From:                                         holly <higinbo@hotmail.com>

Sent:                                           Tuesday, June 4, 2019 5:31 PM

To:                                               RPS, DOER (ENE)

Subject:                                     proposed changes to RPS Class I and Class II regulations

 

 

June 4, 2019

 

To the Department of Energy Resources

Attention: John Wassam

 

I am writing to object to changes being proposed for the Renewable Portfolio Standard, particularly as they apply to biomass power plants. Given the massive effects that climate change is already having and the inevitability that the impacts will worsen dramatically in the very near future, it is imperative that DOER makes sure its policies do not contribute to this situation. 

 

The changes to the RPS as proposed by the Department of Energy Resources would  work against the very purpose for which the RPS was developed.  These proposed changes would in fact open the door for an increase, not a decrease, in greenhouse gas emissions in the Commonwealth, allow clean energy subsidies to be given to biomass power plants and garbage incinerators that create pollution, and allow large-scale biomass power plants to be eligible for renewable energy credits. 

 

Last year, the state legislature voted to double the minimum percentage growth rate of renewable energy from 1% per year to 2% per year starting in 2020.  The task of DOER is to update its RPS regulations to reflect this change.  But instead, what is being proposed would work against that commitment.  

 

More specifically, Massachusetts has the only regulations in the nation that consider greenhouse gas emissions as criteria for biomass eligibility, and only highly efficient biomass plants qualify.  The proposed regulations would roll back or eliminate all of these science-based standards, expand what types of wood can qualify, and would be a windfall for the biomass industry by subsidizing new and existing polluting biomass power plants in Massachusetts and New England. 

 

This proposal would, for example, enable a 35 MW biomass power plant proposed in East Springfield to collect $10-12 million a year in renewable energy subsidies – even as it would emit hazardous air pollution into community that already suffers from some of the highest asthma rates in the nation.  In addition, this proposal would significantly increase renewable energy subsidies for highly polluting garbage incinerators.  This is a betrayal of the promise that the 2018 law expanding the RPS would lead to an increased investment of public funds to support clean renewable energy.  

 

Finally, our governor, Charlie Baker, has joined an alliance of U.S. governors that pledged to support the Paris Climate Change Agreement.  The proposed regulations would take Massachusetts in the opposite direction.  The Paris Agreement calls for reducing greenhouse gas emissions and protecting forests as natural carbon sinks.  Instead, DOER is proposing to use the Commonwealth’s primary clean energy program to incentivize logging and encourage inefficient biomass power plants that release more CO2 per unit of energy than coal-fired power plants.  This proposal would undermine the state’s ability to reduce greenhouse gas emissions, as required by the Global Warming Solutions Act, and contradicts the public statements Governor Baker has made in support of the Paris Agreement. 

 

As a Windsor resident and Massachusetts taxpayer, I urge the DOER to vote against these proposed regulation changes, and to uphold the state's commitment to supporting clean, renewable energy. 

 

 

Respectfully submitted,  

 

Holly Higinbotham,

Windsor, MA