From:                                         Peter Lowitt <peter.lowitt@verizon.net>

Sent:                                           Wednesday, July 17, 2019 8:48 AM

To:                                               RPS, DOER (ENE)

Subject:                                     Comments on proposed changes to Class RPS I and RPS II Regulations

 

To the commissioner,

I object to adding wood-chip biomass into the Renewable Power Standard, for a number of reasons outlined below. 

 

Summary of objections:

1)      Biomass is not a low-emissions fuel source, for a number of reasons

a.       Relatively low efficiency plant

b.       CO2 emissions higher than coal, oil or natural gas

c.       Energy intensive to harvest and prepare fuel

d.       Replacement trees take several decades to regrow

 

2)      Wood biomass is being considered for the RPS, which is a bad idea for several reasons

a.       Previous administration decided not to include it, because it isn’t carbon neutral

b.       Exportation of biomass to the UK (since included in their equivalent of RPS) is devastating forested parts of the southeast US. This could happen in the Commonwealth and New England

c.       Biomass industry presents itself as ‘environmentally friendly’ but it considers forest resources not put to productive use as lost income.

 

3)      We are currently in a biodiversity crash (“the sixth extinction) during our lifetime

a.       Population of wild vertebrates and insects down by 70% from 30 years ago

b.       Million species may be lost in next decades

c.       Need for wildlife corridors to be expanded and protected (EO Wilson)

d.       Growing wood chip market will put pressure on forests throughout New England

 

4)      Wood chip biomass emits particulate emissions

a.       PM2.5 levels lead to higher levels of Asthma

b.       Why are biomass plant being planned for disadvantaged communities such as Springfield and Palmer?

c.       Original intention was to burn construction and demolition debris, aggravating emissions

5)      If you consider allowing these changes please include conditions to require reforestation (including bonding to assure replanting) and the use of sustainable certified forestry methods.  The problem is the lag time between replanting and the production of carbon offsetting growth (30-50 years) that we do not have.

 

Summary:

I commend Belmont, Concord, Holden and Middleborough municipal utilities for deciding against the purchase of biomass electricity.

I ask the Baker administration to not add wood chip biomass to the Renewable Power Standard.  We are in a climate crisis.  It doesn’t make sense to adopt a policy that encourages the destruction of our largest carbon sinks, our forests.

 

 

Peter Lowitt, FAICP

5 Westvale Drive

Concord, MA 01742