Monday, March 7, 2022

Building codes should allow wood and pellet heating systems in new construction

Postscript: The IECC voted down an amendment that would have banned wood and pellet heating appliances in new construction.

Testimony of John Ackerly 

President, Alliance for Green Heat

On Amendments to definition of Biomass Waste in the 2021 IECC

IECC committee meeting

March 3, 2022


Thank you for the opportunity to comment on the exclusion of woody biomass from the definition of eligible biomass in residential applications in the International Energy Conservation Code (IECC). My name is John Ackerly, and I am the President of the Alliance for Green Heat, an independent non-profit that promotes renewable heating. We do not represent industry but advocate on behalf of consumers and architects who use a wide variety of renewable energy technologies to meet their particular circumstances.

We fully support integrating renewable energy in the IECC do not see a substantial conflict between energy efficiency and renewable energy. Both are essential in new construction and states and countries are demanding attention to both.

I speak in opposition to this amendment because it is internally inconsistent, unworkable, not science based and contrary to the renewable residential heating policies of many states and countries. We strongly disagree that solar PV and battery storage are affordable and efficient way to offset 100 percent of all energy end uses in many colder northern areas at this time. Very sophisticated, modern biomass heaters are being strategically used in state and national renewable energy strategies to alleviate the shortage of renewable electricity, strains on the grid and rising construction and energy costs. The IECC should not be pre-empting the ability of jurisdictions who have studied and tested these modern biomass systems for years and are basing their policies on experience and sound science.


The haste with which this IECC committee has developed and addressed this amendment is evident by
An IECC graphic on energy use
in homes and buildings

comments of from committee members. There were several comments referencing biomass issues that are unique to large-scale biomass to electricity when we are addressing biomass heating applications. At other times, several Committee members made the mistake of referring to the release of biomass decades or generations faster if it is burned than if it were left standing. This is true in the biomass to electricity pathway, where whole trees are commonly harvested to make pellets and have no other reason to be harvested. But most biomass used for heating comes from waste biomass, residuals from lumberyards, furniture factories and trees that have already come down for some other reason, and their carbon is only released a year to two before it would be otherwise. 

Confusing largescale biomass to electricity issues with local biomass heating issues is an increasingly common mistake in recent years, but the carbon analysis, emissions, harvesting, sustainability and economics are all very distinct. This indicates some members of your committee may not have the expertise to accurately assess the pros and cons of this amendment. As with solar and wind, this is a highly technical area where the location, deployment and conditions of the technology are vital and can radically change the carbon intensity, the sustainability, and the ROI of a project. We are concerned that this committee may not fully understand the implications of the amendment.

Pellet heating in Europe is an 
integral part of most national
renewable policies

Ironically, restricting the use of biomass in modern high efficiency heating systems may add more incentive to use biomass in very low-efficiency plants to make electricity, which is the opposite direction we need to move. Currently, in the United Kingdom, for example, electricity made from US wood pellets is being used in residential heat pumps to make heat. This puts far more pressure on forests when biomass is used so inefficiently and at scales that may not be sustainable.


A few comments on waste wood. A lot of domestical woody biomass is treated, for better or worse, as a waste product. The EPA documented that in 2018, landfills received 12.2 million tons of wood. This was 8.3 percent of all municipal solid waste landfilled that year.[1]


The US Forest Service estimates that urban waste wood amounts to be 46 million tons based on annual mortality rates.[2] With emerald ash borer, more frequent storms and natural mortality, cities and states struggle with disposing of wood and instead to produce revenue from it and use it as a renewable resource.

I also hope that this committee has been in touch with your IECC colleagues in Europe. In parts of
Stacking multiple pellet boilers
is a common solution for larger

Austria, where installing fossil fuel boilers is no longer allowed, highly advanced wood and wood pellet boilers are the norm.[3] In France, where they just banned the new installation of gas heating, modern wood and pellet boilers are also one of the main alternatives.[4] This overview of pellet heating in Europe shows a vibrant and growing renewable heat market. Even in New England, many states provide incentives to install advanced wood and pellet boilers. It’s important to note that premium heating pellets are predominantly made with waste wood, unlike the industrial pellets that are shipped to Europe to massive electric plants.  

To date, the IECC has built expertise on regulating tight-fitting flue dampers or doors and testing and listing requirements for the doors. This process involved years of engagement with key stakeholders but mostly addressed fireplaces.  Fast tracking an exclusion of an important renewable energy appliance is inappropriate.  Such a proposal should involve extensive and thoughtful engagement with stakeholders as well.

Finally, I would also urge you to ensure that you have considered environmental or social justice issues that favoring one technology or fuel above another may raise. Your amendment causes confusion about a fuel - biomass waste - that is often a low-cost fuel relied on by average households. Excluding them in the IECC could cause an additional energy burden on communities and countries that have developed smart strategies to use it wisely.

As a practical matter, few wood or pellet heaters are installed in new construction, but there is absolutely no reason why some of them shouldn’t be. We support restrictions on new installations of modern cordwood stoves in densely populated areas, which usually have access to affordable gas. But even modern cordwood stoves can be practical and strategic in new homes for Native American and low-income rural households who cannot afford fossil fuel heat or other renewable heating. These households often face the “heat or eat” dilemma[5] and the health risks of a cold home are significant. Many of these households would love to be able to flip a switch and use fossil fuel heat, like most people do in North America and likely many people on this committee do too. But that is not an option for them.

We look forward to working with committee members in the future and to provide assistance in any way we can to strengthen the IECC and make strategic use of renewable heating technologies.

Thank you.





[5], and

AGH Testimony on biomass heat in Maryland's renewable energy portfolio standard

The Renewable Energy Portfolio Standard – Tier 1 Renewable Source – Alterations (Reclaim Renewable Energy Act of 2022)

March 3, 2022

Position: Oppose HB 11.  Support HB 1085.

House Economic Matters Committee


Thank you for the opportunity to testify today. My name is John Ackerly and I am the President of the Alliance for Green Heat, a Maryland based non-profit that promotes cleaner and more efficient wood and pellet heating. We strive to represent consumers and the environment – not the forest industry, or the wood and pellet stove and boiler industry. We support all renewable heating options – from geothermal to solar thermal to biomass thermal – because we need to aggressively deploy all these technologies to meet the global challenge of climate change.

Including thermal biomass as a Tier One renewable in Maryland’s Renewable Energy Portfolio Standard should not be ideological. Let’s follow the science. A few points that are important to consider.

1. Maryland has hardly any market for thermal biomass RECs and that is not likely to change. But we should not prevent good projects from getting built. If an institution can pencil out a project to use wood pellets or wood chips to heat their facility, we should support them, just as we would with other renewables.

2. A lot, if not most wood used in biomass thermal projects is waste wood, residuals that will be produced anyway. In my Takoma Park neighborhood, as in all Maryland towns and cities, we chip hundreds of tons of trees that fall down in storms or are taken down for one reason or another. They can go to make mulch for homeowners or other uses, but I believe they are best used to replace fossil fuel.

3. Larger wood heating systems have modern controls and produce little particulate matter. Otherwise, they would not be permitted by the Maryland Department of the Environment.

4. Compared to other renewables, making heat with wood chips or pellets is extremely low carbon. Remember, technologies like geothermal, for example, usually use a lot of fossil fuels to pump the heat out the ground or air. In fact, 30% or more of the energy created comes from the electricity needed to transfer heat. All technologies should be held to same standards, use the same carbon accounting method, based on science, not ideology.

Increasingly, stakeholders opposing biomass are more likely to have the science on biomass to electricity, and they then apply it to biomass for heat. We continually hear arguments, including from some members of this committee, who have read about the harvesting of trees in the US south to produce industrial wood pellets to ship to Europe to make electricity. This is what is in the news lately and if you don’t have much background on the issue, its easy to conflate the environmental issues with this energy pathway, with local, small-scale, high efficiency heating projects. Pellets made for massive electric utilities are from whole trees cut specifically to make pellets. They are then used at about 33% efficiency to make electricity, and the other 67% of the tree is lost as waste heat.

With local heating projects, trees are rarely cut solely to make heat. In Maryland the amount of residual
Waste wood at Baltimore's urban
waste wood lot
biomass is enormous. I would encourage each of you to read a January story from the Baltimore Sun about urban waste wood in Baltimore. It says “In a city with roughly 4,000 acres of woodland and many miles of streets lined with trees, about 9,000 tons of waste are cleared annually. It cost the city to dispose of that scrap wood and brush.”

A few comments on waste wood. A lot of domestical woody biomass is treated, for better or worse, as a waste product. The EPA documented that in 2018, landfills received 12.2 million tons of wood. This was 8.3 percent of all municipal solid waste landfilled that year.[1]

The US Forest Service estimates that urban waste wood amounts to be 46 million tons based on annual mortality rates.[2] With emerald ash borer, more frequent storms and natural mortality, cities and states struggle with disposing of wood and instead to produce revenue from it and use it as a renewable resource.

Let’s take my town of Takoma Park as an example. I served as co-chair of the Environment Committee that explored quickly reducing fossil fuels. However, the city is nonchalant about heating its buildings with gas, year after year. Often, officials brag that the city uses 100% renewable energy because its electric supply is renewable, forgetting that heat also uses energy. So, we take gas off the grid, gas that is likely made by fracking shale in Pennsylvania, but that gas could have even worse environmental implications and come from far further away. Meanwhile, arborists remove 100s of tons of waste wood from the city, much of it paid for by the city, so that it can be thrown away. Remember, wood is a very clean fuel compared to fossil fuels if you can combust it at a high enough temperature and use electrostatic precipitators and baghouses to reduce the particulates. Takoma Park’s municipal buildings are not ideal to be heated with wood chips, but municipal buildings in many of Maryland’s more rural areas could be.

Mike Tidwell, who led a
residential corn heating co-op
At the residential level, Takoma Park has been a national leader in biomass heat. The city subsidized a silo for corn that residents could use to heat their homes with corn stoves. This initiative was led by Mike Tidwell, who you all know well I assume. Mike still supports using biomass for local heating uses in his own home, in our community, our state and our country. He understands the carbon equation and how different it is from using biomass to ship to Europe to make electricity. While we believe wood pellets are a far better fuel than feed corn, there are many similarities between the two.

I would urge you to let local officials, local architects and planner and local economics in Western and Eastern Maryland make the decision about which renewables work best to heat buildings in their communities. The legislature in Annapolis should not do that for them.

Thank you for your consideration.