From: holly <higinbo@hotmail.com>
Sent: Tuesday, June 4, 2019 5:16 PM
To: RPS, DOER (ENE)
Subject: RPS Class I and Class II regulations
June 3, 2019
John Wassam
Department of Energy Resources
100 Cambridge Street, Suite 1020
Boston, MA 02114
To the Department of Energy Resources,
Members of the
Windsor Green Committee are writing to object to the proposed
regulation changes for the state’s Renewable Energy Portfolio Standard (RPS Class I and RPS
Class II regulations) particularly as they apply to biomass plants. The Windsor Green Committee was
formed nearly
five years ago to help improve the environmental
sustainability of activity in the Town of Windsor. This includes
residential, commercial, and municipal property.
As a designated green community Windsor is taking action to use the cleanest
sources of energy to reduce municipal consumption, thus reducing our carbon
impact.
The changes
to the RPS as proposed by the Department of Energy Resources would, in our
opinion, 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 a 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 town committee whose mission is to help our community
decrease its carbon footprint and do all that is possible to combat climate
change, we argue that these proposed changes to the biomass provisions in the RPS
are absolutely antithetical to the reason the RPS was developed in the first
place. Ratepayer subsidies
should be used to support truly clean, renewable energy and not for more
pollution.
Respectfully submitted,
Stu Besnoff, Chair
Mark Barrette
Jan Bradley
Holly Higinbotham
Bob Meyers
Marnie Meyers