distribution infrastructure and , with minor and very lowcost modifications , work seamlessly in existing appliances to deliver immediate reductions in GHG emissions — all at little to no additional cost to the consumer .
Combined with residential energy efficiency and weatherization , these fuels are substantially reducing GHG emissions in residential and commercial buildings and provide our small family businesses and their customers a pathway to achieve net-zero emissions . Furthermore , they can do so without costly conversions of their entire home heating systems to other fuels or energy sources .
The main goal of the CHS is to install heat pumps , not reduce GHG emissions . The CHS discussion draft openly admits the program is biased towards one specific fuel and technology . As stated therein , the objective of the CHS is not equitable reduction of greenhouse gas emissions , but rather “ electrification of the thermal sector .”
The MassDEP is misrepresenting the CHS as a marketdriven emissions reduction program , not unlike a Low Carbon Fuels Standard ( LCFS ) utilized by some west coast states or the successful federal Renewable Fuels Standard ( RFS ). Both programs utilize tradeable credits to reward strategies that reduce GHG emissions . However , the discussion draft says the intent of these credits under the proposed CHS is to encourage contractors to “ install clean electric heat pumps quickly and at the lowest possible cost to their customers ,” rather than reduce greenhouse gas emissions quickly and at the lowest possible cost to consumers .
The CHS is intentionally designed to discourage , if not outright prevent adoption of non-electric low or zero-carbon heating fuels and technologies in favor of air source heat pumps . The effect of this policy will be to restrict consumer choice and limit access to more immediate , practical , and costeffective options for GHG reduction . The proposed CHS will substantially increase the region ’ s demand for electricity that will continue to be generated by fossil fuels for the foreseeable future , especially during the winter .
Contrary to popular belief , electric heat pumps are not an emissions-free heating solution just because the on-site fuel source is not oil or gas . According to the Independent System Operators of New England ( ISO-NE ), fossil fuels continue to produce a majority of the region ’ s electricity , especially during periods of peak demand .
For example , on December 24 , 2022 , fuel oil alone generated nearly 30 % of the electricity across the six-states as temperatures in Massachusetts plummeted into the teens and natural gas was prioritized for residential space heating .
MassDEP must acknowledge that the source fuel for electric heat pumps is electricity generated by fossil fuels . This will continue to be the case until New England has resolved all major logistical and technological hurdles necessary and expended the enormous financial and political capital needed to ensure all the region ’ s electricity is generated by renewable sources . To be successful , any state climate program , especially one that aspires to be fair and market-based , must account for all lifecycle GHG emissions , including on-site and source emissions .
As for methods of measuring these emissions , we insist that the Commonwealth adopt Argonne National Laboratory ’ s GREET life-cycle analysis model , a well-tested and frequently updated method for measuring tailpipe and burner-tip emissions . The GREET model is utilized by governments , research institutions , businesses , and organizations across the world .
The proposed CHS is not “ equitable .” The discussion draft calls the CHS a “ regulatory option ” for reducing GHG emissions from residential , commercial and industrial sources , which is perceived by the agency as required under the Massachusetts Clean Energy and Climate Plan for 2025 and 2030 .
Despite the fact that a clean heat standard has never been implemented in the Commonwealth or by any other state , local , or territorial government in the United States , MassDEP has somehow determined it to be a “ practical and cost-effective policy tool to meet emissions reduction goals for the thermal sector ,” and further concludes that it can “ be implemented in a progressive , equitable manner consistent with the Commonwealth ’ s objectives for a timely and equitable transition .”
NEFI does not agree with this assertion and believes the CHS , as proposed in the discussion drafts , is neither fair nor equitable . First and foremost , the proposed CHS will unduly burden low- and moderate-income ( LMI ) households . Installation of a whole-home heat pump system is prohibitively expensive . An analysis of the 2014-2019 Massachusetts Whole-Home Air-Source Heat Pump Pilot Program found the cost for installing a heat pump system in a home with about 1,500 air-conditioned square feet was often well over $ 20,000 .
Adjusted for post-pandemic inflation , increased labor costs , and supply constraints in the HVAC sector , we estimate the total cost could exceed $ 30,000 . Costs continue to rise due to several factors which will take years and decades to resolve . These include the national shortfall of qualified professionals and their long and restrictive licensing requirements .
Even taking into consideration available tax credits and public and private rebate programs , homeowners will be saddled with substantial recovery costs of at least five figures , a significant cost burden for LMI households . These households are therefore likely to continue to utilize fuels and technologies that do not meet the requirements of the CHS , effectively making the program regressive .
Second , the CHS will significantly harm our independent Main Street energy businesses by forcing them to surrender their consumers to large private utilities , some of which are foreign-owned . In addition to compliance with stringent annual emissions reduction requirements , the discussion draft
12 JUNE 2023 | FUEL OIL NEWS | www . fueloilnews . com