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. https://fpr.vermont.gov/sites/fpr/files/Forest_and_Forestry/Wood_Biomass_Energy/Library/2018%20V 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. https://www.sciencedirect.com/science/article/abs/pii/S0360544217315451.

Biomass Energy Resource Center at VEIC. 2016. Wood Heating in Vermont. https://publicservice.vermont.gov/sites/dps/files/documents/Renewable_Energy/CEDF/Reports/AWH% 20Baseline%20Report%20FINAL.pdf.

Innovative Natural Resource Solutions LLC. 2007. Biomass Availability Analysis—Five Counties of Western Massachusetts. https://archives.lib.state.ma.us/bitstream/handle/2452/392593/ocn945986525.pdf?sequence=1&isAllow ed=y.

Olechnowicz, Casey, et al. 2021. Industry Leaders’ Perceptions of Residential Wood Pellet Technology Diffusion in the Northeastern U.S. https://www.mdpi.com/2071-1050/13/8/4178.

Maine Department of Agriculture, Conservation & Forestry. N.d. Wood Heat Maine. https://www.maine.gov/dacf/mfs/projects/woodheatmaine/index.html.

Renewable Energy Vermont and Biomass Energy Resource Center. 2018. Expanded Use of Advanced Wood Heating in Vermont. http://www.revermont.org/wp-content/uploads/FINAL-2030-Wood-Heat- Road-Map.pdf. " 

AGH Board Members Detail Home’s Carbon Footprint

To understand carbon impacts of residential heat, it helps to get get personal. Three Alliance for Green Heat (AGH) board members and one AGH supporter - Jon Stimling, John Ackerly, Josh Elmore and Peter Caldwell - calculated the carbon footprint of their homes in order to better understand home heating carbon impacts. Each household employs at least one form of renewable energy. The four individuals emitted between .92 and 3.8 metric tons of carbon per year to heat their homes, which is well below the national average and even further below their respective state averages. 

Postscript: Ten years later, one Board member is nearly fossil fuel free in his house and cars.  And it was easier than many people may expect.

The lower-than-average emissions are due in part to the fact that each household uses wood or pellet stoves to provide some portion of their heating needs. The calculations were reached using the carbon calculator website; www.carbonfootprint.com, a well regarded program that assigns .18 metric tons of carbon for a ton of wood pellets or a cord of wood. The average American home produces about 12 tons of carbon a year, according to most authorities and 40 to 60% of that on average is used for heating.

The EPA estimates approximately 4 metric tons of carbon dioxide (CO2) per person per year (about 17% of total U.S. emissions) are emitted from people's homes. The individuals featured here all have household footprints of 3 to 7 metric tons, but if calculated using the EPA per capita average, these homes would emit 8 to 20 tons metric tons. The home with the lowest carbon impact from heat has a pellet furnace that can meet 100% of the home’s heating needs. One Board member has solar panels, which covers 100% of his electric load and another buys 100% wind power. Some variance in CO2 output can be attributed to how electricity is generated in each household’s particular state.

House #1: 
A 1,900 square foot home occupied by four people in Maryland has a total average output of 6.95 metric tons of CO2 a year. After purchasing 100% wind power, the footprint drops to 2.85. Natural gas, used as a backup heating fuel, is the largest contributor, totaling 2.49 metric tons of CO2 a year. The combustion of 2 cords of wood in an EPA certified LOPI Patriot circa 1995 accounts for the other .37 metric tons. The wood is obtained from the urban wood waste stream through local tree services working in the neighborhood.

Footprint	Metric tons of C02
Total Household	2.85
Total W/ Electricity	6.95
Total Heating Only	2.23
Natural Gas	2.49
Wood Cords	.37
Size of House	1900 Sq/ft
Number of Occupants	4

House #2:

A 1,800 square foot home occupied by five people in Colorado. This household emits 3.08 metric tons of CO2 a year on average. The largest contributor to this impact is due to the reliance on propane as a back up heating fuel. It is 2.90 metric tons of the total emissions. The remaining .18 metric tons of CO2 is attributed to the single cord of wood burned per year in an EPA certified 2002 Jotul. The wood is either self harvested or purchased from people hired to thin local forest for fire suppression. 100 percent of electricity is from solar panels installed near the house.

Footprint	Metric tons of C02
Total Household	3.08
Total Heating Only	2.36
Propane	2.90
Wood Cords	.18
Size of House	1800 Sq/ft
Number of Occupants	5

House #3:

A 2,650 square foot home in upstate New York occupied by two people. The household’s total CO2 footprint is 7.59 metric tons a year. This result is a combination of the home’s electricity consumption (9,733 kwh/yr), which contributes 3.79 metric tons of CO2 to the total, and heating oil (back-up fuel) which is responsible for 2.52 metric tons of CO2 a year. Finally, the combustion of 7 cords of wood a year in a Vermont Castings stove results in 1.29 metric tons of CO2 being released. The wood is self harvested and split by hand.

Footprint	Metric tons of C02
Total Household	7.59
Total Heating Only	3.81
Heating Oil	2.52
Wood Cords	1.29
Size of House	2650 Sq/ft
Number of Occupants	2

House #4:

A four person 2,500 square foot household in New Hampshire emits 7.02 metric tons of CO2 a year. The largest contributor to this total was electricity consumption (15,000 kwh/yr on average), which resulted in 4.65 metric tons of CO2 being released. Propane for cooking and hot water contributed 1.45 metric tons to the total. With the remaining .92 metric tons released through the combustion of 5 tons of wood pellets in a Harman PF100 furnace each year.

Footprint	Metric tons of C02
Total Household	7.02
Total Heating Only	.92
Propane	1.45
Wood Pellets	.92
Size of House	2500 Sq/ft
Number of Occupants	4

These four households demonstrate the wide array of energy saving measures and methods to offset CO2. There is no blanket, cure-all strategy to reduce fossil fuel consumption, however this group shows how relatively small measures like running a wood stove can help to decrease heavy CO2 emissions. Everyone in the thermal biomass or energy efficiency sector should consider doing their household carbon footprint as well as getting a home energy audit to get a more tangible understanding of these issues. Understanding your carbon footprint in comparison with other Americans is also useful. Finally, understanding the potential of strategies to offset CO2 from fossil fuels, like using a modern wood or pellet stove in your home, is the building block for appreciating how we as a society can intelligently leverage this technology.