EPA and Varmebaronen – Is it the end of the line?

Varmebaronen was sent a letter from the EPA after they requested to renew their certificates for the Vedolux boilers. The letter was sent prior to the expiration of the certificate.  The EPA reply letter gave 10 days to come up with a resolution to various deficiencies they found when reviewing the original test. The original tests were made approximately 5 years prior. The test agency  named Research Institutes of Sweden (RISE)  became an approved EPA test site to be able to test the boilers for Varmebaronen. The lab worked to the best of their ability conducting the tests since this was the first time the test Method 28 PTS was actually used after the new rule was implemented for certifying a boiler. The lab provided the information the EPA requested at that time. At the end of the day the EPA accepted the results and gave them the certifications for each boiler they tested.  All of the of the items in the EPA deficiency letter could have been be easily fixed at the time however with the passing of time it is not so easy to come up with the requested information. Points like some additional text in the manual explaining what you can and can not burn, importance of smoke detector language, more details on draft, how to exercise warranty etc would be easy to fix.  However some information simply could not be reproduced without a new test. These items included, close up photos of the individual wood pieces which were used in the original test, a signature of  the person who performed the conditioning burn of the test boilers and their qualifications, revise the report to demonstrate the fuel density was greater than 10lb/ft3 , include all notes taken by the test personnel during the process, instructions the manufacture may have given to the test agency to make sure the notes were consistent with the manual, among other items. These items for the most part should not have affected the end result of the test and are simply paperwork or technicalities following the “letter” of the law.  A retest using the same protocol would give similar results so this  isn’t  a matter of a dirty boiler getting by by gaming the system. Varmebaronen did not plan on testing all their models again so soon and was going for a renewal of the certification  since nothing materially changed to require a new test. The manufacturer and the test agency did try to figure out with the EPA what could be done but they said considering the experience dealing with the EPA it felt like they were talking past each other and there was not a clear path forward. They were not confident conducting another test given how much trouble it was communicating with the EPA and how things may be interpreted. Different people can look at the same NSPS text and come to more than one conclusion. It seemed to Varmebaronen there was no clarity and anything they did at this time would probably be obsolete in 5 years. Most likely new rounds of tests would again be required. Varmebaronen said they had to cut the losses until there is certain clarity with the regulators. I don’t know if they ever will come back to USA with certified models if things get resolved with the test methods. At this time things appear to be “up in the air” at the EPA.  Varmebaronen continues to manufacture the lambda models we sold. For the foreseeable future we will continue to support users with parts including any legacy models. We still have a few models left which were manufactured while the models were certified and will sell them until stock is depleted. The lambda models left  have all the proper EPA labeling.  If you want to see the problems with the EPA wood heater program and the uncertainty that is evident please read the “report at glance” and “full report” at this link.  Report: The EPA’s Residential Wood Heater Program Does Not Provide Reasonable Assurance that Heaters Are Properly Tested and Certified Before Reaching Consumers