Corporate Headquarters: 415 Squantum Road ∙ PO Box 532 ∙ Jaffrey, NH 03452

Tel: (603) 532

‐ 4666 ∙ Fax: (603) 532

‐ 4667

www.pelletheat.com March 25, 2010

Mr. Gilbert Wood

USEPA Mailroom

Mail Code: C404

‐ 05

Research Triangle Park, NC 27711

wood.gil@epa.gov

Dear Mr. Wood,

I am the founder and current Chief Executive Officer of New England Wood Pellet LLC (NEWP). I am

writing to express my sincere interest in working with EPA to promulgate and quality standard for wood

pellet fuels.

By way of background, my company was established in 1992. We now operate three facilities

throughout New York and New England, making us one of the older and larger pellet manufacturing

companies in the country. Since our inception, we have been a member of the Pellet Fuels Institute

(PFI), of which I also served on the board for 10 years. However, I recently resigned from that position

and I’ve discontinued NEWP’s PFI membership in part due to reasons concerning pellet standards.

My intention of this letter is not only to express an interest in working with the EPA in establishing

standards but also to provide another perspective on what, I believe, to be the truth about the pellet

industry as it is today. As a Governor’s appointee to the NH Air Resource Council, I also have a strong

familiarity with air regulations and the relationship between the EPA and the various state agencies. I

feel that there is a serious need for far more comprehensive standards in our industry on both the

combustion appliance side and especially the pellet fuel side.

There is a lot of misinformation in this industry that I feel is important for you to understand. The Pellet

Fuels Institute in partnership with the Hearth, Patio and Barbecue Association (HPBA) is the only

organization attempting to record some statistics of the industry. Unfortunately there have been two

problems. First, there has been poor member cooperation to give accurate information to either

organization (more so with the pellet fuel than the appliances). Second, PFI, which is responsible for

collecting data on pellet manufacturing, only surveys its members that represent roughly 20

‐ 35% of the

industry—much less than I think they admit. The main point I am trying to get across is to be cautious

when using any industry statistics.

The most important point I would like to make is that we are at a place in time where government

involvement may be necessary to move the standards process forward. I heard that you spoke at the

HPBA conference March 10

‐ 11, 2010 and expressed to the listeners that if the industry does not come

up with standards then the EPA will. I applaud you for that statement if it was made. I fear, despite

PFI’s good efforts, it will not be able to come up with standards in the near future, as there are wild

deviations in the basic principles and philosophies of its members. Even if they do manage to get theCorporate Headquarters: 415 Squantum Road ∙ PO Box 532 ∙ Jaffrey, NH 03452

Tel: (603) 532

‐ 4666 ∙ Fax: (603) 532

‐ 4667

www.pelletheat.com ring

e are ready to work on this now, so please don’t hesitate to contact me. For assistance in reaching

incerely,

teve Walker

teve Walker, President & CEO votes and participation in a standards program, this organization represents a minority of the pellet

production in the US. Therefore there may be tremendous pushback from non

‐ members. I am offe

you my experience in this industry and, to what extent appropriate, my company to help you and the

EPA in a quest to have comprehensive standards for the pellet fuel industry.

W

me, please contact Alyson Hotaling.

S

S

S

New England Wood Pellet LLC

swalker@pelletheat.com

A lyson Hotaling, Executive Administrator

New England Wood Pellet LLC

ahotaling@pelletheat.com

603

‐ 532

‐ 4666 x205