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Hearth & Home March 2018

March News

Ryan Carroll, the HPBA’s vice president of Government Affairs.
Photo: ©2018 David Hathcox photography. www.hathcoxphoto.com.

Straps that Bind:
Regulatory efforts continue
to challenge the hearth industry.

Back in the day, it seemed as if everyone who could weld was making wood stoves in their garage. Scores of small companies cropped up over North America, with many entrepreneurs selling out of a pickup truck.

That movement came to a screeching halt in 1983, when Oregon became the first state to set limits on wood smoke emissions, actions soon followed by both Colorado and Washington State. The U.S. Environmental Protection Agency (EPA) quickly took note, and in 1985 began a process that lead to a national wood smoke emissions regulatory program; its New Source Performance Standards went into effect on July 1, 1988.

That move was supported by the hearth industry and the Wood Heating Alliance (later becoming the HPBA), much preferring one national emissions standard to potentially many separate state or local standards. But Oregon’s pioneering efforts began the demise of most of the small wood stove manufacturers such as Fisher, Schrader and Bat Cave, who could not afford to meet the new standards.

Today, the hearth products industry not only continues to face challenges to its wood burners, but also to its gas hearth appliances. These challenges are not limited to the U.S., as Canada faces challenges in major cities such as Vancouver, British Columbia, and Montreal, Quebec.

New Source Performance Standards

The EPA’s New Source Performance Standards (NSPS) for new wood-burning hearth products currently in effect sets allowable particulate emissions maximums at 4.5 gph for all wood stoves. The NSPS excludes open-faced, decorative, wood-burning fireplaces, but does include pellet appliances, wood-fired outdoor hydronic heaters, and wood-fired warm air furnaces.

Step 2 of the NSPS is set to go into effect May 15, 2020, with limits set at 2.0 gph for models tested with traditional cribwood, and 2.5 gph for models tested with cordwood; both standards are applicable to catalytic and non-catalytic models rather than having a separate standard for each technology. Warm air furnaces and hydronic heaters face a separate Step 2 emissions target.

The Hearth, Patio & Barbecue Association (HPBA) filed a legal challenge to the NSPS shortly after it was finalized in 2015, and has been in negotiations with the EPA ever since. The HPBA’s opening brief presentation is currently slated for Feb. 20, 2018. The legal challenge is intended to resolve technical issues with the NSPS, including testing and certification concerns.

The HPBA maintains that Step 2 standards are not cost effective since the last 5 to 10% emissions reduction may cost as much, or more, than was achieved in Step 1; that the EPA made changes to analytical methodology that increases the difficulty in determining whether or not an appliance even complies to the new standard; and, for wood stoves, the EPA set an emissions limit for cordwood testing without an agreed-upon test method.

The HPBA, hearth products manufacturers and retailers also have teamed up to make changes in Step 2 of the NSPS through legislation. This effort is HPBA-supported legislation in the U.S. House of Representatives and the U.S. Senate through HR 453 and S 1857, both aimed at extending the effective date of the Step 2 standard by three years to May 15, 2023.

“Basically, we are trying to buy the industry more time to meet these standards,” says John Crouch, the HPBA’s director of Public Affairs, “and we have to clarify and adjust some provisions of Step 2.”

One of the reasons the HPBA also is attempting to “buy time” for the implementation of Step 2 is because of the EPA’s inclusion of wood-fired, outdoor hydronic heaters and wood-burning forced air furnaces in the NSPS.

“Because of the cost of the technology involved in hydronic heaters, meeting the Step 2 standard would no longer make these products available because of the much increased costs to meet Step 2,” according to Crouch. “And because of the way wood-fired, forced-air furnaces are designed to burn, it is not feasible for them to comply with the standards. Both products would effectively be put out of business.”

“Buying time” also will allow more time for manufacturers and retailers to sell off pre-Step 2 products. Currently, there is no sell-through period in Step 2, but if pending legislation mentioned above is passed, Step 1 products could be sold until May 15, 2023.

The audit provision in the NSPS also has caused particular concern. This provision allows a model to be pulled by the EPA from the field at random and sent to any test lab, even labs not accredited by the EPA. If that unit exceeds the NSPS standards limits by more than 50%, the manufacturer would be issued a 72-hour cease-and-desist order to refrain from shipping more of that model. It also restricts retailers from selling that model.

Because of the proven variability of test results even among EPA-accepted test labs, the HPBA is attempting to have this provision clarified and modified to take into account this variability of testing.

Although Step 2 allows EPA testing with cordwood if a manufacturer receives permission from the EPA, there are no “set in concrete” testing criteria for testing with cordwood. The HPBA and manufacturers are working to develop a consistent cordwood test method to provide more “real world” test results.

In an attempt to negotiate changes to the NSPS, the HPBA has had seven face-to-face meetings with the EPA through January 2018.

U.S. Department of Energy

The U.S. Department of Energy (DOE) for years had been attempting to regulate gas hearth appliances including decorative models. Decorative hearth products in 2014 were officially removed from the DOE’s rulemaking. As of Aug. 24, 2017, the DOE formally withdrew its proposed rulemaking to ban all continuous pilot lights on all gas hearth appliances, and at this time nothing more is on the regulatory horizon with the DOE, according to Ryan Carroll, the HPBA’s vice president of Government Affairs.

Canadian Regulatory Efforts

The HPBA and the HPBA Canada increasingly are looking at regulatory efforts as a total North American market since many hearth product manufacturers sell into each country. “Regulations in either country eventually affect both countries,” says Ryan Carroll, “so we are jointly viewing all regulatory efforts in each country.”

And Natural Resources Canada (NR Can) is a good example with its P.4 efficiency testing and disclosure program. In effect since 2009, this program requires all gas hearth appliance manufacturers to test to the P.4 criteria and to advertise to consumers the efficiencies of its gas hearth products.

The program did not, however, require minimum efficiencies – until now. NR Can now is proposing that all heater-rated, vented, gas fireplaces, stoves, and fireplace inserts meet a minimum 50% efficiency standard by Jan. 1, 2020.

Required product labeling must indicate that the product is heater-rated and must disclose the tested minimum efficiency; decorative gas products must clearly state they are not intended for heating use.

In other Canadian action, the province of British Columbia (BC) is considering the same efficiency testing, disclosure, and labeling, to take effect in that province on Jan. 1, 2019.

Part of the actions by NR Can and the BC government is the ban on all continuous or standing pilot lights on all vented gas hearth appliances. The HPBA and the HPBA Canada are working with a CSA Group to revise product standards to phase out continuous pilots, as mentioned earlier, but with allowances for timed pilots.

California’s Net Zero

The HPBA has been concerned that California, as part of the state’s 2019 energy code, would mandate that all new residential homes as of 2020 must produce their own power. The power needed would have been calculated on an annual basis and would have mandated solar panels. The HPBA has been attempting to include the power savings of using hearth products as zone heaters as part of the discussion on Net Zero. Fortunately, Net Zero did not become part of California’s energy code, but that code does mandate solar panels on all new homes by 2020.

The planning process for the next 2023 California energy code will soon begin. The HPBA is communicating with gas utilities that are similarly concerned since homebuilders now may not even put natural gas into new homes or into new neighborhoods.

“The challenge for us is the software used to calculate needed power and power consumed,” says John Crouch. “It does not allow much credit for zone heating, and that is how we are positioning hearth products.” Crouch is concerned that other states are watching the Net Zero process and considering similar actions.

Vancouver’s Zero Net Carbon

California’s concerns are the energy used in new construction. The City of Vancouver, British Columbia, however, is emphasizing reduction of greenhouse gases by mandating a “zero net carbon” program by 2030. As of May 1, 2017, new high rises built in the City of Vancouver are required to reduce their carbon footprint by 50%. The second phase of the program will be aimed at multi-family homes. The City of Toronto, Ontario, is in the early stages of considering similar actions.

The Metro Vancouver Regional District also is recommending phasing in regulations to control wood smoke emissions by restricting and eventually eliminating uncertified wood burners. As of May 2020, the use of wood-burning fireplaces and stoves will be restricted from May 15 to September 15.

As of September 2022, wood burners must be registered, requiring certification to CSA B41.1 or the EPA 4.5 gph standard except for appliances used only during temporary power outages for four hours or less. As of September 2025, unregistered wood burners will be prohibited except if the appliance is the home’s sole heat source, the owner cannot pay for heating other than with wood, or the appliance is located outside the Urban Containment Boundary.

California’s Proposition 65

California’s Proposition 65 (Prop 65), officially titled The State of California’s Safe Drinking Water and Toxic Enforcement Act of 1986, has been in effect for 30 years, affecting product labeling when a product contains one or more chemicals on the state’s toxic chemical list. But an August 2016, amendment to the Clear and Reasonable Warnings section will affect many products manufactured after Aug. 30, 2018, including hearth products, grills and furniture.

State action already has been taken against a bed and breakfast operation because of unlabeled gas fireplaces and grills on the premises. The HPBA understands that solid fuel products and fire starters also must include Prop 65 warnings on their packaging labels.

The HPBA suggests that manufacturers and importers visit the State of California’s Prop 65 website (www.p65warnings.ca.gov/new-proposition-65-warnings) to review these changes and make certain their labeling complies. California retailers also might want to review this site to learn how Prop 65 violations may affect them.

— By Bill Sendelback


Free Educational Materials for Your Customers

How can partnering with the Environmental Protection Agency’s Burn Wise program help your business? Customers who follow best-burn practices have better wood stove heating performance, less smoke, and reduced creosote build-up!

Free educational materials offered by the Burn Wise program can help you encourage your customers to burn the right wood, the right way, in the right appliance. Customers benefit by reducing heating costs, keeping their homes safer, and improving the air quality in their homes and communities – all while staying comfortably warm.

Some of Burn Wise’s most popular materials focus on the importance of burning dry, seasoned wood. As you may know, about half the weight of fresh cut wood is water. Ideally, energy from wood should be used to warm homes, not to burn off water in the wood. Dry seasoned wood also produces less creosote build-up and less smoke and air pollution. This results in fewer calls to your company about the stove not operating properly!

The materials listed below can assist you in educating your customers about the benefits of dry seasoned wood and how to achieve it. They are free to order at www.epa.gov/burnwise/orderform.

Consider going a step further. Provide a free moisture meter with a new stove purchase to enable customers to check moisture content with their first wood use.

To learn more about the Burn Wise program and order your free materials, go to www.epa.gov/burnwise.

  1. Wet Wood is a Waste: This tri-fold brochure details how to dry wood, includes information on testing wood moisture, and contains a checklist for clean and efficient heating.
  2. How to Build a Firewood Storage Shed: This two-page document contains a list of materials, simple schematics, photos, and the cost to build a firewood shed that holds a cord of wood. It also includes a link to a companion video on building the firewood shed.
  3. Burn Wise: Test Your Wood with a Moisture Meter: This flyer details the benefits of burning dry seasoned wood and how to test firewood using a moisture meter. There is also a companion Burn Wise video on how to use a wood moisture meter at www.epa.gov/burnwise/burn-wise-best-practices-videos.

Ridgewood.

Acadia Hearth: A new company, but with experienced leaders, will launch in Nashville.

Kent Roeder, a long-time member of the hearth industry, is leading a new venture called Acadia Hearth. The company’s debut will be at the HPBExpo in Nashville.

Hearth & Home: How did Acadia Hearth get started and why was it started?

Kent Roeder: “Acadia Holdings was formed by a group of investors led by Richard Rogers, chairman of the board of United States Stove Company (USSC), and August Jones, president of USSC, but there also is a team of silent investors. It’s a completely separate company from USSC. Acadia Holdings was looking for somebody to lead this venture into the specialty hearth business when they began talking with me. While there is a group of investors behind Acadia Holdings, they have fully given me the reins to steer this ship, and I have great latitude to make decisions and guide this company. It’s a new company, but there is a lot of expertise behind it.”

It sounds as if you were much more involved in the beginnings of Acadia Hearth than simply being a hired gun.

Roeder: “That’s true. From its inception, I’ve been involved with every decision, including the logos, the naming of it and what kind of products we are looking at. There are plenty of resources behind us, which, of course, helps start a company like this. The decision-making from its birth has been on my shoulders.”

Was this venture your idea or was it an idea of Richard and August? In other words, did the investors come to you?

Roeder: “A little of both. Richard and August had been in the specialty hearth business years ago, but since then had concentrated on mass merchant business and did a very good job of that. But they knew that it was not their expertise. So we got to talking, because they knew that selling to specialty hearth retailers was something I had done for years.”

You have extensive experience in hearth products. Give me a brief recap of your background.

Roeder: “I was in specialty hearth with a large gas hearth appliance manufacturer for more than 18 years working in all facets of design and production, taking products from concept all the way to production, but I mainly concentrated on the marketing and sales side. With a smaller company like that, you wear a lot of hats. I feel like I have a broad range of expertise. But my main expertise is the sales and marketing side of it.”

Specialty hearth product retailers already have many good manufacturers and products to pick from. What sets Acadia Hearth apart from your competition, and why should a dealer look at Acadia? How do you see Acadia fitting into an already crowded market?

Roeder: “Acadia Hearth is going into business in a very basic, simple way. We are gathering feedback from our dealers and distributors in order to make products that no one else is making. We’re going to have a broad line of products that also offers dealers other products they may not normally sell, such as outdoor hearth products, and products that will not be seen in the mass merchants.

“We will keep products in our warehouses so that customers can place smaller orders to help increase the margins they make. Adding to that, we will have a revamped Breckwell line. And we plan that our products will be engineered and built with quality so that, out of the box, there will be no issues or reasons for call-backs.

“We want to keep our products unique. Of course, you can go into any Big Box store and find a patio heater, but we are going to have unique products that specialty hearth people will be interested in. We will be offering high-quality products priced in the mid range. Our goal is to have no call-backs with our products.”

In regards to USSC, although Acadia is a separate operation, what are you sharing or getting from USSC, if anything?

Roeder: “We are treating USSC as an OEM manufacturer. We will have separate production lines in the USSC operation. Basically, Acadia will be hiring USSC to do what we ask, so USSC is really treated as an OEM manufacturer.”


Kent Roeder.


Kevin Yowler.


Shawn Henson.

You mentioned the expertise of some of the people you have brought in. Tell me about the people who are working with you.

Roeder: “We’ve hired new people with some pretty serious experience. Between the three of us leading this charge, there is a lot of industry experience. Kevin Yowler has been in the industry for almost 20 years and will be handling national sales training. He spent some time years ago with another large hearth products manufacturer as their national tech and sales trainer. I hired him while I was at my previous employer, and he spent about seven years as a sales rep at that manufacturer. He has a vast knowledge of technical issues, and he is going to be helping in product development and design, as well as being one of our sales reps.

“Another addition is Jared Sorenson. He grew up in manufacturing before making the switch to gas products testing and standards compliance with both Omni and Intertek labs. He’s been around the industry for more than 25 years. He is helping with testing our units as product development and testing manager.

“Shawn Henson, who is an industry veteran in sales, will be handling distributorships on the east side of the country. He has been in the industry for a long time, and he will be one of our sales reps.”

I notice Breckwell, which has been a USSC brand, is now part of Acadia. How did that happen?

Roeder: “Breckwell is a natural fit with Acadia. USSC bought that brand several years ago, and since we’re going into the specialty hearth market, Acadia is focusing on gas products, but with the acquisition of Breckwell from USSC, it gives us a broad line of products in solid fuel, pellets and gas. We are also looking at and will have at the trade show some patio furniture, fire pits, outdoor grills, that will complement the line. We are not just gas products, so this was a perfect marriage to have Breckwell in our lineup.”

With all of those products it sounds like you have been working at this for a while. That’s a lot of stuff to get ready to go to market in that short a time.

Roeder: “The amazing thing is that this all came to be since last fall. This company was just started in the fall of 2017, but in that short amount of time we’ve developed a very nice line of products. We are revamping the Breckwell line. In a very short amount of time we’ve accomplished a heck of a lot.”

Regarding the manufacturing, you mentioned setting up a separate line. Is Acadia leasing space from USSC or are you setting up an entirely separate independent manufacturing operation?

Roeder: “We are contracting with USSC as an OEM supplier. They obviously have huge resources in their production capabilities and all the machinery needed. But we will have our own production line running separate from anything else at USSC, and a separate staff. Basically USSC is just a place to produce our products.

“Obviously the thing that USSC has done very well is servicing mass merchants, so we want to make sure that everybody knows that all of the products that we talk about, the Breckwell and Acadia Hearth lines, never will be seen in the mass merchants or online. We’re going through two-step distributors and to specialty hearth dealers all over North America. So dealers and distributors can rest assured that they won’t have any competition from mass merchants with the Acadia Hearth lines.”

Since you will be selling through two-step distributors, will you be using manufacturers’ reps or will you have your own factory people calling on distributors?

Roeder: “The two that I mentioned, Kevin and Shawn, will be leading the sales team selling directly to distributors all over North America, and I will help them too. The distributor salesmen will be handling the local dealer part of it, but we will be supporting them in all ways.”

One of the things that surprised me was your outdoor living products. It surprised me that you got into it so quickly with a fairly extensive line. When do you anticipate those products will be available?

Roeder: “We will be showcasing some of it at the upcoming HPBA show in Nashville, getting opinions from distributors and dealers. We fully plan on having product in our warehouse this summer, with maybe a limited selection to start. Usually in the outdoor market, dealers have to buy large amounts of products on early-buy orders and then have those orders shipped in March. We are going to have the products in stock year round so there is not as much pressure on a customer to buy large amounts at one time. We will keep product stocked so they can get it as needed.”

In regards to the hearth products, when do you anticipate having hearth products ready to ship?

Roeder: “We are going to have products ready to ship in early summer. We will have the first few products available to get to distributors and into dealer showrooms as the season gets here. We will be fully ready for this season.”

How about Canada? Is that a market you are looking at?

Roeder: “We are definitely going to start selling into Canada right off the bat. We’re already talking to some distributors up there, but we’re still deciding on whom to sell. We are heavily pursuing the Canadian market.”

I understand you will be offering a new pellet stove that is gravity fed and requires no electricity. Is that a version of the Wiseway that USSC has or is this something new?

Roeder: “It is something completely different and new and unrelated to that product. There are no similarities except it does not require hooking it up to electric power. This has a whole different system and a different look to it, more of a finished look. We have entered this product into the Vesta Awards program. It’s called the Traverse pellet stove, but it’s gravity fed, not an electric-powered pellet stove. When people see the flame, they will truly see what makes it so unique. There is no other flame in the pellet industry like it.

“The Traverse pellet stove and all our Breckwell and Acadia Hearth products will be on display at the HPBA show in booth 2256.”

– By Bill Sendelback


L to R: Martin Ares and Daniel Beauregard with the Chamane from Invicta.

Energy Distribution: Two Partners will import and distribute the Invicta line of wood-burning appliances.

Hearth & Home: When and how did you get into the hearth business?

Daniel Beauregard: “We set up Energy Distribution in 2015, however, my partner, Martin Ares, and I come from a background in the hearth industry. Martin has many years of experience. He started installing for his uncle when he was just a kid. Eventually, he bought his uncle’s store and has been a retailer for 15 to 20 years now.”

You and Martin started Energy Distribution. Does Martin still own the store?

Beauregard: “He still owns the store. For us it’s important to draw a line. It’s two different companies. We are not importing for the store. Energy Distribution is an import and distribution company.”

Will Martin be able to spend a lot of time working on your new venture as opposed to the store?

Beauregard: “Yes. He is hiring people to replace him in the store. He wants his future to be distribution, and also wants to keep the retail store. His goal is to become a major distribution company, and that’s where he wants to spend his time; we are going to put all our effort in building this company.”

In which city is the retail store located?

Beauregard: “It is called St. Alphonse-de-Granby.”

What kind of store is it? What does he sell?

Beauregard: “Stoves, fireplaces, spas, barbecue grills. He built one of the biggest stores in Canada – La Cité du Feu (The City of Fire). He built that store and then I came along around 2012. I have a background in sales and marketing, so I had a different background than he has, but both of us are passionate about what we do.

“We went to Europe a few times and that’s where we found Invicta, the company we now import from. We decided to go forward and sign a contract to import from them because we found it would bring a fresh air to the hearth industry in North America. It’s a modern look, but at the same time it’s 100% cast-iron stoves.

“Invicta is well structured. They are one of the largest hearth companies in Europe. They own their own foundry, which is rare these days. They handle 100% of the process of manufacturing the stoves, from design to building and assembly. They also have their own enamel factory, so they are really in control of everything. They sell all around the world, but apparently forgot about America.

“At the moment we are in the process of getting all the stoves certified for North America, because all the regulations are different and even the process of doing the tests are totally different from there to here. We will work on some modifications to get them certified for North America. We are actually going to do a bit of the modifications here in our warehouse because it’s a bit problematic for Invicta to change its entire line of production.

“We have a few models already certified and are in the process of certifying a few more. We are working on getting all of them certified to the EPA 2020 standard, which is not easy because we don’t work with catalytic combustors.

“We want to become a major distribution company in Canada and the U.S. Our goal is to bring fresh air to the industry, and to concentrate on style and design. We will still have the old style fireplace and stove, but we want to go with the flow, which at the moment is to have better designed products.”

Now that you have a supplier in France who can deliver, and products that are going through testing, what you have to do next is get retailers to carry your product, correct?

Beauregard: “Yes, that’s correct. That is why we are going to the HPBExpo, to show our products to retailers and get them excited about carrying them. We want to show that the product is high quality. Being at the show will help us consolidate discussions we have had with sales agents. Our goal is to get some agreement with agents so they can get going finding retailers who want to carry the product.”

Do you have both gas and wood, or are you staying with just wood?

Beauregard: “At the moment we’re sticking with only wood products because that has been Invicta’s major fuel for years and years. They are starting to do a little bit of gas in Europe, but we’re going to go with their major product line, and that is wood. We wanted to first establish the company, and then eventually bring gas to the market.”

How old are you?

Beauregard: “I just turned 40 this year; my partner is 44. We’re young but we’re passionate about what we do. That is what drives us. When I started in the industry, I thought the industry was getting old; the retailers are getting old; installers and technicians are getting old. The industry needs a new breed, so the new generations have to push a little bit harder to get into the industry and bring some new energy to the business.

“I find there is a big gap between people who have been in the business for years and the new generations. It seems there is no in-between. It’s either people who have 35 or 40 years’ experience, or none. I think it’s important to have a good relay between generations.

“I’m a rookie in the industry, and I find it’s lacking a little bit. Especially in Quebec, it’s getting harder year after year, and it’s missing that little spark that drives people. I’m excited to get into the market and bring some new ideas. I’m looking forward to working with people who have more experience than me.

“In Europe, when you talk gas they look at you like, ‘It’s dirty!’ When you talk wood, ‘It’s clean! It’s environmentally friendly.’ So for us as a distributor for a major company in Europe that is doing wood, I think it’s important to get people to think that, ‘Yes, wood is clean, especially the new products that have lower emissions than ever.’”

– By Richard Wright


Correction

In an article on fabric companies (“Fabric Wars!” February 2018, page 73), we incorrectly said that Phifer is headquartered in Birmingham, Alabama. We were wrong. Phifer is based in Tuscaloosa.

In that same issue (“Weather Report,” page 81) we incorrectly referred to the chart of the U.S. as reflective of Precipitation ranking, when it actually reflects Average Temperature.

More Stories in this Issue

Perspective:
Women – and Man

A year ago, in our March HPBExpo issue, we chronicled the slow pace at which the chairmanship of the Hearth, Patio & Barbecue Association (HPBA) was turned over to a woman; it required 23 years before Sharla Wagy (2002-2003) was chosen.

» Continue

Fireside Chats

By Richard Wright

It was a very good year for hearth product sales, according to the three manufacturers we interviewed. One had their best year ever; one is forecasting 50% growth in 2018, and one went from zero to 60 stores.

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Meet Amie Ryan

By Richard Wright

The incoming chairperson of the HPBA is the owner of Ryan Brothers Chimney Sweeping in Roseville, California, up north, next to Sacramento.

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Best Infrared Engineer

By Lisa Readie Mayer

Infrared pioneer Bill Best marks the 40th anniversary of his infrared grill; he’s now working on a fourth-generation grill that he says, “Will be the way everyone grills in years to come.”

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Spinuzzi’s Last Stand

By Bill Sendelback

For 40 years, founder and owner Gary Spinuzzi of Bighorn Stove & Spa has battled the many difficulties that come with being a “small” specialty retailer; now, he’s close to retirement.

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Filling the Gap

By Tom Lassiter

Owner Marc Kaufer has positioned Frankford Umbrellas with pricing between that of Treasure Garden and TUUCI.

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Mod Squad

By Lisa Readie Mayer

Modular outdoor kitchens offer high-end style, turnkey ease, and attractive profits.

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2018 January Business Climate

In early February Hearth & Home faxed a survey to 2,500 specialty retailers of hearth, patio and barbecue products, asking them to compare January 2018 sales to January 2017. The accompanying charts and selected comments are from the 209 useable returns.

» Continue