DISCUSSION PAPER · single biggest wood pellet heating customer in the NWT (at about 4,600 tonnes...
Transcript of DISCUSSION PAPER · single biggest wood pellet heating customer in the NWT (at about 4,600 tonnes...
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.
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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:
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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.
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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
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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.
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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;
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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.
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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).
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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.
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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
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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.
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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;
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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
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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.)
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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.
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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.
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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.
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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: 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, 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;
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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: 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.
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.
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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.
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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.
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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.
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.
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.
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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.
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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.
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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 #1: Develop Pellet Heating Guidelines for the NWT
Recommendation #2: Support the Development / Adoption of National Standards for
Biomass Fuel and Heating Equipment
Recommendation #3: Conduct Outreach and Education
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.
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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)
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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)