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.”"