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 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 emission limits put in place in May 2020. The present EPA limit 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In April 2020 (5 years after approval) the EPA officially rescinded our approval citing the lack of 1st hour emission data point.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.

January 2023 Update: It is foolish to pursue retesting (at significant expense and time) while the test method is yet again undergoing more changes by the EPA. Manufactures, test labs and states all wish the EPA would just solidify one reasonable test method; rather than change it every two or three years and require retesting of all products. GARN® will not pursue retesting until the EPA settles on a final test method. Thank you for your time, continued interest and support of our products and mission. I hope you enjoyed your coffee and donut.

GARN® WHS – WOOD HEAT STORAGE

42 YEARS OF INNOVATION WITH MANY FIRSTS:

THE INNOVATIONS:
– EVERY UNIT BUILT SINCE 1978 HAS FULLY INTEGRATED THERMAL STORAGE
– EVERY UNIT BUILT SINCE 1983 USES 2 STAGE GASIFICATION COMBUSTION
– EVERY UNIT BUILT SINCE 1985 INCLUDED AN ANTI-CORROSION CHEMICAL PROGRAM
– EVERY UNIT BUILT SINCE 1985 IS UL & CSA CERTIFIED
– EVERY UNIT BUILT SINCE 1988 CAN BE USED AS THERMAL STORAGE FOR ACTIVE SOLAR SYSTEMS
– MOST UNITS BUILT SINCE 1988 CAN BE FITTED WITH OPTIONAL ELECTRIC BACK UP

THE FIRSTS:
– FIRST HYDRONIC WOOD UNIT WITH BUILT-IN THERMAL STORAGE (1978)
– FIRST HYDRONIC WOOD UNIT WITH DIGITAL CONTROLS (1985)
– FIRST HYDRONIC WOOD UNIT TO OFFER FULLY INTEGRATED ELECTRIC BACK UP (1985)
– FIRST HYDRONIC WOOD UNIT TESTED WITH CORDWOOD PER ASTM E2618-09 APPENDIX X1
– FIRST HYDRONIC WOOD UNIT CERTIFIED TO CANADIAN STANDARD CSA B415.1-2010
– FIRST HYDRONIC WOOD UNIT EMISSIONS CERTIFIED PER ASTM E2618 ANNEX A1

GOOD NEWS: ALL MODELS AVAILABLE IN THE US, ALASKA AND CANADA

MOST UNITS SOLD SINCE 1985 ARE STILL IN OPERATION

THE ORIGINAL 1985 GARN® WOOD EMISSIONS TEST LAB: Inventor and Engineer Martin Lunde began researching wood combustion and emissions in 1975. In 1985 (not 1995, not 2005, not 2015) he established a wood emissions test lab in St Paul, MN. To enhance accuracy with automatic data collection, a Hewlett Packard computer-based data acquisition system was coupled with an Ametek Thermox gas analyzer. Fifty-three (53) full tests were run in 1985 and 1986. Multiple temperatures, airflow (CFM) and exhaust gas composition were recorded every 20 seconds. The fuel was market available cordwood and the unit tested was a prototype GARN® WHS model 1500 H, virtually identical to current WHS 1500 H model. That testing confirmed GARN® WHS to be very efficient & emission clean, 38 years before the present EPA limits. Since 2013 independent labs have confirmed GARN® WHS superior emission and efficiency performance.

CLEAN TECHNOLOGY DOESN’T REQUIRE LAMBDA SENSORS: Many believe that burning wood cleanly and efficiently requires the use of sophisticated sensors and computer technology. A majority of EPA certified downdraft gasifiers use lambda sensing technology to continually adjust dampers to achieve optimum combustion efficiency. The belief is that added complication ultimately means better performance, but the truth is that burning wood is harder to control and more variable than burning gasoline in your car. In the real world, lambda sensors can fail (leading to poor combustion) and require replacement (at significant cost by a service person). GARN® WHS units use a single-speed blower and a single feedback thermocouple to achieve good combustion. GARN® WHS does NOT need variable speed motors, variable position dampers, exotic sensors, etc. This is easily seen when reviewing the GARN® WHS emission numbers. As my father used to say “the fewer the parts, the fewer the problems.”

GARN® WHS: SIMPLE & ROBUST = MORE HEAT, LESS WOOD, FEWER EMISSIONS