Author: Joe Uglietto
As Massachusetts and Vermont get ever closer to the launch of their Clean Heat Standards, it’s easy to forget that other states are working on programs that aim to accomplish the same goals. What we’ve said all along is coming to pass, that as one state adopts a program, the likelihood that other states will follow only increases. This is an industry-wide issue that all dealers will eventually be required to be prepared for. In this article of Renewable Energy Insights, we’ll take a look at what’s happening in the Mid-Atlantic States, specifically in New Jersey and New York.

The Garden State

Since the start of New Jersey’s most recent legislative session, two “copycat” bills were introduced that closely mirror similar legislation in other states. On January 29th, S2425 was introduced. This Low-Carbon Transportation Fuel Standard Bill is based heavily on California, Oregon, and Washington State legislation, and regulates the carbon intensity of transportation fuels (both diesel fuel and gasoline). New Jersey’s proposed legislation sets an emissions reduction target for the transportation sector of 10% below 1990 levels by 2030.

Just a few days later, A3374 was introduced in the State Assembly. This piece of legislation would establish a Clean Heat Standard similar to the early drafts of the Vermont and Massachusetts Clean Heat Standards. It places a compliance obligation on heating oil and propane retailers, natural gas utilities, and electric utilities, requiring the obligated parties to reduce the carbon intensity of the heating fuel that they sell or sell less of it. If they do not, they will be required to purchase credits in an open market.

The significant concern in New Jersey – as it has been in states with similar programs – is these bills will substantially increase the cost of energy and transportation for consumers in New Jersey.

The Empire State

New York’s Cap-and-Invest Program is in the rulemaking process and the program details are still being developed, but new design aspects could hurt businesses and obstruct legitimate carbon reduction.

The “Cap-and-Invest” program is an economy wide cap on emissions, with the goal of reducing emissions across all sectors in New York. This type of program holds auctions, where companies must purchase allowances –where an allowance is measured in metric tons of carbon dioxide – to continue their business operations. Recently, NYSERDA introduced an additional auction to be held towards the end of each compliance year. This auction will allow obligated parties to purchase additional allowances if necessary to meet compliance. As of now, there will not be a set number of allowances that will be auctioned off and all allowances that are demanded will be supplied. Conceivably, a company could decide not to reduce emissions at all and simply continue to buy allowances to remain in compliance. If this change is included in the final regulation, it would essentially turn what was ostensibly a program to reduce emissions into a program that would serve as a cost increase on businesses with no certainty regarding the emissions reductions it would achieve.

We can expect 2024 to be an extremely active year in terms of new legislation, new rules to developing programs and the movement towards the implementation dates on Vermont and Massachusetts’ Clean Heat Standards. Diversified Energy Specialists will continue to keep retailers, wholesalers, and industry stakeholders abreast of the various regulatory programs and their rule-making processes in the weeks and months ahead. If you’d like to join our email list to receive our updates, email me at joe@diversifiedenergyspecialists.com.

Renewable Energy Insights is a regular column by Joe Uglietto, president of Diversified Energy Specialists, a leader in the renewable energy markets and consultant to the industry with a focus around emissions reductions and renewable energy innovation.

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— Ed Scott, General Manager, Scott Energy

Author: Joe Uglietto
Right before Thanksgiving, the Massachusetts Department of Environmental Protection released the Draft Framework for the state’s Clean Heat Standard (CHS). While the draft CHS represents a significant departure from the original concept, the implications for all other Northeast and Mid-Atlantic states remain. As I noted in my previous Renewable Energy Insights article, Governors from 8 different Northeast and Mid-Atlantic States have committed to exploring the possibility of a Clean Heat Standard. Additionally, Vermont has passed a Clean Heat Standard into law and New Jersey issued an executive order in early 2023 to create a Clean Heat Standard. All eyes remain on Massachusetts, and it is likely that programs in other states will closely mirror the final framework implemented in the Bay State.

What You Need to Know about the Mass Clean Heat Standard

First and foremost, the draft CHS calls for the program to be implemented starting in 2026. This is a year later than the original plan. Perhaps the largest change from the initial concept to the draft framework is in the creation of two obligations instead of just one. The draft framework calls for the creation of two different markets with tradeable credits. Both markets will have the same obligated parties – heating oil and propane retailers, natural gas and electric utilities – which will complicate the compliance process for all.

The first market created under the CHS is the Emission Reduction Standard. This standard requires that all heating oil and propane retailers, and natural gas utilities reduce the amount of carbon they sell each year by a set percentage. The amount of carbon reduction required each year is 1 million metric tons. That equates to roughly 4.5% of the estimated carbon emissions from the heating of buildings in Massachusetts. For heating oil and propane retailers to meet compliance, they must sell less fuel, generate Emission Reduction Credits, purchase Emission Reduction Credits in the open market, or pay the Alternative Compliance Payment Price, which is set at $190 per metric ton of CO2e. There are only two ways for stakeholders to generate credits in the Emission Reduction Standard. The first is by selling biodiesel. If a heating oil retailer sells biodiesel to its customers, the retailer will generate Emission Reduction Credits that can be used to meet compliance or can be sold in the market for a profit. The second way to generate Emission Reduction Credits is by installing heat pumps. Credits for heat pumps will be given to the end user, but the installer can enter into a contract with the end user to retain possession of the Emission Reduction Credits.

The second market created under the CHS is the Full Electrification Standard. Retailers of heating oil and propane, and the natural gas and electric utilities will be obligated to convert a specified number of homes each year to electric heat pumps. The overall obligation across the state will be 20,000 fully electrified homes in 2026, increasing by 20,000 per year, resulting in 100,000 in 2030 and each year after. If the obligated parties do not electrify the specified number of residences to meet their compliance requirement, they must purchase Full Electrification Credits or pay the Alternative Compliance Payment Price, which will begin at $6,000 per home and increase to $10,000 per home in 2030. Additionally, 25% of Full Electrification Credits must come from low-income households. Full Electrification Credits from low-income households will have an Alternative Compliance Payment Price of $12,000 in 2026, increasing to $20,000 in 2030.

Since this is a draft framework, the pieces are still moving. As of this writing, the DEP is taking comments and I am deeply engaged in providing input on behalf of the industry. What is certain is that there will be a whole new world in Massachusetts in just a few years. And while it may be scary for some, heating oil retailers will have a pathway to success and profitability through the blending and distribution of biodiesel. For those of you who operate in Massachusetts, I encourage you to stay up to date on the CHS and become engaged in the process. For those of you who operate in other New England or Mid-Atlantic states, it is critical that you view Massachusetts as the canary in the coal mine. This CHS (or something like it) will most likely be coming to your state soon.

Diversified Energy Specialists will be keeping retailers, wholesalers, and industry stakeholders abreast of the various programs and their rule-making processes in the weeks and months ahead. If you’d like to join our email list to receive our updates, email me at joe@diversifiedenergyspecialists.com.

Renewable Energy Insights is a regular column by Joe Uglietto, president of Diversified Energy Specialists, a leader in the renewable energy markets and consultant to the industry with a focus around emissions reductions and renewable energy innovation.

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Hear what our clients have to say about us

“Diversified Energy Specialists has made participation in the APS program a home run for our company. They seamlessly handle the process from applications through selling our AECs. Any APS dealer would benefit from DES’s expertise!”

— Ed Scott, General Manager, Scott Energy

Author: Joe Uglietto
The U.S. Climate Alliance – a group of 25 governors from across the country committed to achieving a net-zero carbon future – met recently during Climate Week NYC. The Alliance pledged to install at least 20 million heat pumps by 2023 with a goal of ensuring that at least 40% of any benefits of these actions would flow to disadvantaged communities. The pledge would effectively quadruple the number of electric heat pumps in use across the Alliance states. Viewed through a narrow lens, it would be easy to conclude that the Alliance’s new pledge is a continuation of the same goal – wholesale electrification – without addressing any of the inherent challenges; electric grid overload, winter peak demand issues, price and cost concerns.

But there was an additional commitment made that would be potentially transformative for our industry and one that stakeholders will need to be made aware of. Governors from Connecticut, Maryland, New York, Pennsylvania and Rhode Island committed to exploring the development of Clean Heat Standards as a means to affect the transition to a net-zero carbon future. Add to that New Jersey which is developing a CHS to comply with an Executive Order from their governor, Vermont which enacted a CHS into law and is in the rulemaking process, and Massachusetts which is currently in the rulemaking process of their own CHS through their Department of Environmental Protection. Taken together, we have eight New England and Mid-Atlantic states that have publicly announced they are considering the creation of a Clean Heat Standard as a regulatory policy to reduce GHG’s from the building sector. That’s almost the entire heating oil industry, not just “super progressive” Vermont or Massachusetts.

What will this mean for our industry? For starters, this will put even more pressure on the states that are currently developing Clean Heat Standards. The early adopters – VT and MA – will likely serve as the guinea pigs and other states will follow their lead when developing their own CHS. As our industry works to support the development of Clean Heat Standards that allow renewable Bioheat® fuel, renewable propane and even renewable natural gas, it will become that much more critical to be treated fairly within these programs.

What needs to be done now? Dealers and stakeholders in our industry must engage in the process. Submit comments during open comment periods. Attend hearings and give voice to your concerns. Donate to the efforts underway in your state to influence the process. Communicate with your customers at the appropriate time to get involved and ensure support for fuel-neutral rules and incentives for all renewable thermal technologies and not just heat pumps.

It might feel like our industry has been dealing with these challenges for years, but I’m here to tell you this is just the beginning. And it’s going to take a mountain of effort from everyone who has a stake in our industry to ensure a positive outcome.

nd industry stakeholders abreast of the various programs and their rule-making processes in the weeks and months ahead. If you’d like to join our email list to receive our updates, email me at joe@diversifiedenergyspecialists.com.

Renewable Energy Insights is a regular column by Joe Uglietto, president of Diversified Energy Specialists, a leader in the renewable energy markets and consultant to the industry with a focus around emissions reductions and renewable energy innovation.

Ready for a consultation? Contact us today!

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Hear what our clients have to say about us

“We’ve worked with Diversified Energy Specialists since the inception of the Massachusetts APS program and we couldn’t be happier with our decision. Joe’s excellent understanding of the program and superb administrative support makes the process very easy for us. He has consistently secured strong returns on our energy credits, and he’s a heck of a good guy on top of it all.”

— Jim Townsend, President & CEO, Townsend Energy

Author: Joe Uglietto
State regulators are quickly approaching a fork in the road when it comes to developing Clean Heat Standards and compliance markets. They will either choose the pathway that is based on pure fantasy, and although politically rewarding will be doomed to fail. Or they’ll choose a pathway that is rooted in science, that is realistic and that can achieve carbon reduction targets without destroying industries in the process.

The MA Department of Environmental Protection (DEP) is at that point as I write this. In the first discussion document of the CHS Program, the DEP would mandate that all heating fuel suppliers convert 3% of their customer base annually to expensive air-source heat pumps or face a large fine. In this scenario, whether the customer wants to switch to heat pumps or not is irrelevant. Building upon this fantasy, the DEP has also considered treating electricity as carbon-neutral. The fuel used to power our electric grid would be irrelevant and all electricity would be considered to be renewable. This despite the reality that more than half of winter electric generation would continue to come from natural gas. And to cap off this make-believe scenario that could potentially become all too real, heating fuel suppliers would be required to either reduce the carbon intensity of their fuel or lower their sales by 29% in 2025 and by 49% in 2030. There would be no time built-in for capital investment or to affect a transition as was afforded to the power and transportation sectors.

The problems with a fantasy approach like this are myriad. Tracking fuel from out of state, regulating out of state entities, accurately carbon-scoring each fuel and a large compliance obligation in year one are just a few issues that come to mind. Not to mention the harm brought to the end-user or consumer. They will bear the financial burden of these programs and they’ll be stripped of the ability to choose how best to heat and cool their home.

It is absolutely a possibility that science and reason will lose out. But this story is far from over. DES – along with other stakeholders like the Massachusetts Energy Marketers Association and individual fuel dealers – has been deeply engaged in the process. It will be critical that the industry continues to shine a light on the deeply negative outcomes brought about by “fantasy-land” plans. Only then can we convince regulators that the greatest promise for effective Clean Heat Standards are ones that embrace reality.

Renewable Energy Insights is a regular column by Joe Uglietto, president of Diversified Energy Specialists, a leader in the renewable energy markets and consultant to the industry with a focus around emissions reductions and renewable energy innovation.

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Hear what our clients have to say about us

“Joe has been assisting us with our DOER report for four years. His attention to detail and understanding of the bioheat marketplace have been invaluable to us. I highly recommend and trust this talented guy in navigating this tricky and confusing area of the heating oil business.”

— Brad Surner, Business Development Manager, Surner Heating Company

Author: Joe Uglietto
Our industry has to deal with enormous threats to its existence each and every day. Many of us have gotten used to the usual suspects…state legislatures considering electrification mandates, clean heat standards that regulate all heating fuels, EV and electric equipment incentives to entice our customers to make the switch. But another approach is gaining steam and will add to the squeeze should it become commonplace. This new-ish threat comes to us in the form of Building Performance Standards.

A Building Performance Standard is yet another attempt to regulate emissions, deployed primarily at the state and local levels. Colorado, Maryland and Washington have already enacted Building Performance Standards. Boston, New York City and Washington, D.C. have joined the party at the local level. And Cambridge, MA is expected to enact its own Building Performance Standard later this year.

The goal of a Building Performance Standard is to reduce emissions in commercial and industrial buildings. A worthy goal to be sure. But as with the rest of the electrification plans that fit into the “nice idea, not so nice results” category, the devil – and the cost – is always in the details. Let’s take a look at a local example, that of Boston’s Building Performance Standard.

Building Emissions Reduction and Disclosure Ordinance (BERDO) is Boston’s recently enacted standard. BERDO sets requirements for all qualifying large building within the city limits to reduce their greenhouse gas emissions gradually, with a goal of net zero by 2050. Buildings larger than 20,000 square feet or with 15 or more individual dwelling units are required to reduce their carbon footprint on an annual basis. All buildings must be carbon neutral by 2050, but the annual reduction requirements range based on the building use. Healthcare facilities, universities, multifamily housing, manufacturing/industrial, and all other building uses will have different reduction requirements. All qualifying buildings will be required to report their emissions on an annual basis to the state. The entire carbon footprint of the building is measured; electricity, heating, hot water, and any other activity that produces greenhouse gas emissions. If a building does not reduce its emissions by the required amount each year, Renewable Energy Credits (RECs) will need to be purchased or the building owner will be required to pay a fine in the form of an Alternative Compliance Payment (ACP) per ton of carbon dioxide emitted above the requirement. Unfortunately for these buildings, there is no incentive for reducing emissions beyond the minimum requirement.

As we have seen in virtually every state that has attempted to adopt narrow policies or regulations to force electrification on its consumers and businesses, the unintended – and in some cases, intended – consequences will be significant. Building owners will incur increased costs whether they are actively complying with the standard or paying for RECs or fines. In either case, operating costs will increase, rent will increase and consumers will bear the brunt of these regulations.

Building Performance Standards are just another example in a long line of legislative and regulatory threats to our industry that will squeeze our businesses, impact consumers and have a negligible impact on reducing emissions. It will be critical that we remain vigilant as individual business leaders and as an industry to vocally oppose these kinds of harmful and poorly thought-out regulations anywhere and everywhere we can.

Renewable Energy Insights is a regular column by Joe Uglietto, president of Diversified Energy Specialists, a leader in the renewable energy markets and consultant to the industry with a focus around emissions reductions and renewable energy innovation.

Ready for a consultation? Contact us today!

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Hear what our clients have to say about us

“Diversified Energy Specialists has made participation in the APS program a home run for our company. They seamlessly handle the process from applications through selling our AECs. Any APS dealer would benefit from DES’s expertise!”

— Ed Scott, General Manager, Scott Energy

Author: Joe Uglietto

The energy industry is undergoing an enormous transition and the number of states that are considering regulatory programs to achieve their carbon-reduction targets is growing by the week. Over the next few years, heating oil, propane and natural gas companies across the Northeast and Mid-Atlantic will be dealing with increasing requirements to reduce their carbon impact. We can expect these new regulations will affect the price of our products and the day-to-day operations of how nearly every energy company conducts its business. Here’s a quick snapshot of what’s on the table around the region.

Massachusetts recently released a Clean Heat Standard (CHS) discussion document and straw proposal, with the goal of implementing a CHS by the beginning of 2024. A Clean Heat Standard is a market-based regulatory program that would require heating fuel companies to reduce the carbon intensity of their fuel by a certain percentage each year, typically aligning with the state’s greenhouse gas reduction goals. If these companies reduce the carbon intensity of their fuel by more than the goal each year, by blending biodiesel or other renewable fuels, they will generate credits that can be sold in the market for a profit. If these heating fuel companies do not reduce the carbon intensity of their fuel by the goal each year, they will be required to purchase credits in the market to meet the compliance requirements within the program.

Legislation for a Clean Heat Standard in Vermont was passed by the VT House in March and is likely to be voted on in the VT Senate in April. In New Jersey, Governor Murphy issued an Executive Order that required the Board of Public Utilities to conduct an 18-month study on the adoption of a Clean Heat Standard. Maryland has hired the Regulatory Assistance Project, the consulting firm that is helping design the Clean Heat Standards in Massachusetts and Vermont, to provide guidance in meeting their greenhouse gas reduction goals. Pennsylvania and New York are considering Clean Fuel Standards, which are transportation-focused regulatory programs aimed at achieving carbon reduction. Both states are considering including heating fuels as well.

Additionally in New York, there is a strong push to implement an economy-wide “Cap-and-Invest” program, which will cap the greenhouse gas emissions that businesses and facilities can produce each year. These businesses will have to purchase allowances at auction for the right to continue operating their business. A Washington Post article in April estimated that New York’s “Cap-and-Invest” will increase the cost of transportation fuels by 61% and increase the cost of heating a home by 80%. It remains to be seen whether the cost impact will deter or slow down the move to adopt such an impactful program.

While many of these programs are not yet finalized – either because details are still being worked out, or legislation has not yet passed to establish them – it is virtually certain that our industry will be dealing with these kinds of programs in short order. The first step for fuel companies is to recognize and embrace that change is coming, and in ways that are likely to squeeze your business. The second step is to prepare for this eventuality by developing a clear-eyed strategy to succeed in this new regulatory environment.

There will be companies that take full advantage of the new regulations in their states. Make sure that your company is one of them.

Renewable Energy Insights is a regular column by Joe Uglietto, president of Diversified Energy Specialists, a leader in the renewable energy markets and consultant to the industry with a focus around emissions reductions and renewable energy innovation.

Ready for a consultation? Contact us today!

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Hear what our clients have to say about us

“Joe has been assisting us with our DOER report for four years. His attention to detail and understanding of the bioheat marketplace have been invaluable to us. I highly recommend and trust this talented guy in navigating this tricky and confusing area of the heating oil business.”

— Brad Surner, Business Development Manager, Surner Heating Company

Author: Joe Uglietto

“Electrify Everything” is gaining ground at the federal level and in many Northeast states. Heat pump incentives, clean energy tax credits and legislation to ban fossil fuels are all on the table in some shape or form. And in states like Massachusetts and Vermont, policies to create new Clean Heat Standards have either passed or are likely to pass in the coming months.

A key driver of the electrification movement in 2023 – and likely for a number of years into the future – is the Inflation Reduction Act (IRA). The recently passed IRA will provide incentives for homeowners to install electric heat pumps that are substantially higher than what has been offered in the past. Rebates for low-income households can reach up to $14,000 for an air-source heat pump system. These rebates will make converting to heat pumps financially competitive in comparison to the installation of new, higher efficiency heating oil, propane and natural gas systems.

Additionally, a number of Northeast states have earmarked millions of dollars of IRA funds for broad-based consumer education campaigns to promote heat pumps and improve perceptions of heat pumps and heat pump technology among the public. The use of IRA funds for consumer outreach and education is in response to the relatively slow adoption of heat pumps thus far. Massachusetts provides an excellent example; the state set a goal of installing 100,000 heat pumps each beginning in 2020 with the ultimate goal of 1,000,000 heat pump installations completed by 2030. According to reporting conducted by the Boston Globe, 2020 heat pump installations totaled 461.

But the slow adoption of heat pumps hasn’t given advocates of electrification pause about the merits of wholesale electrification. It’s simply driven them to double down. The “carrot” of rebates and incentives will likely give way to the “stick” in the form of attempted fossil fuel bans and clean heat standards. A state-by-state clean heat standard would require the heating oil, natural gas, and propane industries to reduce the carbon intensity of their fuel, sell less of their fuel, or pay others to reduce the carbon intensity from heating technologies. Clean heat standards would increase the cost of energy and further incentivize the installation of cold-climate air-source heat pumps.

It is crucial that every stakeholder in the industry prepare for a future that completely embraces renewable liquid heating fuels; a future of clean heat standards and carbon-reduction; and a future that will require a strategic and forceful response in the form of political advocacy and consumer outreach.
Our future is bright. And our industry is poised to play a leading role in the reduction of carbon so long as we aren’t legislated out of business in the process.

Renewable Energy Insights is a regular column by Joe Uglietto, president of Diversified Energy Specialists, a leader in the renewable energy markets and consultant to the industry with a focus around emissions reductions and renewable energy innovation.

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Hear what our clients have to say about us

“I can’t say enough good things about Joe Uglietto and the work that Diversified Energy Specialists has done for us. Joe took care of everything for us at the outset of the APS program. He got us registered, he did the paperwork. He made the process seamless. Best part is, his strategy delivered higher value for my energy credits than I expected, and the returns have been strong each and every year. There’s no one better to help you get the most out of energy credit programs like the APS.”

— Mike Lamparelli, Owner, Frank Lamparelli

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Hear what our clients have to say about us

“Joe has been assisting us with our DOER report for four years. His attention to detail and understanding of the bioheat marketplace have been invaluable to us. I highly recommend and trust this talented guy in navigating this tricky and confusing area of the heating oil business.”

— Brad Surner, Business Development Manager, Surner Heating Company