VERMONT
VFDA DISSECTS PROPOSED AFFORDABLE HEAT ACT
“ This legislation requires heating fuel dealers to help their customers use less of the fuel they sell or else pay someone else to do it for them ,” Matt Cota wrote to members of the Vermont Fuel Dealers Association . “ The most qualified expert has calculated that it will add 70-cents to a gallon of heating oil , kerosene and propane ,” Cota added .
After testifying before the House Environment and Energy Committee on March 29 , Cota submitted a summary of his comments regarding the proposed bill , S . 5 . Cota , a consultant with Meadow Hill Consulting , testified on behalf of the VFDA . The following excerpt has been edited for space and clarity :
While a performance standard in the energy markets is not unique , it has never been attempted in the United States with regards to the distribution of heating oil , kerosene and propane . Determining what this program will cost and how it will be enforced is incredibly complex . [ Summarized here are some ] concerns about moving forward with this policy .
1 ) Point of Obligation : As the legislation is written , the obligated party is the entity that first takes title of the fuel when it enters Vermont for consumption . Whether or not a distributor of fuel is obligated and , as such , required by law to purchase or otherwise obtain clean heat credits has nothing to do with size . It does not matter if you sell 400 gallons or 40 million gallons . The “ obligation ” is wholly dependent on whether you own title of the fuel . Vermont has more than 100 “ obligated entities ” and 95 % of these “ entities ” are retail distributors , not wholesalers . And the vast majority of these distributors are small , locally owned fuel retailers . These are the people that live and work in rural Vermont , where the name on the side of the truck is the same as the person driving the truck or person answering the phone at 2 a . m . to respond to a service call . If S . 5 becomes law , these mom-and-pop businesses will be competing in a complicated credit market with some of the largest for-profit energy conglomerates and utilities operating in Vermont . The point of obligation should be moved up the supply chain . While this may be legally problematic if Vermont “ goes it alone ,” it would not be if this credit marketplace was a regional energy policy , much like the Regional Greenhouse Gas Initiative ( RGGI ) or the Transportation Climate Initiative ( TCI ). Vermont should not go it alone .
2 ) Restrict Obligated Gallons to Thermal Applications : Not all heating fuel sold in Vermont is used for heating . Propane , natural gas , kerosene , and # 2 fuel oil is used for power generation , manufacturing , and transportation . Natural gas and propane [ are ] used for cooking . The energy resource known as # 2 fuel oil ( ULSD / ULSHO ) is the energy that powers train engines , car ferries , skidders , feller-bunchers , cut-to-length wood processors , forwarders , delimbers , loader slashers , log loaders , whole-tree chippers , stationary screening systems , and firewood processors . Fuel oil ( dyed distillate ) powers thousands of vehicles that are exempt from the motor fuel excise tax , including school buses , plow trucks , bulldozers , and farm tractors . These sales are not insignificant . Vermonters consume approximately 200 million gallons of distillate fuel every year . Less than half ( 70 million gallons ) is used for residential heating .
3 ) Remove Kerosene or Provide More Choices for Savings Tony James , Dennis Percy and Rob Stenger are experts on the installation and performance of cold climate heat pumps . All three provided testimony on March 29 before the House Environment and Energy Committee that explained why these devices reduce consumption but fail to eliminate combustion heat in the vast majority of existing homes . While Vermont ’ s heating and cooling experts explained why a single head mini-split will not provide enough BTUs to heat the average home , there is also a tremendous amount of research in our neighboring states on the limitations and cost of heat pumps . An analysis of installations in Massachusetts from 2019 found that the average conversion cost was $ 21,572 . A similar 2 study by NYSERDA found the average cost of a whole-home heat pump installation in a single-family detached home in New York with the average square footage of 1,663 sq . ft . was $ 16,272 . However , as you heard from Vermont ’ s heating and cooling experts , the high 3 cost of conversion is not the only problem for Vermonters of modest incomes . Even if the installation , equipment and maintenance was free , there are certain homes in which combustion heat is necessary . The reliance on electric heat could cause significant structural damage to the more that 20,000 mobile homes in Vermont . Most mobile homes have 4 exposed water pipes running underneath and cannot rely on electric heat pumps which blows warm air from above . Lacking a basement , these homes require an outdoor tank and cannot utilize biodiesel . In many cases , the best recommendation to reduce greenhouse gas emissions and costs is to switch from kerosene to propane . S . 5 does not allow this energy saving , greenhouse gas saving and money saving approach to be counted as a credit . Please remove kerosene from the list of fuels that are obligated in order to protect low-income Vermonters from the escalating fees or allow kerosene to propane conversions to earn credit . l FON
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