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.