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

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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.