State electrification policies and wood and pellet heating

To date, state legislation targets fossil fuel, not wood and pellet combustion

Decarbonizing residential heat generally means the conversion of fossil fuel appliances to primarily electric sources of heat. Typically, this would be high-efficient heat pumps or geothermal – but it could also involve pellet stoves.

In rural areas, wood stoves are likely to remain popular in the transition to heat pumps as a backup energy source during power outages, and they could also relieve stress on the electric grid at peak times. As states begin to pass laws to move towards electrification of homes and buildings, there is some concern that wood and pellet appliances could also be restricted, either inadvertently or purposely but AGH has not found any policies that would restrict wood and pellet combustion appliances. However, the lack of specificity in bills leaves open the possibility of contradictory interpretation at the local or county level. 

AGH has our eyes on six state-wide electrification policies, continuously monitoring movements in the legislature, code councils, or courts as they develop. Much of the current electrification movement is happening at the local level. Over 100 counties or cities have decided to adopt energy codes or ordinances that phase out the use of fossil fuels in the residential heating sector.

We suspect restrictions on wood and pellet appliances will be driven more by concerns over particulate matter (PM) emissions, which may be justifiable when it comes to wood stoves in urban areas but problematic for pellet appliances. The development of “zero emission” heating standards might also be a problem for wood and pellet technology. 

Photo Source: AGH created image to add pellet stove. Original image: Unique Heating and Cooling.

Washington D.C. is the only state-level jurisdiction that targets “on-site fuel combustion,” but it is unclear that this will include fireplaces, wood, or pellet stoves.  Given the number of exemptions that are being added to such policies, we expect technologies like pellet stoves and fireplaces are likely contenders for such exemptions.

Only one state, New York, has passed a bill that would phase out fossil fuel equipment in the residential sector, but they specifically did not include wood or pellet heaters. There are plenty of exemptions in New York’s electrification law: emergency back-up power generation, manufacturing facilities, commercial food establishments, laboratories, laundromats, hospitals, other medical facilities, critical infrastructure such as backup power for wastewater treatment facilities, and crematoriums. It also exempts the full application of the law in situations where the building code council deems it infeasible (Part WW, Subdivision 6 of section 11-104).

Closest to New York’s strategy was Washington state’s decision to adopt energy codes that would effectively phase out fossil fuel infrastructure starting in March 2024 (Section R405) and California’s vote to develop and propose zero-emission standards for space heating by 2030 (CARB, 2022). Washington’s energy code proposal does not threaten wood and pellet use, as they can be an acceptable part of a building’s overall energy performance in conjunction with a heat pump.

California’s proposal for zero-emission standards for space heating is still unclear but could possibly pose a problem for wood heating. Both require follow-up rulemaking as they move throughout committees and councils, fleshing out exemptions and practical applications. Because the gas and homebuilders industry in 2023 asked a federal judge to dismiss their case against the Washington State Building Code Council (Spokane Home Builder’s Association v. Washington State Building Code Council, No.  1:23-cv-03070-SAB), we will be able to see the practical application of the amended energy codes sooner rather than later.

New Jersey is the only state that has current legislation in progress that includes the phasing out of “unregulated fuels” in its push to electrify residential homes (S.249). We suspect the intention of including “unregulated fuels” was to target fuels like propane and oil, which are not delivered by regulated utilities, not wood and pellets. However, wood or pellets could be considered unregulated, despite their obvious role in decarbonizing the building sector. Further defining “unregulated fuels,” and identifying the goals behind that definition, will give us a better idea of how wood and pellets will fare in the future of New Jersey electrification policy.

Photo Source: Bensonwood

Massachusetts has a bill in progress that would need to be fleshed out before determining whether it could apply to wood and pellet heating (H.3183 / S.2115). “An act Relative to the Electrification of New and Substantially Remodeled or Rehabilitated Building,” states that buildings “shall use electricity instead of fossil fuels for space heating.” In some ways, this could be interpreted as still allowing wood and pellets for space heating, if it isn’t a conversion from fossil fuels. There are qualms to be had about this wording, for sure, but flexible enough to allow advocacy for wood and pellets inclusion in practice.

Wood stoves have been restricted in some urban areas and smaller towns and valleys based on concerns over particulate matter but this should not be confused with restrictions on carbon intensive fuels. AGH urges jurisdictions who restrict the use or installation of wood stoves because of excessive wood smoke to exempt pellet heaters.

Summary

AGH urges jurisdictions to consider all low carbon heating technologies, and to be sensitive to how reliant many rural low-income homes are on wood and pellet heating. We suspect it will take decades for there to be enough funding to switch most rural low-income homes to heat pumps, and even then, many households may want a wood or pellet stove back-up.

We also believe it is an important time for wood and pellet heat advocates to reach out to electrification groups and build alliances. By supporting and uniting with this movement, wood and pellet technologies have the best chance to be understood as a respected partner in the low carbon energy transition. This would also open opportunities to educate movement leaders on the critical difference between firewood and pellet use for heating versus its use in electricity generation, or its non-essential uses like in fireplaces, firepit, etc. Wood stoves also play an important role in energy poverty alleviation. The importance of wood and pellet heaters to low-to-moderate-income households is generally understood by legislators. Because of this, many states still incentivize wood or pellet heaters, as does the U.S. Congress through a federal tax credit that is at the same level of solar and geothermal.

Beyond the United States, the Alliance for Green Heat follows standards around the world that might provide some insight and creativity for policies and regulations here at home. Dan Gates, a Luths Services director/engineer in Scotland, recently published an opinion piece on Scotland’s recently adopted “New Build Heat Standard” (NBHS). Dan’s analysis of the NBHS, which would ban direct emission heating systems in newly constructed homes in Scotland starting at the beginning of this month, is similar to analyses we find ourselves undertaking in electrification policies stateside.

Dan analyzes four main points, but we think the first point is the most relatable to the electrification work AGH undertakes. He asks, “Ban on biomass but what about stoves?” In Scotland’s case, it is unclear whether wood stoves could qualify as “emergency heating.” It is likely that you would have to argue that your new wood stoves would act as your energy heating in the event of a power outage (not just as an accessory heating system in general) for it to qualify. Dan makes a point we often make in our own public comments on similar legislation: wood stoves are incredibly complementary to heat pump systems in rural areas. He argues that making an exemption for wood stoves in rural areas would be a good idea, preventing “backlash against the legislation on the main point of the regulation- to ban oil/gas boilers on new build.” Either way, clarification on this question of whether wood stoves have a place in the NBHS needs to be made.

At Alliance for Green Heat, we think it is important to keep our eyes on evolving electrification policy that could affect wood heating no matter the country. Ideas and needed clarifications are often similar to our own, strengthening the resolve and interest in utilizing wood heat in the most strategic manner in the energy transition.