Friday, September 1, 2023

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. 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.

Biomass Energy Resource Center at VEIC. 2016. Wood Heating in Vermont. 20Baseline%20Report%20FINAL.pdf.

Innovative Natural Resource Solutions LLC. 2007. Biomass Availability Analysis—Five Counties of Western Massachusetts. ed=y.

Olechnowicz, Casey, et al. 2021. Industry Leaders’ Perceptions of Residential Wood Pellet Technology Diffusion in the Northeastern U.S.

Maine Department of Agriculture, Conservation & Forestry. N.d. Wood Heat Maine.

Renewable Energy Vermont and Biomass Energy Resource Center. 2018. Expanded Use of Advanced Wood Heating in Vermont. Road-Map.pdf. "