Donna Leban, AIA, member of the AIAVT Public Policy Committee (PPC)

The Clean Heat Standard proposal debated by the legislature in 2022 was developed over the course of a year by Vermont-based energy consultants and stakeholders, spearheaded by the Energy Action Network.  Implementing the Clean Heat Standard as envisioned by this working group was a key recommendation in Vermont’s Climate Action Plan. 

While Clean Energy Standards exist in Colorado and Oregon, in those states they apply only to regulated gas utilities and transportation fuels.   As proposed in Vermont, it would apply to non-regulated fuel oil and propane suppliers as well as Vermont Gas Systems but not to gasoline distributors.   

How would a Clean Heat Standard work in Vermont, as described by the Energy Action Network?    Additionally, how does it need to be amended to address fuel choice in new construction, which is not addressed by the Residential or Commercial Building Energy Standards (RBES and CBES)?

1. The intent of a Clean Heat Standard is to reduce climate pollution from fossil fuel heating, which makes up more than 1/3 of Vermont’s greenhouse gas emissions.  The prevalence of oil and propane heating systems in Vermont’s existing buildings means that a large percentage of the savings will have to come from buildings not served by a regulated utility.
2. Saving money on energy costs is addressed through the Clean Heat Standard by requiring fuel suppliers to provide services and incentives for customers to switch from high-cost, price-volatile fossil fuels like propane and fuel oil to lower-cost, more price-stable clean heating options like heat pumps, heat pump water heaters, and advanced wood heat.   Heating fuel expenses currently make up over a third of Vermonters’ energy costs.  This proposal aims to reduce the cost of heating, especially for lower and middle-income households who currently face a disproportionately large “energy burden”.  
3. Fossil fuel corporations(ie, companies that import fossil fuels for sale in Vermont)will be required by the Public Service Board to provide cleaner heating options and/or to pay for pollution reduction measures.  Fuel companies would likely promote biofuels that can with modifications utilize the existing heating equipment. However, they could also contract directly with companies able to provide weatherization and/or heating system modifications.  Or, they could pay a fee to the state, which may in turn help fund the efficiency utility or other program providers.  Or, as some fear, they may stop serving customers in Vermont.
4. Vermonters will be enabled to voluntarily choose whether to switch to cleaner heating options and if so, the Clean Heat Standard would provide flexibility in deciding which options are right for them.   Heating fuel choices for new buildings are generally made by building owners, their engineers, or contractors without input from fuel distributors, so it is unclear how this would affect heating fuel choices in new construction or major renovation.  It would benefit architects and engineers to have carbon-reduction measures addressed in enforceable building codes so that fossil fuel systems are not being installed that further add to Vermont’s carbon dioxide pollution.  This is not currently the case, but must immediately become part of the discussion.
5. Adopting a Clean Heat Standard as well as addressing heating fuel choices in new construction will together achieve significant pollution reduction over time.  Emissions reductions would be tracked with transparent lifecycle greenhouse gas accounting.  This approach will require new state regulatory and tracking systems to be created over a period of time.  

See the full Clean Heat Standard white paper at www.eanvt.org/events-and-initiatives/clean-heatstandard  

The Scott Administration is looking into alternatives to the Clean Heat Standard as proposed.  Some of these options may help address the market forces that currently encourage building owners and contractors to continue to install fossil fuel heating systems.  An RFP has been issued at the end of September by the Director of the Climate Action Office, Jane Lazorchak, Agency of Natural Resources to evaluate the following policy and/or regulatory approaches to fossil fuel reduction in building heating systems.  Multiple program options or variations are to be considered, including:

• Expansion of existing policies and programs (heat pump and other fossil fuel reduction technology installations through Tier III, weatherization programs, and energy efficiency utility thermal programs.
• Direct carbon pollution pricing
• Cap and trade/invest programs (individually or regionally)
• Sector-wide performance standards (Clean Heat Standard, a clean fuel standard)
• Targeted performance standards for heating appliances
• Direct regulation of fuel emissions and/or appliances

A final report is to be provided by May 1, 2023.   The report will be developed by yet-to-be-selected consultants in collaboration with state ANR staff and utilizing substantial resources developed to date by and for the state of Vermont.   Due to this development, it is unlikely that any further actions may be taken related to a Clean Heat Standard during the upcoming legislative session. 

I encourage architects to discuss the importance of reducing fossil fuel use for heating- including in new construction- with their state and local legislators.   As local professionals in building design, we bring a lot of credibility to the discussion.   Check out AIA 2030 Commitment for a range of tools and resources to help.