From:                                         Anne O'Connor <aoconnor@williamstownma.gov>

Sent:                                           Wednesday, June 5, 2019 12:48 AM

To:                                               RPS, DOER (ENE)

Cc:                                               anne.she.can@gmail.com; Barrett, John - Rep. (HOU); adam.hinds@masenate.gov

Subject:                                     Withdraw the eligibility changes to RPS Class I and II

 

John Wassam

Department of Energy Resources, 

100 Cambridge Street, Suite 1020, 

Boston, MA 02114

 

Re: RPS Class I and Class II regulations

 

Date: June 5, 2019

 

 

Dear Mr. Wassam and the DOER,

 

I am writing in opposition to the DOER’s proposed eligibility changes to the RPS Class I and Class II regulations concerning biomass.

 

In 2011, residents of my town—Williamstown, MA—rallied in opposition to a proposal from Beaver Wood Energy to construct a biomass plant in neighboring Pownal, VT. Concerned residents were quick to be alarmed about the noxious effects of biomass pollution, and their opposition was fierce and effective.

 

Our town is now being invited to join the Mohawk Trail Woodlands Partnership, an initiative purportedly designed to protect our forests, while giving property owners tools to derive revenue from them. This proposal, too, has been met with concern among those who fear it will incentivize increased timber harvesting for the biomass industry.

 

Today, the DOER’s proposed changes to the biomass component of the RPS regulations would seem to support this suspicion. Almost a decade ago, Massachusetts established strong forest-harvesting criteria that were designed to protect our forests, maintain soil fertility and prevent overharvesting. At that time, the state determined that biomass is not carbon neutral, yet this regulatory change would roll back every protection that helps limit CO2 emissions and protect forests. 

 

As a concerned citizen and a member of the Williamstown Select Board, I urge the DOER to abandon its proposal to weaken the state’s RPS regulations on biomass. Among other ills, this misguided proposal would:

- let terms such as “forest salvage,” “residues” and “thinning,” become tools to facilitate the harvesting of healthy, mature trees;

- eliminate our strong harvesting criteria and replace it with vague, unenforceable language about “sustainable harvesting”;

- weaken efficiency requirements for biomass electricity plants;

- disregard the greenhouse gas emissions associated with wood pellet manufacture.

 

And, in a textbook example of environmental injustice, the proposal would pave the way for a large-scale biomass plant to be inflicted upon the residents of Springfield—a fate my own community managed to avoid. 

 

I ask the DOER to withdraw the proposed eligibility changes to the RPS Class I and II regulations.

 

Sincerely,

 

Anne O’Connor

201 Cole Ave, Apt 103

Williamstown, MA 01267

anne.she.can@gmail.com

aoconnor@williamstownma.gov

413 884 2598

 

--

Anne O'Connor

Member, Williamstown Select Board

she | her | hers

 

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