Wood pellet data is vital to understand contribution of pellet heating in America

 The Alliance for Green Heat submitted a public comment on the EIA's Densified Biomass Fuel Report earlier today. The EIA was gathering comments on a proposed three-year extension on the report along with specific questions on its function and use.

"The Alliance for Green Heat (AGH) would first like to thank the U.S. Energy Information Administration (EIA) and the Department of Energy (DOE) for giving the public an opportunity to submit comments on the proposed three-year extension to Form EIA-63C, “Densified Biomass Fuel Report.” As a national nonprofit that advocates for the reduction of fossil fuel heating through the responsible and sustainable use of wood and pellet heat, we are deeply invested in the outcome of the EIA and DOE’s decision to continue to collect data on pellets.

Summary: The EIA does not need to collect more information from pellet manufacturers. However, it does need to publicly release much more of the information it is gathering.

It is important for policymakers, environmental organizations, and the public to have a far more accurate understanding of the differences between how utility pellets are made, how premium heating pellets are made, and the carbon impacts of how they are used. Utility pellets have biodiversity, equity, and carbon impacts that are more serious than premium heating pellets based on their feedstock, the size and location of their manufacturing plants, and the enormous amount of waste heat that is lost when making electricity. Data gathered by the EIA provides some of the underlying metrics to understand those different impacts.

Wood pellets are an excellent low-carbon heating fuel for homes, businesses, and institutions. They will likely become an even greater complement to heat pumps in the future, based on the different pros and cons of each heating pathway as our energy grid seeks to keep up with increasing electric demand. Wood pellet production and use are also extremely important for better understanding air quality and whether states and air quality agencies have been able to increase the percentage of pellet stoves compared to wood stoves. Also, EIA data from their housing survey, part of the Residential Energy Consumption Survey, shows that wood pellets serve many very low-income homes. The 2020 data shows the income bracket with the highest reliance on pellet stoves compared to wood stoves is the $10,000 - $19,000 household income bracket. This makes wood pellets very relevant to the energy equity community.

Our industry and stakeholders have become used to seeing top-level data such as the wood pellet production capacity by region, overall production of heating vs. utility pellets, and domestic vs. foreign pellets. But to really appreciate the various roles this industry plays in providing renewable heating in America, we should all be versed in more granular detail.

For example, it is very important for government agencies, pellet stove manufacturers, pellet fuel distributors, retailers, and consumers to know the volume of:

• PFI certified domestic heating pellets made year-by-year,

• Non-PFI certified pellets made year-by-year if the percentage of bagged vs. bulk domestic heating pellets is trending up or down,

• Utility pellets used domestically,

• ENPlus A1 or A2 bulk heating pellets are made in the US (these would likely be bagged in Europe for residential distribution), and

• Compressed bricks, compressed logs, and briquettes made, year-by-year.

The EIA could also provide more detail about where wood comes from. It provides summary, top-level data, but we believe there is more data available that does not infringe on confidentiality.

A breakdown by state also tells an important story of pellet production in the United States. North Carolina, the top producer of industrial pellets for export, makes nearly as many pellets as the bottom 20 states combined - which produce heating pellets.

Response to EIA questions:

1. In response to the invitation to comment on the following statement: “(a) The proposed collection of information is necessary for the proper performance of agency functions, including whether the information will have a practical utility,” AGH would like to highlight the value that the Densified Biomass Fuel Report provides to hundreds of stakeholders in the renewable energy space who need this information to assess the capacity of this sector. The data provided through the reports helps track trends in pellet production and increases the ability to produce accurate, science- based assessments on pellet heating. Without the Fuel Report, organizations would lose one of their most reliable and unbiased information sources on pellet data.

In the energy transition landscape that our nation is currently undertaking, being able to account for, and have accurate information on, all forms of renewable energy is paramount. If our nation’s leading agency on energy information is missing data and research on a large, mainstream, and established renewable energy source like biomass, the agency is failing to carry out its mission.

2. In response to the invitation to comment on the following statement: “(c) EIA can improve the quality, utility, and clarity of the information it will collect,” AGH would like to suggest that the EIA publish more of the data that it collects. Assuming no confidentiality conflicts, we believe publishing all gathered “Product Type” information is essential (e.g. amount of “Wood Pellets Premium (PFI certified) Bagged,” Wood Pellets Premium (PFI certified) Bulk”, etc.). Similarly, publishing data on “FeedStock Type” (e.g. “Roundwood,” “Sawdust,” “Waste Wood,” etc.) would be helpful when explaining to policymakers and the public the different supply chains in the pellet industry. This is particularly important for policymakers and the public to differentiate how heating vs. utility pellets are made. This would also provide industry and organizations with a clearer vision of the current capacity of biomass for heating, helping provide decision- makers with valid, data-driven information. Because this information is already gathered in the monthly reports, this would not add any time burdens on the pellet manufacturing companies.

Wood is a diverse and vital renewable energy source for America. Many Americans do not seem to know that up until 2015, wood produced more renewable energy than any other renewable source. Since 2016, biofuels have been the top producer, but the intensive process of converting solid biomass to biofuels sharply reduces its carbon benefits.

Many Americans may also be surprised that wood still produces more renewable energy than hydroelectric solar and geothermal combined. As recently as 2015, wood produced more energy than hydroelectric, solar, geothermal, and wind combined. It is a vital part of America’s transition to renewable energy to know that the use of wood as a renewable energy has been relatively stable but shrinking since 1985, and the amount of solar and wind energy has been rapidly growing. Part of this story is understanding and managing all the different feedstocks that go into wood energy - mainly pellets, wood chips, and wood logs.

The EIA can do a better job using the data that it collects from pellet manufacturers to tell a more detailed story about wood pellets made in America and pellet heating in America."

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. " 

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.”"