March 26, 2010 

Mr. Gil Wood 

United States Environmental Protection Agency 

109 TW Alexander Drive 

Durham, NC 27709 

RE: Pellet Fuels Institute Standards Program and NSPS 

Dear Mr. Wood: 

On behalf of the Pellet Fuels Institute (PFI), we would like to take this opportunity to 

express our sincere thanks for your attendance at our recent PFI Board of Directors 

meeting and our association luncheon in Orlando. Your presentation and comments 

may ultimately be seen as the watershed point in the evolution of our standards and 

QA / QC program. 

While we understand that our program does not currently contain all the elements the 

EPA believes are necessary, we appreciate your willingness to work with PFI to address 

EPA’s recommendations to our current standards program. It is our belief that with a 

dedicated and focused effort by industry, along with the cooperation of EPA, we can 

finalize our standards program. It should be recognized that the current program was 

developed with the goal of improving product performance for the consumer. 

Open and ongoing communication with EPA, as well as a clear understanding of what 

EPA currently sees as required changes, is essential for PFI to efficiently guide the 

process over the coming months. 

During your presentation you outlined areas of the PFI standards which EPA thinks 

could be strengthened. While we can see the rationale behind this, we believe that 

some of the EPA’s observations/recommendations may be based on incorrect 

assumptions/data. We would like to further review these specific items with you. The 

following is a list of what we perceive as EPA’s observations/recommendations for the 

program, and a brief comment regarding PFI’s initial thoughts. 

1. Include Third Party Testing, Sampling and Auditing: The current program 

does include third party testing; however, all sampling is carried out by the 

manufacturer. Past considerations for inclusion of third party check sampling 

were left out due to cost and logistical considerations. PFI believes that it can 

maintain the current sampling and testing protocol and add an independent spot 
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sampling and an audit function which will meet EPA’s needs. These additions 

would be consistent with other similar industry standards. 

2. Include Ash Melting Point: The current program includes Ash Fusion testing 

on a periodic basis. This will not be required for each sample; however, 

frequency will be sufficient to determine the clinkering characteristics of subject 

fuels. We believe this is consistent with EPA’s needs. 

3. Recipes with No Bark: PFI believes this is excessive and unnecessary. Many 

pellet manufacturers are currently producing a premium grade product from barkon round wood. These pellets perform well in a wide range of appliances. 

Additionally, even the cleanest of sawmill residuals will include traces of bark, 

and as such, a black and white “no bark” rule would be extremely onerous and 

restrictive. PFI believes that ash limits and other quality parameters will keep 

bark inclusion rates at levels which will not pose a problem. Any restriction on 

the use of bark unnecessarily limits feed stock options for producers. PFI would 

caution that without further information on the balance of this product's quality 

characteristics and the appliance setup, it is extremely misleading to conclude 

that the solution is a total exclusion of bark from feedstocks. 

4. Test Every Batch: Our program currently calls for ongoing, in-house testing of 

feedstocks as well as finished product and independent third party testing of 

product at an interval of once per 1,000 tons. Once the independent check 

sampling and audit functions are added (as per item 1 above), we believe the 

level of product testing will be consistent with other comparable industries. We 

are uncertain as to what would define “batch”, as pellet production facilities 

generally run continuously with ongoing blending and extrusion. PFI needs 

clarification on the definition of a “batch” from EPA. 

5. Internal Options Selection in October 2010: We understand that this timeline 

is real and approaching quickly. We also understand that EPA needs to see far 

greater participation in the PFI program by that time before it would be 

considered a viable option by EPA. In your presentation you stated that if PFI did 

not have a 95% (more or less) participation rate by October, EPA would likely opt 

for an alternate standard. We are committed to making certain changes to the 

PFI program to facilitate the EPA October timeline; however, PFI believes that a 

target of 95% participation by that time is unattainable. PFI would hope that if we 

had a revised program that met the following criteria, that it would be EPA’s 

preferred option. 

A. Meets EPA’s requirements 

B. Meets the industry’s requirements in terms of appliance manufacturer 

 and consumer needs 

C. Has general industry acceptance 

D. Has a reasonable participation rate 
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6. Pellet Appliance Emissions Targets: As noted in EPA’s discussions regarding 

the NSPS, pellet appliances have the recognized ability to combust wood fuels 

and emit lower particulates than conventional wood stoves. We acknowledge 

EPA’s use of the Best Demonstrated Technology (BDT) in terms of emissions 

standards. While this topic is not a direct part of our pellet standards, it could 

have dramatic impact on our industry. If EPA’s single emissions threshold for 

pellet appliances eliminates all but premium grade fuels, it will significantly impact 

the country’s ability to grow its densified fuels capacity. In doing so, it may by 

default, promote a movement back to conventional wood burning stoves with 

their higher emissions, thus making this contrary to your desired outcome. PFI 

would hope that any emissions limits would be implemented with a focus on the 

long-term implications for both our industry and EPA’s air quality objectives. 

The above points include what we understand to be EPA’s observations and 

recommendations to the current PFI standards program, plus a few associated 

issues. Given the time sensitive nature of this process, PFI would like to request 

that we set up a time to discuss these concerns with you via teleconference. We 

want to be sure that we have correctly interpreted EPA’s intentions with regard to 

fuel standards. 

Jennifer Hedrick of PFI staff will follow up with you in the coming days to determine if 

you would be available for a conference call with PFI. It is our intent to maintain 

open communication with EPA throughout this process to ensure that all parties are 

fully apprised of progress and status. 

Again, thank you for your presentation to our industry. We look forward to working 

with you over the coming months. 

Sincerely, 

Jeff Thiessen 

President