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- July 23, 2010 --- Company Names Removed **Pellet Stove Manufactur**  **ers :**  **ICR Answers**  **to Question G** Question G. Please provide a list of characteristics that are critical for pellet fuels used in the units you manufacture (e.g., moisture content, ash content, dimensions, etc.) and why you think so. **1. Redacted**  It is important that the pellet fuel is of pre mium grade. Ash content should be no more than 3%, dimensions need to be consistent in length and preferabl y 1⁄4” diameter X 3⁄4” long. Id eall y moisture content should be 5
- 7 percent. Fuel of substandard value contributes to clogging of the auger sy stem, possible burn back issues, incomplete burn in the firepot and excessive maintenance for the unit. **2. Redacted**  Our stoves are design for wood pellets low in moisture and low ash content. The ty pical size of the pellet fuel is 1⁄4 inch round and less than 3⁄4 inch in length. [redacted some product specific info...] **3. Redacted** 
 Dimensions

– Our stoves are designed to use pellets 1⁄4” maximum diameter and no longer than 3⁄4”. We base our feed rates on this. This also minimizes jams.  Ash Content

– Ash over the PFI Standard co uld cause auger jams in our units.  Sodium Content

– This must be kept to its lowest level to eliminate corrosion and metal degradation.  Additives

– The cleanest burning pellets have no additives.  Fines

– Fines above 1% can cause auger jams.  Chlorides

– Keep as low as possible to eliminate corrosion. **4. Redacted**  The most critical characteristics for pellet fuels that a re used in the pellet stoves we manufacture are going to be: ash content, fines, moisture content and length. Ash content is considered most important, as a lower ash content keeps the burnpot area cleaner for a longer period of time, thus allowing a cleaner bum between cleanings. The most common operational problem for the home user is a dirty bum, and generally

this is related to maintenance. T he lower ash content will allow for users who do not follow regular maintenance schedules to get a clean bum, longer.Draft
- July 23, 2010 --- Company Names Removed **Pellet Stove Manufactur**  **ers :**  **ICR Answers**  **to Question G** Fines are also very

important, as they

tend to clog the augers in pellet stoves. In addition, fines tend to build up in the bumpot; they do not allow a s much airflow, and thus do not promote proper combustion. Moisture content is very

important for the efficiency of the unit (allowing more BTUs per lb. of fuel ), as well as performance. As with an y wood that is burnt, dry wood pellets will bum hotter and cleaner, and thus a low moisture content is preferred. Length is important for the auger feed sy stems of pellet stoves, as well as for consistency of bum. A consistent length of pellet fuel will prevent maintenance issues in stoves and w ill allow for a more even bum. I deally , if we were talking about a perfect world with an ideal fuel, the fuel would be the exact size across the board, and manufacturers such as ourselves would have a steady, even bum all the time. A steady fire bums clean er, thus reducing emissions. With this said, Iwould like to point out that pellet stoves are much cleaner, on average, than wood stoves and, due to the increased efficiency over wood stoves, that advantage is even more pronounced. As much as an y manufac turer wants the pellet industry to provide a perfect product, I believe it must also done practically , as it is in all of our best interests to keep this fuel affordable. If the restrictions upon pellet manufacturers were to become cost prohibitive, that w ould drive up the price of the fuel and keep it from becoming a preferred heating method to some consumers. Particularl y i n this economy , where our country needs to continue to develop products like pellet stoves for energy independence, it is my

hope that if we err, we err on the side of less stringent standards. As a stove manufacturer, of course it is in our best interest to have the best pellet available; however, if pellets become unaffordable due to excessively

strict standards, then nobody wins, as w e will not have a customer base for our product. **5. Redacted**  We recommend the use of premium pellets based on the pellet fuels institute standards listed below: Density : Consistent hardness and energy content (minimum 40 lbs/cubic foot) Dimensions: L ength (1.5” maximum) and diameter (1/4”
- 5/16”) to assure predictable fuel amount and to prevent jamming. Fines: L imited amount of sawdust from pellet breakdown, to avoid dust while loading and problems with pellet flow during operation. (Amount of fines passing through 1/8” screen no more than 5% b y weight.) Chlorides: L imited salt content (no more than 300 ppm) to avoid stove and vent rusting. Ash Content: Important factor in maintenance frequency
. Moisture Content: L ess than 8%Draft
- July 23, 2010 --- Company Names Removed **Pellet Stove Manufactur**  **ers :**  **ICR Answers**  **to Question G** The reason for recommending a pe llet that meets these standards is that quality of fuel greatl y affects the operation of the stove, the maintenance schedule of the stove increases in frequency by using a poor quality

fuel, Currentl y i t is difficult for the end user to determine the actual qualit y of the fuel and always blames the stove when it isn’t burning correctly. **6. Redacted**  Ash Content, Moisture Content, Fines, Species of Wood, and Overall dimensions are all important to the operation of our pellet units. Variability of these charact eristics has no doubt been the biggest challenge to our end users (and therefore the manufacturers) over the last several ye ars. When the customer becomes accustomed to the performance, heat output and maintenance intervals required by a specific fuel...and then those qualities change, the customer is forced to modify or alter how they

use and maintain their appliance. This isn’t necessarily

the issue between “West Coast” and “East Coast” fuel which we’ve dealt with for ye ars, but variability

of quality

and c onsistency

within regions and sometimes within brands which makes it difficult to keep up with. We’ve done all we can do to educate our customers on visual cues which might suggest they need to alter the operation of the units or increase the maintenance i ntervals but more consistency and control of the composition and performance of the fuel would:

 Greatl y increase the satisfaction of our customers
.  Greatl y reduce warranty/ customer service cost for manufacturers
.  R esult in finer tuned, cleaner burning mor e efficient appliances
.  Reduce the R& D costs of developing new units. **7. Redacted**  In formation not provided. **8. Redacted** 
 Density : consistent hardness and energy content (minimum 40 pounds/cubic foot).  Dimensions: length (1 Y2" maximum) and diameter (1/4" x 5/1 6") to assure predictable fuel amounts and to prevent jamming.  Fines: limited amount of sawdust from pellet breakdown to avoid dust while loading and problems with pellet flow during operation (amount of fines passing through 1/8" screen no more than .5 pe rcent by weight).  Chlorides: limited salt content (no more than 300 parts per million) to avoid stove and vent rusting.  Ash content: less than 1%. **9. Redacted**  In formation not provided.