I am writing to you in support of the Affordable Heat Act, currently under consideration in the Vermont House, having passed the Senate already as Senate Bill 5. It is often known as the Clean Heat Standard.

A great deal of incomplete or inaccurate information has been spread about this bill, some by fossil fuel interests whose business model appears to be threatened by passage of this bill, and some by well-intended environmentalists who believe the bill does not go far enough. I want to focus on just one aspect of the bill: the assignment of clean heat credits to various measures that are proposed to reduce greenhouse gas emissions from heating buildings. 

Section 8127 (d) has a list of eleven categories of measures that may be eligible for clean heat credits; and section 8127 (f) has further standards, that get tighter with time, saying that proposed liquid fuel measures won’t be eligible unless their carbon intensity meets certain levels, in comparison to fuel oil. This language does not mean that every proposed measure that fits into these lists automatically gets full heat credits. Instead, every proposed heat measure that is on the list in section (d), and (if a liquid fuel) meets the criteria in section (f), gets assessed by calculating a full life-cycle greenhouse gas emissions per unit of energy, taking into account all the factors that environmentalists wanted included. The amount of greenhouse gas that would have been emitted if the measure had not been implemented is also taken into account in this life-cycle calculation. Experience in other states suggests that dozens or hundreds of proposed clean heat measures will need to be assessed in this way.

So, if someone proposes to replace a fuel oil central heating system with an electric heat pump system, the amount of greenhouse gas reduction from before to after is calculated, using a life-cycle approach, and that is the value for the clean heat credit. It is pretty clear that there will be a net savings in greenhouse gases emitted in this scenario. 

More complicated is the scenario where a fuel oil central heating system would be replaced by an advanced wood heat system that burns wood chips or pellets. Some advocates have said that such proposals should simply not be on the list in section (d), and thus would never generate clean heat credits. The Clean Heat Standard relies on a calculation of the lifecycle greenhouse gas emissions of the advanced wood heat system, including impacts on stored forest carbon, in order to assign clean heat credits. If the advocates are right (as I think they are), that installing wood heat is not a good mechanism for reducing CO2 emissions, then the amounts of the clean heat credits for such a measure will be very small, or perhaps zero.

It is because every proposed measure to reduce greenhouse gases that come from heating buildings is subjected to this lifecycle analysis before credits are awarded, and the credits are proportional to the actual reductions in greenhouse gases, that I support this bill.

Note that this bill does not put any requirements on home- or building-owners: It is fossil fuel dealers and suppliers who will need the clean heat credits. They can generate them as a result of their own actions, or they can buy them from others. Since the clean heat credits will have market value, the effective price to home- or building-owners of buying and installing eligible clean heat measures is expected to go down. 

If this system is put in place, I hope and expect that the process of assigning clean heat credits to various categories of proposed clean heat measures will be done openly and transparently by the professional staff of the Public Service Commission and their contractors. People concerned about reducing our greenhouse production as much as possible will need to be alert, follow this process carefully, and use all the opportunities for public input.

On a related topic, I want to say that at our house we love our electric cold-climate heat pumps. They put out heat, and thus keep the house warm, down to an outside temperature of -18 degrees F, in actual experience. Temperatures colder than this typically happen one or two nights per winter in Middlebury — perhaps more often in mountain communities. While the heat pumps get less efficient at very cold temperatures — using more electricity per unit heat generated — they are still more efficient at their worst than fossil fuel heating systems are at their best. 

Richard S. Hopkins

Middlebury