Archive for February, 2009

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.

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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.

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