From:                                                       Christine Labich <clabich77@gmail.com>

Sent:                                                         Wednesday, May 15, 2019 11:05 AM

To:                                                            RPS, DOER (ENE)

Subject:                                                   Public Comment on RPS Class I and RPS Class II Regulations

 

                                                                                                            Christine Labich

                                                                                                            948 East Pleasant St.

                                                                                                            Amherst, MA 01002

 

John Wassam

Massachusetts Department of Energy Resources

100 Cambridge Street, Suite 1020

Boston, MA 02114

 

 

Public Comment on April 5, 2019 draft regulations to amend portions of  225 CMR 14--Renewable Energy Portfolio Standard – Class I (“RPS Class I”) and 225 CMR 15--Renewable Energy Portfolio Standard – Class II (“RPS Class II”). 

 

I am here to speak against the dismantling of the scientifically-based, protective regulations that restrict biomass and waste incineration as part of Massachusetts’ Renewable Portfolio Standard. I am frankly amazed at this attempt to undermine the fundamental goals of the RPS and to weaken provisions that protect public health and the health of ecosystem functions upon which we all depend. 

 

In it’s October, 2018 Summary for Policymakers, the Intergovernmental Panel on Climate Change offers clear guidance on what steps are needed immediately to prevent the earth from catastrophic warming and climate disruption. In short, drastic reductions in Greenhouse Gasses (GHG) are required immediately. These proposed changes to the RPS allow net GHG emissions to exceed those of fossil fuel plants within the very time horizon that represents our only chance to meaningfully address climate change. In addition, they fail to take into consideration the total carbon impact of harvesting, transporting, and processing biomass, and they open the door to harvesting the very trees that could be helping us sequester carbon—instead releasing it into the atmosphere. It is clear that healthy forests are our ally in both sequestering carbon and providing ecosystem services such as improving water quality, but these proposals eliminate specific protections designed to protect forests and maintain soil fertility.

 

Climate Change is a public health issue in itself. But, in addition, these proposed changes threaten respiratory health by weakening requirements for controlling particulate matter and opening the door to burning contaminated and hazardous materials. Massachusetts already has a higher rate of asthma than the national average. Several members of my family have asthma, and I know that it affects all aspects of life. Weakening these protections would affect the most vulnerable in our commonwealth and beyond—children, the elderly, the health-compromised, and people living with low income. These are the very populations that a clean energy portfolio should be geared toward protecting. 

 

Given the clear scientific evidence that these proposed changes would undermine the RPS as a meaningful policy that addresses net GHG emissions and public health, I, and many others who could not be here today, ask that you keep the protective measures that restrict biomass incineration intact. Please resist the potential give-away of citizen funds to companies that seek to profit off of biomass incineration in the state at the expense of our public health, our climate, and the integrity of the RPS program. 

 

Christine Labich