Read Tim Portz’s Testimony offered at the Office of Management and Budget Regarding Minimum Pellet Requirements in the NSPS

"Good afternoon. My name is Tim Portz. I serve as the Executive Director of the Pellet Fuels Institute a trade association representing the manufacturers of wood pellets, the industries that support them with parts and service and the retail community that ultimately sells their product to the consumer. Wood pellets are a highly-engineered solid fuel heating product manufactured from the waste residues generated from the manufacture of forest products like dimensional lumber, moldings and trim, hardwood flooring, windows and doors, and wood pallets. Wood pellets are burned in heating appliances designed specifically for their use to heat homes, businesses, and outbuildings all across the regions of this country that rely on seasonal space heating. Wood pellets are utilized typically in areas without natural gas service and offer a competitive option to heating oil and propane for as many as 1,000,000 American households.

The manufacture and use of wood pellets is a vital component of the broader forest products manufacturing sector. According to the Energy Information Administration pellet manufacturers spend over $350 million dollars on sawdust, wood chips and other wood waste streams that otherwise would have needed a different disposal option. With just December outstanding from the 2019 data, that number has grown to over $400 million paid for over 13 million tons of material. Wood pellet manufacturing facilities are scattered across the country from Maine to Oregon, located near other forest product manufacturing sites and wood baskets. Wood pellet facilities employ thousands of Americans often in rural economies and in addition to these direct jobs, the wood pellet sector supports tens of thousands of indirect jobs in logging, trucking and retail sales.

Wood pellets are unique from other wood fuels as they are manufactured to exacting standards developed over decades by industry participants in concert with the Pellet Fuels Institute. The world’s most comprehensive and thorough third-party administered wood pellet standards program was developed by the Pellet Fuels Institute and nearly two-thirds of the wood pellet manufacturing capacity in this country are program participants submitting their product for regular testing by certified labs at their own expense. Wood pellets manufacturers test for bulk density, diameter, heating value, moisture content, fines, durability on a daily basis. Participants must validate their own test results with a third-party lab on a monthly basis.  No other pellet standards program in the world is more robust.

 The resultant consistency of quality across the supply chain makes it possible for consumers to heat their homes with a wood fuel while generating emissions far beneath already stringent EPA limits. Consider this, of the 90 EPA-approved solid fuel-burning appliances with emissions ratings of less than 1 gram of particulate matter (PM2.5) per hour of combustion (half the allowable limit), 59 are pellet-burning appliances. It is important to note that these appliances achieve these ultra-low emission ratings without the need for additional catalytic emissions control technologies in the appliance.

We are here today because despite the clean-burning aspects of wood pellets and their position as the cleanest burning solid fuel commercially available they have been uniquely targeted for increased regulation by the EPA in the New Source Performance Standards. It seems that because wood pellets have parameters to measure, they were included in the regulation. The wood-burning technologies that wood pellets compete within the marketplace have either fewer requirements in the final rule (wood chips) or none at all (cordwood).   If the minimum pellet fuel requirements currently included in the rule remain, wood pellets will be the most highly regulated solid burning fuel, including coal, in the United States. Most disappointing of all is that this increased regulation points the enforcement apparatus ultimately at consumers and will not advance the clean air aims of the agency.

The Pellet Fuels Institute is not opposed to ensuring high-quality wood pellets are available to consumers by demanding they are produced to exacting standards. The development of our consensus-based standards program raised the quality of wood pellets across the country and continues to do so. That said, federal regulation is not the right nor legal vehicle to carry these standards forward. Federal regulation places an undue compliance burden on our members, locks in place pellet manufacturing techniques and places a risk of significant risk penalty and fines on the consumers who rely on wood pellets to heat their homes all while doing nothing to advance the goals of the Clean Air Act. We are here today in the hopes that the administration will see the inclusion of minimum fuel pellet requirements for what it is, an unnecessary, burdensome and ultimately impotent overregulation of private industry and excise it from the final rule.

Finally, the Pellet Fuels Institute would like to state for the record that the process of protecting our industry from this regulatory overreach reaches back over six years and has consumed our association’s limited resources of time and money.  Our hope is that today marks the end of that long journey.

Thank you."

Tim Portz
Executive Director, Pellet Fuels Institute
February 24, 2020

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