The Alliance for Green Heat submitted a public comment on the EIA's Densified Biomass Fuel Report earlier today. The EIA was gathering comments on a proposed three-year extension on the report along with specific questions on its function and use.
"The Alliance for Green Heat (AGH) would first like to thank the U.S. Energy Information Administration (EIA) and the Department of Energy (DOE) for giving the public an opportunity to submit comments on the proposed three-year extension to Form EIA-63C, “Densified Biomass Fuel Report.” As a national nonprofit that advocates for the reduction of fossil fuel heating through the responsible and sustainable use of wood and pellet heat, we are deeply invested in the outcome of the EIA and DOE’s decision to continue to collect data on pellets.
Summary: The EIA does not need to collect more information from pellet manufacturers. However, it does need to publicly release much more of the information it is gathering.
It is important for policymakers, environmental organizations, and the public to have a far more accurate understanding of the differences between how utility pellets are made, how premium heating pellets are made, and the carbon impacts of how they are used. Utility pellets have biodiversity, equity, and carbon impacts that are more serious than premium heating pellets based on their feedstock, the size and location of their manufacturing plants, and the enormous amount of waste heat that is lost when making electricity. Data gathered by the EIA provides some of the underlying metrics to understand those different impacts.
Wood pellets are an excellent low-carbon heating fuel for homes, businesses, and institutions. They will likely become an even greater complement to heat pumps in the future, based on the different pros and cons of each heating pathway as our energy grid seeks to keep up with increasing electric demand. Wood pellet production and use are also extremely important for better understanding air quality and whether states and air quality agencies have been able to increase the percentage of pellet stoves compared to wood stoves. Also, EIA data from their housing survey, part of the Residential Energy Consumption Survey, shows that wood pellets serve many very low-income homes. The 2020 data shows the income bracket with the highest reliance on pellet stoves compared to wood stoves is the $10,000 - $19,000 household income bracket. This makes wood pellets very relevant to the energy equity community.
Our industry and stakeholders have become used to seeing top-level data such as the wood pellet production capacity by region, overall production of heating vs. utility pellets, and domestic vs. foreign pellets. But to really appreciate the various roles this industry plays in providing renewable heating in America, we should all be versed in more granular detail.
For example, it is very important for government agencies, pellet stove manufacturers, pellet fuel distributors, retailers, and consumers to know the volume of:
• PFI certified domestic heating pellets made year-by-year,
• Non-PFI certified pellets made year-by-year if the percentage of bagged vs. bulk domestic heating pellets is trending up or down,
• Utility pellets used domestically,
• ENPlus A1 or A2 bulk heating pellets are made in the US (these would likely be bagged in Europe for residential distribution), and
• Compressed bricks, compressed logs, and briquettes made, year-by-year.
The EIA could also provide more detail about where wood comes from. It provides summary, top-level data, but we believe there is more data available that does not infringe on confidentiality.
Response to EIA questions:
1. In response to the invitation to comment on the following statement: “(a) The proposed collection of information is necessary for the proper performance of agency functions, including whether the information will have a practical utility,” AGH would like to highlight the value that the Densified Biomass Fuel Report provides to hundreds of stakeholders in the renewable energy space who need this information to assess the capacity of this sector. The data provided through the reports helps track trends in pellet production and increases the ability to produce accurate, science- based assessments on pellet heating. Without the Fuel Report, organizations would lose one of their most reliable and unbiased information sources on pellet data.
In the energy transition landscape that our nation is currently undertaking, being able to account for, and have accurate information on, all forms of renewable energy is paramount. If our nation’s leading agency on energy information is missing data and research on a large, mainstream, and established renewable energy source like biomass, the agency is failing to carry out its mission.
2. In response to the invitation to comment on the following statement: “(c) EIA can improve the quality, utility, and clarity of the information it will collect,” AGH would like to suggest that the EIA publish more of the data that it collects. Assuming no confidentiality conflicts, we believe publishing all gathered “Product Type” information is essential (e.g. amount of “Wood Pellets Premium (PFI certified) Bagged,” Wood Pellets Premium (PFI certified) Bulk”, etc.). Similarly, publishing data on “FeedStock Type” (e.g. “Roundwood,” “Sawdust,” “Waste Wood,” etc.) would be helpful when explaining to policymakers and the public the different supply chains in the pellet industry. This is particularly important for policymakers and the public to differentiate how heating vs. utility pellets are made. This would also provide industry and organizations with a clearer vision of the current capacity of biomass for heating, helping provide decision- makers with valid, data-driven information. Because this information is already gathered in the monthly reports, this would not add any time burdens on the pellet manufacturing companies.
Wood is a diverse and vital renewable energy source for America. Many Americans do not seem to know that up until 2015, wood produced more renewable energy than any other renewable source. Since 2016, biofuels have been the top producer, but the intensive process of converting solid biomass to biofuels sharply reduces its carbon benefits.
Many Americans may also be surprised that wood still produces more renewable energy than hydroelectric solar and geothermal combined. As recently as 2015, wood produced more energy than hydroelectric, solar, geothermal, and wind combined. It is a vital part of America’s transition to renewable energy to know that the use of wood as a renewable energy has been relatively stable but shrinking since 1985, and the amount of solar and wind energy has been rapidly growing. Part of this story is understanding and managing all the different feedstocks that go into wood energy - mainly pellets, wood chips, and wood logs.
The EIA can do a better job using the data that it collects from pellet manufacturers to tell a more detailed story about wood pellets made in America and pellet heating in America."
