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