What…Commercial Only!? From the Desk of Martin Lunde

Posted on Mar 11, 2021

What…Commercial Only!?
March 11, 2021

At the present time GARN® WHS equipment can only be sold for commercial use, and not residential applications in the US because it has not received a final Step 2 certification from the EPA. Therefore GARN WHS equipment can be sold for use in commercial, industrial, institutional, small business, shop, process heat, farm outbuilding facilities, etc. I believe you deserve an explanation as to why this is the case. So grab some hot coffee, a sticky warm donut, sit back and follow with me as I explain the convoluted thinking behind this decision by the EPA.

Both GARN WHS models WHS 1500 and WHS 2000 have lower particulate emissions than allowed under the current Step 2 emission limits put in place in May 2020. Under Step 2 the maximum allowed output is .15 lbs of particulates per million BTUs delivered.

  • GARN® WHS model 1500 unit particulate emissions rate is .14 lbs/MMBTUH delivered… is less than the allowable.15 limit.
  • GARN® WHS model 2000 unit particulate emissions rate is .07 lbs/MMBTUH delivered… is less than one half of the allowable.15 limit.
  • A summary of Emission and Efficiency Data can be found here. Complete test reports can be found in the Product tab, under the Emission heading for each model unit.

Both models were approved by the EPA first in 2011, again in 2013, yet again in March 2015. Think about that, GARN WHS models 1500 and 2000 first met the 2020 EPA limit in 2011, 9 years before the 2020 limit was set.

In April 2020 (5 years after approval) the EPA officially rescinded our Step 2 approval citing the lack of 1st hour emission data point. The 1st hour emission test was added to the original test. There is no EPA numerical limit on 1st hour emissions. Nor is it reported on the EPA list of approved equipment to help with a customers’ buying decisions. It is a single data point (one number) that the EPA wants only for their internal information.

Any manufacture who had equipment tested before the added 1st hour test requirement, would have to retest each unit at significant effort, time and cost to determine a single data point…for which there is no EPA limit. Essentially, the EPA wants additional information, but does not want to pay for it. Monies spent on retesting take from product innovation, quality and available inventory.

Now to the really bizarre parts of this story:

  • Because the EPA does not provide the funds for states to enforce the NSPS residential limit, few states enforce the limit. Enforcement has been on an “as required” based on a specific air quality compliant.
  • There presently are no Federal emission limits for wood heating equipment between 1 BTUH and 10 million BTUH output used in commercial, industrial and institutional applications. Refer to Federal document 40 CFR Part63, Subpart JJJJJJ, Section 2.3, Table 1.
  • There are no EPA emission limits for residential coal fueled heating equipment. So a number of manufacturers have modified their wood units to burn coal, a much dirtier fuel source than woodbecause of the mercury and sulfur embedded in coal.
  • A number of small, local mom and pop “builders” of questionable equipment have popped. In most instances, this equipment has never been UL or CSA safety certified, or EPA emissions certified so “buyer beware.” Where is the enforcement by the EPA?
  • The EPA will most likely continue to reset the limits and modify the test method, yielding more testing and cost to the manufacturer. All of which means higher retail pricing for you.

The really good news about GARN WHS equipment:

  • GARN WHS equipment has been and remains some of the most durable, clean and efficient wood fired equipment available throughout the US, Alaska and Canada today. It is also the lowest priced durable commercial equipment available.
  • GARN WHS equipment is legal in most states for all commercial, industrial, etc applications, but not in residential applications.
  • GARN WHS equipment is legal in almost all of providences of Canada for residential as well as commercial, industrial and farm installations.
  • When you purchase a GARN WHS unit you will be asked to confirm that it is for a non-residential use. It is impossible for us to keep up with each states laws and regulations, so it is the responsibility of the purchaser to confirm legality in their state or providence before purchase.

GARN will pursue retesting to get that single missing data point; however, this will take significant time (months) and dollars (into the 6 figures). I hope this story did not detract from your coffee and donut. Thank you for your time, continued interest and support of our products and mission….and please stay safe.

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