Comment on Massachusetts's H.3183 / S.2115, "An Act relative to the electrification of new and substantially remodeled or rehabilitated building,"

 AGH recently submitted another comment on proposed legislation in Massachusetts. "An Act relative to the electrification of new and substantially remodeled or rehabilitated building," (H.3183 / S. 2115) aims to establish a law requiring that "all newly constructed commercial buildings and substantially remodeled or rehabilitated commercial buildings and newly constructed buildings and substantially remodeled or rehabilitated buildings containing a residential dwelling unit shall use electricity instead of fossil fuels for space heating and cooling; cooking; and clothes drying; and, in the case of hot water, including for pools and spas, shall use electricity or thermal solar."

AGH is part of a coalition on non-profits, businesses and forest owners led by Chris Egan at the Massachusetts Forest Alliance who support modern wood heating systems.

Read below for the full comment: 

"Chairs Barrett and Roy:

The Alliance for Green Heat supports H.3183 / S.2115, "An Act relative to the electrification of new and substantially remodeled or rehabilitated building," provided that modern wood heating will not be excluded as a viable low carbon, renewable heating option in newly constructed or substantially remodeled residential dwelling units. Modern wood stoves play a highly beneficial role in the rural electrification movement because they are a preferred back-up heat for many people, giving households the confidence to install electric technologies like heat pumps.

Massachusetts is no stranger to electrical power outages. Earlier this year, the state experienced a brutal polar vortex. In the midst of dangerous, record cold, temperatures, a peak number of 60,000 households experienced power outages (Mass Live 2023).

Due to our changing climate, extreme winter events are set to increase (Union of Concerned Scientists 2023). In the inevitable moment when a household's heat pump could not run, wood stoves could provide essential heating for the hours or days that an electrical outage would drag on. This is particularly important for lower-income rural households. While the smoke from wood stoves can be problematic, pellet stoves offer a far cleaner and more efficient option, and they can easily run on a back-up battery. For homes that want to be as close to off-grid as possible, pellet stoves also draw very little energy compared to heat pumps.

We would like to commend the work that Massachusetts is attempting to carry out in order to promote the energy transition through H.3183 / S. 2115. But we urge the Joint Committee on Telecommunications, Utilities and Energy to take into account that modern wood heating as a technology has the potential to quell concerns over electrical outages for Massachusettsans as the state moves toward a more sustainable and cleaner residential energy profile. We hope you support H.3183 / S.2115 and urge that you consider language that would not inadvertently eliminate modern wood heating usage in the state."

Sincerely

John Ackerly, President

Darian Dyer, Policy Analyst

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.”"

Renewable Left Out of Heating Fuel Price Reports

For many years, the federal and state governments have issued monthly reports on the prices of fuels including winter heating fuels so that consumers, businesses, and the media have accurate information. Traditionally, this has meant prices of fossil fuels – oil, natural gas, propane, etc. Recently four states started to provide price information on a renewable fuel – wood pellets: Massachusetts, New Hampshire, Vermont, and Maine.

Advocates for renewable energy say it’s been a hard sell to get government bureaucracies to add wood pellets to their price reports. The most important reports come from the Energy Information Agency (EIA), which is part of the Department of Energy (DOE). However, the EIA collects their data from states, and unless states report on pellet prices, they say they can’t include it in federal reports.

State energy offices are stretched thin and some say they can’t take the extra work of including a fuel that may have more price fluctuations and not as many major retailers who can provide the price information. In New York, the New York Biomass Energy Alliance, a trade association is undertaking research and surveys to help the state start reporting on pellet prices. Other states where wood and pellets are a widespread heating fuel include Pennsylvania, the Great Lake states, and the Pacific Northwest.

Fossil fuels have received extensive government subsidies over the decades, but advocates of wood pellets say that these price reports can be seen as an informational subsidy. As federal and state agencies switch gears to include more information about renewable energy, this may result in less staff time spent on fossil fuels.

A example of this is a high profile report the EIA puts out every fall called the “Winter Fuel Outlook.” This annual report had never mentioned a word about firewood and pellets, America’s third most common heating fuel until last year. The report has always had extensive information about heating fuels, such as oil and propane, that provide fewer Btus to US homes than wood and pellets provide. The Alliance for Green Heat, Hearth & Home Technologies, New Hampshire Senator Jeanne Shaheen and others pressed EIA to also include renewable fuels. The report did include some information about wood and pellets and EIA is likely going to increase their coverage in the 2013 report. Visit this page to read more on the EIA’s winter fuel outlook. 

A coalition of non-profit and industry groups is starting to call on state energy offices to urge them to include pellet and wood prices in their monthly reports. Below are details and links to the four states that currently report on pellet prices.

New Hampshire’s Office of Energy and Planning compares both wood pellets and cordwood to other fuel types such as natural gas, propane, and gasoline. The price/unit; heat content/unit (Btu); and price per million Btu are all compared between the different fuel types. The data is supposedly published weekly with the latest update being June 3rd, 2013. The website will also have historical fuel price data as well. The OEP notes that the price of firewood sold by the cord can vary widely depending on the location, time of year and quality of the wood being sold.

Vermont’s Public Service Department compares BTU/unit, efficiency, $/unit, and $/MMBtu between wood pellets, green cordwood, fuel oil, natural gas, propane, etc. The data is compiled into monthly reports from 01/08 to 06/13. Prices are collected on or about the first Monday of each month and reflect dealer discounts for cash or self-service. The cord wood information has not been updated since 11/11.

Maine’s Governor’s Energy Office conducts a weekly survey of fuel prices during the peak season between October and March. Information on the price of cordwood and wood pellets has been archived since October 9, 2012. The survey is released monthly during the rest of the year. It reports the weekly price averages of oil as compared to natural gas, propane, wood pellets, cordwood, and electricity.

Massachusetts’ Executive Office of Energy and Environmental Affairs website provides detailed monthly fuel price averages of heating oil, propane, gasoline and diesel. For pellets, it only provides links to third party websites. These websites, of which woodpelletprice.com is the most comprehensive, compile wood pellet retailers in Massachusetts, their contact information, the brands of pellets they sell, the corresponding price, and the date the price was last updated.