Manufacturers & Vendors

This web page is dedicated to solid fuel-fired heating device manufacturers and vendors to assist in communication on the status of their devices for possible sale and installation within the Fairbanks North Star Borough’s (FNSB) nonattainment area.

On January 8, 2020, regulations pertaining to the FNSB fine particulate matter (PM_2.5) Serious Area State Implementation Plan (SIP) became effective. Those regulations have a number of provisions that regulate solid fuel-fired heating devices. Implementation of those regulations is currently in progress.

The Alaska Department of Environmental Conservation (DEC) has been reviewing the certification test results of EPA Step 2 certified devices. The process and lists/results are listed below.

Select any of the boxes below to go to the specific portion of the web page.

Questions and Answers

Regulations/Methods (LAST UPDATED 02/01/2022)

The regulations may be found in the Air Quality Regulations. In summary, 18 AAC 50.077(b) & (c) require that wood heating appliances installed in the FNSB PM_2.5 air quality nonattainment area must meet the following requirements:

Have a rated heat output capacity of less than 350,000 Btu per hour validated by certification testing.
Hold a valid certification from EPA using a test method approved by DEC and for which the Department has reviewed and accepted the underlying certification test results.
Have a complete certification test report posted on the manufacturer’s website that provides sufficient data to assure that testing was completed in accordance with all 40 CFR Part 60 requirements.
Meet the designated PM emission limits codified in 18 AAC 50.

Methods - The regulations require that test results must be obtained using the listed test methods applicable to the specific device within the regulations. Alternative test methods, including broadly applicable test methods, may be used if approved by both EPA and the department; and results must be obtained using the listed emission concentration measurement methods.

All Federal Reference Methods are approved. Alternative test methods are under review and may continue to be used unless specifically disapproved.

Fully approved alternative test methods are:

ALT-140 (Updated 4/9/2021) - Broadly Applicable Test Method for cordwood stoves

Alaska Disapproved alternative test methods are:

None at this time

Note: EPA recently revoked ATM-125 and ATM-127, effective February 23, 2022. Devices certified using this method prior to the effective date will be reviewed on a case by case basis.

PROCESS (LAST UPDATED 02/01/2022)

Process for certification test report review:

Each test report reviewed, and a summary sheet filled out. Example summary sheets: Cordwood, Pellet
The summary sheet was developed based on a Regulatory Basis Mar2021
A preliminary finding by reviewer is identified.
Each test report summary is then reviewed by a committee made up of multiple state/local programs.
A final determination is made by the committee.
Results are posted online through lists and summary review sheets.
Manufacturer has an opportunity to review their certification test report summaries and submit corrections, any substantiated errors or corrections will be applied to the summary sheet.
AK List Status is available on the various lists. Milestone dates track those devices on the transition list. Once a milestone date passes the device is moved to the no determination list. Requests to extend milestone dates received after February 2, 2021, will only be extended if the device’s certification test report meets the criteria identified in the Decision Matrix.
DEC continues to work with EPA on the various issues discovered regarding the review of the certification test reports. As information from EPA becomes available DEC will continue to refine the Decision Matrix, Regulation Basis Document, lists and website accordingly.

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LISTS/RESULTS/STATS (last updated 11/07/2024)

Transition Device List includes individual milestone date fields when devices are proposed to be removed from the approved list unless requirements are addressed. See Instructions for more information.

Approved Device Lists

(Approved Device Lists Oct2024)
(Wood Stoves, Pellet Stoves, Pellet Hydronic Heaters)

Transition Device Lists

(Cordwood Transition List Oct2024, Pellet Transition List Jan2024)

No Determination Device List

(No Determination Device List Oct2024(Devices that are on EPA-certified list but have not been reviewed)

Disapproved Lists

(Cordwood May2024, Pellet Jan2024, Hydronic Mar2021)

Summary Review Sheets

(Cordwood Sep2024 , Pellet Sep2024, Hydronic Jan2024)

See Instructions for directions on how to move a device between lists.

The Decision Matrix explains which flags may still be present and a device may remain on the Approved List. Some flags are dependent on feedback from EPA. General statistics on the results of the certification review are provided for cordwood and pellet devices.

Options for Addressing Deficiencies Through Retesting

Options Document (Last Updated June 1, 2021)
M28R report template (coming soon)
Alt 140/IDC report template (coming soon)
Pellet report template (coming soon)

Certification - Expiration Tracking

Certification - Expiration Tracking Workbook (Cordwood & Pellet Stoves) (Last Updated February 1, 2022)

The Certification - Expiration Tracking is for cordwood and pellet devices

IMPORTANT DATES (LAST UPDATED 03/01/2022)

July 31, 2020 - Updated Approved Device Lists posted.
August 31, 2020 - Lists (Transition, Disapproved, No Determination) are posted on Manufacturer and Vendor web page. Devices on the Transition List will have an initial milestone of November 1, 2020.
September 1, 2020 - DEC updated Approved Device List by removing highlighted devices that had not been addressed by the manufacturer from the Approved List to the Disapproved List, posts the Disapproved List.
September 1, 2020 - Manufacturers could request a copy of their devices' certification test report review summaries. Contact Cory McDonald and follow the instructions below.
October 1, 2020 - Deadline for manufacturers to submit a written commitment to providing new or revised information by May 1, 2021, or submit new or revised information for re-review of minor or major deficiencies identified. Updated milestone dates were added to Transition List as appropriate.
October 1, 2020 - DEC began review of any new information submitted.
November 16, 2020 - DEC posted all summary review sheets. These included any corrections, if errors were identified by manufacturers and corrected information provided, as indicated above, from existing tests. Summary review sheets are updated as necessary.
February 1, 2021 - February 1, 2021 will now be the first major milestone expiration date. DEC will re-examine the status of each device and begin to update the various lists. DEC will remove devices from the Approved Device List and add them to the No Determination List for those devices currently listed on the Transition List where the manufacturer has not submitted information or a written commitment that data addressing deficiencies will be submitted to DEC by May 31, 2021. New milestone dates will be added to the remaining Transition List devices as necessary based on new information or commitments received from manufacturers. DEC will also post a decision matrix that will explain why some devices will remain on the Approved List even though their summary review sheet continues to display flags.
February 2, 2021 - DEC posted the updated lists, and Decision Matrix. All requests for milestone date extensions, after this date, must meet the criteria within the Decision Matrix to either remain or be added to the Approved List. Those devices on the Approved List with milestone dates, that have been tested with ASTM 3053 have been highlighted. DEC has concerns with ASTM 3053 and continues to evaluate the test method. DEC is actively seeking options with EPA to address concerns and has requested approval of an alternative cordwood test method from EPA.
June 1, 2021 - Any devices whose deficiencies have not been addressed, and do not meet the criteria in the Decision Matrix, will be removed from the Approved Device List and placed on the No Determination List, unless their milestone date has been extended.
September 14, 2021 – DEC announces change to review process. DEC will continue reviewing certification test reports, but only after EPA has ‘cleared’ the report for those certifications issued prior to July 1, 2021. For devices certified after July 1, 2021, only those devices that request a DEC review will be reviewed.
February 1, 2022 – DEC posts major update to cordwood lists that incorporates review findings related to the EPA Deficiency List posted in April 2021. Also, DEC announces its policy regarding renewals of existing certification tests. DEC will generally not accept EPA renewals of existing certification tests (those conducted prior to April 16, 2021) given the deficiencies found. DEC also announced how it will address the use of ASTM 3053 given EPA’s revocation of the method for certification testing.
March 1, 2022 – DEC posts pellet list update that incorporates review findings related to the EPA Deficiency List posted in April 2021. Also, DEC confirms its earlier announcement regarding the policy on renewals of existing certification tests. DEC will generally not accept EPA renewals of existing certification tests (those conducted prior to April 16, 2021) given the deficiencies found.
On-Going - DEC will post, monthly, updates to lists, worksheets, information as needed. DEC is targeting postings within the first week of the month. One week prior to an anticipated posting, DEC will stop review of any data received to focus on posting preparation. Any data received within a week of a posting will not be posted until the following month.

INSTRUCTIONS (LAST UPDATED 02/1/2022)

How to report errors or request corrections:

Send an email to Cory McDonald
Identify device(s) name and report number(s).
Provide publicly available link of report for device(s).
Identify error or correction needed.
Identify each specific page number in report or report appendix that corresponds to the identified error or correction.
Device model name must match the model name on EPA’s database for each device.

Revised or Updated reports – to address identified deficiencies

How to submit revised or updated report for devices with an existing summary review sheet:

Send an email to Cory McDonald
Identify device(s) name and report number(s).
Identify error(s) or correction(s) that the revised or updated report is addressing.
Provide proof that a copy of the revised or updated report has been submitted to EPA.
Provide publicly available link of report for device.
Device model name must match the model name on EPA’s database for each device.

Please do not submit CBI reports, DEC will not accept or review CBI reports in this process.

New Reports – device with an existing summary review sheet

Send an email to Cory McDonald
Identify device(s) name.
Identify old report number and new report number (if applicable).
Proof that report has been submitted and accepted by EPA.
Provide publicly available link of report for device.
The review process will take several weeks depending on the number of reviews currently being conducted. Milestone date in the Transition List will be adjusted as necessary.

Device whose certification test report has not been reviewed (EPA certification after July 1, 2021 - No Determination List)

Send an email to Cory McDonald
Request that device be reviewed for inclusion in the Approved Device List
Identify device name.
Identify report number.
Device must be on EPA certified list.
Provide publicly available link of report for device.
The review process will take several weeks depending on the number of reviews currently being conducted.
Once review is completed, a copy of the summary report will be sent to Manufacturer for review. Report will be posted on the Manufacturer page after approximately 45 days unless errors or corrections are identified. Once complete, the summary report will be posted even if final determination is pending – minor or major, or disapproved. If final determination is pending, major, or minor, the device will remain on this No Determination List with the Pending in the status column and will not be placed on the Approved List, until Pending items are addressed.
Until a final determination of Approved is made, the status column on the No Determination List will be updated and used to indicate where in the review process the device’s certification test is at.
No Request Received
Request Received [Date]
Reviewed-Information Required for approval
Report Deficiencies Not Addressed

Note: If final determination is Approved, the device will be removed completely from this list and placed on the Approved List.

QUESTIONS AND ANSWERS (Last UPDATED 02/01/2022)

As questions are submitted to DEC, they will be added to the list of questions below, with their answers. Answers may be updated as the Alaska review process continues to evolve or guidance from EPA is received. DEC will update this approximately once a month so answers to questions received may be delayed until the next posting cycle. Please note that the Questions and Answers are in no specific order.

How is Alaska going to address EPA’s revoking ASTM 3053? Added (02/01/2022).

Alaska is supporting the EPA decision to allow devices certified with the ASTM 3053 test method to remain certified and possibly be on Alaska’s Approved List even though the ASTM 3053 method will be revoked on 2/23/2022. However, in order to be on Alaska’s Approved List, the certification test that has used ASTM 3053 must still have Alaska acceptance of the underlying certification test report. If DEC accepts the report results the device may remain on or be added to the Alaska Approved List. As of 2/1/2022 there is one ASTM 3053 certified device on the Approved List and another that may be added when some identified deficiencies have been addressed.

Recertifying a stove using a different test method does not exempt the stove from the ADEC looking back at the data from any or all previous tests. Yes/ No? So if a manufacturer makes one K-list design change and then retests a unit with either ASTM E3053 or EPA M28/M28R, does that suffice to eliminate all previous test data? Added (02/01/2022).

Correct, DEC will consider all certification test data when making a determination for a model line. If EPA approves a modification under 60.533(k) & 60.533(b)(1) that results in a model name change and a new certification, then DEC will review that as a new certification result and will not consider any previous certification test data. However, if the past certification test has expired, DEC will not consider that expired test report’s results when making a determination but instead will rely on the results from the re-test.

Where do we stand having tested exclusively with the ASTM 3053 method? I see where it can be used if it is approved by ADEC. Is it an approved method, or is it on track to become approved? [Amended 2/01/2022]

See ADEC’s response to the question regarding ASTM 3053 revocation as noted above.

Is there a process I could use to request that ADEC NOT use the first-hour filter data from an excluded (outlier) run? Having specific protocol within the method to follow, we replaced a bad run with 2 more test runs at the same burn rate. Since the method allowed it (as does the crib method), we had no reason to assume it could be a problem for us in the future. Alaska's SIP doesn't appear to address the outlier run issue directly. There is language referring to "valid" runs, and while an outlier run is valid in the sense that it was a completed run and is included in the test report as required. However, it would not be unreasonable to define the run as invalid for the purpose of calculating the weighted average, since it is in fact not used in the calculation. [Added 4/06/2021]

DEC reviewed the underlying certification test results for comparison to the 6.0 g/hr standard. DEC’s review found that a test run may be considered invalid for certification purposes, but the 1-hour filter data is still a valid measurement, representative of emissions from the appliance, and suitable for comparison to the 6.0 g/hr emission standard.

Once we get revised reports reviewed and approved by the EPA, and posted on our website, what is the best procedure for requesting that Alaska reconsider the model lines for inclusion on the list? [Added 4/06/2021]

Notify DEC that the above steps have been completed and request a review. Instructions are included in the Manufacturers & Vendors web page above.

Why has DEC flagged train precision when it is clearly stated as OK (meeting 7.5% requirement) in the test report? [Added 03/02/2021]

Calculations and percent for train precision are required in test report. This has been confirmed with EPA. DEC will not derive calculations from data to confirm compliance where none are previously given. To clear this flag, the calculations will need to be shown and the data supporting the calculations will need to be available to allow the calculations to be verified.

Will DEC accept statements from the lab regarding the appropriateness of negative filter weights and preburn burn rates? [Added 02/02/2021]

DEC will not accept standalone statements from labs, especially in absence of any back up documentation in the original reports. DEC will forward this issue to EPA for a determination, which will be required in order for DEC to consider changing the status of the flags.

Are Firebox Calculations considered to be Confidential Business Information (CBI)?

Please refer to the Regulatory basis document, Appendix B, page 50, where you will see that in an email from Steffan Johnson of the EPA it is clearly stated that firebox dimensions are not considered to be CBI.

Why 6 grams per hour? Why has Alaska selected a 6 gram per hour 1st hour filter pull standard and how does this related to the PM2.5 problem in Fairbanks Alaska? Where does this magic number come from? Why not 3, or 12 g/hr? Is this number somehow used in modeling? If is, of course, a number derived from Laboratory work; how is that relevant to Fairbanks?

Please see ‘DEC Response to Comments’ dated November 19, 2019: Response to Comments (PDF) (page 37-38) EPA Comment (50) and DEC’s response.

Has DEC submitted a list of questions to EPA, OECA? Will those affected in the industry receive copies of these questions? Could you please share these with the industry?

DEC has not submitted a list of questions to OECA; therefore, we do not have a list to share. As issues arise that require EPA consultation, we reach out to them for guidance. When this guidance comes in the form a written response, we can circulate that information.

What type of other regulations affecting solid fuel fired devices exist in the Fairbanks nonattainment area?

For a list of standards and requirements pertaining to the Fairbanks nonattainment area please refer to the Solid Fuel-fired Heating Device Standards & Requirements web page.

What other organizations are working with DEC on this review project?

The review process involves a committee representing managers from multiple agencies within and out of the state of Alaska. This group often raises questions about the content of the reviews, and the report is often re-reviewed. DEC is now working closely with the EPA in order to answer questions and concerns regarding the federal requirements.

Do all review flags need to be addressed for a device to remain on the approved list?

Manufacturers should attempt to address all flags they are able to. However, having flags does not guarantee a device will be excluded from the approved list.

What determines the severity of the review flags? [Last updated 02/02/2021]

Initial reviews included different types of flags (red, orange, yellow). Red indicated missing or validated inaccurate or conflicting information from emission related data requirements. Orange flags indicated more inaccurate information or what appeared to be mis-handled information or process. Yellow flags indicated there was partial/incomplete information.

What are manufacturers to do about flags or issues that cannot be resolved through providing information (i.e. if the information/data does not exist or was not recorded)? [Last updated 02/02/2021]

It will depend on the information/data that is missing or was not recorded. DEC is developing a Decision Matrix which will identify those issues/data that must be present in order for a device to be on the Alaska Approved Device List. If the information/data does not exist or was not recorded, such as a 1-hr filter pull (that is needed to meet an Alaska regulation), the device will not be allowed on the Approved List. It is up to the manufacturer to decide whether to re-test to participate in the Alaska market or not. It will be up to EPA to determine the validity of the certification test if there is data that does not exist or not recorded properly during the certification test.

Local Impacts. I am told that the requirement to remove any wood heater that does not meet the current EPA standard before transferring real estate will include units which are built in. Is that the case?

Real Estate Requirement - this is the website regarding devices that may stay and what may need to be removed within the FNSB nonattainment area. It is noted that there are some exceptions and there is the ability to request a temporary waiver. These exceptions include those types of devices that were previously exempt from EPA certification. We encourage real estate agents and homeowners to contact us for assistance.

“Pre-burn data” is flagged as partially report Q1: This is a nomenclature issue, but I am assuming based on the comments, this item is in reference to the required pre-test conditioning of a appliance, rather than the pre-burn cycle immediately preceding a “hot start” certification test?

Correct, this is the conditioning data required per the test method and EPA regulations.

“Pre-burn data” is flagged as partially report Q2: The comment section indicates that data does not meet requirements, could that be expanded upon? The conditioning data summary sheet (attached for reference) has hourly scale and temperature data.

The method specifies that conditioning must be a certain number of hours at the medium burn rate. If data was reported but did not provide sufficient information to determine that both the hour and burn rate requirements were met, it was flagged as partially reported.

“Pre-burn data” is flagged as partially report Q3: Could you explain the process the reviewer went through to determine that only 8 of the 50 hours meet the medium burn rate requirements? A burn rate (as defined by the method) can only be calculated over a full burn cycle of a fuel charge. Considering that the unit was loaded with varying fuel charges and rarely burned to “completion” before reloading, any attempts at calculating an actual burn rate are futile. We have adequately documented that pre-test conditioning was performed, we attest to the fact that it was done at a medium air setting, and if you really want to question that data, a more useful (though not perfect) comparison would be average flue and catalyst temperature data from this set versus the data from the “medium” burn rate certification tests.

Both ASTM 2780 and ASTM 3053 define burn rates as the amount of fuel burned over a period of time, not stack temperature or catalyst temperature. As such, the reported kg/hr metric (within the test report) was used to assess medium burn rate conditions of the test’s device.

Specifically, this report calls out that the 3rd party certifier was not reported. As I have stated before and confirmed by EPA, this information is not required in the EPA Report. [Last updated 02/02/2021]

DEC regulation 18 AAC 50.077(c)(2) states: “have a valid certification from EPA under 40 C.F.R. 60.533, revised as of July 1, 2019, and adopted by reference, for which the department has reviewed and accepted the underlying certification test results.” Please note the regulation states ‘underlying test results’, not report. In order to meet this requirement, all elements of the certification are being reviewed. Please submit the 3rd party certifier information (the 3rd party certifier and if they report was certified). As of this February 2021, of the 131 report reviews on cordwood stoves conducted only 18 do not contain this information, the third-party certification – who the certifier was and if the report was certified. Of the 96 pellet stoves report reviews conducted, 84 do not contain this information. We would like that the 3rd party certifier information as well as if the report was certified. The issue will remain flagged until the information is submitted.

Also, this review calls out that the dates of the aging were not provided. ASTM E2779 does not call out that the date of the aging is required.

As mentioned, DEC is reviewing the underlying certification test results, not just the certification test report. DEC is interested in when the aging was done in conjunction with the certification test. Please submit the dates the aging was conducted. This issue will remain flagged until the information is submitted.

The review also calls out the 30-day notice “could not be determined.” Again, the 30-day notice is not part of the EPA test report.

As mentioned, DEC is reviewing the underlying certification test results, not just the certification test report. Please submit a copy of the 30-day notice. We would like that information. The issue will remain flagged until the information is submitted.

What if a device has two step 2 certification test reports using two different methods?

If the tests were performed prior to September 1, 2020, each test report, for each method, will be reviewed and subject to Alaska requirements. Both reports must pass to be approved given they are for the same design. If either one fails an Alaska standard, (2.0 g/hr emission average or the 6.0 g/hr 1-hr filter pull), then the device will not be on the approved list. DEC is working to develop a process for those who may wish to re-test and will provide guidance at a later date.

If a re-test is considered, are there any new requirements?

DEC is working to develop a process for those who may wish to re-test and will provide guidance at a later date. Please contact DEC before conducting any re-test of a device.

Why is Alaska reviewing certification reports?

The Clean Air Act section 189(b)(1)(B) and 40 C.F.R. 51.1010 describes the requirements for Best Available Control Measures (BACM). These requirements state that Serious nonattainment areas are required to implement all measures implemented in other areas unless the measure may be found to be technically or economically infeasible. Furthermore, CAA section 189(d) and the final PM 2.5 Rule requires the state to include ‘options not previously considered as BACM’. Missoula City-County Montana regulations (Section 9.203.1.a) allows installation permits only for pellet stoves emitting no more than 1.0 gm/hr. Alaska embarked on the certification test review and the establishment of a 1-hr filter pull standard as an alternative to a pellet only program for the nonattainment area as DEC feels this approach meets the communities desire for more device options and is at least equal to the Missoula requirement (as demonstrated that there are pellet devices unable to meet the 1-hr 6.0 gm/hr standard established by DEC). However, EPA will need to complete its review and action on the Serious SIP to verify that Alaska’s approach meets the BACM requirement for wood heater standards.

Alaska is also reviewing the certification test reports for those US EPA appliances certified as complying to the Step 2 standards per 40 CFR part 60 Subpart AAA or Subpart QQQQ, and as reported on the EPA Wood Heater Database, that are or wish to be on the DEC Approved Device List to ensure compliance with the Alaska standards and requirements in accordance with 18 AAC 50.077. Alaska’s regulation requires DEC to review and accept the underlying certification test results. This effort to review certification reports is to ensure that wood burning may continue in the Fairbanks North Star Borough nonattainment area now and into the future. In order to continue improving the air quality, reach attainment and continue to allow burning from a range of devices, ADEC needs assurances that the devices that are allowed to be installed within the area were tested in accordance with all requirements detailed in the US EPA regulations without anomalies, deviations, or defects.

A single certification test is relied upon to demonstrate compliance for potentially hundreds of appliances within a PM2.5 Serious nonattainment area. In this nonattainment area, residential wood burning has been determined to be the largest contributing source sector; therefore, certification test reports must be held to the highest standard for makes and models being installed to ensure that low-emitting appliances are used to provide emission reduction benefits into the future. In addition, the New Source Performance Standards (NSPS) Subparts AAA and QQQQ require a recertification every 5 years; however, a recertification with a new test is not guaranteed. It is possible that a device could pass a single certification test and meet NSPS Subpart AAA or QQQQ requirements for years if not decades. With the new federal regulations specified in NSPS Subpart AAA and QQQQ, all certification testing has been completed within the last five years. Completing a full report review is important to ensure that the goals for the program and community are met now and into the future

A single 1 – hr filter pull value exceeds 6.0 g/hr standard, but all of the other test runs meet 1-hr filter pull values. Does an entire certification report need to be done or just a replacement test run?

18 AAC 50.077(c) are based upon the EPA certified test methods and underlying certification test results. The standard and review are based on formal test reports. Therefore, for a device to be on the Approved Device List, it must have an EPA certified test that the Department has approved the underlying results. DEC is working to develop a process for those who may wish to re-test and will provide guidance at a later date. Please contact DEC before conducting any re-test of a device.

Is Alaska requiring manufacturers to pay for additional certification test(s) to meet Alaska’s standards? [Last updated 02/02/2021]

No, it is the manufacturer’s choice to conduct additional testing, if needed, and if the manufacturer desires to sell devices in the FNSB nonattainment area. Please contact DEC before conducting any re-test of a device.