance for
control of fugitive dust and prescribed burning) to develop
area-specific BACM strategies.:
The information contained•in this document was obtained,
in large part, from the input and expertise of a task force
assembled in December 1990. The task force met several times
in 1991 and consisted of representatives from Federal, State,
and local agencies involved in the control of residential wood
combustion (see Appendix A).
The measures described .in this document represent what
the task force believes are the most effective measures for
controlling PM-10 from RWC. Thus, not all the measures
described in the 1989 "RWC Guidance Document" are included in
this document because the task ^force did not regard them as
"most effective."
1.3 DOCUMENT ORGANIZATION
1.3.1 Available Control Measures for RWC BACM
The available measures for RWC BACM recommended in th -
document are divided into two types (see Table l-l below);
integral measures in column A and flexible measures in
columns B-D. The suggested integral measures are measures
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that are regarded as critical for the success of RWC control
programs in PM-10 nonattainment areas. The integral measures,
though, are not, by themselves, intended to ensure long-term
attainment of PM-10 NAAQS by serious areas. These measures
<•*••
are described in section 2.0 of this document.
The flexible measures (described in section 3.0 of this
document) are intended to provide for long-term attainment of
the PM-10 NAAQS and reduce the need for short-term episodic
controls. The flexible measures are listed in three
categories (columns B-D of Table 1-1): (1) Measures That
Reduce or Eliminate Emissions From Existing Installations,
(2) Measures That Reduce Emissions or Prevent Emission
Increases From New Installations, and-(3) Measures that Reduce
Emissions From New and Existing Installations. The measures
are listed in the categories only to show what emissions they
impact and not because this guidance recommends serious areas
adopt a certain measure or measures per se from each column.
1.3.2 RWC BACM Economic Feasibility Methodology
Section 4.0 provides a methodology that the implementing
or lead planning agency should employ to assess the economic
feasibility of the available measures described in
sections 2.0 and 3.0. The methodology consists of an approach
for estimating the emissions reductions and costs associated
with each measure.
1-7 September 1992
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1-8
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References
1. U.S. Environmental Protection Agency, Guideline Series.
"Guidance Document for Residential Wood Combustion
Emission Control Measures." EPA-450/2-89-015. September
1989.
1-9 . September 1992
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SECTION 2.0
INTEGRAL MEASURES AVAILABLE FOR RESIDENTIAL
WOOD COMBUSTION BACM
This section provides guidance on the suggested integral
measures for RWC BACM. The measures are regarded as critical
for the success of RWC control programs. The measures,
however, are not intended, by themselves, to result in long-
term attainment of the PM-10 NAAQS for serious PM-10
nonattainment areas.
A background discussion of each of the'integral BACM
measures is available in the EPA "RWC Guidance-Document." The
following subsections explain the purpose of each integral
measure and recommend an effective strategy for their
implementation.
2.1 PUBLIC AWARENESS AND EDUCATION
As the "RWC Guidance Document" explains, public awareness
and education (PAE) is critical for the success of RWC
emission control programs. The BACM PAE program should serve
to inform the public about the RWC control program, (including
program operational details, program justification and citizen
responsibilities); and persuade and convince them to meet
their responsibilities under the RWC control program.
The PAE program should address the following three areas:
Program Effectiveness and Tracking;
Key PAE Program Elements; and
Communication Strategy.
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Section 2 of the "RWC Guidance Document" provides details on
existing PAE programs. ;
2.1.1 Program Effectiveness and Tracking
The PAE program should be designed to educate the public
effectively on the reason for controlling RWC emissions, as
well as on the mechanics of controlling these emissions. The
PAE program should also be tailored to the community's
attitudes toward wood heating,; their wood burning habits and
patterns, and the extent and nature of the air guality
problem. This information should be obtained by conducting a
survey of the community's residents. The survey's findings
should give implementing or lead planning agency officials an
indication of how to tailor the PAE program to the community.
In addition, a follow-up survey should be conducted to
assess the effectiveness of the PAE program on the parameters
measured in the initial survey and to adjust the. program
accordingly as necessary. Additional information on assessing
public attitudes and program effectiveness are provided in
sections 2.1, 2.4, and 2.5 of the "RWC Guidance Document."
2*1*2 Kev Public Awareness and Education Program Elements
The local implementing or!lead planning agency should
provide sufficient resources arjid staff to develop a PAE
program that educates the public about:
the health risks of wood smoke;
proper wood-burning operation and maintenance;
relevant State, local and EPA regulations;
• heating fuels and practice; and
available stove types, including their relative
"in-home" field testing emissions for PM-10 and
relative efficiencies.
More information • on--PAE program elements is contained in
section 2.2 of the "RWC Guidance Document."
•
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2.1.3 Communication Strategy
In a PAE program, the local implementing or lead planning
agency should provide sufficient resources and staff to
communicate the PAE elements to the public through all three
types of media: print, broadcast, and public contact.
(Section 2.3 of the "RWC Guidance Document" discusses each of
these media at length.) An effective PAE program should
include: (1) extensive public contact through events such as
stove fairs and school assemblies; (2) the use of print media,
including newspaper and brochures; and (3) the use of public
service announcements for radio and television. Specific
detail on a "High Level of Effort" PAE program is contained in
section 2.4.3 of the "RWC Guidance Document."
/
2.2 MANDATORY CURTAILMENT PROGRAM
The purpose of wood smoke -curtailment programs is to
restrict wood burning during periods when atmospheric
conditions and the level of wood burning activity result in
ambient concentrations of wood smoke in excess of the NAAQS
for PM-10. The curtailment program should include the
following components:
Public Awareness;
Forecasting and Prediction;
Public Notification;
Exemptions;
Enforcement; and
Tracking.
The curtailment program should be implemented in a staged
fashion, where the wood burning restrictions are less severe
at lower predicted PM-10 concentrations. The implementing or
lead planning agency administering the curtailment program
should establish a two-stage curtailment program with two
action points for determining when to call for restrictions on
wood burning. One action point should trigger the
implementation of Stage I voluntary curtailment (or mandatory
2-3 September 1992
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with exemptions) and the other should trigger Stage II
mandatory curtailment (with only low-income exemptions).
This guidance does not prescribe specific action points
for a BACM curtailment program1. The action points selected,
though, should be low enough tp provide for attainment of the
PM-10 NAAQS and the Stage I action point should be lower than
the Stage II. Table 5-2 of the "RWC Guidance Document"
presents several sets of action points which are part of
existing RWC curtailment programs and section 5 of the
"RWC Guidance Document" provides details on establishing
wood-burning curtailment programs.
2.2.1 Public Awareness ~
The implementing or lead planning agency should conduct
an ongoing public awareness program to educate the public on
the elements discussed in section 5.1.3.1 of the "RWC Guidance
Document,» which includes the health threat of wood smoke and
how the RWC control program will function. Those elements
should be communicated to the public in three formats. One,
the implementing or lead planning agency should have staff and
resources available to answer questions and disseminate
information on these elements. Two, the implementing or lead
planning agency should have mechanisms for mass media
communication which include issuing frequent press releases
and purchasing time on local radio and TV stations for public
service announcements. And, three, personal public contact
should also be established and maintained through, for
example, town meetings and local school presentations.
2.2.2 Forecasting and Prediction
The purpose of this component is to establish the
capabilities to predict when high PM-10 concentrations will
occur so that, the implementing or lead planning agency can
call a curtailment ban when necessary to avert a potential
NAAQS exceedance. To be able tp predict NAAQS exceedances,
2-4 * September 1992
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the implementing or lead planning agency should have access to
a meteorologist who has local forecasting capabilities and
should have a negotiated agreement with the National Weather
Service or other qualified entity to provide timely
information on meteorological conditions. In addition, the
implementing or lead planning agency should have ready-access
to real-time air quality data via telemetry. During the wood
burning season, both the forecasting information and
monitoring data should be available 24-hours per day.
2.2.3 Public Notification
This component concerns the minimum requirements for
notifying the public that a curtailment ban is in effect. The
implementing or lead planning agency should have the ability
to notify the media promptly in the event that curtailment is
required, and,.if necessary, the resources to pay for media
announcements to ensure adequate notification. The
implementing or lead planning agency should provide sufficient
notice of the ban to allow burners time to shut down before
the ban goes into effect. A 24-hour hot-line should be
created with recorded messages on current curtailment
activities and requirements. Notification should be made via
all three public information media (as described in
section 5.2 of the "RWC Guidance Document").
2.2.4 Exemptions -
In Stage I, the implementing or lead planning agency
should allow exemptions for EPA-certifled stoves or
2-5 September 1992
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equivalent,1 wood stoves at residences where wood combustion
is the -sole source of heat, and wood stoves in low-income
households. . In Stage II, exemptions should be limited to low
income households, but not for houses where wood is sole
source of heat.
The implementing or lead planning agency should have a
mechanism in place for publicizing the need to apply for an
exemption and sufficient staff and resources to process and
maintain exemption records. Wood burners requesting any
exemption should be required to swear to their status (as it
qualifies them for an exemption) in an affidavit and permit
their premises to be inspected^to verify their status.
Exemptions for sole-source wood burners should be sunsetted
after a reasonable period of time.
2.2.5 Enforcement
The purpose of this component is to ensure compliance
with the curtailment program. The implementing or lead
planning agency should commit to maintaining a curtailment
enforcement plan and resources to ensure compliance during
Stage II curtailment. Table 5-9 of the "RWC Guidance
Document" discusses the necessary elements for an effective
mandatory curtailment enforcement program. Table 5-7 of the
"RWC Guidance Document" also contains reported effectiveness
•^Equivalent is defined as RWC. devices for which "in-home"
field testing data are available, document emissions equivalent
to or less than "in-home" field, test emissions of EPA-
certified. Phase II stoves. See memorandum clarifying nature
of RWC guidance and describing procedure for entities seeking
emission reduction credit for RWC devices not certified by EPA
but which can demonstrate comparable or lower emissions through
field testing. Process includes consultation with EPA's Office
of Research and Development on.appropriate in-use testing
methods and procedures (Ref. 1), For example, EPA has recently
reviewed in-home field data .for, certain masonry stoves tested
during the 1991/92 heating season and has accepted the
resultant emissions data for use in SIP-related activities
(Ref. 2). I
2-6 September 1992
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levels for curtailment programs achieved in practice as high
as 90 percent.
2.2.6 Tracking
The tracking component measures how effective the
curtailment program is at achieving compliance. The
implementing or lead planning agency should commit to
conducting periodic tracking studies to determine the level of
compliance with the burn ban. A statistically-valid method
should be used for conducting field compliance tracking
surveys of RWC users and there should be periodic evaluations
of the forecasting method. Lastly, reporting and record
keeping should be required to obtain data on enforcement
efforts and on the number of burn ban da"ys called.
2.3 MEASURES TO IMPROVE WOOD BURNING PERFORMANCE
The recommended integral measures should include measures
to reduce wood smoke emissions from RWC through improving wood
burning operation and maintenance practices and modifying wood
burning conditions. These include:
controlling wood moisture content;
weatherizing homes that contain RWC devices; and
establishing an opacity limit program.
2.3.1 Control of Wood Moisture Content
The purpose of this measure is to promote the burning of
drier wood in wood stoves and fireplaces to reduce PM-10
emissions. Its main thrust should be educational. The
implementing or lead planning agency should educate the public
on the benefits for the wood burner and the community's air
quality of burning only well-seasoned-, dry wood. To achieve
this goal, moisture-content checks should be available to the
public at convenient locations during" convenient hours.
Educational materials should also be made available that (1)
describe proper wood splitting and storage techniques to
2-7 September 1992
-------
ensure wood is properly seasoned before burning, and (2)
provide information on the benefits of burning hardwoods
versus softwoods (i.e., greater heat content, etc.).
• *
In addition, if wood sold by wood dealers does not have
sufficient time to "dry-out" before the heating season (i.e.,
if it is sold, for instance, in the fall), then the program
should require wood dealers to have their wood "certified" for
moisture content prior to sale |to ensure the wood can be
properly seasoned before burning. Upon request, the dealer
should then present the certificate of moisture content to
consumers purchasing wood to verify the wood is dry enough to
be burned. Fines should be imposed on'wood dealers who sell
wood that is not certified. •;
x»-
Section 3.5.2 of the "RWC Guidance -Document" provides
more detail on measures limiting wood moisture content,
including examples of existing wood moisture ordinances.
2.3.2 Weatherization of Homes with Wood Stoves
The purpose of the weatherization program is to improve
the energy efficiencies of homes burning wood in stoves for
heat so that less wood is burned and, hence, PM-10 emissions
are lower. Under a weatherization program, the implementing
or lead planning agency should explain to the public the
rationale for improving the energy efficiency of wood-burning
homes by making the public aware that energy-efficient homes
require less wood and hence reduced fuel costs for the
homeowner.
Energy audits should be arranged by the implementing or
lead planning agency or performed itself. Low-income homes
would probably have the greatest need for weatherization and
hence should be the focus of a financial incentive program.
Financial incentives could include low-interest loans, cash
grants, and tax credits.
Discussion of weatherization is provided in section 3.6
of the "RWC Guidance Document.";
2-8 September 1992
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2.3.3 Educational Opacity Program
The goal of this measure is to identify RWC device
operation and maintenance habits that contribute to visible
emissions of wood smoke and to correct the problem. The
implementing or lead planning agency should first educate the
public that visible emissions are an indicator of completeness
of burn and then send opacity inspectors to the field to
perform opacity readings of chimneys.2 Wood burners of homes
with high opacity should be targeted for education and
consultation to determine and eliminate the cause of the
visible emissions. In addition, a consultation with a
qualified chimney sweep should be required to educate the high
opacity wood burner on proper wood stbve operation and
maintenance and examine the wood burners'7 stove and flue
systems. The consultation should include tips such as an
"acid wash" that is available to clean clogged catalysts and
hence extend their lives.
Repeat opacity violators who do not correct the source of
the high visible emissions after consultation and
recommendations on how to correct the problem should be
required to attend a class on how to operate and maintain a
wood stove properly. More information on this measure is
contained in section 3.7 of the "RWC Guidance Document."
? " '
"Since the intent of""this measure is corrective and not
punitive, the document does not prescribe specific opacity
reading methods and procedures or opacity limits but leaves
that flexibility to the implementing or lead planning agency.
2-9 - September 1992
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2.4 ALL NEW WOOD STOVE INSTALLATIONS3 EPA-CERTIFIED,
PHASE II STOVES OR EQUIVALENT
This integral measure recommends that stoves not be
allowed to be installed which are (1) not certified by EPA to
Phase II emission limits or (2) cannot document (through
"in-home" field testing data) emissions equivalent to or less
than "in-home" field test emissions of EPA-certified Phase II
stoves.4 The intent of this requirement is to prevent the
sale or resale and installation of non-EPA-certified stoves
and the resale and installation of used EPA-certified Phase I
stoves. The program should require that when homeowners
intend to install a new or used wood stove, they file a form
with the implementing or lead planning agency and swear in an
affidavit that the stove is EPA-certified to Phase II emission
limits. The implementing or lead planning agency should be
responsible for processing the,forms and affidavits and
checking the brand name of the;proposed stove installation
against a list of EPA-certified, Phase II stoves (and their
equivalents). Properly trained and qualified inspection
personnel should conduct random surveys of stoves in homes to
confirm compliance.
The implementing or lead planning agency should make the
public aware of the requirement for stove certification, the
^ installations should include both "brand-new" stoves
and fireplaces and "new-used" units (i.e., newly purchased
units that are not "brand-new") ,
See memorandum clarifying nature of RWC guidance and
describing procedure for entities seeking emission reduction
credit for RWC devices not certified by EPA but which can
demonstrate comparable or lower,emissions through field
testing. Process includes consultation with EPA's Office of
Research and Development .on? appropriate in-use testing methods
andfprocedures (Ref. l). For example, EPA has recenti"
reviewed in-home field data for- certain masonry stoves"tested
during the 1991/92 heating season and has accepted the
resultant emissions data for use in SIP-related activities
(Ref. 2).
2-10 September 1992
-------
need to file a form and affidavit, and which stove types are
certified. The local building code should also be modified to
prohibit the installation of non-EPA-certified, Phase II
stoves. All installations should be performed by trained and
certified installers to ensure the performance of the new
stove (see section 3.3 of the "RWC Guidance Document" for a
discussion of installation quality assurance).
Discussion of this integral measure is provided in
section 3.2.3 of the "RWC Guidance Document."
2-11 September 1992
-------
-------
References
1. Memorandum. Renner, Fred H. , Acting Chief,
SO2/Particulate Matter Programs Branch, Air Quality
Management Division, Office of Air Quality Planning and
Standards, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, to Chief, Air Branch,
Regions I-X, U.S. Environmental Protection Agency.
"Interpretation of EPA's Guidance for Residential Wood
Combustion Emission Control Measures." September 23,
1991.
2. U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Compilation of Air
Pollutant Emission Factors TAP-42K Research Triangle
Park, North Carolina (masonry stove data to be
published).
2-12 September 1992
-------
-------
SECTION 3.0
FLEXIBLE MEASURES AVAILABLE FOR RESIDENTIAL
WOOD COMBUSTION BACM
This section provides guidance on the flexible available
measures that are designed to provide^permanent control of RWC
emissions and hence long-term attainment of the PM-10 NAAQS.
As with section 2.0, a background discussion of each of the
measures described in this section are available in the "RWC
Guidance Document." The following sections discuss the
purpose of the flexible measures and effective implementation
strategies.
3.1 EMISSIONS REDUCTION OR ELIMINATION - EXISTING
INSTALLATIONS
This section discusses the measures that result in an
emission reduction or elimination of emissions from existing
stove and fireplace installations.
3.1.1 Conversion of Existing Wood-Burning Fireplaces to Gas
Logs
This measure eliminates wood smoke emissions from
existing fireplaces by requiring conversion to "gas log"-type
fireplaces that use-either natural or propane gas. As
indicated in section 4.1.2 of the "RWC Guidance Document,"
gas-log fireplaces are commonly used to replace .wood
combustion in both zero clearance and masonry types of wood-
burning fireplaces.
3-1 September 1992
-------
The implementing or lead planning agency should establish
a conversion deadline and publicize the requirement to the
community. The conversion process should be accelerated by
requiring conversion following transfer of real estate or re-
leasing of a rental unit. Befpre the new homeowner or renter
can obtain municipal services,|the homeowner or landlord
should be required to file a form with the implementing or
lead planning agency indicating whether any wood-burning
fireplaces are located in the home. if so, then the homeowner
or landlord should be required to have the home inspected to
verify, within a certain period of time after the re-lease or
transfer, that the fireplace has been converted or the flue
sealed.
x-.
For homes not transferred or re-leased prior to the
conversion deadline, the implementing or lead planning agency
should encourage the homeowner or landlord to file for an
exemption if no wood-burning fireplace are present or to have
the premises inspected to verify conversion or seal of flue.
As an incentive for homeowners or landlords to file for an
exemption or submit to an inspection, the implementing or lead
planning agency should add a "nbncompliance fee" to a
municipal service bill. TO have the fee removed, the
homeowner or landlord should have to comply wi.th the
conversion requirements. The noncompliance period should be
reasonable in length but not so long as to prevent the area
from meeting any control strategy implementation dates and
other milestones required under the amended Act.
After a certain period of time, the fee should expire and
it should become a violation of the law to operate a wood-
burning fireplace. The implementing or lead planning agency
should then follow-up with random surveys of homes by properly
trained and qualified personnel;to ensure compliance.
In addition, the fireplace conversion should be enforced
as well through a zero percent'opacity limit for those homes
required to convert. By requesting forms and affidavits to
3~2 " September 1992
-------
verify conversions, the implementing or lead planning agency
should have an accurate inventory of the homes subject to the
zero percent opacity limit.
3-1-2 Changeover to EPA-ce'rH -FJPH t PH^SB II Stoves or
Equivalent
This measure reduces emissions from existing wood stoves
by accelerating the replacement of conventional1 stoves with
EPA-certified, Phase II stoves or equivalent2. New
installations should include both "brand-new" stoves and
fireplaces and "new-used" units (i.e., newly purchased units
that are not "brand new" ) . Section 3 . 4 of the "RWC Guidance
Document" discusses the advanced design and technology stoves
available and the mechanisms areas have 'used to achieve stove
changeover.
The implementing or lead planning agency should establish
a conversion deadline and publicize the requirement to the
community. The conversion process should be accelerated by
requiring conversion upon transfer of real estate or re-
leasing of rental units. Before the homeowner can close on a
Any stove that is not EPA-certified that burns cord wood
should be included as stoves to be converted, except for wood-
burning stoves that document (through "in-home" field testing)
emissions equivalent to or lower than the "in-home," field test
emissions of EPA-certified, Phase II stoves (see footnote 2).
Equivalent is defined as RWC devices for which "in-home"
field testing data are available that document emissions
equivalent_to or less than "in-home" field test emissions of
EPA-certified, Phase II stoves. See memorandum clarifying
nature of RWC guidance and describing procedure for entities
seeking emission reduction credit for RWC devices not certified
by EPA but which can demonstrate comparable or lower emissions
through field testing. Process includes consultation with
EPA's Office of Research and Development on appropriate in-use
testing methods and procedures (Ref. 1). For example, EPA has
recently reviewed in-home field data-for certain masonry stoves
tested during the 1991/92 heating season and has accepted the
resultant emissions data for use in SIP-related activities
(Ref. 2).
3-3 September 1992
-------
real estate transfer or a landlord re-lease a rental unit, the
home should be inspected to verify either removal of the
conventional stove and sealing, of flue or installation of an
EPA-certified, Phase II stove or equivalent. The conventional
stove should be surrendered to; the implementing or lead
planning agency or its agent to be destroyed in a manner in
accordance with any Federal, State, or local laws governing
disposal of hazardous or potentially hazardous substances
(i.e., creosote). The homeowner or landlord can file for an
exemption from the changeover requirement (i.e., swear in an
affidavit that the residence contains no wood stoves) and thus
be freed from the inspection requirement. All installations
should be performed by a trained and certified installer to
enhance the emissions performance of the new stove (see
section 3.3 of the "RWC Guidance Document" provides
information on installation quality assurance).
For homes not transferred!or re-leased prior to the
conversion, the implementing or lead planning agency should,
encourage the homeowner or landlord to file for an exemption
or have the premises inspected'prior to the conversion
deadline. As an incentive to obtain early compliance, the
implementing or lead planning agency should add a
"noncompliance fee" to a municipal service fee. To have the
fee removed, the homeowner should have to comply with the
conversion requirements. The noncompliance period should be
i
reasonable in length but not so long as to prevent the area
from meeting any control strategy implementation dates and
other milestones required under the amended Act.
After a certain period of time, the fee should expire and
it should then become a violation of the law to operate a non-
EPA-certified stove within the nonattainment area. The
implementing or lead planning agency should then follow-up
with random surveys of homes by trained and qualified
personnel to ensure compliance. In addition, the implementing
i • • .(•
3;-4 September 1992
-------
or lead planning agency can enhance enforcement of the
changeout through an opacity limit program.
Sections 3.4.5 and 3.4.6 of the "RWC Guidance Document"
*> •
discuss accelerated changeover requirements and inducements.
3.1.3 Changeover to Low-Emitting Devices
This measure is virtually identical to the changeover
measure described above in section 4.1.2, except that the
changeover is recommended to a "low-emitting" device
(EPA-certified or otherwise) that can document "in-home" field
test emissions less than the emission factor averages of "in-
home" field test emissions data for EPA-certified stoves (Ref.
2). This can include classes of devices that are demonstrated
to be capable as a class of producing lower field emissions,
as well as specific model units that perform better in the
field than the class collectively.
Key elements of the measure are the same as the
EPA-certified, Phase II stove changeover measure and include a
changeover deadline, a conversion acceleration vehicle, a
conversion deadline, a survey of affected homes to ensure
compliance, and, for further enforcement, the use of an
opacity limit program. The conventional or non-EPA-certified
stoves should be surrendered to the implementing or lead
planning agency or its agent to be destroyed in a manner in
accordance with any Federal, State, or local laws governing
disposal of hazardous or potentially hazardous substances
(i.e., creosote). Finally, all installations should be
performed by trained and certified installers to ensure the
performance of the new stove (see section 3.3 of the "RWC
Guidance Document" for a discussion of installation quality
assurance).
3-5 September 1992
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3.2 EMISSION REDUCTION OR EMISSION INCREASE PREVENTION — NEW
INSTALLATIONS3 ;
This section discusses the measures that can be
undertaken by a implementing or lead planning agency to reduce
emissions or to prevent emissions increases resulting from the
growth of new stove or fireplace installations.'
3.2.1 Gas Fireplaces or Gas Logs for New Wood-Burning
Fireplace Installations:
The purpose of this measure is to eliminate wood smoke
emissions from new wood-burning fireplace installations by
requiring an alternate fuel, natural gas, or propane. Under
this measure, the implementing1 or lead planning agency should
establish a regulatory requirement that 'allows only gas
fireplaces or gas logs in new fireplace installation in either
new or existing housing units and educates builders,
developers, and homeowners about the restriction.
When the premises are inspected for conformity with the
building code, the building inspector, should specifically
inspect the fireplace units to ensure they are only either
natural gas or propane-fired, not wood burning. Any fireplace
in violation of the regulation would have to be converted
before the builder or homeowner could receive an approval from
the building department that t|ie dwelling complies with the
building code. Section 4.2 of.the "RWC Guidance Document"
discusses some existing RWC control program limit new RWC
devices.
3.2.2 Upgrade Offset
The purpose of this measure is to prevent emission
increases from new stove installations by requiring enough
3New installations should include both "brand-new" stoves
and fireplaces and "new-used" units (i.e., newly-purchased
units that are not "brand new").
3-6 September 1992
-------
existing conventional stoves to be upgraded to offset any
increase in emissions resulting from the proposed installation
of new EPA-certified, Phase II stoves or equivalent4. The
ratio of upgrades to new stoves should be based on the
relative emissions of the devices as reflected in the emission
reduction credits discussed in Appendix F of the. "RWC Guidance
Document" as updated (see Appendix B).
Key elements of this measure are an affidavit
requirement, a permit or registration system, installation
quality assurance, and enforcement activity. The implementing
or lead planning agency should require that the existing stove
owner participating in the transaction surrender the old
conventional stove to the implementing" or lead planning agency
or its agent to be destroyed in a manner in accordance with
any Federal, State, or local laws governing disposal of
hazardous or potentially hazardous substances (i.e., creosote)
and register or file a permit for the new stove. For the new
stove owner, the implementing or lead planning agency should
require a permit or registration form verifying .participation
in the program. The transaction should be overseen by the
implementing or lead planning agency to ensure that it is bona
fide. In addition, the implementing or lead planning agency
should require that the installation be performed by a trained
and certified installer (see section 3.3 of the "RWC Guidance
4Equiyalent is defined as RWC devices for which "in-home"
field testing data are available that document emissions
equivalent to or less than "in-home" field test emissions of
EPA-certified, Phase II stoves. See memorandum clarifying
nature of RWC guidance and describing procedure for entities
seeking emission reduction credit for RWC devices not certified
by EPA but which can demonstrate comparable or lower emissions
through field testing. Process includes consultation with
EPA's Office of Research and Development on appropriate in-use
testing methods and procedures (Ref» 1). For example, EPA has
recently reviewed in-home field data for certain masonry stoves
tested during the 1991/92 heating season and has accepted the
resultant emissions data for use in SIP-related activities
(Ref. 2).
3-7 " September 1992
-------
Document" provides information on installation quality
assurance).
3.2.3 Restriction on Number and Density of New Wood-Ru-mi
Stove and/or Fireplace Installations
The purpose of this measure is to limit RWC emissions
growth by restricting the number and density of new RWC device
installations—stove and fireplace—in new and existing
housing units. Under this measure, the implementing or lead
planning agency should establish a building code requirement
restricting both the number and types of new RWC devices. The
implementing or lead planning agency should inform builders,
developers, and homeowners of this requirement to prevent
installations in violation of the regulation.
This provision should require that stove and fireplace
dealers provide an evidence of[ sale form to the implementing
or lead planning agency for each stove and fireplace purchased
and that information on stove and fireplace restrictions be
made available to the purchaser at the time of purchase. The
dealers should provide the evidence of sale forms to the
agency in a timely manner and the agency should enforce the
requirement through a system of warnings and fines. The
stoves should also be installed by a trained and certified
installer (see section 3.3 of the "RWC Guidance Document" for
information on installation quality assurance).
Upon receiving a record-of-sale form, the implementing or
lead planning agency should inform the homeowner of the stove
or fireplace installation number and density restrictions. To
install the new stove or fireplace, the builder or homeowner
should have to file a registration form or permit with the
implementing or lead planning agency and obtain building code
approval.
3-8 September 1992
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3.2.4 Requirement that New Wood Stove Installations be Low-
Emitting
This measure limits RWC emissions growth by requiring
that all new installations be low-emitting stoves, which is a
device (EPA-certified or otherwise) that can document "in-
home" field test emissions less than the emission factor
averages of "in-home" field test emissions data for EPA-
certif ied stoves (Ref. 2). This can include classes of
devices that are demonstrated to be capable as a class of
producing lower field emissions, as well as specific model
units that perform better in the field than the class
collectively.
Under this measure, the implementing or lead planning
agency should establish a building code 'provision requiring
that all new stoves be low-emitting. The measure should
function similar to the number and density restriction
measures described in section 4.2.3 above. Additionally, in
its PAE program, the implementing or lead planning agency
should publicize the list of certified devices that qualify as
low-emitting so that the public can understand what stoves can
and cannot be installed in the serious PM-10 nonattainment
area.
3.3 EMISSION REDUCTION — NEW5 AND EXISTING WOOD STOVE
INSTALLATIONS
This section discusses two measures—device and upgrade
offsets—that the implementing or lead planning agency can
undertake to achieve emission reductions in offset
transactions beyond the emission reduction necessary to merely
offset emission increases from new wood stoves.
5New installations should inclxide both "brand-new" stoves
and fireplaces and "new-used" units (i.e., newly purchased
units that are not "brand new").
3-9 September 1992
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3.3.1 Device Offset
When implemented, this measure is intended to achieve an
emissions reduction associated with retiring existing
conventional stoves that is greater than the emissions
increase resulting from new stove installations. The device
offset should require that for every new EPA-certified,
Phase II stove installation, an appropriate number of existing
conventional stoves be retired and destroyed (see Appendix B).
The ratio of stoves removed to new stoves should be based on
the relative emissions of the devices as reflected in the
emission reduction credits discussed in Appendix F of the "RWC
Guidance Document" as updated (see Appendix B). Given that a
wood burner willing to retire his or her stove probably did
not use the stove, this measure should b'e limited to
participants who rely on wood as a sole source of heat and who
are also low-income. j
Key elements of this measure are an affidavit
requirement, a permit or registration system, installation
quality assurance, and enforcement activity. The implementing
or lead planning agency should require that the existing stove
owner participating in the transaction surrender the old
conventional stove to the implementing or lead planning agency
or its agent to be destroyed in a manner in accordance with
any Federal, State, or local laws governing disposal of
hazardous or potentially hazardous substances (i.e.,
creosote). The existing stove owner should also register or
permit the new stove with the implementing or lead.planning
agency. For the new stove owner, the implementing or lead
planning agency should require a permit or registration form
documenting participation in the program. The transaction
should be documented and xxversejen by -the implementing or lead
planning agency to ensure that ;it is bona fide. Furthermore,
the implementing or lead planning agency, should require that
the installation be performed by a trained and certified
5,
3-10 September 1992
-------
installer (see section 3.3 of the "RWC Guidance Document"
provides details on installation quality assurance).
3.3.2 Upgrade Offset
This measure is intended to achieve emission reductions
from new stove installations by requiring enough existing
conventional stoves to be upgraded to more than offset any
increase in emissions resulting from the proposed installation
of new EPA-certified, Phase II stoves or equivalent6. The
ratio of upgrades to new stoves should be based on the
relative emissions of the devices as reflected in the emission
reduction credits discussed in Appendix F of the "RWC Guidance
Document" as updated (see Appendix B) ."
The implementation of this measure'should be similar to
the upgrade offset measure described in section 3.3.1 of this
document. Key elements of this measure are an affidavit
requirement, a permit or registration form system,
installation quality assurance, and enforcement activity. The
implementing or lead planning agency should require that the
existing stove owners participating in the transaction
surrender the old conventional stove to the implementing or
lead planning agency or its agent to be destroyed in a manner
in accordance with any Federal, State, or local laws governing
disposal of hazardous or potentially hazardous substances
Equivalent is defined as RWC devices for which "in-home"
field testing data are available that document emissions
equivalent to or less than "in-home" field test emissions of
EPA-certified, Phase II stoves. See memorandum clarifying
nature of RWC guidance and describing procedure for entities
seeking emission reduction credit for RWC devices not certified
by EPA but which can demonstrate comparable or lower emissions
through field testing. Process includes consultation with
EPA's Office of Research and Development on appropriate in-use
testing methods and procedures (Ref. 11). For example, EPA has
recently reviewed in-home field data for certain masonry stoves
tested during the 1991/92 heating season and has accepted the
resultant emissions data for use in SIP-related activities
(Ref. 2).
3-11 September 1992
-------
(i.e., creosote). The existing stove owner should also
register or permit the new stove with the implementing or lead
planning agency. For the new stove owner, the implementing or
lead planning agency should require a permit or registration
form indicating participation in the program. The transaction
should be documented and overseen by the implementing .or lead
planning agency to ensure that: it is bona fide. Furthermore,
the implementing or lead planning agency should require that
the installation be performed by a trained and certified
installer (see section 3.3 of the "RWC Guidance Document"
provides details-on -installation quality assurance).
3-12
September 1992
-------
References
1. Memorandum. Renner, Fred H. , Acting Chief,
SO2/Particulate Matter Programs Branch, Air Quality
Management Division, Office of Air Quality Planning and
Standards, U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina, to Chief, Air Branch,
Regions I-X, U.S. Environmental Protection Agency.
"Interpretation of EPA's Guidance for Residential Wood
Combustion Emission Control Measures." September 23,
1991.
2. U.S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Compilation of Air
Pollutant Emission Factors fAP-42"). Research Triangle
Park, North Carolina (masonry stove data to be
published).
3-13 September 1992
-------
-------
SECTION 4.0
RWC BACM ECONOMIC FEASIBILITY METHODOLOGY
4.1 INTRODUCTION
This methodology is provided to enable serious PM-10
•\«-
nonattainment areas to assess the economic feasibility of the
measures described in sections 2.0 and ?.0 of this document.
Specifically, this section provides a methodology for
estimating the cost and emission reduction effectiveness of
.each available integral and flexible measure. The methodology
does not provide specific data for agency and user costs
associated with each measure since they are largely area-
specific in nature and, hence, should be obtained locally.
For example, full-time employee (FTE) costs will vary from
area-to-area, as will fuel .costs and the purchase and
installation costs for RWC devices.
4.2 INTEGRAL MEASURES
4.2.1 Public Awareness and Education
Emission Reduction Calculations:
As a general rule, no emissions reductions are generally
associated with this measure, though a public awareness and
education (PAE) program is vital to the overall success of any
RWC control program. It is typically very difficult to
ascertain and quantify specific emission reductions that
result from this program. Therefore, no emission reduction
methodology is given for this measure.
September 1992
4-1
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Cost Calculations:
The cost of implementing a BACM PAE program is more
easily quantified and consists of the amount of time an FTE
should spend to administer the; program, plus any other costs
such as radio, newspaper, and television advertising;
establishment of an information hotline; education seminars;
and the like. The equations necessary to quantify these costs
are given below.
A x B = C
where: j
i
A = annual time for FTE to administer program, fraction
B = annual cost for an FTE, $
C = annual cost for FTE, ; $/year,.
The annual cost obtained above, C, 'is then added to the
total cost of other program facets (e.g., advertising,
hotlines, education seminars, etc.) to obtain the total annual
cost.
C + D = E
where:
i
D - total annual cost of'other program facets, $/year
E = total annual cost for PAE program, $/year
4.2.2 Mandatory Curtailment Program
Emission Reduction Calculations;
i
Unlike other RWC control measures in which PM-10 emission
reductions are calculated on an annual basis, emission
reductions from episodic curtailment are calculated on both an
annual and worst case 24-hour basis. This is because episodic
curtailment is fundamentally a measure designed to reduce
24-hour emissions and, over the course of the heating season,
implementation of this measure ;Will also reduce annual
emissions simply due to the cumulative effect of multiple
24-hour reductions. - Therefore /- reductions on an annual and
worst case 24-hour basis are calculated below.
September 1992
4-2
-------
Annual curtailment emissions are calculated based on the
fraction of heating degree days (HDD) occurring during
curtailment episodes divided by total HDD for the year
multiplied by total yearly emissions.
The first step in this procedure is to calculate annual
PM-10 emissions during the exceedance months using the
following formula:
A X B/C = D
where :
A = Annual baseline PM-10 RWC emissions, tons per year
(tpy)
B = Heating degree days during exceedance days
C = Annual heating degree days
D = Annual emissions of PM-10 during all exceedance
days, tpy
The emission reductions are calculated as:
D x E = F ~
where:
E = emission reduction credit level, fraction
F = annual emissions reductions, tons PM-10 removed/year
Worst-case 24-hour emission reductions are calculated in
a similar manner:
D24-hour x E = F24-hour
where:
D24-hour = worst case 24-hour PM-10 emission, tons
per day
F24-hour = 24-hour emission reductions, tons, PM-10
removed/day
Cost Calculations:
The costs of implementing this program are calculated on
both an annual and 24-hour basis. These costs are divided
into costs incurred by the implementing agency and the user.
The annual costs to the implementing agency are largely a
function of the effort necessary to enforce and administer
effectively a curtailment program. The costs of a curtailment
September 1-992
4-3
-------
program to the wood stoves and,fireplace user are the costs
associated with heating through an alternative source. These
two cost elements (implementing agency and user) are
determined separately as follows:
i
* t
Implementing Aaencv Cost Calculations; The annual cost
of implementing a BACH program-may be calculated by the
formula below: ;
G x H - I ;
where:
G - curtailment program cost, $/stove and
f ireplace.curtailment day
H = number of curtailment days per year
I - annual cost, $/year ',
The 24-hour implementing agency cost is 'obtained by simply
dividing the annual cost, I, by the number of curtailment days
per year, K.
I/K = J24-hour
where:
J24-hour = 24-hour implementing agency incremental
BACM cost, $/day
K = number of curtailment days per year
User Cost Calculations: The annual cost of the program
for a stove user is based on an average cost incurred for each
curtailment day. This estimate accounts for the daily cost of
an alternative heating system on curtailment days. .No costs
to a fireplace user are estimated, since fireplaces are not
intended to be used as a source of heat.
LQ » M x K
where:
LO - average annual cost to each nonexempt stove user for
the curtailment period,$/year
M = average cost to stove user. per. curtailment day,
$/day ;
September 1992
4t-4
-------
The average cost to each stove user per curtailment day, M,
may be difficult to precisely calculate. A methodology for
estimating this cost follows.
First, the cost of wood burning on curtailment days -needs
to be calculated. This is estimated in a two-step process.
The first step yields the annual fuel cost to the wood stove
owner as follows:
AC = Cd x Ct
where:
AC = annual fuel cost to the wood stove owner, $/year
Cd = average number of cords burned in wood stoves,
cords/year
Ct = average cost of a cord of wood, $/cord
This annual cost, AC, is then multiplied by the fraction of
heating degree days during exceedance months divided by the
annual heating degree days [(B/C), as calculated above], to
obtain annual fuel costs during the curtailment period. This
product is then divided by the number of curtailment days per
year to obtain the fuel costs per curtailment day:
FCD = [AC x (B/C)]/K
where:
FCD = fuel cost per curtailment day, $/day
The cost of alternative fuels needs to then be
calculated. This is based on the cost of obtaining an
identical heat output (i.e., heat input x efficiency) from an
alternative heating system. Therefore, the heat output from a
"typical" wood stove needs to be obtained. A "typical" wood
stove will vary from area-to-area, depending on the
composition of the stove population. Generally, surveys can
be performed to estimate -the typical heat output of wood—
stoves for a given area. The energy input into a typical wood
•stove per curtailment~day^is^basedT on the-wood usage per day,
which in turn, is obtained from the annual wood usage as
follows:
DEI = [Cd x EC x (B/C)]/K
September 1992
4-5
-------
where:
DEI = daily energy input into typical wood stove,
British thermal unit (Btu)/day
EC = energy content of
a cord of wood, Btu/cord
This value, DEI, is then multiplied by the wood stove system
efficiency to obtain the heat output on a daily basis.
DHO = DEI x WSE
i
where:
DHO = daily heat output'of wood stove, Btu/day
WSE = typical wood stove efficiency, fraction
j
The daily heat output, DHO, can then be used to obtain the
daily heat input requirements of an alternative system as
follows. I N
DHR = DHO/n i
where: :
DHR = daily heat input requirement for alternative
system, Btu/day
n - alternative system efficiency, fraction
The daily cost of this quantity of heat input is a
function of the type of alternative system in the home (e.g.,
natural gas or propane heater, ', electric heat, etc.). The cost
of alternative heat on Btu basis [or kilowatt hour (kWh) basis
for electricity] can be obtained from local gas or electric
companies. If electricity is used as the alternative heat,
L
the energy units in Btu's must :be converted to kWh as follows:
9.486 X 10~4 Btu = 2.778 X 10~7 kWh
As an example, the conversion of 100,000 Btu to kWh would be
calculated as: '
100,000 Btu X (2.778 X 10~7 kWh)/(9.486 X 10~4 Btu) =
; 29.3 kWh
The fuel cost on a per day basis is then the difference
between the alternative heating system, fuel costs and the wood
stove fuel heating costs as shown below:
M = (DHR X AEC) - FCD ;
where: •
! September 1992
4-6
-------
DHR = daily heating requirement for alternative heat
source, Btu/day
AEC = alternative energy cost, $/Btu
The 24-hour cost to the stove user is simply M as defined,
above.
4.2.3 Measures to Improve Wood Burning Performance
4.2.3.1 Control of Wood Moisture Content.
Emission Reduction Calculations:
This measure reduces RWC emissions by promoting the
burning of drier wood. It is difficult to accurately quantify
either emission reductions or costs from, this measure due to
factors that will necessarily vary from area to area.
However, the guidance document for residential wood combustion
("RWC Guidance Document") recommends that a maximum credit of
5 percent of baseline emissions be allowed for areas
implementing this measure (Ref. l). For purposes of this
document, a 5 percent credit is assumed. This credit can be
calculated according to the formula below:
A x 0.05 = B
where: „
A = RWC annual baseline emissions, tons per year
B = emissions reductions- from control of wood
moisture, tons per year
Cost Calculations:
In areas where this measure is not included in any
pre-serious area control strategy, the full cost of
instituting this measure would be incurred. The cost to the
implementing agency would include the purchase of wood
moisture monitors and-various -administrative'and "educational
charges. The cost to the RWC owner would include the time and
effort necessary to-ensure the" wood-burned falTs-'wlthiri a~n "
acceptable moisture content range.
September 1992
4-7
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4.2.3.2 Weatherization of Homes with Wood Stoves.
Emission-Reduction Calculations;
The "RWC Guidance Document1.1 suggests a credit for a
weatherization program (Ref. 2). The emission reductions from.
this measure are calculated using the formula below:
A x B = C
where: !
A = RWC annual baseline emissions, tons per year
B = emission reduction credit
C = emission reductions from weatherization, tons per
year
Cost Calculations:
For this measure, the annual implementing agency costs
are assumed to equal the product of th,e average cost of
weatherizing a home multiplied by the number of homes
weatherized per year. There are minimal or no user costs
assumed for this measure since it is intended to target low
income households. ;
Implementing ftTency Cost Calculations; Total costs for
this program are the product of the number of homes
weatherized multiplied by the average cost to weatherize each
home as shown below: •
D x E = F i
where:
D = average cost to weatherize a-home, $
E - number of homes weatherized per year
F = cost of weatherization program, $/year
A community may prefer to defer weatherization costs and
implement the program over a longer time period as prescribed
by EPA. In that instance, the icost of the weatherization
program should be amortized over that period.
Amortizing purchases is quite common and most people have
experience with this:through.:caruand house: purchases. The
technique described below is a amortizing method which yields
equal payments incurred by the borrower over the life of the
j
finance period. The amortization factor is called the capital
recovery factor and is calculated as follows:
September 1992
4-8
-------
CRF =
where:
CRF = capital recovery factor, decimal
i = annual real interest rate, decimal
n = length of finance time, months
As an example, the CRF can be calculated using a 10 percent
real interest rate and a 10-year time period (i.e., 120
months):
CRF = [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322
This factor should be multiplied by the purchase cost to
obtain the monthly payment over the length of the finance
time:
E x CRF = G .
*
where:
G = implementing agency monthly payment for program, $
The monthly payment multiplied by 12 then yields the annual
cost to the implementing agency:
F x 12 = "Cm
where:
Cm = annual cost to implementing agency, $/year
4.2.3.3 Educational Opacity Program.
Emission Reduction Calculations;
This measure reduces PM-10 emissions through an
educational program identifying operation and maintenance
habits contributing to visible emissions. It is difficult to
accurately quantify the emission reductions or costs from this
measure due to lack of measurable parameters. Therefore, a
low credit (i.e., a maximum of 5 percent of baseline
emissions) is recommended in the 'JRWC Guidance Document"
(Ref. 3). For purposes of this document, the following ... -
formula can be used to estimate emission reductions from this
measure:
A'x 0.05 = B
September 1992
4-9
-------
where:
emissions
A = RWC baseline
B = emission reductions
tons per year
strategies
checks
i, tons per year
from educational opacity,
is not included in any
, the full cost of
be incurred, which would
public education forums
Cost Calculations:
In areas where this measure
pre-serious area control
instituting this measure would
include opacity enforcement
and seminars, and related items
4.2.4 All New Wood Stove Installations EPA-certif ied ,
Phase II stoves or Equivalent
Emission Reduction Calculations:
Annual emission reductions are based upon the number of
installations that occur in a given year of non-EPA-certif ied,
Phase II stoves (or equivalent)'. The emission reductions are
calculated based on the emission reduction credit associated
with the conversion of a conventional to an EPA-certif ied)
Phase II stove (or equivalent). These reductions can be
calculated using the formula below:
(A X
where:
A
JDi
i
2
D
E
X B2 X C x D)/(454; X 2,000) = E
number of new installations of used, non-EPA-
certif ied, Phase II stoves (or equivalent) per
year
emission reduction credit1 from conventional to
Phase II or equivalent, decimal (Ref. 4)
conventional wood stove emission factor, (Ref. 5)
average cords of wood burned in each stove per
year , cords/year i
wood density, kg/cord
annual emissions reductions from this measure,
tpy
•"•The credit should reflect the types of stoves it is
assumed would be installed in the absence of the restriction
(e.g., conventional stoves and EPA-certified, Phase I stoves).
4-10
September 1992
-------
454 = conversion factor, grams to pounds, g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
Cost Calculations:
Implementing Aaencv Cost Calculations: To administer and
enforce effectively this program, some cost will be incurred.
These costs may be estimated based on the amount of time an
FTE would spend to administer and enforce this program each
year. This cost can be estimated using the formula below:
F x G = H
where:
F = time for an FTE to administer program, fraction
G = annual cost for an FTE, $/year
H = implementing Agency cost, $/year
User Cost Calculations; To calculate the incremental
cost to each stove user, the purchase and installation costs
of an EPA-certified, Phase II stove (or equivalent) and of a
conventional stove need to be obtained from local wood stove
dealers. The cost of the conventional stove is subtracted
from the cost of an EPA-certified, Phase II stove (or
equivalent). This cost difference is assumed to be financed
over a period of time by the stove buyer. This requires that
these costs be "amortized" by a numerical factor based on the
length of the finance period and the interest rate. The
technique described below is a amortizing method which yields
equal payments incurred by the borrower over the life of the
finance period. Amortizing purchases is quite common and most
people have experience with this through car and house
purchases. This amortization factor is called the capital
recovery factor and is calculated as follows:
CRF = [i/12(i + i/12)n]/[(l + i/12)n-l]
where:
CRF = capital recovery factor, decimal
i = annual real interest rate, decimal
n = length of finance time, months
As an example, the CRF can be calculated using a 10 percent
real interest rate and a 10-year length of time (i.e., 120
months):
September 1992
4-11
-------
CRF = [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322 •
This factor multiples the purchase cost to obtain the monthly
payment over the length of the ; finance time:
I x CRF = J ;
where:
I *s differential purchase and installation cost of
stove, $ ;
J => monthly payment, $/month
The monthly payment multiplied iby 12 then yields the annual
cost:
J x 12 = Co
where:
i *
Co = annual cost to stove 'owner, $/year.stove
\
4.3 FLEXIBLE AVAILABLE MEASURES
4.3.1 Emission Reduction or Elimination - Existing
Installations \
4.3.1.1 Conversion of Existing Wood Burning Fireplaces
to Gas Logs.
Emission Reduction Calculations;
\
Annual emission reductions are based on the number of
wood-burning fireplaces converting to gas logs per year. The
first step is to obtain the number of fireplaces that will
convert to gas logs under this measure for a given
implementation period. This implementation period is
determined by the circumstances, under which the nonattainment
area is reclassified to serious. This is done using the
formula given below: |
(A/X) - B
where:
A = number of existing fireplaces for baseline year
X — implementation period, of available measure, years*
B = annual number of fireplaces converting to gas logs
September 1992
4-+12
-------
The emission reductions from this measure can then be
calculated as follows:
(B X D x E X F)/(454 x 2,000) ='G
where:
D = fireplace emission factor, (Ref. 6) g/kg wood
burned
E = average wood usage in one fireplace, cords/year
F = average wood density, kg/cord
G = annual emission reductions from this measure,
tpy
454 = conversion factor, grams to pounds, g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
Cost Calculations;
x«-
Implementing Agency Cost Effectiveness Calculations: To
administer and enforce effectively the program, some costs
will be incurred. These costs may be estimated based on the
amount of time an FTE would spend to administer and enforce
the program each year. This cost can be estimated using the
following formula:
H x I = J
where:
H = time for an FTE to administer program, decimal
I = annual cost for an FTE, $/year
J = annual implementing agency cost, $/year
User Cost Calculations ; The costs to the fireplace user
are based upon two components. The first is the conversion
cost of a conventional fireplace to gas logs, and the second-
is the difference in annual energy costs between wood and
natural gas.
The cost to convert a conventional fireplace to a gas log
fireplace will vary from community to community, but is not
typically a big expense. The local gas company and local wood
stove and fireplace dealers should be contacted to obtain this
cost. Since this amount is not large, it is assumed the user
will not finance this cost.
The energy cost difference between wood and natural gas
is calculated assuming the fireplace usage (i.e., hours used
September 1992
4-13
-------
per year) between a conventional and gas fireplace will not
i
vary. The fireplace usage can be calculated as shown below:
(E X F)/K = L
where: i
K = fireplace burn rate,|(Ref. 7) kg wood/hour
L = fireplace usage, hours/year
The amount of natural gas consumed during this time period is
then calculated as follows:
L x M = N \
where: :
M = natural gas fireplace consumption rate, Btu/hour
N = energy consumption of natural gas fireplace,
Btu/year x"
• ! *
The annual cost difference between natural gas and wood is
then calculated as shown below; The cost of natural gas can
be obtained from the local gas!company, while the cost of wood
can be obtained from wood stove dealers or local classified
advertisements.
(E x O) - (N x P) = Q ;
where:
O = cost of a cord of wood, $/cord
P = cost of natural gas,[$/Btu
Q = annual cost difference between natural gas and wood,
$/year
The total annual cost of the user is then the difference of
these two cost components: '
R - Q - Co !
where:
Co — annual user cost $/year
R = cost to convert a conventional fireplace, $
i September 1992
4-14
-------
4-3.1.2 Changeover to EPA-Certifiad. Phase II stoves or
Equivalent:. : ~ "
Emission Reduction Calculations;
Annual emission reductions from this measure are based
upon the number of conventional and non-EPA-certified stoves
that convert annually to EPA-certified, Phase II stoves (or
equivalent) minus the number of EPA-certified, Phase II stoves
presently in the stove inventory. The number of stoves
annually converting to EPA-certified, Phase II stoves (or
equivalent) is determined by the total number of stoves that
will convert over the allowed implementation period.
To calculate the emission reductions that would occur
through implementation of this measure, the formula below can
be used:
[(A/X) X BJL X B2 x C'x D]/(454 x 2000) = E
'where:
A = number of affected stoves
BIL = emission reduction credit from conventional to
Phase II or equivalent, decimal (Ref. 8)
B2 = conventional stove emission factor, (Ref. 9)
g/Kg wood burned
C = average cords of wood burned in each wood
stoves per year
D = wood density, kg/cord
E = emissions reductions from this measure, tpy
X = implementation period, years
454 = conversion factor, grams to pounds, a/lb
2,000 = conversion factor, pounds to tons, Ib/ton
Cost Calculations:
Implementing Agency Cost Calculations: To effectively
administer and enforce this program, some cost will be
incurred. These costs may be estimated based on the amount of
time an FTE would spend to administer and enforce this program
each year. This cost can be estimated using the formula
below:
F x G = H
where:
F = time for an FTE to administer program, fraction
G = annual cost for an FTE, $/year
H = implementing agency cost, $/year
September 1992
4-15
-------
User Cost Calculations: To calculate the cost to each
stove user, the purchase and installation cost of an -EPA-
certified, Phase II stove (or equivalent) needs to be obtained
from local wood stove dealers. For purposes of this analysis,
it is assumed that the stove buyer will finance the purchase
and installation cost over a period of time. This requires
that these costs be "amortized" by a numerical factor based on
the length of the finance period and the interest rate. The
technique described below is an' amortization method which
yields equal payments incurred by the borrower over the life
of the finance period.,.Amortizing purchases is.quite common
and most people have experience with this through car and
house purchases. This amortization fagtor is called the
capital recovery factor and is calculated as follows:
CRF = [i/12(i + i/12)n]/t(l + i/12)n-l]
where:
CRF = capital recovery factor, decimal
i = annual real interest rate, decimal
n — length of finance time, months
As an example, the CRF can be calculated using a 10 percent
real interest rate and a 10-year length of time (i.e., 120
months): I
CRF = [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322
This factor multiples the purchase cost to obtain the monthly
payment over the length of the finance time:
I x CRF = J
where: t
I » purchase and installation cost of stove, $
J *= monthly payment, $/month
The monthly payment multiplied by 12 then yields the annual
cost:
J x 12 = Co |
where: l ' '
Co =* annual cost to stove owner, $/year-stove
September 1992
4-16
-------
4.3.1.3 Changeover ±o Low-Emitting Devices.
Emission Reduction Calculations!
Annual emission reductions from this measure are based
upon the number of conventional and non-EPA-certified stoves
annually converting to low-emitting stoves minus the number of
low-emitting stoves presently existing. The number of stoves
annually converting to low-emitting is determined by the total
number of stoves that will convert over the allowed
implementation period.
To calculate the emission reductions that would occur
through implementation of this measure, the formula below can
be used:
X"
[(A/X) X B-L X B2 X C X D]/(454 X 2000) = E
where:
A = baseline number of conventional or Oregon 1986
certified stoves
Bl = emission reduction credit from conventional to
low-emitting stove, decimal (Ref. 10)
B2 = conventional stove emission factor, (Ref. 11)
g/Kg wood burned
C = average cords of wood burned in each wood
stoves per year
D = wood density, kg/cord
E = emissions reductions from this measure, tpy
X = implementation period, years
454 = conversion factor, grams to pounds, g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
Cost Calculations:
Implementing Aaencv Cost Calculations: To administer and
enforce effectively this program, some cost will be incurred.
These costs may be estimated based on the amount of time an
FTE would spend to administer and enforce this program each
year. This cost can be estimated using the formula below:
F x G = H
where:
F'=" time for an FTE to administer program, fraction
G = annual cost for an FTE, $/year
H = Implementing Agency cost, $/year
September 1992
4-17
-------
User Cost Calculations; To calculate the cost to each
stove user, the purchase and installation cost of a low-
emitting stove needs to be obtained from local wood stove
dealers. For purposes of this analysis, it is assumed that
the stove buyer will finance the purchase and installation
cost over a period of time. This requires that these costs be
"amortized" by a numerical factor based on the length of the
finance period and the interest rate. The technique described
below is an amortization method which yields equal payments
incurred by the borrower over tpae life of the finance period.
Amortizing purchases is quite common and most people have
experience with this through car and house purchases. This
amortization factor is called the capital recovery factor and
is calculated as follows:
CRF = [i/12(i + i/12)n]/[(l + i/l2)n-l]
i
where:
CRF - capital recovery factor, decimal
i = annual real interest rate, decimal
n = length of finance time, months
As an example, the CRF can be calculated using a 10 percent
real interest rate and a 10-yeajr length of time (i.e., 120
months):
CRF = [0.1/12 (1 + 0.1/12)12°]/[(1 + 0.1/12)120-!] =
0.01322
This factor multiples the purchase cost to obtain the monthly
payment over the length of the ^finance time:
I x CRF = J ! •
where: ;
i
I =* purchase and installation cost of stove, $
J = monthly payment, $/month
i
The monthly payment multiplied by 12 then yields the annual
cost:
J X 12 = CQfS
where:
s s annual purchase ;and installation cost to stove
' owner, $/year-stove
September 1992
4-18
-------
To obtain the total costs to the user, the difference in fuel
costs assuming an identical heat input between a conventional
and low-emitting stove per year needs to be calculated (this
example assumes a pellet stove for a low-emitting device).
'The first step is to calculate the amount of heat input to a
conventional stove per year.
C X K = L
where:
K = heat content of wood, (Ref. 12) 106 Btu/cord
L = heat input to conventional stove, ~106 Btu/year
The amount of pellet fuel this heat input represents is then
calculated as shown below. ^
K/(0.008 X 2,000) = L
where:
0.008 = heat content of pellet fuel •(Ref. 13) io6
Btu/lb
2,000 = conversion factor, pounds to tons, Ib/ton
L = tons pellet fuel consumed per year, ton/year
The cost difference between pellet fuel and wood is then
calculated. The cost of pellet fuel and wood can be obtained
through local wood stove dealers or through classified
advertisements.
(L x M) - (B x N) = O
where:
M = cost of pellet fuel, $/ton
N = cost of wood, $/cord
O = annual cost difference between pellet fuel and
wood, $/year
This cost is then added to CQ/S to obtain the total annual
user cost, C .
co/S + ° - C0
where:
GO = total annual user cost, $/year.
September 1992
4-19
-------
4.3.2 Emission Reduction or Emission Increase Prevention -
New Installations |
4.3.2.1 Gas Fireplaces or Gas Logs in New Fireplace
Installations. i
Emission Reduction Calculations:
Annual emission reductions are based on the growth rate
of fireplaces in the absence of regulations, assuming all new
fireplaces installed are fueled by wood. The calculations to
obtain the emission reductions are given below. First, the
number of new gas logs and fireplaces installed per year needs
to be calculated as shown below.
A x B - C i
where:
A =* annual wood-burning fireplace growth rate in absence
of regulation
B = current wood-burning >fireplace population
C as number of new wood-burning fireplaces installed per
year in absence of regulation
The number of wood-burning fireplaces not installed annually
due to this regulation is then assumed to equal C, the number
of wood-burning fireplaces installed per year in the absence
of regulation. The emission reductions obtained from this
measure are then calculated as follows:-
(C X D X E X F)/(454 X 2,000) = G
where:
D = fireplace emission factor, (Ref. 14) g/kg wood
burned
E — average wood usage in one fireplace, cords/year
F = average cord density, kg/cord .
G as annual emission reductions, tons/year
454 = conversion factor, grams to pounds, g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
Cost Calculations: " . \
Implementing Agency Cost Calculations; To administer and
enforce effectively the program", some costs will be incurred.
These costs may be estimated based on the amount of time an
FTE would spend to administer and enforce the program each
year. This cost can be estimated using the following formula:
September 1992
4^-20
-------
H x I = J
K. '.. ' > si
where:
H = time for an FTE to administer program, decimal
I = annual cost for an FTE, $/year
J = annual implementing agency cost, $/year
User Cost Calculations: The costs.to the user are based
upon two components. The first is the difference in the
purchase and installation cost of gas logs or gas fireplaces
and the purchase and installation cost of a conventional,
wood-burning fireplace which could not be installed under this
regulation. These cost items can be obtained through local
wood stove dealers. This difference is assumed to be financed
x-
over the length of the home mortgage, since this cost is
usually included with the rest of home purchase cost.
The second cost to the user is the difference in energy
costs between gas and wood. This cost difference is based on
the amount of time a conventional fireplace would be used over
the course of the year. The calculations to obtain both of
these costs are given below.
First, the cost difference between a gas fireplace and
wood fireplace is calculated.
K - L = M
where:
K = cost of natural gas fireplace, $
L = cost of wood fireplace $
M = differential cost between gas and wood fireplace, $
The differential cost is the amortized over the length of the
mortgage (which is typically 15 to 30 years) to obtain the
annual differential cost, L. This is calculated using an
amortization factor called the capital recovery factor. This
requires that these costs be "amortized" by a numerical factor
based on the length"of the finance period and the interest
rate. The technique described below is a amortization method
which yields equal payments incurred by the borrower over the
life of the finance period. Amortizing purchases is quite
common and most people have experience with this through car
September 1992
4-21
-------
and house purchases. This amortization factor is called the
capital recovery factor and is calculated as follows:
CRF * [i/12(i + i/12)n]/[(l + i/12)n-l]
where: ;
CRF - capital recovery factor, decimal
i = real interest rate;, decimal
n = length of finance time, months
As an example, the CRF can be calculated using a 10 percent
real interest rate and a 10-year length of time (i.e., 120
months): ;
CRF = [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322 I
This factor multiplies the; differential purchase cost, L,
to obtain the monthly payment ojver the Tength of the finance
time:
M X CRF = N ;
where: ' •
N — monthly payment, $/month
The monthly payment multiplied by 12 the yields the annual
cost for this cost component. >
N x 12 - 0 I
where: :
O = annual cost differential between gas and wood and
wood fireplace, $/yeair
The next step is to calculate the energy cost difference
on an annual basis. This is obtained based on the amount of
time a fireplace is used and thie corresponding natural gas and
wood usage during this time. First, the annual hours a
conventional fireplace is used !is calculated.
(E x F)/P = Q
where:
P = fireplace burn rate, (Ref. 15) kg wood/hour
Q = fireplace usage, hours/year
The amount of natural gas consumed during this time period is
then calculated as follows: '
; September 1992
4-22
-------
Q X R = S
where:
R = natural gas fireplace consumption rate, Btu/hour
S = energy consumption of natural gas fireplace,
Btu/year
The annual cost difference between natural gas and wood is
then calculated as shown below. The cost of natural gas can
be obtained through the local gas company, while the cost of
wood can be found in classified advertisements, or through
wood stove dealers.
(E x T) - (S x U) = V
where: ' x. . . .
T = cost of a cord of wood, $/cord
U = cost of natural gas, $/Btu
V = annual cost difference between natural gas and wood,
$/year
The total annual cost to the user is then the sum of these two
cost components:
O + V = CQ' .
where:
C0 = annual user cost, $/year
4.3.2.2 Upgrade Offset.
Emission Reduction Calculations:
The purpose of this measure is to prevent emission
increases due to an increase in wood stove population. As
such, this measure does not reduce wood stove emissions and,
therefore, emission reductions are considered negligible. An
emission reduction calculation for this measure is therefore
not performed. However, the cost incurred by the implementing
agency and by the user can be estimated using the steps
described below. .... ..'
Cost Calculations:
Implementing Agency Cost Calculations: To administer
effectively this program, some costs will be incurred. These
costs may be estimated based on the amount of time an FTE
September 1992
4-23
-------
would spend to administer and enforce this program each year.
This cost can be estimated using the formula below:
E x F = G j
where: : ' " .
E = time for an FTE to administer and enforce this
program, fraction
F = annual cost for an FTE, $/year
G = program cost, $/year
No implementing agency cost effectiveness for this measure is
calculated. |
User Cost Calculations: To calculate the cost to each
stove user, the purchase and --installation cost of an EPA-
certified, Phase II stove needs! to be obtained from local wood
stove dealers. Note that for this measure, each new stove
buyer may need to purchase an EPA-certif ied, Phase II stove.
Depending upon individual agreements between the new stove
purchaser and the conventional stove owner ('whose stove is to
be upgraded) , the cost to the new stove purchaser will vary,
particularly if the conventional stove owner does not demand
full payment f for a newly installed EPA-certif ied, Phase II
stove to decide to upgrade his or her stove. It is therefore
not possible to accurately quantify this cost, unless specific
information between new stove purchasers and conventional
stove owners is known. f
For purposes of this analysis, it is assumed that the
stove buyer will finance the purchase and installation cost
over a period of time. This requires that these costs be
"amortized" by a numerical factor based on the length of the
finance period and the interest rate . The technique described
below is a amortization method which yields equal payments
incurred by the borrower over the life of the finance period.
Amortizing purchases is quite common and most people have
experience with this through car and house purchases. This
amortization factor -is called the capital recovery factor and
is calculated as follows
CRF =
where :
September 1992
4-24
-------
CRF = capital recovery factor, decimal
i = annual real interest rate, decimal
n = length of finemce time, months
* .
As an example, the CRF can be calculated using a 10 percent
real interest rate and a 10-year length of time (i.e., 120
months):
CRF = [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-1] =
0.01322
This factor multiples the purchase cost to obtain the
monthly payment over the length of the finance time:
H X CRF =1
where:
H = cost to new stove purchaser 7
I = monthly payment, $/month
The monthly payment multiplied by 12 then yields the annual
cost: .
I x 12 = Co
where:
Co = annual cost to stove owner, $/year-stove
4.3.2.3 Restriction in Number and Density of New Wood
Burning Stove and/or Fireplace Installations.
Emission Reduction Calcnla-hinng; ' .
Emission reductions from this measure should be based on
an assumed growth rate of wood stoves and fireplaces minus
stoves or fireplaces not installed due to the restriction.
This is done in two parts: calculating wood stove emission
reductions and calculating fireplace emission reductions.
Stove Emission Reduction: The calculations to obtain the
emission reductions from EPA-certi-fled, Phase II stoves are
given below:
A x B = C
where:
A = annual EPA-certified, Phase II stove growth rate in
absence of regulation, decimal
B = current EPA-certified, Phase II stove population
September 1992
4-25
-------
C =3 number of EPA-certifled, Phase II stoves installed
in absence of regulation
The number of stoves not installed due to this measure is
dependent on the type of density restriction. This may range
from full restrictions on stoves (i.e., a ban) to partial
restrictions. If a full restriction program is instituted,
the annual number of stoves not installed is simply the annual
stove growth rate multiplied by the stove population.
For full restriction, use the following formula:
E - G
where:
E = number of stoves not;installed due to this measure
Xv
If a partial restriction on stoves ,in enacted, the number
of stoves not installed will depend on the density allowance
(e.g., number of stoves allowed per acre). Historical data
may be used to determine the average number of stoves per acre
in the area, and the difference between this and the density
restriction multiplied by the number of acres developed per
year equals the number of stoves not installed. The
calculation to determine this value, E, is:
E = (D - RS) x AD
where: ,
E = annual number of stoves'not installed due to this
measure
D = average number of stoves per acre
RS = density restriction, number of stoves allowed per
acre
AD = acres developed annually
The emission reductions obtained from not installing these
stoves are calculated as shown below:
(E X F X G x H)/(454 x 2,000) = I
where:
i , •
_
F = emission factor[for EPA-certified, Phase II
stoves, (Ref. 16) g/kg wood burned
G = average wood burned in one stove per year,
cords/year i
H = average cord density, kg/cord
September 1992
4-26
-------
I = annual emission reductions from stoves,
tons/year
454 = conversion factor, grams to pounds, g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
An identical procedure needs to be performed for fireplaces.
Fireplace Emission Reduction: The calculations to obtain
the emission reductions from fireplaces are given below:
AF x BF = CF
where:
AF = annual fireplace growth rate in absence of
regulation-, -decimal-—• -
BF = current fireplace population
Cp = number of fireplaces installed in absence of
regulation ^ . •
The number of fireplaces not installed due to this
measure is dependent on the type of density restriction. This
may range from full restrictions on fireplaces (i.e., a ban)
to partial restrictions. If a full restriction program is
instituted, the annual number of fireplaces not installed is
simply the annual fireplace growth rate multiplied by the
fireplace population.
For full restriction, use the following formula:
EF = CF
where:
EF = number of fireplaces not installed due to this
measure
If a partial restriction on fireplaces in enacted, the
number of fireplaces not installed will depend on the density
allowance (e.g., number of fireplaces allowed per acre).
Historical data may be used to determine the average number of
fireplaces per acre in the area, and the difference between
this and the density'restriction multiplied by the number of
acres developed per year equals the number of fireplaces not
installed. The calculation procedure to determine this value,
Ef, is:
EF = (Dp - RSp) X ADF
where:
September 1992
4-27
-------
Ep =* annual number of fireplaces not installed due to
this measure ;
Dp = average number of'fireplaces per acre
RSp = density restriction, number of fireplaces allowed
per acre
ADp = annual developed acres
The emission reductions obtained from not installing these
fireplaces are calculated as: '.
f
(EF X Fp X GF X Hp)/(454 X 2,000) = Ip
where: '>
Fp = emission factor for fireplaces, (Ref. 17) g/kg
wood burned
Gp = average cord usage for fireplaces, cords/year
Hp == average cord density for fireplaces, kg/cord
Ip — annual emission reductions from fireplaces,
tons/year
454 — conversion factor, grams to pounds, g/lb
2,000 = conversion factbr, pounds to tons, Ib/ton
Total emission reductions are then calculated as the sum of
reductions from stoves and fireplaces.
H ~t~ Hp == Hm
where: ;
Hip = total emission reductions from this measure,
tons/year ',
i
Cost Calculations:
Implementing Agency Cost Calculations; To administer
effectively this program, some costs will be incurred. These
costs may be estimated based on the amount of time an FTE
would spend to administer the program each year. This cost
can be estimated using the formula below:
I x J - K
where: ;
I S3 time for an FTE to administer program, fraction
J — annual cost for an FTE, $/year
K = annual implementing agency cost, $/year
User Cost Calculations: There are two different
procedures for calculating.,the cost to an RWC user, depending
upon whether the RWC is a wood stove or fireplace.
The cost to each wood stove user is based on two items:
(1) the differential purchase and installation costs between a
; September 1992
4!-28
-------
gas furnace or other form pf heat,,and an EPA-certifled, Phase
II wood stove; and (2) the differences in fuel costs based on
an identical heat input to a gas furnace and a wood stove.
Differential costs for fireplaces are estimated based on the
cost of a wood-burning fireplace and a gas fireplace or gas
log fireplace (both of which can be obtained from local wood
stove and fireplace dealers) and the amount of time a
fireplace is used annually.
Stoves: The purchase and installation cost differential
for stoves is calculated as:
L - M = N
where:
•v-
L = purchase and installation cost for gas furnace, $
M = purchase and installation cost for wood stove $
N = cost differential, $
For purposes of this analysis, it is assumed that this
cost differential, N, is financed over the life of the stove
which is typically 10 years.
This requires that these costs be "amortized" by a
numerical factor based on the length of the finance period and
the interest rate. Amortizing purchases is quite common and
most people have experience with this through car and house
purchases. The technique described below is a method which
yields equal payments incurred by the borrower over the life
of the loan. This amortization factor is called the capital
recovery factor and is calculated as follows:
CRF = [i/12(i + i/l2)n]/[.(I + i/l2)n-l]
where:
CRF = capital recovery factor, decimal
i = annual real interest rate, decimal
n = length of finance time, months
As an example, the CRF can be calculated using a 10 percent
real interest rate: and1'a- ten; year- length rof time:
CRF = [0.1/12 (1 +.0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322
September 1992
4-29
-------
This factor multiples the ^purchase cost to obtain the
monthly payment over the length of the finance time (i.e., 120
months):
N x CRF .- o ;
where:
N = purchase and installation cost of stove, $
O = monthly payment, $/month
To obtain the annual cost to trie user, multiply this value, O,
by 12 as shown below: I
O x 12 - P
where: , ;
P = annual purchase installation cost to user, $/year
The difference in energy costs pe.r year can be estimated
once the costs for natural gas 'and wood 'are obtained on a
$/106 Btu basis. The cost of natural gas on a $/106 Btu basis
can be obtained from the local gas company. The energy cost
of wood on a $/106 Btu basis can be calculated using the
formula below. The cost of wood ($/cord) can be obtained from
local wood stove dealers or the classified advertisements.
Q/R - S I
where: I
Q = cost of wood, $/cord
R = energy content of wood, 106 Btu/cord
S = energy cost of wood, $/106 Btu
The differential cost is then obtained as:
i
I
(NGC - S) = T [
L
where:
NGC - natural gas cost, $/106 Btu
T = cost differential, $/106 Btu
The annual cost difference is then calculated using the
formula below:
GF x R x T = U
where:
U = annual cost difference between natural gas and wood,
$/year
i
September 1992
4-^30
-------
The total annual cost to the wood stove user is the sum of
these two components as shown below:
cow - p + u
where:
CQW = annual cost to wood stove user, $/year
Fireplaces; The purchase and installation cost
differential for fireplaces is calculated as shown below. The
cost for both types of fireplaces can be obtained from local
wood stove dealers. The cost of a gas line, can be obtained
from the local gas company.
Lp - MF = Np
where:
LF = purchase and installation cost for gas fireplace or
gas log fireplace, $
MF = purchase and installation cost for wood burning
fireplace, $
NF = cost differential, $
For purposes of this analysis, it is assumed that this
cost differential, Np, will be financed over the length of the
home mortgage.
This requires that these costs be "amortized" by a
numerical factor based on the length of the finance period and
the interest rate. The technique, described below is a method
which yields equal payments incurred by the borrower over the
life of the finance period. Amortizing purchases is quite
common and most people have experience with this through car
and house purchases. This amortization factor is called the
capital recovery factor and is calculated as follows:
CRF = [i/12(i + i/12)n]/[(l + i/i2)n-l]
where:
CRF = capital recovery"factor," decimal - ~
i = annual real interest rate, decimal
n = length of finance time> months
As an example, the CRF can be calculated using a 10 percent
real interest rate and a ten year length of time (i.e., 120
months):
September 1992
4-31
-------
CRF =" [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322
This factor multiples the purchase cost to obtain the
j
monthly payment over the length of the finance time;
Op x CRF = Pp |
where: i
Op = purchase and installation cost of fireplace, $
Pp = monthly payment, $/month
To obtain the annual cost to the fireplace user, multiply this
j
value, PF/ by 12 as shown belovjr:
Pp X 12 = QF
where: i
Qp = annual purchase and installation cost to fireplace
user, $/year \ ^ ,
The first step to obtain the differential fuel cost
between a conventional fireplace and gas logs, is to calculate
the annual hours a fireplace is used. This is done according
to the formula below. |
(GF x HF)/RF = SF
where:
Rp — fireplace burn rate, kg wood/hour (Reference 2)
Sp = fireplace usage, hours/year
The amount of natural gas consumed during this time period is
then calculated as follows: '
Sp x Tp = Up
where: ;
Tp «= natural or propane gas fireplace consumption
rate, Btu/hour
Up — energy consumption of natural or propane gas
fireplace, Btu/year
|
The annual cost difference between natural gas and wood
is then calculated as shown below.
(GF x Vp ) - (Up x WF ) = |xF
where: i
I
Vp — cost of a cord of wood, $/cord
Wp = cost of natural gas $/Btu
Xp = annual cost difference between natural gas and
wood, $/year
September 1992
4-32
-------
The total annual cost to the fireplace user is the sum of X
cinci Qp • .' *
XF + QF = YF
where:
YF = total annual cost for fireplace, $/year
4 • 3 • 2 • 4 Require New Wnnrf sfrrwo installations hg T.nw
Emitting.
Emission Reduction Calculations:
Emission .reductions -will be -calculated • based on
reductions from EPA-certif ied, Phase II stoves to low
emitting.
The emission reductions will be calculated assuming an
annual stove growth rate in the absence 'of regulation , and the
emission reductions achieved by requiring these new stoves to
be low emitting. This is done in a two step process. First,
the number of stoves that will be required to be low emitting
is calculated. Second, the emission reductions for these low-
emitting stoves relative to EPA-certif ied, Phase II stoves are
calculated as shown below:
A x B = C
where :
A = stove growth rate in absence of regulation, decimal
B = current stove population
C = number of stoves restricted to low emitting
The number of stoves restricted to low emitting, C, is then
used to calculate the emission reductions as follows:
(C X D-L X D2 x E x F)/(454 X 2,000) = G
where:
Dx = emission reduction credit for conversion from
Phase II stove to low emitting/ decimal (Ref.
18 )
D2 = emission factor of EPA-certif ied, Phase II
stove r'CRef . "19) g/Kg wood burned
E = average number of cords per year burned in one
wood stove, cords/year
F = average cord density, kg/cord
G = emission reductions from this measure,
tons/year
September 1992
4-33
-------
454 = conversion factor, grams to pounds, g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
Cost Calculations:
Implementing Agency Cost Calculations: To administer and
enforce effectively the program, some costs will be incurred.
These costs may be estimated based on the amount of time an
FTE would spend to administer and enforce this program each
year. This cost can be estimated using the formula below:
H x I = J
where:
H = ' time for 'an FTE ~tro~ administer and enforce program,
fraction
I =* annual cost for an FTE, $/year
J = annual implementing agency cost, $/year
/
User Cost Calculations; jTo calculate the cost to each
stove user, the purchase and installation cost of a low-
emitting stove needs to be obtained from local wood stove
dealers. For purposes of this analysis, it is assumed the
stove buyer will finance (i.e., discount) this cost over a
period of time. The purchase and installation of a low-
emitting stove may be obtained by calling local dealers.
Financing stove costs requires that these costs be
"amortized" by a numerical factor based on the length of the
finance period and the interest rate. The technique described
below is a method which yields equal payment incurred by the
borrower over the life of the finance period. Amortizing
purchases is quite common and most people have experience with
this through car and house purchases. This amortization
factor is called the capital recovery factor and is calculated
as follows:
CRF =
where: I
i
CRF = capital recovery factor, decimal
annual- real interest rate, decimal
n = length of finance
As an example, the CRF can be
time, months
calculated using a 10 percent
real interest rate and a 10-year length of time:
September 1992
4-34
-------
CRF = [0.1/12 (1 + 0.1/12)1j20]/[(l 4- 0.1/12)120-!] =
0.01322
This factor multiples the purchase cost to obtain the
.monthly payment over the length of the finance time (i.e., 120
months):
K X CRF = L
where:
K = purchase and installation cost of stove, $
L = monthly payment, $/month
To obtain the annual cost to the user, multiply this value, K,
by 12 as shown below:
L X 12 = M
x-
where:
M = annual cost of purchase and installation of a low-
emitting stove, $/year
In addition to the purchase and installation cost, the
annual fuel cost must be calculated. This cost is based on
the difference between the cost of pellet fuel and wood,
assuming the same heat input to a pellet stove and an EPA-
certif ied, Phase II stove (this example assumes a pellet stove
for a low-emitting device). The calculation procedure is
given below. First, calculate the annual heat input to an
EPA-certifled, Phase II stove as shown: , ,
E x N = O
where:
N = average cord energy content, Btu/cord
O = total annual heat input to stove, Btu/year
Once this value is calculated, the annual cost of pellet fuel
can be obtained using the following formula. The cost of
pellet fuel ($/ton) can be obtained through local wood stove
dealers.
(N X P X Q)/(8,000 X 2,000) = R
where:
P = cost of pellet fuel, $/ton pellets
Q = relative efficiency ratio of EPA-certified,
Phase IT wood stoves to low-emitting stoves,
September 1992
4-35
-------
decimal (Ref. 20). (e.g., pellet stoves in this
example) |
R = annual fuel cost of pellets, $/year
2,000 = conversion factor, pounds to tons, Ib/ton
8/000 = heat content of pellet fuel, Btu/lb
The annual cost of wood is calculated according to the formula
below. The cost of wood ($/cord) can be obtained through wood
stove dealers or classified advertisements.
E x S = T
where: ;
S — cost of wood, $/cord
T = annual wood cost, $/year
i
The annual wood cost, T, is then subtracted from the annual
pellet cost, P, to obtain the incremental fuel costs of
switching to pellet fuel from cord wood 'as shown below:
Q - T = U ;
where:
U - incremental fuel cost, $/year
The total annual costs to the stove purchaser are then
calculated as: [
M + U ^ Co
where:
I
Co — tdtal annual cost to stove purchaser, $/year-stove
4.3.3 Emission Reduction - New and Existing Installations
4.3.3.1 Device Offset.
Emission Reduction Calculations;
Emission reductions will be based on a decrease in
emissions from removal of an appropriate number of
conventional stoves for every stove installed.
The calculations to obtain the emission reductions are
given below. First, the .number..of_.new. stoves .installed .per
year needs to be calculated as shown below.
A x B = C - ' . i
where: |
A = annual stove growth rate in absence of regulation
B — current stove population
C = number of new stoves installed per year
September 1992
4-36
-------
The emission reductions can then be calculated as:
(C X Dx x D2 x E X F)/(454 x 2,000) = G
where:
D-j^ = emission reduction credit from conventional to
Phase II stove or equivalent, decimal (Ref. 21)
D2 = emission factor for conventional stove, (Ref.
22) g/Kg wood burned
E = average wood burned in one stove per year,
cords/year
F = average wood density, kg/cord
G = annual emission reductions, tons/year
454 = conversion factor, grams to pounds,g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
NV
Cost Calculations:
*
Implementing Agency Cost Calculations: To effectively
administer the program, some costs will be incurred. These
costs .may be estimated based on the amount of time an FTE
would spend to administer the program each year. This cost
can be estimated using the following formula:
H x I = J
where:
H = time for an FTE to administer program, decimal
I = annual cost for an FTE, $/year
J = annual implementing agency cost, $/year
The implementing agency cost effectiveness is calculated as
the ratio of program costs divided by the total reductions
obtained.
CEia = J/G
where:
CEia = implementing agency cost effectiveness, $/ton
PM-10 removed
User Cost Calculations: The costs to stove purchasers
proposing to install a. new- EPA-certified, Phase II,stove in
the serious nonattainment area are .assumed to equal the
installation cost of a new EPA-certified, Phase II stove, the
cost to remove a conventional stove, and the cost of an
alternative heating system to replace the conventional stove.
September 1992
4-37
-------
These costs can be obtained from local wood stove dealers, the
local gas company, and the locbal electric company. For
purposes of this analysis, it is assumed the purchaser will
finance these costs over a period of time.
This requires that these|costs be "amortized" by a
numerical factor based on the length of the finance period and
the interest rate. The technique described below is a method
which yields equal payments incurred by the borrower over the
life of the finance period. Amortizing purchases is quite
common and most people have experience with this through car
and house purchases.- -This amortization factor is called the
capital recovery factor and is calculated as follows:
CRF = [i/12(i + i/i2)n]/[(l + a/12)n-l]
where:
CRF = capital recovery factor, decimal
i = annual real interest rate, decimal
n = length of finance time, months
As an example, the CRF can be !calculated using a 10 percent
real interest rate and a 10-y4ar length of time (i.e., 120
months): I
CRF = [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322 i
This factor multiples the purchase cost to obtain the
monthly payment over the length of the finance time:
K x CRF = L
where:
K = total cost to remove conventional stove, plus cost
of alternative heating system, plus cost of EPA-
certified, Phase II stove, $
L — monthly payment, $ '
The monthly payment multiplied by 12 then yields the annual
cost: I
L x 12 = co ;
where: [
Co = annual cost to stove owner, $/year-stove
[ ' September 1992
4-38
-------
4.3.3.2 Upgrade Offset.
Emission Reduction
Emission reductions are calculated assuming a stove
growth rate in the absence of regulation with an appropriate
number of conventional stoves upgrcided for every new EPA-
certified, Phase II stove installed. The first step in
calculating the emission reductions is to estimate the number
of stoves that will be upgraded using the two formulas below:
A x B = C
where :
A = stove growth rate in absence of regulation, decimal
B = current stove population
C = number of stoves installed "
The number of upgraded stoves is calculated as:
D = _ E x C
where:
D = number of conventional stoves upgraded
E = appropriate number of stoves to achieve net
emission reduction
The emission reductions are calculated in a two-step
process. First, the reductions from the upgraded stoves
relative to conventional stoves are estimated. Second, the
emissions from the new stoves installed are calculated and
subtracted from the reductions obtained in the first step.
(D X E-L X E2 X F X G)/(454 X 2000) = H
where :
EX = emission reduction credit from conventional to
Phase II, decimal (Ref. 23)
E2 = emission factor for conventional stoves, (Ref.
24) g/Kg wood burned~ -------- ..........
F = average cords per year burned in one stove
G = average cord density, kg/cord
H = emission reductions from upgraded stoves,
tons/year
454 .= conversion factor, grams to pounds, g/lb
2,000 = conversion factor, pounds to tons, Ib/ton
September 1992
4-39
-------
The emissions increase resulting from installation of that new
stove are calculated as follows1:
i
(C X I X F X G)/(454 X 200,0) = J
where: _ |
I = emission factor for EPA-certified, Phase II
stoves, (Ref. 25) g/kg wood burned
J — emissions from new stove installations, tons/year
!
The emission reductions are then calculated as the difference
between the reductions from the upgraded stoves minus the
emissions occurring from the new stoves as shown below:
K ~ H-J
where:
i
K — emission reductions from this measure, tons/year
Cost Calculations; ;
Implementing Agency Cost Calculations: To effectively
administer this program, some costs will be incurred. These
costs may be estimated based on the amount of time an FTE
would spend to administer this program each year. This cost
can be estimated using the formula below:
E x F = G i
r
where:
E = time for an FTE to administer program, fraction
F = annual cost for an FTE, $/year
G = Implementing Agency cost, $/year
i
User Cost Calculations; To calculate the cost to each
i
stove user, the purchase and installation cost of an EPA-
j
certified, Phase II stove needsl to be obtained from local wood
stove dealers. Depending upon individual agreements between
the new stove purchaser and the conventional stove owners
(whose stoves are to be upgraded), the cost to the new stove
purchaser will vary, particularly if the conventional stove
owners do not demand full payment for a new installed EPA-
certif ied, Phase II stove. It is therefore not possible to
accurately quantify this cost, unless specific information
between hew stove purchasers and conventional stove owners is
known.
September 1992
4-40
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For purposes of this analysis, it is assumed that the
stove buyer will finance whatever costs are incurred over a
period of time. This requires that these costs be "amortized"
by a numerical factor based on the length of the* finance
period and the interest rate. The technique described below
is a method which yields equal payment incurred by the
borrower over the life of the finance period. Amortizing
purchases is quite common and most people have experience with
this through car and house purchases. This amortization
factor is called the capital recovery factor and is calculated
as follows:
CRF = [i/12(i + i/12)n]/[(i + ix/i2)n-l]
where:
CRF = capital recovery factor, decimal .
i = annual real interest rate, decimal
n = length of finance time, months
As an example, the CRF can be calculated using a 10 percent
real interest rate and a 10-year length of time (i.e., 120
months):
CRF = [0.1/12 (1 + 0.1/12)120]/[(1 + 0.1/12)120-!] =
0.01322
This factor multiples the purchase cost to obtain the
monthly payment over the length of the finance time:
H x CRF = I
where:
•H = cost to new stove purchaser,
J = monthly payment, $
The monthly payment multiplied by 12 then yields the annual
cost:
I x 12 = Co
where:
Co = annual cost to stove owner, $/year.stove
September 1992
4-41
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References
1. U.S. Environmental Protection Agency, Guideline Series.
"Guidance Document for Residential Wood Combustion
Emission Control Measures." EPA-450/2-89-015. 'September
1989. pp. Fl - F4.
2. Reference 1, pp. Fl - F4.
3. Reference 1, pp. Fl - F4.
4. Reference 1, pp. Fl - F4.
5. U.S._Environmental Protection Agency, Office of Air
Quality Planning and Standards, Compilation of Air
Pollutant Emission Factors rAP-421. Research Triangle
Park, North Carolina. -
6. Reference 5.
*
7. Reference 5.
8. Reference l, pp. Fl - F4.
9. Reference 5.
10. Reference 1, pp. Fl - F4.
11. Reference 5.
12. Reference 1, p. AS. *
13• Hearth and Home. August 1990. p. 25.
14. Reference 5.
15. Reference 5.
16. Reference 5.
17. Reference 5.
18. Reference 1, pp. Fl - F4.
19. Reference 5.
20. Reference 1, pp. Fl - F4.
21. Reference 1, pp. Fl - F4.
21. Reference 6.
22. Reference 5.
September 1992
4-42
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23. Reference 1, pp. Fl - F4.
24. Reference 5.
25. Reference 5.
4-43
September 1992
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APPENDIX A •
RWC BACM TASK FORCE MEMBERSHIP
Barbara Bates
US EPA Regional Office IX
75 Hawthorne Street
San Francisco, CA 94196
Steve Body
US EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
John Chamber1in
US EPA, Office of Policy, Planning,-and Evaluation (PM-221)
401 M Street, S.W. ;
Washington, DC 20460
Kevin Golden
Washoe County District Health Department
Air Quality Management Division
777 Sinclair Street, Suite 101
Reno, Nevada 89501
Merlyn Hough
Oregon Department of Environmental Quality
Air Quality Division
811 SW 6th Avenue
Portland, OR 97204-1390
Rosalyn Hughes
US EPA Region Office IV
345 Courtland Street, NE
Atlanta, GA 30365
Dan Johnson
Washington State Department of Ecology
M.S. PV-11
Olympia, WA 98504
Jim King
Colorado Department of-Health
Air Pollution Control Division
4210 East llth Avenue
Denver, CO 80220
A-l September 1992
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George Lauderdale
US EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
Linda Lay
US EPA Office of Air and Radiation
Stationary Source Compliance Division (EN-341W)
401 H Street, S.W.
Washington, DC 20460 . •
Bob Lebens
US EPA Office of Air and Radiation
Stationary Source Compliance Division (EN-341W)
401 M Street, W.W.
Washington, DC 20460, ,'•..,
Bob McCrillis
US EPA !
Office of Research and Development
Air and Energy Engineering Research Laboratory (MD-61)
Research Triangle Park, NC [27711
!
Thompson Pace
US EPA
Office of Air and Radiation
Air Quality Management Division (MD-15)
Research Triangle Park, NC 27711
Vickie Patton
Office of General Counsel (LE-132A)
US EPA
401 M Street, S.W.
Washington, DC 20460
Mike Silverstein
US EPA Regional Office VIII
999 18th Street
Denver Place - Suite 500
Denver, CO 80202-2405
Christopher Stoneman, Chairman
US EPA
Office of Air and Radiation
Air Quality Management Division (MD-15)
Research Triangle Park,. NC 27711
Tim Williamson
US EPA :
Office of Policy Analysis anid Review (ANR-443)
401 M Street, S.W. ;
Washington, DC 20460
A-2 September 1992
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Gary Yee
California Air Resources Board
Post Office Box 2815
Sacramento, CA 95812
A-3 September 1992
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APPENDIX B
METHODOLOGY FOR CALCULATING DEVICE AND
UPGRADE OFFSET RATIOS
Device Offset
A l-to-1 device offset ratio by definition produces a net
emissions reduction since a conventional, old stove is being
replaced with a cleaner burning unit. The emissions reduction
resulting from the transaction should be calculated based on the
appropriate emissions reduction credit. To calculate the '
emission reductions, see EPA's AP-42 document (Ref. 1) for
appropriate emission factors and, for a methodology on how to
calculate emission reduction credits, see an updated Appendix F
of the "RWC Guidance Document1" to be issued.
The participants in this measure whose stoves are being
removed, though, should be limited to sole-source, low-income
wood burners since a regular wood burner who has a back-up
heating system would be willing to participate in the transaction
probably because the wood stove was not being used. Thus,
emissions might increase from the transaction.
Upgrade Offset
From a l-to-1 upgrade offset transaction, resulting
emissions would be:
Emissions = (existing conventional stove emissions *
emission reduction credit for conversion
upgrade) + (emissions of new stove)
The net effect on emissions from an upgrade transaction
depends on the magnitude of the reduction in emissions relative
to the increased emissions of the new stove. Thus, the
appropriate ratio of upgrades to new stoves will depend on
whether the measure is intended to produce no net effect on
emissions or a net reduction. To determine the appropriate ratio
and the net impact on emissions, see EPA's AP-42 document
(Ref. 1) for appropriate emission factors and, for -a methodology
on how to calculate emission reduction credits, see an updated
Appendix F of the "RWC Guidance Document" to be issued
September 1992
B-l
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References
1. U.S. Environmental Protection Agency, Office of Air Quality
Planning and Standards, Compilation of Mr Pollutant-
Emission Factors (AP-47J, Research Triangle Park, North
Carolina.
September 1992
B-2
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