Archive for the ‘Legislative’ Category

Moving the dial

Friday, October 12th, 2012

Dutch Dresser

When you work on introducing a new technology to a population and region, you discover lots of intriguing impediments to that introduction that you’d never have imagined. Yesterday (October 11, 2012) the Maine Fuel Board voted to allow Maine Energy Systems to engage in an “Emerging Technologies” project with them that might lead to elimination of one of those impediments for the pellet central heating industry in the State of Maine.

Maine is unique in its licensure of technicians for “solid fuels.” In Maine a person installing a boiler must have “solid fuel” authority on his license to legally install a “solid fuel” boiler in someone else’s building. (It’s a bit more complicated than that, but let’s avoid the levels of license detail.) The need for this rule apparently arose from three potential hazards associated with “solid fuel” boilers: the possibility for a thermal run-away during a power outage as combustion continues on a load of fuel while circulation fails due to lack of power, high chimney temperatures, and high boiler surface temperatures.

As highly sophisticated automatic pellet boilers made their way into the American market, they were defined in Maine as “solid fuel” appliances because pellets are solid. While that seems innocent and logical enough, the categorization has one substantial flaw and it creates one significant impediment to product growth in the marketplace.

The Flaw

State-of-the-art pellet boilers display none of the attributes that led to the perceived need for “solid fuel” rules in Maine. The rules were devised for cordwood boilers and coal stoker boilers that can hold a significant charge of fuel at any given time. The combustion of that fuel is relatively uncontrolled. Pellet boilers burn a very small quantity of fuel at any given time, and the combustion of that fuel is highly controlled. Combustion stops almost immediately if the power goes out, hence, no excessive heat can be produced during a power outage.

Cordwood boilers and coal stoker boilers can produce very high stack temperatures. The exhaust gas temperatures from state-of-the-art pellet boilers are very much like those of modern oil boilers. In fact these boilers are so efficient, the stack gas temperature is often quite cool, 250F, or so, but it never exceeds 400F. Therefore, high chimney temperatures never occur.

Old cordwood and coal stoker boilers could develop high surface temperatures making installed distance from combustible surfaces important. The surface temperature of these state-of-the-art pellet boilers is the same as the temperature of the room. The heat exchangers are extremely well insulated to achieve the desired efficiencies. So, the worry about proximity of flammable materials due to high boiler surface temperatures is not justified with these boilers.

The Impediment

Because these highly sophisticated boilers are lumped in the same category as cordwood boilers and coal stoker boilers, “solid fuel” license holders must install them in Maine. There are many fewer “solid fuel” license holders than ordinary oil license holders, so scheduling boiler installations in this rapidly growing segment is very challenging in the busy times of the year. Other busy technicians find it hard to justify studying for a test that focuses generally on boilers they’ll never see, so they’re not inclined to prepare for the “solid fuel” test to install pellet boilers as they’re just beginning to make a mark on the marketplace.

The Emerging Technologies Project

On October 11, 2012, the Maine Fuel Board approved a request made by Maine Energy Systems for a year long project intended to confirm the company’s assertion that their boilers, and those similar to them, can be installed by oil boiler license holders who have been suitably trained in the differences between pellet boilers and oil boilers.

This is great news for the pellet industry in Maine as the State’s boiler inspectors will inspect some, or all, of these installations and, thereby, become much more familiar with these sorts of systems. If the project leads to the anticipated conclusion, the request to re-categorize the boilers for licensure requirement purposes should be reasonably received. We have little doubt that the Project will reach successful conclusion as these very same boilers are installed throughout the Northeast by the same technicians who install oil boilers and who have been trained at Maine Energy Systems in fuel handling and burner adjustment.

In the meantime, Maine Energy Systems will be training oil boiler technicians in the installation of their equipment to ensure that all who choose to install the MESys AutoPellet boiler can do it this heating season on a schedule that works for them.

Dutch Dresser is the Managing Director of Maine Energy Systems in Bethel, Maine.

New Hampshire Takes Leadership Role

Thursday, May 13th, 2010

On May 11,  2010, I had the pleasure of attending a meeting in Concord, NH, in which Jack Ruderman, Director of the Sustainable Energy Division of the New Hampshire Public Utilities Commission,  Laura Richardson, ARRA Coordinator for SEP, NH Office of Energy and Planning, and Barbara Bernstein, Sustainable Energy Analyst, NH Public Utilities Commission, were accepting industry assistance in the drafting of language for a proposed Residential Central Pellet Heating System Rebate for the residents of New Hampshire.

This was a refreshing experience for several reasons.  First, the New Hampshire PUC had decided to earmark a small, but meaningful, sum of ARRA money to begin to catalyze residential fuel switching in New Hampshire through incentivization of residential central pellet-fired heating systems.  Their goals for the proposed plan are intelligent and forward-looking and recognize the importance of helping homeowners take advantage of locally produced heating fuel for economic, environmental, and independence reasons.

Second, the government officials sought industry advice on ensuring that the equipment to be incentivized would include  equipment that would both be sufficiently automatic to satisfy American homeowners and insurance underwriters and would be sufficiently well developed to be environmentally friendly.  They also understood the value of reasonable pellet storage volumes to encourage a growth in bulk pellet distribution to ultimately replicate the distribution systems which have successfully provided us with liquid fossil fuels for years.

I applaud those who have advanced the constructive, forward-looking thinking represented by this effort.  New Hampshire citizens can be proud of those in their government who are pro-actively addressing energy sustainability issues.

Dutch Dresser

Appliance venting regulation

Wednesday, February 25th, 2009

Testimony offered in writing in support of a bill that would require rules relating to the venting of multiple devices into the same chimney to be heard at the legislative committee level rather than allowing the Oil and Solid Fuel Board to establish rules without committee intervention.

An Act To Permit the Use of a Common Flue for Oil and Solid Fuel Burning Equipment, LD 53

Public hearing conducted by the Joint Standing Committee on Criminal Justice and Public Safety Committee, February 25, 2009

Senator Gerzofsky, Representative Haskell, and Esteemed Members of the Criminal Justice and Public Safety Committee,

I am Harry “Dutch” Dresser from Bethel, Maine. I come to you today as a Founding Director of Maine Energy Systems and as one who has been involved in introducing technological change to populations throughout his adult life. I would encourage you to support LD 53 both for the immediate effect a change can have on peoples’ abilities to heat their homes in compliance with the law and for the advantage its passage could lend to a fundamentally important transition we’ve embarked upon as a State.

I, and many like me, have lived many of our younger years in homes with wood-burning stoves in the same chimney as a large oil boilers; the houses still stand and so do we. However, I am not here to talk about that, I’m here to talk about the regulatory process in times of significant change. That’s what this bill is about.

80% of the nation’s #2 heating oil is burned in the Northeastern United States. Maine is the largest consumer per capita of heating oil in the nation. 80% of our homes are heated by burning #2 oil. In 2008, we consumed nearly $1.6 billion worth of oil just to keep our homes warm. 75% of that money left the U.S. economy nearly immediately. The uncontrollable spike in oil prices that caused that very difficult winter reminded people in Maine and across the country about the great value of oil. Oil is a remarkable resource; it is the base material in many of our manufactured goods, and is recyclable for repeated use in those applications. We were reminded last winter that oil is also in finite supply and that it is unconscionably wasteful to burn it for heating when sustainably renewable alternatives exist. Despite the low oil prices today, occasioned by a deeply troubled economy, Mainers are turning in ever-greater numbers to alternative means of heating their homes, which will ultimately lead us to greater energy independence in the State. When that heating transition involves wood and wood pellets manufactured in Maine, as 400,000 tons currently are, the net positive effect on Maine’s economy and its tax base is truly remarkable at the same time that greenhouse gas emission is profoundly reduced.

When transitions as significant as the one we are just beginning to experience occur in a population, flexible, entrepreneurial, business leaders take care of the necessary technological change. Hardware issues resolve themselves quite quickly and products to support the transition begin to proliferate. We are seeing those things occur in the heating fuel transition already. Geothermal technologies are now commonly available, wood pellet stoves are well-established in our region, pellet-fired central home heating systems are becoming more common, and thermal solar installations are taking their places on many roofs. As the public begins to understand the opportunities available to them, early adopters of new technologies have a variety of experiences as new products are refined, and gradually the early majority takes up the new equipment. The way of seeing the base problem is forever changed.

In Maine, we are currently in the stage of residential heating transition where early adopters are finding ways to heat their homes more inexpensively, more environmentally, and safely using energy sources that are locally available and are sustainably renewable. This transition will spread naturally as more and more people understand the advantages of alternatives available to them and as more and more refined products to support that transition reach the market and find accessible price points.

Generally, product innovation and public education about product difference and advantage are filled with both stress and exhilaration, but they can be accomplished with focused hard work and persistence.

The most difficult aspect confronting widespread technological change and adoption is quite frequently that of bringing existing regulation in line with actual characteristics of the new technologies. The regulation has often been established expressly for the existing mature technologies. Often some of that regulation has as its main purpose the preservation of the mature of the mature technology usually accomplished by making it difficult for competing technologies to occupy the same space.

(Legislation and regulation were ultimately turned on their heads as emerging digital communications technologies supplanted analog technologies and vied for bandwidth on existing infrastructure.)

With this bill, and surely more that will follow it, we are seeing a new emerging view of residential heating trying to make legitimate space for itself in regulation after it has already made that space in the real world.

New ways of viewing well-established practices are very difficult for many people. They are often most difficult for those most expert in existing practices who have been well trained to see all issues related to the practice through the lens of a very particular model. As we have already seen, and will see more frequently in our lifetimes, change is not always gradual, and it is not always simply modification of existing practice. Sometimes, it is just different.

At its roots, the issue being addressed by LD 53 is about beginning to make way for fundamentally changing the way we look at residential, and probably commercial, heating in the State of Maine. I support this bill because it is a political attempt to get decision-making on this critical issue into the larger legislative forum where members will generally have only casual understanding of the existing model allowing them room for open-minded exploration of the issues before them.

Maine will face many paradigm changing issues in the next decade; it will be wise for the State to learn to look as broadly at those changes as is possible. This bill is an attempt for such thing on a paradigm shift that is underway.

Thank you for the opportunity to address you.

Respectfully submitted,

Harry H. Dresser, Jr., Ed.D.

Pellet labeling regulation

Wednesday, February 25th, 2009

This is my testimony presented at public hearing on February 24, 2009, to a proposed bill to require those manufacturing or selling wood pellets in Maine to comply with the proposed PFI standards if they used the words “premium” or “super premium” on their bags.

An Act Regarding the Labeling of Wood Pellet and Biomass Heating Fuel Sold in Maine, HP 238, LD 298, 124th Legislature

Testimony provided to the Joint Standing Committee on Natural Resources by Harry H. Dresser, Jr., Ed.D.

Good morning, Senator Goodall, Representative Duschesne, and the Honorable members of the Joint Standing Committee on Natural Resources.

I am Harry “Dutch” Dresser from Bethel, Maine.

Thank you for the opportunity to discuss L.D. 298, An Act Regarding the Labeling of Wood Pellet and Biomass Heating Fuel Sold in Maine.

My testimony comes from three perspectives:

• I am a director of Maine Energy Systems, probably the largest consumer and distributor of bulk wood pellets in the State of Maine,
• I am a member of the PFI (Pellet Fuels Institute) national Commercial Fuel Committee, and
• I heat my large, Bethel home with a Bosch/Janfire pellet boiler system.

Basically, I would like to share with you the reasoning I shared some time ago with Mr. Bertyl when he sought advice by phone from me. In so doing, I will urge the Committee to find that this bill ought not to pass.

As you know, wood pellets are a solid fuel derived from hard and softwood in different proportions grown in soils of different chemical composition in regions with variable growing and weather seasons around the State and the region. Because of the many variables affecting wood growth and composition, all “batches” of densified wood pellets are somewhat different from all other “batches.”

There are many attributes of wood pellets that lead to their suitability, or unsuitability, as fuel for pellet stoves and small, residential size boilers. Most common among them are ordinary factors like bulk density, heating value, pellet moisture content, and non-combustible inorganic ash content. These attributes can be measured by labs, either at the manufacturing site or at third party sites far away. Manufacturers make pellet test information available to me as it is reported out by remote testing labs, typically a week, or more, after the production of the fuel. There are a growing number of manufacturers who test their products on-site, daily for fundamental attributes, and there is discussion about a testing lab within the State, perhaps at the University, for third-party testing.

Reading the pellet analysis summaries of Twin Ports Testing of Superior, Wisconsin, or of Bodycote of Pointe Claire, Quebec, one finds understandable quantifications of these fundamental pellet attributes. These are the same attributes the Pellet Fuels Institute finds interesting in its proposed standards references in this bill.

Small pellet boilers are perhaps the most sensitive of pellet burning equipment to poor pellet quality. The heat they generate in the burner is high making more than the basic attributes of the pellet important to understand. Combustion at high temperatures makes the chemical composition of pellets, and impurities that may find their way into their manufacture, at least as important as the more basic measures listed above. This is well understood in Europe where pellets have been used in residential and industrial boilers for more than two decades. Three countries, Austria, Germany, and Sweden have adopted their own standards in law; other European countries are waiting for the adoption of European Union standards likely to be derived from the ÖNORM Standards of Austria and the DIN Standards of Germany.

If we look at a European report of pellet analysis, we will find twenty-five to thirty attributes tested including the proportions present in the pellets of many elements including fluxing agents like potassium and sodium, and corrosives like chlorine. As we understand more of what the Europeans have already discovered, we, too, will understand the complex relationships among the chemical components of pellets as they’re burned at relatively high temperatures.

I would urge you to recommend this bill not be passed for two reasons: first, we are young to this industry; there is more we don’t know about pellets than we do. Codifying the little that we currently know could give a regulation unwarranted persistence. Second, the Maine Pellet Fuels Association manufacturing members have unanimously adopted a policy under which they have agreed to adopt PFI standards and are actively replacing poor quality pellets with good ones without much question to the consumer leaving the consumer with little, or no, risk. I’ve returned tanker loads of pellets under these terms; I know it works.

I have little doubt that we will one day define grades of densified fuel pellets, probably at the federal level. There is no need for us to rush to that moment when those much more astute about the subject than we are moving thoughtfully and cautiously.

Thank you for the opportunity to address you.

Respectfully submitted,

Harry H. Dresser, Jr., Ed.D.