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

New York bans fossil fuels in new builds beginning in 2026: Implications for hearth retailers are still unfolding

By: Darian Dyer

On May 2nd, New York State lawmakers approved their FY 2024 New York State Budget. Embedded in this budget is a historic provision to electrify buildings and homes on a state-wide basis. The provision designates New York as the first state to pass legislation banning the installation of fossil fuel equipment in new buildings. The mandate comes into effect in 2026, initially applying to shorter buildings and then expands to encompass all new construction by 2028. Prohibited appliances in new buildings include gas, oil and propane space heating systems, gas dryers and gas water heaters, among others.

The hearth industry in New York, and especially hearth retailers, will experience little impact until 2030, when a ban on fossil fuel equipment includes installations in existing homes. Until then, they will likely experience more demand for gas appliances and have time to diversify into heat pumps or other products and services. Gas installers and technicians will have work maintaining existing equipment after 2030, but that will gradually contract over the ensuing decades, while other types of hearth installations grow.

The hearth industry, represented by the Hearth, Patio and Barbecue Association (HPBA), sells appliances that use any and all fuel— gas, propane, electric, wood, and pellets. However, they are now doubling down in defense of gas, aligning with major oil and gas lobbies. HPBA’s position statement on its website says they believe, “it is critical to lower carbon emissions based on solid science and technology. Requiring communities to be all-electric does not achieve the intended reduction due to inefficiencies with generation, distribution, and lack of storage.” However, many HPBA members, including the Alliance for Green Heat, strongly support electrification and the increased use of modern wood and pellet heating as a proven pathway to reduce fossil fuel heat. AGH’s President, John Ackerly, said, “We urge the new CEO of HPBA to provide the leadership for the hearth industry to evolve and attract and retain a younger and more diverse workforce who can thrive in the future.”

Wood and pellet stoves are not impacted by the NY policy other than possibly benefitting retailers with greater wood and pellet appliances sales, as gas fireplaces are phased out. Indoor gas fireplaces appear to be the hearth product that will be most impacted, and it is still unclear if piped natural gas to outdoor barbecues, pool heaters, and hot tubs, for example, will face restrictions after 2030. Most experts think appliances using outdoor portable propane tanks, like barbecues, firepits, and outdoor fireplaces will not be impacted after 2030. Karen Arpino, Executive Director for the Northeast Hearth, Patio, and Barbecue Association’s Board of Directors, expressed reservations in that the law stands more as a symbolic rule rather than a law to really impact New York’s GHG emissions.

Almost all stove retailers sell to the existing home market. The industries to be affected by this law are new home builders and smaller retail businesses focused on supplying appliances to new construction. These will likely be the hardest hit if they don’t diversify their business to include heat pumps, for example. A stove retailer in Rochester, New York, was more concerned about the precedent for other states than the impact on their own business. They, like others interviewed for this article, are planning on “just riding it out.”

Hearth retailers have steadily expanded their product lines and many now focus
more on outdoor patio items, most of which will not be impacted at all by the New York law.

The New York law, as in many states, relies on changes to building codes to be implemented. Thus, it will be the state fire prevention and building code council that will provide clarification and exemptions that determine some of the critical gray areas for outdoor hearth gas and propane uses, as well as what kind of electrical appliances could be installed. The Alliance for Green Heat is urging jurisdictions to put guardrails on baseboard electrical heating, especially in lower income homes and apartments, as it is less expensive to install compared to heat pumps, but far more expensive to run.

The Alliance for Green Heat reached out to some of the primary advocates of the ban to see whether they knew how it would impact specific indoor and outdoor hearth appliances. The Alliance for a Green Economy’s Executive Director, Jessica Azulay, said that the gradual phasing out process of fossil fuels allows time for the industry to familiarize itself with the required technology, educate installers, and ramp up the production of electric appliances. Patrick McClellan, the Policy Director for the New York League of Conservation Voters, underscored the importance of the phased approach, but neither were sure how outdoor gas and propane appliances would be treated. However, they did suggest that outdoor appliances are not the target.

Hearth industry ramifications in other electrification policies

While New York is the first state to put electrification of new buildings into law, several other municipalities, most notably in California, have approved pro-electric energy and building codes. For instance, Brisbane’s city council voted to amend their building code to require new residential buildings to be all electric in 2019. Notable exceptions to the code include the ability for residences to still incorporate non-electric cooking appliances and fireplaces in new buildings. Oakland, CA, amended their municipal code in 2020 to require “all-electric construction in newly constructed buildings.” This ordinance did not restrict portable propane appliances for use outside of the building envelope, including outdoor cooking and heating appliances. Marin County, CA, passed a similar ordinance amending their building code in 2022, making an exception for portable propane appliances outside of the building envelope. These are only three examples from over 50 cities in California that have similar electrification requirements in their building and energy codes.

Low carbon electric heat and the grid

Much of New York’s ban on fossil fuel equipment installation has to do with space and water heating, even though gas stoves often get more attention. The shift to heat pumps and heat pump water heaters will initially run mostly on electricity made by fossil fuel, but their extremely high efficiencies still significantly reduce carbon impacts. Currently, nearly 60% of the state’s electricity is generated from natural gas, accounting for 46% of its utility-scale in-state generation. Achieving lower carbon emissions in New York relies heavily on rapidly decarbonizing the energy grid. New York has developed a plan to address this challenge. By 2030, 70% of the grid load will be met with renewables, with the goal of 100% of the grid being powered by renewables and zero-emission sources by 2040.

New York’s restrictions on fossil fuel installations target buildings, the largest source of greenhouse gasses in the state.

New York will face scrutiny on whether an unjust energy burden materializes for low-to-moderate income (LMI) households living in existing buildings and whether all-electricity stands as an affordable option for everyday consumers. To support LMI households during this transition, the New York legislature has approved $200 million to help weatherize and electrify low-income homes. In addition to this, the NY Home Energy Affordable Transition (HEAT) Act is in the works, hoping to lead an equitable, neighborhood-scale decarbonization effort. It is currently sitting in the Senate Energy and Telecommunications Committee. Still, some construction companies say that mandating electrification in new builds will increase construction prices, further pushing LMI families off of the housing market.

Opportunity for wood and pellet stoves

For those producing wood and pellet stoves though, there doesn’t seem to be an obvious downside. NEHPBA’s Karen Arpino had discussions with New York legislators and many were eager to work on legislation to promote wood stove change-out programs in the state. NYSERDA used to offer rebates for pellet stoves if a household turned in an old wood stove.

While 108,202 households heat primarily with wood (1.4%) in the state of New York, its use in rural counties is substantial, providing a significant level of low carbon energy resilience and diversification without adding further stress to the grid. For example, in Schoharie county, 15% of homes use wood as a primary heat source and 20% in Hamilton, with far more homes using it as a secondary heat source. Wood stoves provide homeowners more confidence to electrify, and they are likely to become more popular in electrified homes if it is cheaper than using a heat pump in the coldest weeks or months of the year. If the grid becomes even more unreliable in rural areas, wood stoves are an obvious back-up option and as solar and battery options grow, pellet stoves could also be a back-up heat source.

Are wood stoves the back-up heating solution in our electrified future?

With longer and more frequent power outages, back-up heat options are limited

By Darian Dyer and John Ackerly

Heat pumps are now the second most common heating appliance in the United States after natural gas furnaces, and the Biden Administration is heavily promoting them to decarbonize home heating. But power outages are also more frequent. According to the U.S. Energy Information Agency, the average American spent twice as long in the dark in 2021 as they did ten years ago. 

The electrification of heat has become a global solution to avoid the direct use of fossil fuel heat. 

For Americans in colder parts of the country, back-up heat is essential and wood stoves are already the second most common source of secondary heat in the U.S. - after electricity. “Wood stoves may become more popular as more homes switch to heat pumps,” speculates Tom Butcher, a Research Engineer at Brookhaven National Lab in New York, who is a leading expert on oil and wood heat. 

The availability of back-up heat is one of many barriers to households shifting to heat pumps and few heat sources don’t need electricity other than wood stoves. While wood stoves are common and practical in rural areas, they are by no means an obvious, or desirable, choice for many in suburban areas, much less urban ones. 

Severe weather events are more common

 

Ice storms inevitably lead to a surge of sales in wood stoves, and nowhere was this more evident than northern New York and the Montreal area when an ice storm was so bad it brought down long-distance transmission lines in 1998. In the recent past, a 2022 December winter storm racked up 1.6 million outages across the United States. In September of 2022, Hurricane Ian caused 2.78 million outages. In early 2021, Texas saw 4.4 million outages from a winter storm that revealed just how fraught our energy infrastructure is as rolling blackouts were instated and fossil fuel infrastructure froze over.

The North American Electric Reliability Corporation (NERC) concluded that a “large portion of the North American BPS (bulk power system) [was] at risk of insufficient electricity supplies during peak winter conditions” in their 2022-2023 Winter Reliability Assessment. Currently, almost all of the colder parts of the US are at an elevated or high risk of insufficient electric supply during the winter months. NERC also projected the growth rates of electricity peak demand and energy in North America will increase for the first time in recent years.

The U.S. electricity customer was without electricity for 7 hours on average in 2021. But the average number of power outages, and the average length of power outages per state does not make distinctions between rural and urban outages. Rural and suburban areas are more vulnerable to outages, especially in remote areas, and these outages are usually far longer than urban ones. Some areas measure power outages not in hours, but in days.

 

Seasonal weather events are annual occurrences that many expect to affect them at some point, particularly in their access to electricity, no matter what state or territory they live in. However, this threat is only heightened by the likelihood that climate change is increasing the frequency and intensity of extreme weather events. In addition to extreme weather events, two concerns loom over the U.S energy grid when it comes to supporting our electrical energy needs: aging infrastructure and limited transmission capacity

Back-up heat options

 

There are few good back-up heating options, especially low-carbon ones. Gas or propane fireplaces, or stoves, can work without electricity, as do indoor kerosene heaters. Even more common than wood stoves, but far less effective, is the traditional open fireplace which radiates heat to people right in front of it, but does little to warm the rest of the house. 

Wood stoves are an obvious choice for many (or their far more expensive cousin, the masonry heater, which is an effective whole-house solution if you can afford it). The other obvious choice for tens of millions of Americans is a back-up gas generator, which can cost as little as $500. Again, most gas generators aren’t powerful enough to run heat pumps but can run a pellet stove, or even a gas furnace.

Home batteries, like Tesla Powerwalls, and electric vehicle batteries that can be run in reverse to provide power to a home, open up more back-up heat options. But home batteries or EV car batteries can run out quickly and many only provide 2-8 hours of juice if connected to a heat pump. However, they can easily run a pellet stove for several days, or indefinitely if they are being recharged during the day with solar panels. (There are a few gravity fed pellet stoves on the market but they can be more finicky.)

The average pellet stove uses about 100 kWh per month- as much electricity as a refrigerator or a heat pump water heater. Geothermal heat pumps can use 3 or 4 times that much in a month.

Wood stove retailers see the writing on the wall and many are adding heat pumps to their businesses. One major stove manufacturer, Napoleon, is the first to market their own line of heat pumps. Pellet stove manufacturers could do a better job marketing and selling back-up batteries which are available for $100 - $200 and will automatically take over if the power goes out when you are not at home. 

 

The other major consideration is stress on the grid during winter peak load events, which are occurring more frequently. As more homes electrify their heat and their cars, some grids will be under tremendous stress during cold snaps. Back-up heaters could be used during cold snaps and utilities could also incentivize their use by raising electric rates when electricity supply is limited. In the coming decades, many homes will still have legacy gas, propane, and oil heaters for their back-up heat. Wood and pellet stoves would be an excellent heating technology to help avoid collapsing the grid and reduce fossil fuel usage. In places like Vermont and Maine, where a quarter or more homes have wood or pellet stoves, the grid is already benefiting from their use during cold snaps. 

A French study found that among single-family homes in 2020, with an estimated 7 million wood log and pellet appliances in France, domestic wood heating covered 24% of the heating needs. Moreover, it found that more than 70% of wood and pellet appliances were in use before the 7 p.m. peak electricity demand. Similarly in Vermont, if 70% of wood and pellet heaters were in use during peak electric demand, it would take a significant load off the grid, as more homes switch to heat pumps, according to a presentation made by Adam Sherman,  Advanced Wood Heat’s Role in Renewable Energy and Clean Heating Policy, at Brookhaven National Lab.

Longer power outages will be a part of the future for many if not most Americans in both colder and more moderate U.S. climactic zones. Planning for back-up heat is not just a task for homeowners but also policy-makers promoting greater electrification.