Issue link: http://palletcentral.uberflip.com/i/1243182
36 PalletCentral • March-April 2020 palletcentral.com NWPCA SCORES BIG WIN WITH EPA ON BIOMASS RESIDUALS BIOMASS By Patrick Atagi Y ou may or may not be a fan of the '80s TV series The A-Team, but you probably know the famous catchphrase from the show: "I love it when a plan comes together!" And the plan came together for a win for the pallet industry. NWPCA resolved a quintessential problem in Washington, DC, where a minor technical glitch causes a significant problem. In this case, the disposal of recycled wood pallet biomass. The issue was all caused by an oxford comma, a small dot, or lack thereof. 9) Railroad ties, pressure-treated wood or pallets; It's going to get a bit political wonky here, but please indulge and read on. It's an exciting story. The lack of an Oxford comma after pressure treated wood in (9) above, as part of the EPA regulation on residential wood heaters, meant that the Pellet Fuels Institute (PFI) interpreted the language to mean all pallets. This led to the PFI certification of wood pellet fuel that restricted the use of recycled wood pallets under their current standards. The PFI interpretation led to an essential ban on recycled pallet wood in wood pellets. What does this mean? It means that wood stoves using non-certified pellets would, at minimum, void their warranty, stated in owner's manuals, and in their product warranties. Thus, an incentive not to use wood pellets using recycled wood pallets. An opportunity to make a change - On March 16, 2015, the Environmental Protection Agency (EPA) issued a final rule revising the Standards of Performance for New Residential Wood Heaters. 80 Fed. Reg. 13,671 (Mar. 16, 2015). In that rule, the EPA promulgated regulations governing requirements for pellet fuel. As previously noted, as written, however, this prohibition should apply only to pressure-treated wood or pressure-treated pallets given the absence of the Oxford comma. The limited application of this exemption is also apparent given that railroad ties and pressure-treated wood are both chemically treated wood products. Not all wood pallets are constructed from pressure-treated wood. In fact, most are not. An opportunity provided itself to fix the oxford comma because the regulation was opened-up for comments and revision. Under the PFI Standards Program, wood pellets with wood pallet residuals could not be certified. This is of grave concern across the industry that these pallets would be diverted to landfills, rather than recycled as a renewable fuel source. The exclusion also causes a financial hardship on the small, family businesses that count on the pellet market for their pallet residuals. Instead of receiving "Working Together Works! 123rf.com