21-0419 Exception Request for Indoor Fireplace


Dear ILFI,

This email serves as motivation and response to your dialogue post #9 response: Request for Ornamental Fireplace in Transects L1, L2, L3. The Green School South Africa Project Team request the approval for an indoor fireplace under the available and applicable Exception:  I06-E5 8/2011 Ornamental Fireplace in Transects L1, L2, and L3 (please see attached).

Compliance requirements:

  1. Heat Source: Cannot be a primary heat source.
  2. Enclosed: Must be closed.
  3. Nordic Swan Standards: "… meet current Nordic Swan emission and efficiency standards."

"Nordic Swan Standards (through June 2017)

Emissions criteria:

  1. Organic gaseous carbon (OGC): 100 mg/m3
  2. Carbon monoxide (CO): 1250 mg/m3
  3. Particles: 3.0 g/kg (for up to 4 loads); 6 g/kg (for each load)

Efficiency criteria:

  1. 76% for manually operated stoves or inset fireplaces for intermittent use."
  2. EPA 2013 PM2.5:

The project must be in a region that is compliant with the EPA 2013 PM2.5 primary annual fine particle standard of 12 μg/m3.


The custom concrete indoor fireplace creates a non-combustible open environment where a fire can be built, started, and maintained to provide aesthetic/ornamental and heating of winter beverages relating to the cultural heritage of the school and area. The fireplace works in tandem with the specifically engineered chimney which provides a passageway and draft for by-products (minimal due to alternative fuel source) from the fire to leave the space safely and efficiently.


The indoor fireplace in ''The Heart of School (dining hall)'' is envisaged to be used mainly during the Winter months and only once a month which is a maximum of approximately 4 times/year. The idea is to utlise the fireplace for cultural school events during Winter, harnessing an experience of community and cultural history.


  1. Heat Source:

The Project Team confirms that the indoor fireplace will not be a primary heat source. The fireplace will be used on the rare occasion for gatherings in the " Heart of School" space as supplementary heating.

  1. Enclosed:

The Project Team confirms that the closing of the fireplace is not feasible for the school for the following reasons:

  1. the intention of using the fireplace in the Winter months is to be able to heat up big pots of hot chocolate for school events, such as family movie nights, cultural events, etc.
  2. The closing of the fireplace is not practical and poses a potential safety risk as kids might be inclined to touch the glass which does heat up.
  3. The project team believe that the carbon footprint associated to enclosing the fireplace does not warrant the frequency and the alternative fuel source being proposed.

The project team request if the ILFI could propose an alternative compliance for the enclosure of the fireplace as the frequency is minimal and alternative fuel source is low in emissions?

  1. Nordic Swan Standard:

The Project Team confirms that, due to the unavailability of "eco-labelled" fireplaces in the project's National region (South Africa), compliance with the Nordic Swan emission and efficiency criteria cannot be confirmed.

Emissions Criteria

  1. Unfortunately, third-party certifications for fireplaces in the South African Market (sustainability industry) are not available.
  2. To transform and encourage the uptake of energy-efficient and low emission fireplaces in South Africa, the Project Team propose advocating for third-party sustainability certifications for fireplaces.
  3. To lessen the environmental impacts of combustion, the Project Team propose using an alternative fuel source which is better performing and consider an ''eco''-firewood called Good Wood (refer to the infographic attached for more information) which is local and readily available.
  4. Good Wood is an engineered wood product designed for the purpose of being a less harmful alternative to regular firewood (https://www.goodwoodlogs.co.za/).

Benefits of  Good Wood:

  1. Made from 100% recycled sawdust.
  2. Contributes to waste management.
  3. Manufactured to be space efficient resulting in efficient use of packaging material and transporting.
  4. Consistently dry (10-15% moisture content)
  5. Therefore, less firelighters required.
  6. Lights easily
  7. Emits minimal smoke.
  8. Easy to kindle.
  9. Has a low-smoke odour.
  10. Results in less than 4% ash remains.
  11. Has a 2 hour burn time per piece.
  12. Local and readily available.

Efficiency Criteria

  1. The Project Team cannot confirm the efficiency of the fireplace as it is a custom built-in inset. However, the Project Team are prepared to take all measures available to improve combustion efficiency i.e.:
  2. Good Wood fuel - Instead of burning typical firewood, the engineering of Good Wood fuel ensures that fuel is burnt as efficiently as possible due to its density, moisture content and ability to burn for 2 hours resulting in only 4% residue.

Please could ILFI have provide any other suggestions to improve combustion efficiency? The Project Team will happily investigate the feasibility of such suggestions.

  1. EPA 2013 PM2.5:

The Project Team confirms that the  EPA 2013 PM2.5 standard does not include the Project's local region (Paarl, Western Cape, South Africa), the following information is available for the Projects Local Region:

  1. The project local region's air quality has been studied in recent years as required by the National Environmental Management: Air Quality Act (NEMAQA) (Act 39 of 2004) using the National Ambient Air Quality Standard (NAAQS) for PM2.5, PM10, NO2, SO2, carbon monoxide, ground-level O3, lead and benzene (Department of Environmental Affairs 2005, 2012).
  2. An annual study using six ambient air quality monitoring stations assessed real-time levels of the criteria using equivalent methods of the United States Environmental Protection Agency and in accordance with ISO 17025 guidelines (Department of Environmental Affairs 2005; Western Cape Air Quality Management Plan 2016). The mean PM2.5 level for Western Cape for the 1-year study period was 13.3 μg m−3, which exceeded the yearly WHO air quality guideline (10 μg m−3).

From the above research, the project team confirm that Paarl does not have any air monitor data available. Therefore, PM2.5 is not currently measured in accordance with the  EPA 2013 PM2.5 primary annual fine particle standard as the long-term determination of the annual average PM2.5 (as per the EPA standard) is unavailable.

Alternative compliance: To try and obtain the required information, the project team has queried the availability of historical data from IQair for the Projects local region (https://www.iqair.com/us/south-africa/western-cape/paarl). However, it is seen that no ground-based air monitoring station information is available, therefore the public has no access to real-time, public, air quality measurements, so the AQI data available for Paarl is modelled using satellite data and is therefore an estimate.

The project team kindly request if ILFI could please provide comment if the above alternative compliance approach is acceptable (provided historical data is available), alternatively could further guidance/compliance for the  EPA 2013 PM2.5 primary annual fine particle standard?


The inclusion of the indoor fireplace cannot align with the current compliance requirements for the available Exception:  I06-E5 8/2011 Ornamental Fireplace in Transects L1, L2, and L3. The project team will implement all measures available to relieve the environment of unsustainable practices and request further guidance/assistance from ILFI to ensure compliance with the available exceptions for Imperative 6: Net Positive Energy, Combustion Facilities.

We thank you for your consideration of approval and assistance with demonstrating alternative compliance with the Imperative.


Exception EC-004 8/2011 Ornamental Fireplace in Transects L1, L2, and L3 provides a pathway, with clear conditions, for use of wood-burning fireplaces, which are otherwise prohibited by the Standard. The project team has not made the case that a closed fireplace, which provides the basis for subsequent air quality-related requirements, is infeasible.

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