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
buildings

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.

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[1] https://www.epa.gov/facts-and-figures-about-materials-waste-and-recycling/wood-material-specific-data

[2] https://www.fs.usda.gov/treesearch/pubs/59115

[3] http://www.biomassthermal.org/wp-content/uploads/2017/12/Austria_Biomass_heating_2010.pdf

[4] https://www.thelocal.fr/20220124/france-brings-in-ban-on-gas-boilers-in-housing/

[5] https://inews.co.uk/news/households-facing-heat-or-eat-dilemma-energy-bill-surge-april-1381152, and https://childrenshealthwatch.org/the-heat-or-eat-dilemma/.