From the Director's Desk:

The Devil is in the Definition

Last week and earlier this week members of our organization and staff sat in on two subcommittee calls of the International Energy Conservation Code Consensus Committee, Residential as that committee considered revisions to its definition of ‘biomass’ and more specifically which types of ‘biomass’ qualify as a renewable energy resource within the context of the IECC. 

Specifically, the subcommittee is planning to consider a revised definition of biomass for inclusion in the International Energy Conservation Code. I do not pretend to have even an inkling about the impact of building codes or the International Energy Conservation Code but I have been around the industry long enough to know the definitions, lists of acceptable or not acceptable materials can become a bit like open-source HTML codes. They start to show up in a wide variety of disparate places, far from where they were originally intended. In fact, the existing definition of biomass waste within the IECC being considered for replacement comes from the U.S. Energy Information Administration. In this way, when new definitions are being considered for codification within codes, clauses, or federal regulation we are well-advised to pay close attention. 

Most troubling of all is the new definition of ‘biomass waste’ being considered by the IECC includes the following sentence:

Biomass waste includes municipal solid waste from biogenic sources, landfill gas, sludge waste, agricultural crop byproducts, straw, and other biomass solids, liquids, and biogases; but excludes wood and wood-derived fuels (including black liquor), biofuel, feedstock, biodiesel, and fuel ethanol.

Even when considering this definition through the lens of the limited reach of the IECC on new construction and energy sources applicability and qualification as a trade-off for energy efficiency measures not deployed in a building, that definition should trouble anyone in our industry, anyone making renewable heating oil (sometimes called bio-heat) and fuel ethanol. 

So, why the move to exclude these sources?

In the documents circulated before the meeting the IECC’s reason statement says, “Without an available standard to cite in the IECC for sustainable biomass, it is critical to ensure that biomass used in compliance with the IECC s derived from waste products or byproducts.”

Earlier in the same reasoning statement, the point is sharpened further by stating, “…this proposal ensures that virgin material of unknown origin does not count as a renewable energy resource”.  

Suffice it to say, these proposals have gotten the attention of almost everyone within the biomass category largely because the statements represent a significant departure from the value proposition of almost every biomass-to-energy technology and the ambitions and hopes that many have for our industry’s future. 

Consider for a moment the U.S. Forest Service and the cyclical disaster they face during every wildfire season as national forests with extreme fuel loading problems combust and destroy tens of thousands of acres, homes, businesses, and sometimes, regrettably, human lives. The PFI and our colleagues at the Biomass Thermal Energy Council and the Biomass Power Association regularly participate in phone calls with staff from the U.S. Forest Service to imagine how our varied sectors might help in reducing dangerous fuel loading in our nation’s forests. These ambitions already face headwinds as renewable fuel manufacturers utilizing fiber from national forests are largely locked out of the Renewable Fuels Standard. This new definition would simply be one more impediment to our industry’s potential contributions to solving a very real threat to our national forests. 

Considering just this instance, is anyone really ready to standby the assertion that the virgin fiber overloading western forests and burning (in an uncontrolled, massive release of CO2) each fire system should be codified as forever off-limits as a renewable energy resource within the pages of the International Energy Conservation Code? I would hope not. 

Full disclosure, this commentary was written before the committee heard and discussed these definitions. Expect a full briefing in the next issue of the Pellet Wire and expect the PFI to closely monitor and when possible contribute to this important conversation about what biomass is, the role it plays in the wood products and forest health categories, and why it is vital we are not carelessly excluded from definitions of ‘biomass’ wherever they may be found.