21-0527 Alternate Standard for Enclosed Wood Burning Fireplace 3.X

As of 10/12/22, this exception is slightly revised from below. See 22-1012 Revision to Ornamental Fireplace in Transects L1, L2, and L3.


Referencing: Energy Petal Handbook Exception I06-E5 8/2011 Ornamental Fireplace in transects L1, L2 and L3.
Request: Temporary exemption from I06-E5 8/2011 emission requirements within the United States.
Our projects - both registered under LBC Standard 3.1, both located in Bend, Oregon (a region in compliance with EPA 2013 PM2.5  primary annual fine particle standard of 12 g/m3) and both within Living Transect L3 - include River Sol, a single-family residence with ADU pursuing Living Certification, and One Riverstone, a single-family residence pursuing Petal Certification. Both projects wish to include a closed, ornamental, wood-burning fireplace – not to be used as a primary heat source.
Having researched over ten (10) North American and European high performance wood-burning fireplaces, our findings suggest there are no wood-burning fireplaces available in the United States marketplace that comply with Nordic Swan Ecolabel emission standards. It is impossible to confirm, however, as emissions testing procedures and measurement units used by the Environmental Protection Agency (EPA) and the European Union (EU) differ from each other and from those used by the Nordic Swan Ecolabel group.
For example, particulate emissions must be less than 2.5g/hr per the EPA (cord wood), yet less than 3.0g/kg per ILFI I06-E5 8/2011/Nordic Swan. And in the EU, particulate emissions are measured as mg/Nm3. The difference in units is not unique to particulates but applicable to all relevant emission standards. 
With our project owner’s design goals and (per the intent of I06-E5 8/2011) the strong cultural legacy of the hearth and hygge in mind - and in recognition of current market realities – we request ILFI grant a temporary exemption from I06-E5 8/2011 emission requirements to allow for the installation of one (1) of the three (3) following, high-performance, wood-burning, ornamental fireplaces in each of our two (2) single-family projects:
Morso 5660 (Note, the manufacturer has allowed their Nordic Swan Ecolabel to expire)
  • Particles: 5.24 g/kg
  • Efficiency: 82%
RSF Focus 3600
  • Particles: 1.49 g/hr
  • Efficiency:79%
Fireplace Xtrordinair Apex Clean Face
  • Particles:0.93 g/hr
  • Efficiency:73% - 79%
This temporary exemption would remain in effect only until confirmed I06-E5 8/2011-compliant fireplaces are available within the United States. 


The project team may use the Exception EC-004 Ornamental Fireplace in Transects L1, L2, and L3 which has been updated to now include a pathway for teams that are unable to source fireplaces with Nordic Swan labels within the US. In addition to the other new requirements, ILFI recognizes that US-based manufacturers currently do not test for CO or OGC and therefore there is no direct equivalency to Nordic Swan for those emissions. Therefore, the project team needs to document advocacy done to the regional air quality regulatory body (US EPA, in this case) so that policies are created that require fireplace manufacturers to test for CO and OGC. Additionally, the project team must provide documentation showing the installation of carbon monoxide detector within the home.

Language added to the Exception below is in bold.

EC-004 Ornamental Fireplace in Transects L1, L2, and L3
In the limited instances where development is allowed in Transects L1 and L2, it is acceptable to install a single indoor woodstove or fireplace because ecological impacts are minimal, intensely local fuel supply is guaranteed, and there is a strong cultural legacy of the “hearth in the wilderness.” The allowance for a single woodstove or fireplace in Transects L1 and L2 assumes that these are merely ornamental and ceremonial and are not used for primary, day-to-day heating purposes. Therefore, they should not be included in the project’s energy calculations. This Exception also allows one outdoor fireplace in addition to the indoor woodstove or fireplace. The use of a propane igniter is not allowed.
Fireplaces are also allowed in residential projects in Transect L3 under the following conditions.
The fireplace:

  • Cannot be a primary heat source.
  • Must be closed and meet current Nordic Swan emission (or prove equivalency) and efficiency standards as developed by the Nordic Council of Ministers (see below).

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

Nordic Swan Standards
Emissions criteria:

  • Organic gaseous carbon (OGC): 100 mg/m3
  • Carbon monoxide (CO): 1250 mg/m3
  • Particles: 2.0 g/kg (for up to 4 loads); 5 g/kg (for each load)
    Efficiency criteria: 76% for manually operated stoves or inset fireplaces for intermittent use.
    The project team must provide a narrative describing the functionality of the fireplace with regard to these requirements.

If fireplaces with Nordic Swan labels cannot be sourced from within a project's country, the project team may prove equivalency by showing that the fireplace:

  • falls below the US EPA's particulate matter emissions level of 2.5g/hr for cord wood or 2.0g/hr for all other wood, AND
  • meets the Nordic Swan's efficiency requirement of at least 76%.

The project team must also advocate to the regional air quality regulatory body to require fireplace manufacturers to perform CO and OGC testing.

Regardless of whether or not a project team is pursuing any Health + Happiness Imperatives, the project must provide documentation showing the installation of carbon monoxide detector within the home.

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