In March of this year the Northeast States for Coordinated Air Use Management (NESCAUM) published an attack on the EPA wood stove certification process.
The document, entitled “Assessment of EPA’s Residential Wood Heater Program”, claims that the EPA process is dysfunctional and a systemic failure. In addition, the document attacks test labs that perform the wood stove certification tests, the third-party reviewers who certify these test reports for the EPA, and alleges collusion between manufacturers and test labs. In short, it attacks every entity in the wood stove testing and certification process.
Almost simultaneously with the publication of the “Assessment”, NESCAUM released its own new woodstove test method. Their “Integrated Duty-Cycle Test Method (“IDCTM”) is alleged to solve all problems NESCAUM had identified with both the current EPA test methods and also with the participants in the certification process: manufacturers, test labs, third-party certifiers, and the EPA itself.
In the “Assessment,” NESCAUM makes various claims that are deeply colored by bias and conflict of interest, untrue, or factually incorrect. Appended to this blog post is a response to NESCAUM’s “Assessment” by Tom Morrissey, President of Woodstock Soapstone Company.
Tom’s response, “Review Part 1”, is the first of what will likely be a number of posts on this topic.
At issue are the accuracy of NESCAUM’s claims, the way both emissions and efficiency are measured going forward, the accuracy of cordwood test methods, the cost of compliance testing and regulatory approval, and the barriers to both entry and innovation in this market. Stay tuned.