discussion paper - energy north · in effect, installations of wood pellet stoves, furnaces and...

NWT BIOMASS ENERGY ASSOCIATION

DISCUSSION PAPER

BARRIERS TO BIOMASS ENERGY

INSTALLATIONS IN THE NWT

MAY 2014

Discussion Paper: Barriers to Biomass Energy Installations in the NWT

NWT BIOMASS ENERGY ASSOCIATION i

EXECUTIVE SUMMARY

Since 2006, the NWT has been moving away from the use of oil-fired heating systems by installing wood

pellet heating, which is suitable for residential, commercial and institutional buildings. Wood pellet

supply is now available in at least fourteen (14) of the NWT’s thirty-three (33) communities. Total wood

pellet consumption is currently estimated at about 15,000 tonnes per year (5% of total NWT space

heating demand) and is projected to reach 50,000 TPY by 2022. The GNWT has played a leadership role

in promoting and supporting wood pellet market developments through its conversion of numerous

GNWT facilities to wood pellet heating and steady implementation of the NWT Biomass Energy Strategy,

now in its second edition (2012 – 2015).

In 2013, some of the businesses involved in the wood pellet industry worked together to establish the

NWT Biomass Energy Association (NWTBEA), in order to pool resources and knowledge to promote,

support and develop biomass markets, products and services. The NWTBEA receives some financial

support from the Department of Environment and Natural Resources (ENR) and administrative support

from the Arctic Energy Alliance (AEA).

One of the drivers for the creation of the NWTBEA is the need to address barriers that are hampering

the ability of homeowners, commercial and institutional heating customers to easily convert to wood

pellet heating systems, particularly boilers. The NWTBEA’s concerns (which stem largely from the fact

that pellet heating systems are still relatively new to Canada and the NWT) include the following:

a lack of technical guidelines specific to automatic feed pellet boiler systems;

a general lack of understanding of the latest generation of automatic feed pellet boiler systems

by regulatory and permitting agencies (and staff) and resulting inconsistencies or contradictions

in technical requirements and responses;

inconsistent treatment of pellet boiler systems by insurance companies in the NWT; and,

a need to monitor and control the quality of wood pellets being supplied to the NWT.

Following an initial meeting in February 2014 between representatives of the NWTBEA and Minister

Michael Miltenberger to discuss the above-noted concerns, the NWTBEA has prepared this Discussion

Paper to document its concerns and suggested remedies for submission to Minister Miltenberger for his

review and consideration. The NWTBEA gratefully acknowledges the funding support provided by ENR

towards the preparation of this paper.

In the NWT, the design, installation and operation of biomass heating systems falls under a number of

different codes, standards and regulatory authorities ranging from national building codes to territorial

legislation to municipal bylaw requirements. Adding to the complexity is the fact that the details change

depending on whether the pellet heating system is a residential pellet stove, a residential pellet boiler /

furnace or a commercial pellet boiler and depending on the community involved.

Sections 2.3 and 2.4 outline the various requirements and authorities involved and provide flow charts

to summarize the steps typically involved for each of the three types of projects.


NWT BIOMASS ENERGY ASSOCIATION ii

Section 3 outlines the NWTBEA’s main concerns, including:

Legislation, Regulations, Codes and Standards

The various provisions (i.e. in the NBC 2010, the NFC 2010, the CSA Code B365-10, the Fire Prevention

Act, the Fire Prevention Regulations, the Boilers and Pressure Vessels Act and the Boilers and Pressure

Vessels Regulations) which are relevant to the installation and operation of wood pellet boiler systems

and must be complied with, were generally written in the context of larger, solid-fuel combustion

technologies and are not specific to wood pellet heating systems.

In effect, installations of wood pellet stoves, furnaces and boiler systems in the NWT are held to

standards originally established for different solid fuel sources (i.e. cordwood, coal etc.) which bear little

resemblance to the “factory built” pellet combustion heating systems on the market today.

The NWTBEA has two recommendations:

Recommendation #1: Develop Pellet Heating Guidelines for the NWT

Recommendation #1 is voluntary and is intended to provide a short-term solution (i.e. next 5 years) to

help reduce challenges to the installation of biomass heating systems in NWT communities.

Specifically, the NWTBEA is proposing that it work collaboratively with the GNWT (ENR, PW&S, OFM)

and other stakeholders (Arctic Energy Alliance, municipal governments, designers, contractors,

equipment suppliers etc.) to develop NWT-specific guidelines for the design, procurement, permitting,

installation, inspection, operation and maintenance of wood pellet heating systems.

Recommendation #2: Support the Development / Adoption of National Standards for

Biomass Fuel and Heating Equipment

Recommendation #2 is a longer-term solution that will likely take several years to complete.

Specifically, the NWTBEA is proposing (with the support of ENR and PW&S) that it engage with other

jurisdictions (in Canada) and the Canadian Standards Association to support the development of

national standards for “Solid Biomass Fuel and Heating Equipment in Canada”.

Once developed, such a standard could be adopted through the Office of the Fire Marshal for use

throughout the NWT.

Outreach and Education

Assuming that Recommendation #1 regarding the development of guidelines is undertaken, a sustained

outreach and education effort will be required to familiarize all affected parties with the new guidelines

and encourage positive changes in the various processes involved in the installation of a wood pellet

boiler system and storage.

The NWTBEA has one recommendation:


NWT BIOMASS ENERGY ASSOCIATION iii

Recommendation #3: Conduct Outreach and Education

The NWTBEA is proposing to work collaboratively with the design community, the regulatory

authorities, heating and plumbing contractors, the insurance companies and other stakeholders to

address concerns and increase understanding of wood pellet boiler and pellet storage systems and find

ways to reduce “red tape”, delays and costs associated with the installation of pellet heating systems.

Pellet Quality and Emissions

In Canada, wood pellets are made from sawmill residues, logging waste, insect-killed trees and low-

grade logs. At present, the NWT’s pellet supplies are being shipped in primarily from large pellet plants

in the Prince George area of B.C. and from a smaller pellet mill at La Crete, Alberta.

Given the different sources from which wood pellets are made, pellets are classified based on a number

of key characteristics, with moisture content, ash content and % of fines being the most important pellet

properties. In North America, pellets are generally classified and sold as “Premium”, “Standard” and

“Industrial” grades. In Europe, pellets are classified under the ENPlus certification system which

specifies “A1”, “A2” and “B” grades.

The quality of wood pellets is important in space heating applications as pellet quality can impact on the

performance, maintenance, emissions and reliability of the pellet heating system. This is particularly the

case for residential pellet stoves and small residential boiler systems which are more sensitive to the

amount of fines, resulting in problems in the in-feed auger or the burning chamber.

In Canada, the Wood Pellet Association of Canada recently became licensed to manage CANplus, which

is a quality certification scheme based on the highly successful ENPlus certification system being used in

Europe. Key components will include quality specifications (using the A1, A2 and B grades) and

approved laboratories and inspection bodies. It is anticipated that as pellet producers and distributors

become certified, the CANplus seal will be seen on pellets produced, distributed and sold in Canada.

The NWTBEA has one recommendation:

Recommendation #4: Develop and Implement a Pellet Testing Protocol for NWT Pellet Supplies

Assuming that the CANplus pellet certification system becomes fully implemented and pellet mills in BC

and Alberta become certified, this would provide the basis for implementing a testing protocol to ensure

that quality pellets are being shipped to the NWT.

The NWTBEA is proposing to work collaboratively with ENR and PWS to determine the details for a

suitable testing protocol, who would be involved, what the annual cost may be and how such costs

would be covered.

It should be noted that a testing protocol would likely need to be applied to each segment of the pellet supply chain of producers, transporters and distributors.


NWT BIOMASS ENERGY ASSOCIATION iv

TABLE OF CONTENTS

EXECUTIVE SUMMARY………………………………………………………………………………………………………………… I

1 INTRODUCTION ............................................................................................................. 1

1.1 NWT Biomass Energy Association ...................................................................... 1

1.2 Purpose and Objectives .................................................................................... 2

2 BACKGROUND ............................................................................................................... 4

2.1 NWT Wood Pellet Industry ................................................................................ 4

2.1.1 Residential ...........................................................................................................................4

2.1.2 Commercial .........................................................................................................................4

2.1.3 Institutional .........................................................................................................................5

2.2 Territorial Targets ............................................................................................. 5

2.3 Building Codes, Standards and Regulatory Agencies .......................................... 6

2.4 Flow Diagrams for Pellet Heating System Installations ..................................... 11

3 ISSUES AND ANALYSIS .................................................................................................. 14

3.1 Legislation, Regulations, Codes and Standards ................................................. 14

3.1.1 Examples from Other Jurisdictions ...................................................................................15

3.1.2 Canadian Initiatives ...........................................................................................................15

3.1.3 Recommendations ............................................................................................................16

3.2 Outreach and Education ................................................................................. 17

3.2.1 NWT Heating and Plumbing Contractors ..........................................................................17

3.2.2 Pellet Heating System Manufacturers & Suppliers ...........................................................18

3.2.3 Design Professionals .........................................................................................................18

3.2.4 Office of the Fire Marshal .................................................................................................19

3.2.5 Insurance Brokers / Underwriters .....................................................................................19

3.3 Wood Pellet Quality and Emissions ................................................................. 20

4 CONCLUSIONS ............................................................................................................. 23

APPENDIX A: REFERENCES ............................................................................................... 24


NWT BIOMASS ENERGY ASSOCIATION 1

1 INTRODUCTION

Biomass energy is any energy derived from a biological source, such as wood, agricultural crops

and other wastes. In the NWT, biomass energy (cordwood and wood pellets) is becoming

increasingly popular for space heating as it provides significant energy-cost savings and

environmental benefits compared to fossil-fuel fired heating systems1.

Cordwood, which represents about 6% of total NWT space heating demand, is used almost

entirely for home heating. Wood pellet heating, which is suitable for residential, commercial

and institutional buildings, is now in use in at least fourteen (14) of the NWT’s thirty-three (33)

communities and the market continues to grow. Total wood pellet consumption is estimated at

about 15,000 tonnes per year or 5% of total NWT space heating demand.

The first pellet heating system in the NWT was installed in 2006 by private entrepreneurs under

an energy services contract with the GNWT. Since then, the GNWT has played a leadership role

in promoting and supporting wood pellet market developments through its conversion of

numerous GNWT facilities to wood pellet heating and steady implementation of the NWT

Biomass Energy Strategy, now in its second edition (2012 – 2015). As a result, the GNWT is the

single biggest wood pellet heating customer in the NWT (at about 4,600 tonnes per year).

1.1 NWT Biomass Energy Association

The rapid increase in the use of wood pellet heating systems has resulted in numerous business

opportunities related to wood pellet supply and distribution and the provision of technical

services (pellet heating system design, procurement, installation and maintenance).

In 2013, some of the businesses involved in the wood pellet industry (pellet delivery and pellet

system sales and installation) began working together to establish the NWT Biomass Energy

Association (NWTBEA). The creation of the NWTBEA (which is Action 14 in the NWT Biomass

Energy Strategy 2012-2015) recognizes the need for businesses to pool resources and

knowledge to promote, support and develop biomass markets, products and services. The

NWTBEA receives some financial support from the Department of Environment and Natural

Resources (ENR) and administrative support from the Arctic Energy Alliance (AEA).

One of the drivers for the creation of the NWTBEA is the need to address barriers that are

hampering the ability of homeowners, commercial and institutional heating customers to easily

1 In the near future, it is expected that the production and use of wood chips will also occur, particularly in Fort

McPherson, Fort Providence, Fort Resolution and the Tlicho Region.



convert to wood pellet heating systems, particularly boilers. The NWTBEA’s concerns, which

stem largely from the fact that pellet heating systems are still relatively new to Canada and the

NWT, include the following:

a lack of technical guidelines specific to automatic feed pellet boiler systems;

a general lack of understanding of the latest generation of automatic feed pellet boiler

systems by regulatory and permitting agencies (and staff) and resulting inconsistencies

or contradictions in technical requirements and responses;

inconsistent treatment of pellet boiler systems by insurance companies in the NWT;

and,

a need to monitor and control the quality of wood pellets being supplied to the NWT.

In February 2014, two members of the NWTBEA met with Minister Michael Miltenberger to

discuss their concerns and seek remedies. The main result of this meeting was a request that

the NWTBEA detail its concerns in a Discussion Paper that would be submitted to the Minister

for his review and consideration.

This document represents the NWTBEA’s submission to Minister Miltenberger with respect to

these matters.

1.2 Purpose and Objectives

The NWTBEA’s purpose in preparing this Discussion paper is to initiate a process of dialogue

and collaboration with the GNWT and other parties to evaluate and implement real solutions

that will improve the industry’s ability to install and operate automatic feed pellet boiler

heating systems in the NWT. As such, the NWTBEA is of the view that its interests are the same

as the GNWT’s in wanting to see the continued growth of the NWT biomass market while

ensuring proper safeguards on public health and safety at all times.

The NWTBEA’s objectives in preparing this Discussion Paper are to:

Provide information on the technical specifications and best practices used in other

jurisdictions where wood pellet heating systems are commonplace;

Illustrate the key issues that end-use customers and contractors in the NWT are

regularly encountering in the process of designing, permitting, installing and

commissioning automatic feed wood pellet heating systems;



Engage with the GNWT and other agencies to identify, evaluate and implement viable

solutions; and,

Continue to support the growth of the biomass market and industry and achieve the

goals and targets contained in the NWT Greenhouse Gas Strategy and NWT Biomass

Energy Strategy.



2 BACKGROUND

This section provides additional information that forms the general context for the issues

discussed in Section 3.

2.1 NWT Wood Pellet Industry

As described earlier, approximately 15,000 tonnes per year of wood pellets are being imported

to the NWT and distributed to at least 14 communities for space heating purposes. The

delivery of pellets into the NWT is done by truck and by CN railway to Hay River. Significant

pellet suppliers are located in La Crete, AB and in Prince George and Grand Cache, BC.

Privately-owned distribution networks are in place to serve all southern NWT communities, the

Yellowknife region, Norman Wells and Inuvik. In the near future, it is expected that a pellet

supply arrangement from the Yukon will decrease the cost to truck pellets into the Delta region.

The three different market segments that make up the NWT pellet market are described below:

2.1.1 Residential

Residential customers predominately purchase wood pellets in 18-kg bags but may also

purchase bulk pellets if an-town pellet distributor is available to them.

Two types of pellet heating systems are used for residential applications:

Pellet Stove Installations – the vast majority of the pellet heating systems installed (so far) for

residential customers are pellet stoves (10-15 kW range). Since 2007, an estimated 800 to

1,000 pellet stoves have been installed in the NWT. The total pellet supply required to serve

these customers is about 2,500 tonnes per year. Given that much of this market has developed

in the last five years, the residential market is growing by about 125 to 150 pellet stove

installations (500 – 600 tonnes of pellets) per year.

Automatic Feed Pellet Boiler Systems – on occasion, a small, automatic feed pellet boiler

system (12-25 kW range) may be installed for a larger residential application that involves space

heating and other domestic hot water requirements.

2.1.2 Commercial

Commercial installations typically include apartment and other multiplex buildings, office and

retail buildings and various industrial buildings. Smaller automatic feed pellet boiler systems

(18-75 kW) are usually installed in the mechanical room and involve in-town bulk delivery of

pellets (<100 tonnes per year).



Larger commercial systems, which can range from 75 to 150 kW (or larger), typically require

that the boiler be housed in an outside container and often involve bulk delivery of pellets

(>200 tonnes per year) direct from a mill to a large storage silo.

The total pellet demand for commercial heating is estimated at about 9,000 tonnes per year

(TPY). The NWTBEA estimates that 60 to 80 installations have occurred in the last five or six

years.

2.1.3 Institutional

Larger, automatic feed pellet boiler systems suitable for institutional applications may range

from 150 to 600 kW. In the last six years, PWS has played a pivotal role in developing the

biomass market in the NWT by installing automatic feed pellet boilers to supplement oil heating

in public buildings.

As of 2013, PWS had commissioned thirteen (13) pellet heating systems with total annual pellet

consumption of approximately 4,600 tonnes and have several more in design or construction

(Action 1, NWT Biomass Energy Strategy).

In addition, the GNWT is examining the potential for integrating biomass heating for public

housing and helping communities in implementing biomass energy projects (Actions 2 and 5

respectively, NWT Biomass Energy Strategy).

2.2 Territorial Targets

The NWT Greenhouse Gas Strategy (2012-2015) contains the following performance targets

related to the increased use of biomass heating (see p. 26):

By 2015, increase the capacity of biomass heat in residential buildings by 100 per cent;

and,

By 2015, increase the capacity of biomass heat in commercial and institutional buildings

by 100 percent.

These targets are also reflected in the NWT Biomass Energy Strategy (2012-2015). Specifically,

it is noted (see p. 9) that the achievement of these goals will require a doubling of the current

demand for wood pellets from 15,000 tonnes per year to about 30,000 tonnes by 2015.



2.3 Building Codes, Standards and Regulatory Agencies

In the NWT, the design, installation and operation of biomass heating systems falls under a

number of different codes, standards and regulatory authorities, including:

National Building Code of Canada (2010) – the NBC 2010 is the model building code that forms

the basis for all provincial and territorial building codes. It details the minimum provisions

acceptable to maintain the safety of buildings, with specific regard to public health, fire

protection, accessibility and structural sufficiency. It is typically revised and updated about

every five years. Provinces and territories can either adopt the National Building Code (often

with laws or regulations that are supplementary to the requirements of the NBC) or may create

their own building code based on the NBC.

National Fire Code of Canada (2010) – the NFA 2010 sets out the technical provisions that

regulate activities related to the construction, use and demolition of buildings and facilities, the

condition of specific elements of buildings and facilities, the design or construction of specific

elements related to certain hazards and protection measures for current or intended use of

buildings. Both the NBC 2010 and the NFC 2010 must be considered when constructing,

renovating or maintaining buildings.

CSA Standards – the Canadian Standards Association (CSA) is a not-for-profit organization which

develops standards in fifty-seven (57) areas. It is composed of representatives from industry,

government and consumer groups. CSA is accredited (by the Standards Council of Canada) as a

standards development organization and as a certification body.

There are a number of CSA standards applicable to biomass boilers in Canada, including:

CSA Standard B365-10 – is the code for the installation, alteration and maintenance of

solid-fuel-burning appliances and equipment installed indoors or outdoors. Under the

code, solid-fuel-burning appliances include stoves, furnaces and boilers (section 1.2) and

the definition of “solid fuel” includes cordwood, wood chips and wood and other

biomass pellets (section 1.3).

This code also makes reference to other applicable standards such as the Underwriters

Laboratories of Canada (ULC). ULC standards that apply to components of biomass

boiler systems include:

o CAN/ULC S629-M87 – Standard for 650° C Factory-Built Chimneys

o CAN/ULC S635-M90 – Standard for Lining Systems for Existing Masonry or

Factory-Built Chimneys and Vents



o CAN/ULC S641-00 – Standard for Factory-Built Chimney Connectors and Wall

Pass-Through Assemblies

CSA Standard B366.1-M91 – specifies the requirements for solid-fuel-fired central

heating appliances. Section 4.2 specifies that the electrical features of solid-fuel-fired

central heating appliances shall meet the applicable requirements of CSA Standard

C22.2 No.3.

Section 7.1 specifies the requirements for solid-fuel-fired furnaces, section 7.2 specifies

the requirements for solid-fuel-fired boilers and section 7.3 specifies the requirements

for automatic fuel-feeding devices. Sections 8.1 to 8.4 indicate the markings that are to

be clearly placed on any solid-fuel-fired furnace or boiler including basic data, operating

instructions and installation instructions.

CSA Standard C22.2 No. 3 – this standard specifies the electrical features of gas, oil and

solid-fuel burning appliances where the specific standard for such appliances requires

compliance with this standard and the appliances are intended to be connected to

supply circuits with voltages of 750 V and less, for use in no-hazardous locations.

CSA Standard B.51-14 – just released in January 2014, this version replaces B.51-09.

Part 1 contains code requirements for boilers, pressure vessels, pressure piping and

fittings. It is intended to promote safe design, construction, installation, operation,

inspection, testing and repair practices and to facilitate adoption of uniform

requirements by Canadian jurisdictions.

CSA Standard B415.1-00 – provides the emission specifications for wood burning

appliances (up to 2 MW).

Fire Prevention Act and Fire Prevention Regulations – the Fire Prevention Act is territorial

legislation that governs the establishment, authorities and duties of the Office of the Fire

Marshal. Under the Fire Prevention Act, the GNWT may establish Fire Prevention Regulations

pertaining to a number of the areas in the Act including regulations that provide for

enforcement, the carrying out of the intent and provisions of the Act and the adoption of rules

and standards.

Section 2(1) of the Fire Prevention Regulations specifies the adoption of the National Building

Code of Canada and the National Fire Code of Canada (and other recognized codes and

standards) as amended from time to time. Section 2(2) specifies that in the various codes and

standards adopted in section 2(1), the “authority having jurisdiction” means the Fire Marshal.



Boilers and Pressure Vessels Act and Regulations – the Boilers and Pressure Vessels Act is

territorial legislation that governs the design, fabrication, installation, inspection and safe

operation of boilers and pressure vessels in the NWT.

The provisions of the Act apply to boilers in excess of 30 kW or pressure vessels that operate

above a pressure of 103 kPa. This includes triplex (or larger) residential housing and any

commercial building. Boilers that are less than 30 kW or that are used for heating private

residences (that house less than three families) are exempt.

Under section 57 of the Boilers and Pressure Vessels Act, the GNWT may establish Boilers and

Pressure Vessels Regulations that specify the codes and standards that are in force, the process

for the approval and registration of boiler and pressure vessel designs and other matters

pertaining to the installation, inspections and operations of a boiler or pressure vessel. Sections

4 to 12 of the Regulations specify that the design and specifications of a boiler or pressure

vessels and the fittings and accessories to be used in connection with boilers or pressure

vessels must be submitted to the Chief Inspector for approval and registration in accordance

with the rules set out in CSA B51.

Electrical Protection Act and Regulations – the Electrical Protection Act is territorial legislation

that governs the permitting, installation and use of electrical equipment and the performance

of electrical work in the NWT. Section 7.(1) specifies that all electrical work and equipment

must conform to the standards set in the Canadian Electrical Code (the Code), as altered or

amended by regulations made under the Act.

Under section 22 of the Electrical Protection Act, the GNWT may make Electrical Protection

Regulations prescribing alterations or amendments to the Code, the adoption of codes and

standards, the approval of electrical equipment, the approval of plans, the application and fees

for an installation permit and the inspection of electrical work.

The Department of Public Works and Services is responsible for the administration and

enforcement of the Boilers and Pressure Vessels Act and Regulations and the Electrical

Protection Act and Regulations.

Office of the Fire Marshal – the OFM is responsible for delivering several programs related to

fire and fire safety. Duties include:

fire investigations and fire loss reporting;

fire and life safety inspections / enforcements;

fire service training;

Public safety and risk management education and prevention programming;



Reviewing building plans to ensure compliance with adopted codes and standards; and,

Enforcement of the Fire Prevention Act.

All construction and renovation in the NWT must be reviewed by the Office of the Fire Marshal

prior to the onset of construction (unless it is exempted pursuant to section 3 of the Fire

Prevention Regulations).

Technical bulletins are issued by the OFM, under the authority of the Fire Prevention Act, to

clarify or modify codes, standards and guidelines referenced in the Fire Prevention Act and Fire

Prevention Regulations.

Technical bulletin FM-065-2008 (revised on May 31, 2013) outlines the regulatory requirements

for the installation of all future solid-fuel fired boiler systems in the NWT for commercial

applications. The specifications in the bulletin include the requirements contained in CSA Code

B365-10.

Public Works and Services – pursuant to the provisions of the Boilers and Pressure Vessels Act

and Regulations and the Electrical Protection Act and Regulations , the Electrical / Mechanical

Safety group within PWS is responsible for providing advice, registration, installation permits

and inspections for boilers and pressure vessels and for electrical work. Duties include:

Approval of Design and Specifications – some boilers, pressure vessels, fittings and

pressure piping require registration. In these cases, the manufacturer is required to

submit (to the Chief Inspector) the design and specs for review and approval in order

to receive a Canadian Registration number (CRN) with the designation “T” before the

boiler can be used in the NWT. Registration is a one-time requirement, unless

alterations to the original design are made.

Installation Permits – section 17 of the Boilers and Pressure Vessels Regulations state

that no person shall install, alter, repair, or add to a boiler, pressure vessel or pressure

piping system without having an installation permit. Similarly, various sections of the

Electrical Protection Regulations specify that only qualified electrical workers can

perform electrical work and must obtain an installation permit before undertaking

electrical work.

Inspections – under section 12 of the Boilers and Pressure Vessels Act, the chief

inspector may require the inspection of a boiler or pressure vessel during any stage of

its fabrication or installation. If inspected during fabrication or installation, the chief

inspector may issue a certificate of inspection. Under section 13 of the Act, if a boiler

or pressure vessel has not been inspected during its fabrication or installation, the



chief inspector may issue a certificate of approval. A certificate of inspection or

certificate of approval remains in force for 12 months after the date of inspection.

Subject to section 19 of the Act, a boiler or pressure vessel shall be inspected every 12

months or at the periodic intervals fixed by an inspector. Under section 25 of the Act,

if a boiler or pressure vessel is insured, the annual (or periodic) inspection shall be

carried out by (or through) the insurer. If satisfied that the boiler or pressure vessel

can be operated or used safely, the insurer shall issue a certificate of inspection. Every

insurer is required to file a copy of the report of an inspection with the chief inspector.

In communities where an electrical inspector is available, up to three inspections may

be performed, depending on the nature of the job (Permission to Make Roughed in

Electrical Work Inaccessible, Authorization for Power Connection, Final Inspection). In

communities where an inspection cannot be performed within 14 days of notification,

the first two inspections may be approved by the qualified electrical worker by faxing a

completed Statutory Declaration (followed by a phone call) to the Regional Electrical

Inspector.

Local Authorities / Community Bylaws – all installations must comply with the requirements of

local authorities. The details are usually contained in a community bylaw and can vary,

depending on the community.

To illustrate, the City of Yellowknife’s Building Inspections Division is responsible for issuing

Building Permits and Mechanical Permits and conducting inspections. In accordance with City

of Yellowknife Building Bylaw #4469:

a Building Permit is required for the construction and occupancy of new buildings and

the alteration, reconstruction, demolition, removal, relocation, and occupancy of

existing buildings; and,

a Mechanical Permit (section 19) is required to construct, install, extend, alter, renew,

relocate or repair a mechanical system, the definition of which includes solid fuel

heating systems.

Documentation required as part of the application package for a Building Permit or Mechanical

Permit includes:

all required plans, specifications and schedules;

a Letter of Commitment (Form D) signed by the registered design professional of record

assuring that the design described by the supporting documents (plans specs etc.)



substantially comply with the NBC and the City’s Building Bylaw. The undersigned also

undertakes to be responsible for field review activities during construction;

a Summary of Design and Field Review Requirements (Form E) on which the registered

design professional of record initials the applicable responsibilities and crosses out the

non-applicable items within the list of Building Code activities; and,

The review of the project plans, specs and schedules completed by the Office of the Fire

Marshal.

An application for a Building Permit or Mechanical Permit is reviewed by a Building Inspector to

ensure compliance. Once the application is approved, the Permit can be picked up. The plan

review sheet lists the inspections that will be required by the Inspections Division.

For the installation of solid-fuel burning appliances and equipment, the City requires that the

contractor complete and sign an Installation Checklist that is then submitted to the Inspections

Division prior to the final inspection. The Installation Checklist form contains 35 items derived

from the NBC and CSA B365 that may be applicable for a solid-fuel heating system installation.

In smaller communities outside Yellowknife, the specific requirements are typically much

simpler as most community governments do not have a Building Division or inspectors,

however, local bylaws must be complied with.

2.4 Flow Diagrams for Pellet Heating System Installations

To understand how the various requirements specified in section 2.3 above apply, flow

diagrams have been prepared to illustrate the typical steps involved to install a residential

pellet stove or small pellet boiler system (<30 kW) or a commercial pellet heating system:

Residential – pellet stoves are sized for residential use and are often installed as a form of

supplementary heat. For larger residences, a small pellet boiler or furnace may also be used.

To re-cap, a project is considered residential if it is less than 30 kW and It is for a single family

dwelling or duplex. The residential flow diagram is on page 12.

Commercial (includes Institutional) – to re-cap, a pellet heating project is considered to be

commercial if it is greater than 30 kW, has a pressurized vessel (> 103 kPa) or it is for a triplex

(or larger) residential building or any commercial / institutional building. The commercial flow

diagram is on page 13.



3 ISSUES AND ANALYSIS

Based on the experiences of the NWTBEA’s member companies since 2007, several areas have

been identified that the NWTBEA feels can (and should) be addressed to make it easier to

install wood pellet heating systems in the NWT.

3.1 Legislation, Regulations, Codes and Standards

As shown in section 2.4, there are various provisions in the NBC 2010, the NFC 2010, the CSA

Code B365-10, the Fire Prevention Act, the Fire Prevention Regulations, the Boilers and Pressure

Vessels Act and the Boilers and Pressure Vessels Regulations that are relevant to the installation

and operation of wood pellet boiler systems and must be complied with.

The basic problem is that these provisions are generally written in the context of larger, solid-

fuel combustion technologies and are not specific to wood pellet heating systems. Solid fuel (as

contrasted with liquid or gaseous fuels) is defined as various types of solid material that can be

combusted to provide energy and heating. Types of solid fuel include wood, charcoal, peat,

coal, hexamine fuel tablets and pellets made from wood, corn and grains.

In effect, installations of wood pellet stoves, furnaces and boiler systems in the NWT are held to

standards originally established for different solid fuel sources (i.e. cordwood, coal etc.) which

bear little resemblance to the “factory built” pellet combustion heating systems on the market

today. This creates potential for confusion in the interpretation of rules and regulations and

often results in delays or unnecessary complications in the completion of wood pellet stove and

boiler projects.

Some specific examples of the problems that NWTBEA members have experienced in the

installations of both residential and commercial / institution pellet heating systems include:

High costs to get engineered design packages for pellet boiler systems (>100 kW);

Inconsistencies in the interpretation of OFM Technical Bulletin FM-065-2008 (revised

on May 31, 2013);

Confusion around the rules for installing pellet heating systems in outside containers

(such as seacans) and in proximity to combustible materials (such as a sub-floor); and,

Unnecessary requirements regarding pellet storage silos and pellet storage.

Delays or complications generally increase the cost of the project, cause frustration for the

contractor (and customer) and are counter-productive to the GNWT’s intent to significantly

increase biomass heating in the NWT.



3.1.1 Examples from Other Jurisdictions

It is beyond the scope of this paper to delve into the details of how wood pellet supply and

wood pellet heating systems are regulated in other jurisdictions.

However, it is instructive to note that several jurisdictions outside Canada have developed

standards or guidelines that are specific to wood pellets. Some examples include:

European Pellet Standards

o EN 14961-1 (for general use) - published

o EN 14961-2 (for wood pellets for non-industrial use) – under development

European Pellet Council

o Handbook for the Certification of Wood Pellets for Heating Purposes (version

2.0)

German Wood Fuel and Pellet Association

o Recommendations for Storage of Wood Pellets

Pellet Fuels Institute (USA)

o Standard Specification for Residential / Commercial Densified Fuel

o North American Certification of Residential / Commercial Densified Fuel

o Residential / Commercial Densified Fuel QA/QC Handbook

o Residential / Commercial Densified Fuel Enforcement Regulations

International Organization for Standardization (ISO)

o ISO/TC 238 is currently developing 60 standards for solid biofuels. Once

published, these standards will replace the EN 14961 standard (listed above)

3.1.2 Canadian Initiatives

In Canada, there have been some recent efforts to begin improving the regulatory framework

for biomass fuel and heating appliances. These include:

Wood Pellet Association of Canada – has established ENplus and CANplus pellet

certification for domestic use

Canadian Standards Association – has established a mirror committee for ISO/TC 238 on

solid biofuels

It should also be noted that Ontario Ministry of Natural Resources and Natural Resources

Canada are proposing to partner on the development of “Standards for Solid Biomass Fuel and

Heating Equipment”. Preliminary information on the nature of this work indicates that it is

focused on applications for the scale of 150 kW to 3 MWth and is being driven by

environmental and air quality concerns.



The NWTBEA will need to contact the CSA and other stakeholders in Canada to obtain

additional information on current or future plans for the potential development of standards

for solid biofuels and heating equipment in Canada.

3.1.3 Recommendations

The NWTBEA has two recommendations to make regarding the development and adoption of

biomass-specific guidelines and standards:


Recommendation #1 is voluntary and is intended to provide a short-term solution (i.e. next 5

years) to help reduce challenges to the installation of biomass heating systems in NWT

communities.

Specifically, the NWTBEA is proposing that it work collaboratively with the GNWT (ENR, PW&S,

OFM) and other stakeholders (Arctic Energy Alliance, City of Yellowknife, designers, contractors,

equipment suppliers etc.) to develop NWT-specific guidelines for the design, procurement,

permitting, installation, inspection, operation and maintenance of wood pellet heating systems.

Topics that could be addressed through comprehensive guidelines might include:

Pellet boiler systems (makes & models) already approved for use (in the NWT)

Process for obtaining certification for new pellet heating systems

Explanation / interpretation of CSA Code B365-10, OFM Technical Bulletin FM-065-2008

requirements, territorial legislation and regulations etc. for:

o Residential pellet stoves

o Residential pellet boilers / furnaces

Installed inside main building

Installed in an ancillary building

o Commercial pellet boiler systems

Installed in a mechanical room inside the building

Installed in an ancillary building or “container”

Pellet storage and handling

Insurance company requirements re: residential and commercial systems

Pellet supply, quality (specifications) and testing protocols

Air quality and emissions concerns;



Assuming that Recommendation #2 below is undertaken successfully, it is expected that the

voluntary Pellet Heating Guidelines for the NWT would eventually be replaced by biomass-

specific codes and standards.



Recommendation #2 is a longer-term solution that will likely take several years to complete.

Specifically, the NWTBEA is proposing (with the support of ENR and PW&S) that it engage with

other jurisdictions (in Canada) and the Canadian Standards Association to support the

development of national standards for “Solid Biomass Fuel and Heating Equipment in Canada”.

Once developed, such a standard could be adopted through the Office of the Fire Marshal for

use throughout the NWT.

3.2 Outreach and Education

Assuming that Recommendation #1 regarding the development of guidelines is undertaken, a

sustained outreach and education effort will be required to familiarize all affected parties with

the new guidelines and encourage positive changes in the various processes involved in the

installation of a wood pellet boiler system and storage.

There are a number of key parties that the NWTBEA could reach out to, including:

3.2.1 NWT Heating and Plumbing Contractors

As noted in section 2.2 above, the GNWT’s target for annual pellet consumption in the NWT is

30,000 tonnes. This is double the 15,000 tonnes currently estimated for annual pellet

consumption in the NWT.

If wood pellet heating continues to grow in popularity and the GNWT target is eventually

reached, this will result in many more heating and plumbing contractors and tradesmen

becoming involved in pellet heating system installations.

Rather than let each new entrant “learn the hard way”, the NWTBEA envisions playing a

leadership role in assisting existing or new companies and individuals learn the ropes and avoid

common mistakes or misunderstandings. Such efforts would also help increase the

membership within the NWTBEA and enable it to grow in terms of resources and capacity.

Depending on the level of interest, specific activities might include:

Basic education on NWT standards and installation methods; or

Certification of installers.



3.2.2 Pellet Heating System Manufacturers & Suppliers

As shown in the diagrams in section 2.4, the wood pellet heating systems (i.e. stoves, furnaces

and boilers) that are brought to the NWT should be certified under a standard recognized in

Canada.

To re-cap:

For pellet stoves used in a residential application, the stove should be certified by ULC,

CSA or another certifying body;

For small pellet furnaces or boilers used in a residential application (i.e. <30 kW), the

unit should be certified under CSA B366.1; and,

For larger pellet boilers used in a commercial (or institutional) application, the unit

should be certified with a “CRN-T” designation.

The difficulty for the NWTBEA members is the fact that many of the pellet heating appliances

and systems on the market today are manufactured or supplied by European companies that

are certified under European standards and selling units to numerous countries and/or North

American jurisdictions. In these cases, it appears that some of the manufacturers or suppliers

are simply unaware of Canadian requirements or possibly unwilling to seek Canadian

certification due to limited sales volumes to Canada.

This situation puts the onus on the system purchaser to determine if a particular make and

model is suitable for use in the NWT. While it is possible to get an uncertified unit installed (as

long as it complies with all Canadian and NWT codes and requirements), problems are often

encountered in obtaining permits, passing inspections or with insurance companies.

The NWTBEA is proposing that it work with ENR to find ways to reduce the “red tape” in getting

pellet heating systems certified for use in the NWT. One aspect of this may be for ENR to

provide financial support to help defray the costs of the certification process.

3.2.3 Design Professionals

Design professionals such as architects and engineers are an essential part of the process for

the design, installation and inspection of pellet heating systems, particularly for systems greater

than 30 kW in heating capacity which involve PWS permits and inspections.

The NWTBEA may be able to play a constructive role by helping ensure that existing (and

future) design professionals in the NWT are knowledgeable and up-to-date on the various

provisions within CSA B365-01, territorial legislation, OFM Technical Bulletin FM-065-2008 etc.

and the requirements of insurance companies.



Such efforts should eventually lead to better “off-the-shelf” designs and may help reduce

design costs and potential concerns by design professionals about liability risks. The specific

nature of these efforts would need to be determined in collaboration with the appropriate

industry groups (NAPEG, NWTAA).

3.2.4 Office of the Fire Marshal

The Office of the Fire Marshal plays a crucial role in the installation of commercial pellet heating

systems by reviewing and approving the design package prior to installation. In this regard, the

OFM has issued Technical Bulletin FM-065-2008 (revised May 31, 2013) in an effort to provide

guidance and clarity regarding the interpretation of CSA B-365-01 and other standards.

The research and meetings conducted as part of the development of this Discussion Paper

indicate that there may be several minor points in Technical Bulletin FM-065-2008 that are

unclear or potentially confusing.

The NWTBEA believes it would be useful to arrange additional meetings with the OFM to

discuss the identified points and generally review how the OFM’s Plan Review Officer conducts

a review of a design package for a commercial pellet heating system.

3.2.5 Insurance Brokers / Underwriters

Members of the NWTBEA have heard complaints from their heating customers that some

insurance companies have refused to provide insurance coverage after wood pellet heating

systems have been installed or have charged much higher premiums.

In Canada, the insurance industry is highly regulated at both the federal and

provincial/territorial level.

All insurance undertaken in the NWT and all insurers carrying on business in the NWT are

subject to the provisions contained in the Insurance Act and Insurance Regulations. Under the

Act, every insurer carrying on business in the NWT is required to hold a license (obtained from

the Superintendent of Insurance).

A review of the Insurance Act indicates that the provisions in the Act are very technical in

nature and are intended to govern:

the mechanics of how different types of insurance businesses (fire, automobile, life,

accident and sickness, livestock etc.) are conducted;

how agents, brokers and adjusters are licenced and can operate;

the calculation and payment of insurance premium tax; and,

the powers and responsibilities of the Superintendent of Insurance.



Among other duties, the Superintendent is charged with ensuring that the laws related to the

conduct of insurance are enforced and obeyed. Sections 239 to 243 specifically provides the

Superintendent with the power to examine and investigate the affairs of an insurance company

or agent to determine if any unfair or deceptive act or practice has been, or is, being engaged

in.

Feedback provided by an experienced (and neutral) insurance professional in the NWT

confirmed that the NWTBEA cannot rely on the Superintendent of Insurance to become

involved in the investigation or mediation of cases where an insurance company is reluctant (or

refuses) to issue an insurance policy to a heating customer after a wood pellet heating system

has been installed or is charging a significantly higher premium than before. Such questions are

outside the scope of the mandate established for the office of the Superintendent of Insurance.

Specifically, the Superintendent does not instruct insurance companies on what types of

insurance policies to write, the terms of such policies or the premiums to be charged. These

decisions are the sole purview of the insurance companies.

However, there may be a role for the NWTBEA to help inform / educate insurance industry

professionals, such as agents and brokers, on the state of the technology on the market and the

proposed use of NWT Pellet Heating Guidelines. In turn, the NWTBEA could hear the concerns

of the insurance professionals and play a role in explaining these concerns to customers, design

professionals and heating and plumbing contractors.


The NWTBEA is proposing to work collaboratively with the design community, the regulatory

authorities, heating and plumbing contractors, the insurance companies and other stakeholders

to address concerns and increase understanding of wood pellet boiler and pellet storage

systems and find ways to reduce “red tape”, delays and costs associated with the installation of

pellet heating systems.

3.3 Wood Pellet Quality and Emissions

In Canada, wood pellets are made from sawmill residues, logging waste, insect-killed trees and

low-grade logs. As of 2012, Canada had 42 pellet plants with a total annual production capacity

of 3 million tonnes. About 65% of this production capacity is located in British Columbia which

tends to have large plants (average of 150,000 tonnes annually) that export much of their pellet

production to Europe for use in space heating and electricity generation.

At present, the NWT’s pellet supplies are being shipped in primarily from large pellet plants in

the Prince George area of B.C. and from a smaller pellet mill at La Crete, Alberta (~60,000 tonne

annual capacity) that only sells to domestic customers.



Given the different sources from which wood pellets are made, pellets are classified based on a

number of key characteristics, including:

Physical parameters (diameter and length);

Mechanical durability;

Moisture content;

Ash content;

Fines; and,

Net calorific value.

Of these, the moisture content, ash content and % of fines are the most important pellet

properties. In North America, pellets are generally classified and sold as “Premium”,

“Standard” and “Industrial” grades. In Europe, pellets are classified under the ENPlus

certification system which specifies “A1”, “A2” and “B” grades.

The quality of wood pellets is important in space heating applications as pellet quality can

impact on the performance, maintenance, emissions and reliability of the pellet heating system.

This is particularly the case for residential pellet stoves and small residential boiler systems

which are more sensitive to the amount of fines, resulting in problems in the in-feed auger or

the burning chamber.

In Canada, the Wood Pellet Association of Canada recently became licensed to manage

CANplus, which is a quality certification scheme based on the highly successful ENPlus

certification system being used in Europe. Key components will include quality specifications

(using the A1, A2 and B grades) and approved laboratories and inspection bodies. It is

anticipated that as pellet producers and distributors become certified, the CANplus seal will be

seen on pellets produced, distributed and sold in Canada.

The implementation of the CANplus certification system should help address the fact that there

is currently no testing or quality control procedures in place to verify the quality of the pellets

being supplied to the NWT from pellet mills in BC or Alberta.

Recommendation #4: Develop and Implement a Pellet Testing Protocol for NWT Pellet Supplies

Assuming that the CANplus pellet certification system becomes fully implemented and pellet

mills in BC and Alberta become certified, this would provide the basis for implementing a

testing protocol to ensure that quality pellets are being shipped to the NWT.



The NWTBEA is proposing to work collaboratively with ENR and PWS to determine the details

for a suitable testing protocol, who would be involved, what the annual cost may be and how

such costs would be covered.

It should be noted that a testing protocol would likely need to be applied to each segment of

the pellet supply chain of producers, transporters and distributors.



4 CONCLUSIONS

In conclusion, the NWTBEA has four (4) recommendations on ways in which positive changes

can be made to reduce barriers or challenges to the installation and operation of biomass

heating systems in the NWT.

These recommendations are listed below:





Recommendation #4: Develop and Implement a Pellet Testing Protocol for NWT Pellet

Supplies

The NWTBEA appreciates the Minister’s time in considering these suggestions and looks

forward to working with ENR, PWS and others in the ongoing development of the biomass

markets in the NWT.



APPENDIX A: REFERENCES

PUBLICATIONS / DOCUMENTS Arctic Energy Alliance, “Residential Wood Pellet Heating: A Practical Guide for Homeowners”, (2012) Canadian Standards Association, “CSA Code B365-10 Installation Code for Solid-Fuel-Burning Appliances and Equipment”, (2010) City of Yellowknife, “Building Bylaw #4469”, (2008) City of Yellowknife, “Building Permit Application”, (2014) City of Yellowknife, “Installation Checklist for Solid-Fuel Burning Appliances and Equipment”, (2008) City of Yellowknife, “Mechanical Permit Application”, (2014) European Committee for Standardization, “European Pellets Standard – EN 14961-1”, (2010) European Pellet Council, “Handbook for the Certification of Wood Pellets for Heating Purposes version 2.0”, (2013) German Wood Fuel and Pellet Association, “Recommendations for Storage of Wood Pellets”, (2012) Government of the Northwest Territories, “Boilers and Pressure Vessels Act” Government of the Northwest Territories, “Boilers and Pressure Vessels Regulations” Government of the Northwest Territories, “Electrical Protection Act” Government of the Northwest Territories, “Electrical Protection Regulations” Government of the Northwest Territories, “Fire Prevention Act” Government of the Northwest Territories, “Fire Prevention Regulations” Government of the Northwest Territories, “Insurance Act” Government of the Northwest Territories, “NWT Biomass Energy Strategy (2012-2015)”, (2012) Government of the Northwest Territories, “NWT Greenhouse Gas Strategy (2011-2015)”, (2011)



National Research Council of Canada, “National Building Code of Canada 2010” Office of the Fire Marshal, “Technical Bulletin - Commercial Solid Fuel Fired Boiler Systems FM-065-2008”, (revised May 31, 2013) Wood Pellet Association of Canada, “2012 Wood Pellet Map”, (undated)

WEB SITES

Canadian Biomass Magazine – www.canadianbiomassmagazine.ca

Canadian Standards Association – www.csagroup.org

Department of Public Works and Services – www.pws.gov.nt.ca

Office of the Fire Marshal – www.maca.gov.nt.ca

Pellet Fuels Institute – www.pelletheat.org

National Research Council of Canada – www.nrc-cnrc.gc.ca

Wood Pellet Association of Canada – www.pellet.org

PERSONAL COMMUNICATIONS

Dwayne Wohlgemuth, Ko Energy (various conversations, February – March 2014)

Bryan Pelkey, Alternative Energy Specialist, Climate Change Group, ENR (various

conversations, February – March 2014)

Ron McRae, Manager, Gas Boilers and Electrical, Ron Hiscock, Chief Electrical

Inspector and Matthias Mailman, Chief Boiler Inspector, Electrical / Mechanical Safety

Group, PWS (Thursday, March 6, 2014)

Chucker Dewar, Territorial Fire Marshal and Kevin Brezinski, Director, Public Safety

Division, MACA (Friday, March 21, 2014)

Ron Dennill, Insurance Program Manager, Northern Communities Insurance Program,

NWT Association of Communities (Monday, March 31, 2014)

http://www.canadianbiomassmagazine.ca/

http://www.csagroup.org/

http://www.pws.gov.nt.ca/

http://www.maca.gov.nt.ca/

http://www.pelletheat.org/

http://www.nrc-cnrc.gc.ca/

http://www.pellet.org/

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