Maryland stove rebate aimed at low- and middle-income households may expire

Stakeholders urge state to keep stove program as it pursues electrification 

With little warning or stakeholder engagement, the Maryland Energy Administration (MEA) said it planned to sunset a stove rebate program that was established more than 10 years ago to help rural, low- and middle-income households who had the highest heat burden. 

A coalition of Maryland stakeholders wrote to MEA urging the agency to consider the impact on low and middle income households and to extend the program.

 

Maryland residents can still purchase eligible stoves through Jan. 4, 2024 and submit rebate applications up to March 31, 2023.  The program has been effective over the years and 80% of residents chose the higher rebate level to purchase a pellet stove. The rebate levels are $700 for a pellet stove, $500 for a wood stove, $1,000 for solar panels or shingles and $3,000 for geothermal systems.

A 2020 analysis of data from MEA showed that solar rebates primarily flowed to rich, more urban zip codes, and least likely to go to less affluent, rural zip codes, where wood and pellet heating are popular. 

 

“Its outrageous for millions of rebates to flow to wealthier homes for solar panels and geothermal systems while closing the only rebate program designed for rural low- and middle-income households,” said John Ackerly, President of AGH.  “During this climate crisis, we need to support renewable energy technologies that fit the budgets and preferences of everyone, not just well-to-do families.”

In Maryland, an average home needs 
about 2 tons of pellets as a primary or 
sole source of heat, which costs about
$550.

Low and middle income (LMI)  families are often marginalized, overlooked  and left behind in energy transitions and “the potential closure of this program is a classic case study of this.” Ackerly said. 

 

The Alliance for Green Heat is working with stakeholders to find out more about how the stove rebate program was assessed, why stakeholders were not engaged and whether changes can be made instead of closing it.  The Maryland Energy Administration said funds were getting tighter but there is no upper income limit to be eligible for solar and geothermal rebates.

Pellet stoves like this can cost up to
$4,000 and more basic ones cost
around $1,500

For years, the Alliance for Green Heat has urged to only allow rebates for pellet stoves, and not wood stoves.  AGH does not believe new cordwood stoves should be subsidized if installed in more densely populated areas.  AGH had also urged the MEA to correct confusing requirements like allowing eligible stoves to emit up to 3 grams an hour, a half gram higher than federal EPA limits, but the MEA decided not to align with EPA standards. These and other issues indicated to many that the rebate program designed for LMI households was not a priority. 

 

A wealth of data shows that electrification is perhaps the best way to address the climate crisis but there is also a high chance that many LMI communities will be left behind, in part because upfront costs of heat pumps are so high, and electric rates could continue to climb.  AGH is concerned that states may pursue electrification to the exclusion of program that can benefit certain demographics, potentially making the energy burden of some communities worse than before.

Pellet stoves can be very affordable and
in parts of Europe far more expensive
pellet boilers are routinely installed in
new construction, paired with solar,
battery storage and smart controls.

In many northern states, pellet stoves are being used along with solar panels so that a home can produce both renewable heat and electricity, lowering the carbon footprint of a home far more than either technology could alone. Solar panels, even with battery storage, can't produce enough electricity for heat pumps during the winter.  Pellet stoves also offer cheaper heat than heat pumps during the coldest weeks of the winter.

 

For one AGH staff member, Lilith Guzman, confronting this issue with MEA hits hard, and is personal. “I grew up in Minot North Dakota and my family has always been low-income. We were reliant on programs like SNAP, reduced school lunches, and clothing drives when the seasons turned. The native American community helped us get by too. I vowed to work on these issues when I graduated, but I didn’t expect this in Maryland.”

To make your voice heard, you can contact the head of the MEA, Director Paul Pinsky at paul.pinsky@maryland.gov. 

 

 

 

 

 

 

 

How to make the EPA stove database more useful

The EPA's wood heater database, also known as the EPA list of certified stoves, is the official site where the EPA publicly registers certified wood heaters after they have been tested by third party labs.  The list has EPA sanctioned data including the emissions, efficiency, firebox size and Btu per hour range of all certified stoves, and previously certified stove information is also available.

As such it is the go-to site for consumers, manufacturers, retailers and air quality agencies. The EPA has updated it many times, most notably in May of 2019 when they switched from a static to a searchable database. 

But the site remains clunky, not consumer friendly and also not sufficient for many stakeholders such as some states and air quality agencies who want far more data included.  The Alliance for Green Heat has often sent recommendations for improvements and corrections since our founding in 2009 and we have generally had a good and productive relationship with the managers of the site, who have appreciated our input.  

Recently, AGH sent a lengthy memo to the EPA with a long list of suggestions to overhaul the site again, as they did in 2019.  To follow along with our comments, you may want to go to the site and follow along as we move through its features and terminology. 

1. Overall suggestions: make the database more consumer facing, while also retaining information and data that is valuable to states, air quality agencies, industry etc. To make it more consumer oriented, we suggest:

    A. Include many links to EPA Burn Wise, so that consumers can easily access relevant information such as how to size a stove, differences between cat and non-cat, etc. These should be prominent links on the home page of the room heater and central heater list. Integrating this list with Burn Wise info will help expand on the details that you provide to consumers so they can better understand the terminology you use.  If you want consumers to use this list and learn for it, include vital information that they want and should have.

    B. One of the main functions consumers like, and even expect, is the ability to choose 3 or 4 stoves and have them come up together on a page so they can easily compare them. A “compare my stoves” option allows anyone to see exactly which stoves they want to compare, whether you are a consumer or a state/air quality organization.

    C. When the page loads, you should see a list, and can easily start sorting. Currently, that first step of getting to the actual list seems clunky.

    D. We also suggest you have an introductory paragraph in big font, giving basic information about how to use the list, and how not to use the list. Knowing that seasoned wood is almost always more important that the lab emission and efficiency number, and maybe something like “This list does not include many vital details about stoves, such as distances to combustibles, type of floor protection required, etc.”

    E. Add a button: send reports of inaccuracies or possible violation of these regulations.

    F. You should consider having half a dozen of the most important columns appear right away on a main page, and then give users the option to choose to see other columns. We suspect that this process of updating the database will lead to adding more columns and that will be clunky and crowded unless you somehow hide some of the columns. Thus, test method, date of certification, and other things that specialists want on the list, but are not important for the consumer, or even too confusing for the consumer, should not be initially visible. You could also have an “Advanced search page” where everything is available for whoever wants to go there.

2. Name: The overall name should be EPA Certified Wood Heater Database. Then, we recommend changing “room heater” to “wood and pellet stoves.” The EPA can do far more to give pellet heaters stature and visibility as a cleaner and more modern option. The term “room heater” is not used often. “Space heater” is far more accurate and more in tune with lower income households, where the space to be heated is their smaller home, not a single room. “Room heater” is simply out of touch with how most people use their stoves, which is often in the largest area of the house than it also connected to other rooms. Historically, and to some extent today, stoves are located in the basement, not to heat that room, but to drift up into the house. Conversely “Central heater” is a more commonly used term in the HVAC space. Or, you could say “Central heaters: boilers and furnaces.”

3. Slide bar searches: We urge you to at least only include realistic ranges, thus 0 – 5 cubic feet, not to 10 cubic feet. And emissions should top out at 2.5, not 10. But we question whether the tool is really effective enough to encourage consumers to use, unless they have been somewhat educated about its limits. We think its less of a problem with pellet stoves, who are likely to have real world emissions and efficiency that track lab values far better than wood stoves. The EPA should not be hesitant to say that. If you keep it, you need to stress that seasoned wood and proper stove use (giving the stove sufficient air when needed) is more important than choosing a stove that is 1 vs. 2 grams per hour, or 70 vs, 75% efficiency. And you should not be hesitant to include a link to the IRS tax credit as other EPA pages would when a product gets tax credits. Again, if you want consumers to come to this page and be educated here, vs. manufacturer literature, include the info and the links that consumers want to know about. Lastly, as we describe in more detail below, we think BTU output is less relevant than firebox size to estimate heat output.

4. Columns
    a. On an “Advanced search” page, or an area where you can select other columns, we would add Test Method (denoting which ones got modified or alternative tests), date of certification or recertification (but not any certification expiry date), maybe the test lab and a link to the owner’s manual and non-confidential test report. If you want more people to use this list and come to it, include info that consumers want like the owner’s manual.

    b. Hybrid stoves: Make sure to accurately include all hybrid stoves.  This is a very important, relatively new type of stove that many experts think is an important technology improvement over catalytic stoves. Currently, the database has 22 hybrids, but we think there are far more. Are they being correctly and consistently labeled as hybrid?  Make sure consumers understand what they are and how they benefit from using both cat and non-cat secondary combustion strategies to reduce emissions. 

    c. Single burn rate stoves: We encourage you to designate which stoves are single burn rate stoves. This is also an important type of stove and can be an easier and cleaner for consumers because it has no levers and cannot be put into a smoldering mode. We think they are all no-catalytic, but if not, it could say single burn rate/cat or single burn rate/non-cat.  

    d. Model: You should not need to say that all models meet the 2015 NSPS. If not, how would it be on this list? You seem to confuse the 2015 NSPS with the staggered emission standards within that NSPS.  I would add that if there are multiple models, tell the consumer that the differences between them are either cosmetic or have some different external feature but the firebox is the same.

    e. Manufacturer: In the days of industry consolidation, the manufacturer is often less important than the brand. For this to be useful to consumers, you need to have a column for brand and then the manufacturer could be noted under the brand, and the manufacturer need not have its own column. And, where the manufacturer is something like “Gruppo Piazzetta S.P.A.”, it should be listed alphabetically by the brand “Piazzetta” followed by the manufacturer.

    f. Firebox volume: We think this is as much or a better indicator of heat output than the “Heat Output (BTUs)” column and it should be recognized as such. Many retailers know this and sell stoves based on firebox volume. BTU numbers are notoriously unreliable and we've got a number of different explanations from test labs and industry experts. We also recommend defining Firebox Volume not as its used for test fuel, but as its used by consumers, and why it matters. Small fireboxes can’t take 18-inch logs. Large fireboxes do not perform well in small spaces, etc. etc.

    g. Heat output (BTUs): As mentioned above, we question the consistency and accuracy of BTU numbers from test labs and as such they are not very useful for consumers. At the very least, we suggest saying something to the effect that sizing your stove to the space you can heat with it is really important and while BTU output can be one data point, the firebox size of the stove is another important one.

    h. Emission rate: The “annual avg” is confusing. If anything, consumers want to know the grams/hour, not average grams per year. We realize this is not an average per year, but it could sound like that to consumers. It should emphasis that this is a lab number and consumers need to use seasoned wood and give the stove enough air for this number to mean anything. Or, maybe say something to the effect that if seasoned wood and sufficient air it not supplied, emissions can be many times higher than the lab number.

    i. Efficiency: Efficiency terms need to be better standardized so that manufacturers report the same type of efficiency in their materials as the EPA lists in its database. Perhaps the way to get to this is to only ask labs to report “overall efficiency” and “combustion efficiency” in the next NSPS and drop “Heat transfer efficiency.” As you know, Overall Efficiency tracks closely with Heat Transfer Efficiency, but the often 1-point difference between them can make a stove eligible for the IRS tax credit which is based on a minimum 75% “thermal efficiency,” a term not technically used by test labs but most often associated with Heat Transfer Efficiency. The term “weighted” should not be used in the EPA database as that just makes things more confusing.

    f. Type: On the room heater page, there are two Types are wood and pellet stoves, so it may not be necessary to talk about central heaters. It may be an opportunity to briefly distinguish between wood and pellet stoves, noting that pellet stoves are typically cleaner and more efficient because the fuel has a standardized, low moisture content and a more consistent combustion conditions.

    j. Subtype: First, you should list and define the subtypes before talking about one of them. I don’t think saying that any type of heater can be equipped with a catalyst is a point worth making. The main point here is that consumers have choices between three types. Non-cats are most common and typically the simplest. Cats are typically more efficient, and hybrids have the added benefit of two distinct forms of emissions reductions and are sometimes even more efficient as a result.

    k. Fuel type: This is unnecessarily confusing. First, you should delete all the fuels if there are no stoves that can be certified with them, such as coal, wood chips and biomass. Only include the fuels that you list in that column. Can corn be a “certified” fuel or just a fuel that is allowed to be advertised with the certified fuel: pellets. Second, you need to explain “crib wood.” Then, in the description below, room heaters are always designed for either wood or a pellet fuel. Why even mention wood chips if there are no room heaters certified with wood chips? As far as I know, there are no certified multi-fuel stoves on the market and the EPA continues to fail in their enforcement of non-certified multi-fuel stoves that list pellets as a fuel. You could say as of the date the new database is released that there are currently no certified multi-fuel stoves anymore and no non-certified multi-fuel stove can be sold if it advertises pellets as a fuel.

    l. CO: This is very confusing because it brings up the image of a gas stove, where CO is being released directly into the living space. The amount of CO released by a stove is more relevant as an indication of clean combustion, not because a higher CO stove is more of a health risk for consumers. CO from a wood stove is rarely a health risk but can happen when flue gases reverse and come back into the room, which is most likely (though rare) in the tail when there is little heat, but a lot of CO. It can also be dangerous when you put live coals in a bucket and leave the bucket indoors. Stoves in tiny spaces like boats are riskier if flue gases reverse and come back into the living space. We also recommend putting this column in an Advanced Search page, or an optional column that you can choose to see but is not initially served up on the main page.

    m. “NSPS Compliance 2020” should only be an advanced search page if currently certified stoves are mixed with uncertified ones. Otherwise, its confusing for the consumer, who should rightly assume that these stoves are certified and legal to make and sell.

“Quick Searches”

Remove “Previously EPA Certified” from this box. That option can be in a much less prominent
place, not in such valuable real estate. Then, you can also remove “Currently EPA Certified” because the list should only be currently certified units, unless you specifically want to see old ones, which only specialists want to see. You may not even need the “Quick search” box, as it may give lab numbers of emissions and efficiency too much emphasis, when we need more emphasis on fuel and operator skill.

I would suggest using that box for headings and links about the role of seasoned wood and giving the stove enough air, and how that is as or more important than lab tested emissions and efficiency numbers, except in pellet stoves. Again, the EPA can use its voice to say that lab numbers are likely to be more realistic for pellet stoves than they are for wood stoves. Don’t write caption info that inadvertently applies to wood stoves without noting the differences for pellet stoves.

I find this para, below, extremely confusing. Is there really a “2020 Rule”? Both the 1988 and 2015 rules had staggered compliance dates but this detail does not need to be here. Then, the line starting “If you question whether you can keep or operate …” I also may cut as its pretty rare that you can’t keep or operate the stove in your home, and if so, it’s not a federal rule.

Thank you for your consideration of these recommendations and we would be happy to elaborate on any of them, and provide further input as you go through the process of improving this database.

Comment on Massachusetts's Clean Heat Standard

The Alliance for Green Heat just submitted a comment to Massachusetts's Department of Environmental Protection concerning their Clean Heat Standard (CHS). To learn more about their CHS
check out this useful document. Ultimately, a CHS is a policy tool to require heating energy suppliers to gradually replace fossil heating fuels with cleaner heat over time by implementing clean heat or purchasing credits. Some would like to see the exit of advanced wood heating/automated wood heating from the CHS. The Alliance is in opposition to its removal. Please see our full comment below.

"The Alliance for Green Heat appreciates the opportunity to share comments regarding the Clean Heat Standard. We are a nonprofit that advocates for low- carbon heating strategies across the nation. We have a strong expertise in modern wood heating, heat pumps, and energy audits and weatherization, with a focus on low-to-middle-income households.

We believe that Massachusetts must keep advanced wood heating (AWH) technology in the Clean Heat Standard. AWH typically refers to pellet stoves and boilers at the residential level and can also include wood chips in larger systems. Residential wood stoves are not included in the definition of AWH because they do not have the automation to reduce particulate matter (PM) effectively and consistently. A similar term “automated wood heat” is often used and specifically excludes cordwood.

Advanced wood heating has a significant potential to be a complementary decarbonization technology that can increase electrification adoption for middle- income households and serves as an effective alternative heating source for energy providers to offer to customers.

Pellets for advanced wood heating are available locally in New England and are from sustainable sources, a mix of mostly sawdust from sawmills and wood chips from low grade wood. Many studies have investigated the use of woody biomass for local heating and have largely dismissed concerns that forest resources are being degraded to provide wood pellets. (See list of studies and peer reviewed scientific articles at the end of the comment.)

At the residential level, any state Clean Heat Standard should primarily focus on air source heat pumps – and weatherization services. In states with higher percentages of renewable electricity on their grids, heat pumps offer an excellent low carbon solution. However, there are still many drawbacks with heat pumps, many of which can be alleviated with back-up pellet stoves. High purchase and installation cost is of course one of the biggest issues with heat pumps. Pellet stoves can be installed for under $5,000 and can heat a home up to 2,000 square feet. Back-up wood stoves also provide an excellent source of heat when the grid goes down and gives rural consumers the confidence to switch to heat pumps (but we still do not advocate for including wood stoves as an eligible measure for obligated parties).

Because advanced wood heating systems use a fraction of the electricity that air source heat pumps require, its use in a house can reduce electric grid stress during the winter or reduce use of a back-up home battery. Wood pellet fuel has the added advantage of experiencing more price stability than both fossil fuels and electricity. For middle-income families trying to balance monthly costs, automated wood heating could provide a more consistent and affordable heating bill. Pellet boilers and stoves also have major disadvantages, including requiring far more maintenance and repair than heat pumps and repair technicians are not always easy to find. 

Equity concerns are significant for states designing Clean Heat Standards, and primary or back-up pellet heating is one measure that benefits rural low and middle income families. Giving those households the possibility of buying a more price stable fuel and one with an annual cost lower than air- source heat pumps is important. (Massachusetts Clean Energy Center). Another important measure is to ensure that energy auditors in Massachusetts include full inspections of wood and pellet stoves in energy audits. Old, unsafe polluting wood stoves should be eligible for removal but unless energy auditors are trained to do a safety inspection on them, this rarely happens. 

Pellet heating has a documented track record of delivering fewer CO2 emissions compared to electric baseboard heating, oil, propane, natural gas, and even air-source heat pumps with the current electricity grid (Massachusetts Clean Energy Center). (It is sometimes confused with carbon footprint studies on using pellets to make electricity in Europe, a far high carbon emitting application.) Removing a heating technology from the Clean Heat Standard that consistently performs just as well as other renewable energy and has the added benefits of greater price stability and local sourcing, would be misguided and not science based. In comparison, Vermont’s Clean Heat Standard includes automated wood heating. Vermont enthusiastically included this technology as their experience with the benefits of wood heating and ease of technology adoption has long been understood. 

Again, we thank the Department of Environmental Protection for this public comment opportunity. We hope that the Clean Heat Standard remains open to all viable low-carbon solutions to present the best possible outcome for Massachusetts to meet its clean energy and climate goals.

Further Resources:

Biomass Energy Resource Center. 2019. 2018 Vermont Wood Fuel Supply Study. https://fpr.vermont.gov/sites/fpr/files/Forest_and_Forestry/Wood_Biomass_Energy/Library/2018%20V WFSS%20Final%20Report%20with%20Letter.pdf.

Buchholz, Thomas, John S. Gunn, David S. Saah. 2017. Greenhouse gas emissions of local wood pellet heat from northeastern US forests. https://www.sciencedirect.com/science/article/abs/pii/S0360544217315451.

Biomass Energy Resource Center at VEIC. 2016. Wood Heating in Vermont. https://publicservice.vermont.gov/sites/dps/files/documents/Renewable_Energy/CEDF/Reports/AWH% 20Baseline%20Report%20FINAL.pdf.

Innovative Natural Resource Solutions LLC. 2007. Biomass Availability Analysis—Five Counties of Western Massachusetts. https://archives.lib.state.ma.us/bitstream/handle/2452/392593/ocn945986525.pdf?sequence=1&isAllow ed=y.

Olechnowicz, Casey, et al. 2021. Industry Leaders’ Perceptions of Residential Wood Pellet Technology Diffusion in the Northeastern U.S. https://www.mdpi.com/2071-1050/13/8/4178.

Maine Department of Agriculture, Conservation & Forestry. N.d. Wood Heat Maine. https://www.maine.gov/dacf/mfs/projects/woodheatmaine/index.html.

Renewable Energy Vermont and Biomass Energy Resource Center. 2018. Expanded Use of Advanced Wood Heating in Vermont. http://www.revermont.org/wp-content/uploads/FINAL-2030-Wood-Heat- Road-Map.pdf. " 

Comment on Massachusetts's H.3183 / S.2115, "An Act relative to the electrification of new and substantially remodeled or rehabilitated building,"

 AGH recently submitted another comment on proposed legislation in Massachusetts. "An Act relative to the electrification of new and substantially remodeled or rehabilitated building," (H.3183 / S. 2115) aims to establish a law requiring that "all newly constructed commercial buildings and substantially remodeled or rehabilitated commercial buildings and newly constructed buildings and substantially remodeled or rehabilitated buildings containing a residential dwelling unit shall use electricity instead of fossil fuels for space heating and cooling; cooking; and clothes drying; and, in the case of hot water, including for pools and spas, shall use electricity or thermal solar."

AGH is part of a coalition on non-profits, businesses and forest owners led by Chris Egan at the Massachusetts Forest Alliance who support modern wood heating systems.

Read below for the full comment: 

"Chairs Barrett and Roy:

The Alliance for Green Heat supports H.3183 / S.2115, "An Act relative to the electrification of new and substantially remodeled or rehabilitated building," provided that modern wood heating will not be excluded as a viable low carbon, renewable heating option in newly constructed or substantially remodeled residential dwelling units. Modern wood stoves play a highly beneficial role in the rural electrification movement because they are a preferred back-up heat for many people, giving households the confidence to install electric technologies like heat pumps.

Massachusetts is no stranger to electrical power outages. Earlier this year, the state experienced a brutal polar vortex. In the midst of dangerous, record cold, temperatures, a peak number of 60,000 households experienced power outages (Mass Live 2023).

Due to our changing climate, extreme winter events are set to increase (Union of Concerned Scientists 2023). In the inevitable moment when a household's heat pump could not run, wood stoves could provide essential heating for the hours or days that an electrical outage would drag on. This is particularly important for lower-income rural households. While the smoke from wood stoves can be problematic, pellet stoves offer a far cleaner and more efficient option, and they can easily run on a back-up battery. For homes that want to be as close to off-grid as possible, pellet stoves also draw very little energy compared to heat pumps.

We would like to commend the work that Massachusetts is attempting to carry out in order to promote the energy transition through H.3183 / S. 2115. But we urge the Joint Committee on Telecommunications, Utilities and Energy to take into account that modern wood heating as a technology has the potential to quell concerns over electrical outages for Massachusettsans as the state moves toward a more sustainable and cleaner residential energy profile. We hope you support H.3183 / S.2115 and urge that you consider language that would not inadvertently eliminate modern wood heating usage in the state."

Sincerely

John Ackerly, President

Darian Dyer, Policy Analyst

10 States sue the EPA to improve wood stoves, but the grounds are dubious

Old stoves removed during change out
programs range from ones like these ...

Ten states and one large air agency filed a notice that they intend to sue the EPA over its weak wood stove testing, certification and enforcement programs. The lawsuit is one of the only ways to keep the agency on the required timeline of updating its wood and pellet heater regulations every eight years. Otherwise, the agency can easily let timelines slip and put wood heater policies and regulations on the back burner as both Republican and Democratic administrations have usually done.

The Alliance for Green Heat (AGH) supports the lawsuit for these reasons: EPA needs to keep focused on this technology and keep doing the testing that can get better test methods and stoves that operate better in the hands of the consumer. Automated wood stoves that use sensors, computer chips and actuators to mix the fuel and the air, like in cars, probably offer the best hope for cleaning up wood stoves. But they may be left out of the next updated regulations, known as New Source Performance Standards (NSPS).

... to stoves that are decrepid
and/or dangerously self-installed.

However, AGH does not agree with much of the faulty narrative that says new stoves are not likely to be cleaner than old stoves. And maybe most worrisome is that the AGs of so many states appear willing to make such claims without citing data to support it. 

Unlike the dynamic around auto emissions, where car manufacturers are pitted against the EPA, in this case all fingers are pointed at the EPA for being too lax. The EPA’s wood heater program has had huge weaknesses and it is an easy target. But it is important to understand that the EPA is not a monolith, and it is the wood heater certification and enforcement programs in Washington that are far more of a problem than the section in North Carolina that does the test methods and change out programs.  

One of the many problems with the filing by 10 state Attorney Generals (AG) is that it is mainly based on a review of the EPA’s certification program done by the State of Alaska and Northeast   States for Coordinated Air Use Management (NESCAUM), with funding from New York State Energy Research and Development Authority (NYSERDA). It is not based on testing of new stoves in the field compared to old, uncertified stoves in the field. The narrative that the EPA has been wasting money on change-outs because new stoves aren’t necessarily cleaner than old ones seems to be gaining traction despite evidence to the contrary. Moreover, it distracts from the real, complex tasks at hand and is divisive. As a public relations strategy, it has been successful, gets good media coverage and rallies liberals.

The reality is far more complex. Ironically, it also misses what blue states care about: maximizing renewable energy in smart ways and creating more equity in the energy transition. Starting with the NESCAUM report, pellet appliances have been sidelined from the narrative and they are not even mentioned at a time when much of America is confused about the difference between premium heating pellets and industrial pellets to make electricity. If wood and pellet stoves are to play a role at helping the US reduce residential fossil fuel and protecting low to moderate income (LMI) households from the high costs of the new energy paradigm, it is vital for AG offices to understand the role of the technology in America. 

The Notice to Sue, likely leading to a lawsuit can be good for our common goals of getting cleaner wood stoves, but AG offices need to understand some things. First, we don’t need a new NSPS before we have new test methods. (One of NESCAUM’s many roles is providing data for new test methods, but compared to other labs, NESCAUM’s lab is way behind schedule, which complicates the whole timeline.) Second, the goal of getting better repeatability of a test result within a lab and between labs does not necessarily lead to a cleaner stove in the hands of homeowners. Third, tilting scales toward hybrid stoves may help in the short run, but is not necessarily a long-term or nationwide solution. Fourth, there has never been much agreement on what constitutes the best systems of emission reduction (BSR) in stoves which hinders the EPA in writing regulations that can force technology to change and improve. 

Wood and pellet heaters can help the nation in our transition to electrification by giving homeowners a back-up heating source, lowering stress on the grid during wintertime and providing LMI households protection from rising electricity costs which helps achieve equity. And environmental justice is improved in poor communities not just by a reduction in woodsmoke but also by improving energy security so that homes do not have to choose between heating and eating. For low-income households, change-out programs have been very important by removing unsafe stoves that pose a fire risk, improving not just ambient particulate matter (PM) and indoor PM, and adding heat pumps to many homes. 

The next NSPS will be best served by an EPA with the budget that enables them to collect their own data and properly manage the certification and enforcement programs, which are still far from effective. Underfunding leaves the EPA vulnerable to just reacting to one side or the other, and making poor decisions like revoking a cordwood test method that should have been changed and improved instead. That revocation was also prompted by the same group of states, most of which lack the expertise to understand the complexities and the politics of such a move. Tightening up that test method would have helped the EPA gather vital data it needs for this NSPS and not rely on data from parties who are sparring for an upper hand in the process.

The mostly blue states leading this lawsuit also need to manage wood and pellet heating far better in their own borders, as all states do. Vermont is a good model which is also heavily promoting heat pumps. States should be promoting pellet stoves and boilers and demanding stricter PM limits for those appliances. They should also limit the new installation of cord wood stoves in densely inhabited areas unless, or until, automation and mini-electrostatic precipitators can make cordwood units far cleaner. While cordwood stoves are essential for rural LMI households and help them get off fossil fuels, manually operated wood stoves are simply not a good energy solution where lots of homes are close together, particularly when the topography leads to frequent inversions, trapping PM close the ground where we breathe. 

As for the solution to reduce wood smoke in Fairbanks, even Albert Einstein would be scratching his head. Managers of that change-out program have done an admirable job and used many different strategies. They also uncovered huge problems in the EPA’s stove certification program which were hiding in plain sight. But we should not expect the next NSPS to make much of a dent in that intractable problem. 

Nationally, the solution lies in far more funding for R&D in stove technology, more attention to enforcement of current regulations, more experts for state AGs to rely on and collaboration. Like many big energy issues, the solutions are multi-faceted and rely on a collaborative approach by stakeholders. We should take this lawsuit as a wake-up call.

AGH urges IECC to keep residential wood heaters in building code

On Friday, AGH submitted a proposal for the 2024 Residential Section of the International Energy
Conservation Code. The International Energy Conservation Code (IECC) is the most commonly adopted system in the U.S. and covers about 80 percent of the nation’s population. It is up to states and counties to adopt the IECC and they can do so with amendments. The code is a relative newcomer, gaining traction since the 1990s because it can be easily implemented by architects and builders and provides consistency. Its updated every three years and committees are now working on changes for the 2024 version. Codes set the minimum requirements for energy-efficient building design and construction and impact energy use over the life of the buildings. Building energy codes are developed through consensus-based public processes and are supposed to reflect what is technologically feasible and economically justified energy efficiency measures. Assuring the cost effectiveness of model code changes also encourages their adoption and implementation at the state and local levels.

There are no official proposal right now to take biomass out of the residential energy code's definition of "renewable energy resources," but code committees have tried and there is a proposal to effectively remove biomass out of the commercial energy code. AGH signed on as a co-proponent in opposition to this removal along with a long list of institutions such as the Maryland Clean Energy Center, USDA Forest Service, and the Massachusetts Forest Alliance. Instead, our proposal was submitted as preventative comment to shore up support for keeping biomass in the definition of "renewable energy resources" in the residential sector.

See our official proposal below:

"SECTION R202 GENERAL DEFINITIONS. “RENEWABLE ENERGY RESOURCES. Energy derived from solar radiation, wind, waves, tides, landfill gas, biogas, biomass or extracted from hot fluid or steam heated within the earth.” Should Remain Unchanged.

Reasons:

1. Removing woody biomass inordinately harms rural LMI and tribal households.

A proposal to change the definition of renewable energy resources by removing biomass will have a disproportionate impact on rural low-to-middle income (LMI) and tribal households. Wood or pellet heating systems are usually put in existing homes, not during new construction but there are many cases when rural homes, off-grid homes, or new native American homes need to include wood heaters in new construction.

Some homes need to be built with wood stoves not by choice, but by necessity, such as in tribal areas, where affordable heating options are few. At the end of the spectrum can be expensive homes are “net zero” homes that are on or off the grid, and who need non-electric heat because their renewable electricity supply and/battery storage can’t provide sufficient energy. Many people want to pair a wood or pellet stove with solar panels, heat pumps and home batteries because heat from a wood or pellet stove complements other renewable technologies. Heat pumps draw too much energy to be powered by most solar panel arrays in the coldest months of the year.

Wood heat help reduce electric demand during the early evening
reducing peak load stress.

2. Wood and pellet heaters are essential to the growth of electrification in America.

Electrifying heat is the future and should be incentivized and promoted as much as possible. However, in rural areas, where households experience more frequent and longer electricity outages than in urban and suburban areas, people want back-up heat. Having a wood stove or a pellet stove (with a battery pack) gives many households the confidence to install heat pumps or even go fully electric. The state of Vermont officially recommends having a back-up source of heat with heat pumps and specifically mentions that wood stoves are a good option. In the future, we expect many homes that use wood stoves as their primary heat source will be willing to switch to heat pumps as long as electricity prices remain stable and do not rise too much. These homes will still want a wood stove for both secondary and emergency back-up heat. Keeping biomass within the definition of renewable energy resources will make this connection undeniable.

Heat pumps outsold gas furnaces as of last year and will only gain larger shares of the market.

3. The proposal suggesting the removal of biomass from renewable energy resources is confusing, flawed, and shows a lack of understanding of current practices.

Many concerned with keeping biomass within the renewable energy resources definition appear to be reacting, in part, to news about harvesting practices for industrial pellets that are shipped to Europe for electricity production. This mistake was reinforced by comments made by committee members in a previous meeting when some in the committee tried to remove woody biomass.

The source of firewood for residential heating in America is easy to understand. Firewood is available all around us. Much of it is free for the taking from anywhere to downed trees that litter roads and neighborhoods after storms, from regular tree trimming and tree removal operations, and from firewood dealers. Many firewood dealers themselves are tree trimmers trying to make additional income from trees they were hired to remove. Firewood also comes from thousands of small firewood retailers, many of whom cut live trees from their own plots of land, or as part of a commercial timber harvest.

4. The IECC should be as applicable in climactic Zones 5, 6, 7, and 8 as it is in warmer areas.

Climactic zones 5, 6, 7, and 8 present unique challenges for wintertime heating technologies, particularly for LMI households. Heat pumps are effective in all climactic zones, but they can get very expensive in the coldest months and years and will always be more expensive than gathered wood.  Wood and pellet heaters are ubiquitous in many rural areas in the coldest parts of our country. We hope the committee has a strong commitment to diversity and inclusion at the committee level the diversity to understand the levels of poverty and economic stress on many families in the coldest areas.  Many need to choose between heating and eating needs.

5. Woody biomass is consistent with the goals of the IECC.

An important goal of the IECCC is “safe, technologically feasible, and life cycle cost effective, considering economic feasibility, including potential costs and savings for consumers and building owners, and return on investment.” Woody biomass is widespread in the U.S. because it is affordable and technologically feasible. It is generally safe when units are installed by professionals and maintained properly. Like other household systems, lack of replacement, repair and cleaning can lead to unsafe conditions.

Cost Impact:

The code change proposal will neither increase nor decrease the cost of construction."

Comment on Massachusetts's H.3211/S.2137 "An Act Limiting the Eligibility of Woody Biomass as an Alternative Energy Supply"

AGH recently submitted a comment on H.3211/S.2137 out of Massachusetts that proposes to eliminate woody biomass from the alternative energy supply definition. This would make modern pellet boilers ineligible for the Alternative Energy Portfolio Standard and subsequent incentives associated with the program. Read below for the full comment:

One main example of a
high-tech pellet boiler.

"Chairs Barrett & Roy:

The Alliance for Green Heat opposes H.3211/S.2137, known as “An Act Limiting the Eligibility of Woody Biomass as an Alternative Energy Supply.” As an organization working to make local, low-carbon heat more accessible, we support many technologies, from heat pumps to pellet stoves. No technology is perfect but, in this age, when getting off fossil fuels is paramount, it is hard to believe legislation would oppose the inclusion of the cleanest pellet heating systems in the world.

We also work with firewood banks in Massachusetts that take waste wood and provide it to low-income homes on an emergency basis. The amount of wood that is available for free from towns, cities and utilities is enormous, and it is often thrown away.

Disqualifying woody biomass fuel from being an “alternative energy supply,” deters a viable low-carbon fuel choice, which most New England states are trying to expand. Eliminating a valuable tool for households that would qualify for incentives under the Alternative Energy Portfolio Standard, through the earning and selling of Alternative Energy Credits (AECs) with their wood pellet or wood chip biomass systems, is contrary to the promotion of renewable energy goals and priorities of the state of Massachusetts. The bulk of peer reviewed scientific analysis shows clear carbon benefits for small scale biomass heating. Unfortunately, some people are confusing this with the largescale, industrial use of pellets to generate electricity.

The Alternative Energy Portfolio Standard is a program that provides homeowners and businesses an incentive to install eligible alternative energy systems that both lower GHG emissions and increase energy efficiency (Massachusetts Department of Energy Resources). This market-based program seeks helps homeowners participate in helping the state to reach its climate goals. Owners of an eligible system, including ones that produce thermal energy, receive AECs that are then put on a market to be bought by entities in Massachusetts with a compliance obligation. For woody biomass systems, eligible fuels are wood pellets, dried wood chips, and green chips. In order to participate, a homeowner needs to install an eligible system, submit a Statement of Qualification, and then wait for approval.

The process that owners of woody biomass systems must undertake in the gaining of AECs involves multiple steps ensuring sustainable sourcing of the wood pellets and chips. Each owner of a qualifying woody biomass system must purchase their pellets or chips from a verified and set list of distributors/suppliers who are evaluated for their sustainability practices. Most of the pellets and chips involved are specifically from wood waste streams, meaning no trees are being cut down to feed the woody biomass systems involved in the Alternative Energy Portfolio Standard. The consumption of this fuel is then reported quarterly to a third-party, independent verifier. There is little worry about the misuse or exploitation of local forest systems within this process.

Another example of a
high-tech pellet boiler.

The technology that H.3211/S.2137 intends to disincentivize appears to be further misunderstood. These are not like cordwood stoves or outdoor boilers. These systems are expensive, highly advanced, automatically fed, and capable of thermal storage that can replace oil boilers in your home. In a 2,000-square-foot home, an automated wood heat system emits 1.8 metric tons of CO2 annually compared to heating oil’s 5.2 metric tons of CO2 or 3.6 metric tons of CO2 with natural gas systems (Massachusetts Clean Energy Center). Because of the high upfront cost, there is not a widespread demand for them, and payments from the AECs are modest at best.

In terms of the annual cost to operate an automated wood heating system, a household can save, on average, $415 in comparison to an oil system. The saving jumps even higher when compared to electric baseboard heating ($2,771) and propane ($1,441). It is only $48 more expensive than a natural gas system on average, but with automated wood heating’s advantage of being a renewable source of energy, the slight cost difference pales in comparison to the climate impact overall (Massachusetts Clean Energy Center).

For those concerned about woody biomass’s place in the renewable energy field, it is important to remember that no renewable energy source is perfect. Each comes with its own less-than-ideal supply chain stories and impact on the environment. In the past, Massachusetts has seen undeveloped land, some 10,000 acres of the state’s forest, be cleared for solar farms (Boston Globe 2020). This is less than ideal. Still, many fertile fields which could return to forest are being used for solar farms. Large off-shore wind farms have always been plagued with concerns for marine habitat health, like the 2021 lawsuit out of Nantucket (Boston NPR 2021). Again, less than ideal. However, these technologies, despite their challenges, are constantly evolving to instill more policy guardrails and stronger research to bring them to fruition. The methods used to evaluate these renewable technologies produce the understanding that they are essential but need to be guided with scientific evidence and reflective consideration—the same method by which woody biomass should be judged.

Passing H.3211/S.2137 would diminish the most modern and cleanest biomass heating technology. If the state, counties, or towns want to address problematic wood heating technology, such as wood stoves, there are many tools to use. We urge you to vote “NO” on H.3211/S.2137 “An Act Limiting the Eligibility of Woody Biomass as an Alternative Energy Supply.”"

Alliance for Green Heat, USDA Forest Service Support Growing Demand for Firewood in Low-income Communities

For immediate release            
Monday, June 12, 2023  

Contact

John Ackerly, President

jackerly@forgreenheat.org

Pam Porter, Grant Manager

pam@forgreenheat.org

The U.S. Department of Agriculture’s Forest Service has awarded more than $824,000 from President Biden’s Bipartisan Infrastructure Law to the Alliance for Green Heat to expand firewood banks that serve low-income communities who struggle with high heating costs.

North Idaho Firewood Rescue
provided 140 cords of wood to 
needy families. Funding will go for
a drying shed to ensure they can
deliver seasoned wood. 

Hundreds of firewood banks across the country serve households that may otherwise face bone-chilling temperatures and frozen pipes.  Firewood banks are often run by churches, towns, tribes, and groups of volunteers. Most receive donated wood and turn it into split, seasoned firewood and others purchase truckloads of logs.

“Many families, especially in tribal communities, depend on firewood to heat their homes. Firewood banks are helping to ensure that everyone has access to this lifesaving renewable resource,” said Forest Service Chief Randy Moore, “The Forest Service is joining with Alliance for Green Heat to invest in the vital work of firewood banks to serve those in the greatest need.”

Homes with wood stoves have the option of using a local, renewable, and free heating fuel, unlike homes that only have furnaces or boilers. Homes without wood stoves sometimes have to turn to federal and state emergency heat assistance if they run out of money during the winter. With increased storms and power outages, wood stoves also provide back-up heat.

The Forest Service funding will allow the Alliance for Green Heat to provide up to $20,000 to larger firewood banks and up to $10,000 to smaller ones.  Large firewood banks produce more than 100 cords a year, with some producing over 1,000 cords. New firewood banks who want to begin distributing free wood to needed homes will also be eligible for funding.

This marks the second year the Alliance for Green Heat has run this program. The first year, the Alliance made grants of up to $15,000 to 46 firewood banks. This marks the second year the Alliance for Green Heat has run this program. The first year, the Alliance made grants of up to $15,000 to 46 firewood banks. Together, those banks delivered nearly 10,000 cords of wood to more than 6,500 homes. Most of the grant funds went to purchase critical equipment like splitters, chain saws, sheds, trailers, conveyor belts, and protective equipment.  That equipment will help the firewood banks process and deliver firewood for many years to come.

“During the first year, we were particularly inspired by the efficiency of tribes who provided firewood to thousands and thousands of homes, some of which had no electricity or running water,” said John Ackerly, President of AGH. Four tribal groups representing the Chippewa Cree, the Washoe, Santo Domingo, Hopi, and Navajo, provided nearly more wood than the other 41 firewood banks funded during the first year. However, every bank touches the lives of those they serve through the hard work and generous spirit of their volunteers and staff.

For more information and to submit an application, go to Firewoodbanks.org. Applications may be submitted beginning on September 1.

For official release: http://www.forgreenheat.org/upload/upload/June 12 Press Release .pdf

#  #  #

The Alliance for Green Heat promotes modern wood and pellet heating systems as a low-carbon, sustainable, and affordable energy solution. The Alliance works to advance cleaner and more efficient residential heating technology, particularly for low and middle-income families. Founded in Maryland in 2009, the Alliance is an independent non-profit organization and is tax-exempt under section 501c3 of the tax code.

New York bans fossil fuels in new builds beginning in 2026: Implications for hearth retailers are still unfolding

By: Darian Dyer

On May 2nd, New York State lawmakers approved their FY 2024 New York State Budget. Embedded in this budget is a historic provision to electrify buildings and homes on a state-wide basis. The provision designates New York as the first state to pass legislation banning the installation of fossil fuel equipment in new buildings. The mandate comes into effect in 2026, initially applying to shorter buildings and then expands to encompass all new construction by 2028. Prohibited appliances in new buildings include gas, oil and propane space heating systems, gas dryers and gas water heaters, among others.

The New York law will require its building code to implement the fossil fuel equipment ban starting in 2026.

The hearth industry in New York, and especially hearth retailers, will experience little impact until 2030, when a ban on fossil fuel equipment includes installations in existing homes. Until then, they will likely experience more demand for gas appliances and have time to diversify into heat pumps or other products and services. Gas installers and technicians will have work maintaining existing equipment after 2030, but that will gradually contract over the ensuing decades, while other types of hearth installations grow.

The hearth industry, represented by the Hearth, Patio and Barbecue Association (HPBA), sells appliances that use any and all fuel— gas, propane, electric, wood, and pellets. However, they are now doubling down in defense of gas, aligning with major oil and gas lobbies. HPBA’s position statement on its website says they believe, “it is critical to lower carbon emissions based on solid science and technology. Requiring communities to be all-electric does not achieve the intended reduction due to inefficiencies with generation, distribution, and lack of storage.” However, many HPBA members, including the Alliance for Green Heat, strongly support electrification and the increased use of modern wood and pellet heating as a proven pathway to reduce fossil fuel heat. AGH’s President, John Ackerly, said, “We urge the new CEO of HPBA to provide the leadership for the hearth industry to evolve and attract and retain a younger and more diverse workforce who can thrive in the future.”

Wood and pellet stoves are not impacted by the NY policy other than possibly benefitting retailers with greater wood and pellet appliances sales, as gas fireplaces are phased out. Indoor gas fireplaces appear to be the hearth product that will be most impacted, and it is still unclear if piped natural gas to outdoor barbecues, pool heaters, and hot tubs, for example, will face restrictions after 2030. Most experts think appliances using outdoor portable propane tanks, like barbecues, firepits, and outdoor fireplaces will not be impacted after 2030. Karen Arpino, Executive Director for the Northeast Hearth, Patio, and Barbecue Association’s Board of Directors, expressed reservations in that the law stands more as a symbolic rule rather than a law to really impact New York’s GHG emissions.

Almost all stove retailers sell to the existing home market. The industries to be affected by this law are new home builders and smaller retail businesses focused on supplying appliances to new construction. These will likely be the hardest hit if they don’t diversify their business to include heat pumps, for example. A stove retailer in Rochester, New York, was more concerned about the precedent for other states than the impact on their own business. They, like others interviewed for this article, are planning on “just riding it out.”

Hearth retailers have steadily expanded their product lines and many now focus more on outdoor patio items, most of which will not be impacted at all by the New York law.

The New York law, as in many states, relies on changes to building codes to be implemented. Thus, it will be the state fire prevention and building code council that will provide clarification and exemptions that determine some of the critical gray areas for outdoor hearth gas and propane uses, as well as what kind of electrical appliances could be installed. The Alliance for Green Heat is urging jurisdictions to put guardrails on baseboard electrical heating, especially in lower income homes and apartments, as it is less expensive to install compared to heat pumps, but far more expensive to run.

The Alliance for Green Heat reached out to some of the primary advocates of the ban to see whether they knew how it would impact specific indoor and outdoor hearth appliances. The Alliance for a Green Economy’s Executive Director, Jessica Azulay, said that the gradual phasing out process of fossil fuels allows time for the industry to familiarize itself with the required technology, educate installers, and ramp up the production of electric appliances. Patrick McClellan, the Policy Director for the New York League of Conservation Voters, underscored the importance of the phased approach, but neither were sure how outdoor gas and propane appliances would be treated. However, they did suggest that outdoor appliances are not the target.

Hearth industry ramifications in other electrification

policies

While New York is the first state to put electrification of new buildings into law, several other municipalities, most notably in California, have approved pro-electric energy and building codes. For instance, Brisbane’s city council voted to amend their building code to require new residential buildings to be all electric in 2019. Notable exceptions to the code include the ability for residences to still incorporate non-electric cooking appliances and fireplaces in new buildings. Oakland, CA, amended their municipal code in 2020 to require “all-electric construction in newly constructed buildings.” This ordinance did not restrict portable propane appliances for use outside of the building envelope, including outdoor cooking and heating appliances. Marin County, CA, passed a similar ordinance amending their building code in 2022, making an exception for portable propane appliances outside of the building envelope. These are only three examples from over 50 cities in California that have similar electrification requirements in their building and energy codes.

California and New York, leaders in the electrification movement, account for 17% of the total US population, more than the 25 least populated states combined.

Low carbon electric heat and the grid

Much of New York’s ban on fossil fuel equipment installation has to do with space and water heating, even though gas stoves often get more attention. The shift to heat pumps and heat pump water heaters will initially run mostly on electricity made by fossil fuel, but their extremely high efficiencies still significantly reduce carbon impacts. Currently, nearly 60% of the state’s electricity is generated from natural gas, accounting for 46% of its utility-scale in-state generation. Achieving lower carbon emissions in New York relies heavily on rapidly decarbonizing the energy grid. New York has developed a plan to address this challenge. By 2030, 70% of the grid load will be met with renewables, with the goal of 100% of the grid being powered by renewables and zero-emission sources by 2040.

New York’s restrictions on fossil fuel installations target buildings, the largest source of greenhouse gasses in the state.

New York will face scrutiny on whether an unjust energy burden materializes for low-to-moderate income (LMI) households living in existing buildings and whether all-electricity stands as an affordable option for everyday consumers. To support LMI households during this transition, the New York legislature has approved $200 million to help weatherize and electrify low-income homes. In addition to this, the NY Home Energy Affordable Transition (HEAT) Act is in the works, hoping to lead an equitable, neighborhood-scale decarbonization effort. It is currently sitting in the Senate Energy and Telecommunications Committee. Still, some construction companies say that mandating electrification in new builds will increase construction prices, further pushing LMI families off of the housing market.

Opportunity for wood and pellet stoves 

For those producing wood and pellet stoves though, there doesn’t seem to be an obvious downside. NEHPBA’s Karen Arpino had discussions with New York legislators and many were eager to work on legislation to promote wood stove change-out programs in the state. NYSERDA used to offer rebates for pellet stoves if a household turned in an old wood stove. 

While 108,202 households heat primarily with wood (1.4%) in the state of New York, its use in rural counties is substantial, providing a significant level of low carbon energy resilience and diversification without adding further stress to the grid. For example, in Schoharie county, 15% of homes use wood as a primary heat source and 20% in Hamilton, with far more homes using it as a secondary heat source. Wood stoves provide homeowners more confidence to electrify, and they are likely to become more popular in electrified homes if it is cheaper than using a heat pump in the coldest weeks or months of the year. If the grid becomes even more unreliable in rural areas, wood stoves are an obvious back-up option and as solar and battery options grow, pellet stoves could also be a back-up heat source.