From:                                         Gia Neswald <gneswald@gmail.com>

Sent:                                           Friday, June 7, 2019 1:28 PM

To:                                               RPS, DOER (ENE)

Subject:                                     Comments on 225 C.M.R. 14.00 (RPS I & RPS II)

 

I am a resident of Turners Falls, writing to state that no changes should be made to the RPS 1 & RPS 2.  Below are some reasons to maintain the current standards.

 

- The Commonwealth should be proud of the model intensive process that resulted in current RPS regulations.  We must honor the scientific understanding and agreements reached as a direct result of this process.  The proposed changes to biomass emissions requirements within the RPS would go against well-founded and working policies based on the Manomet study and much admirable collaborative planning based on that analysis.  The vast majority of people have spoken loudly and clearly and repeatedly against relaxing the standards therein, where our money and our health and our future are all at stake.  ANY relaxation of emissions rules by official policy or de facto is a violation of that excellent democratic process.

 

- Honest analysis of biomass combustion shows that any form of biomass in any facility will emit more CO2 than coal or gas.  The Commonwealth has a responsibility to reduce GHG emissions vis a vis the UN Framework Convention on Climate Change and our own Global Warming Solutions Act.

 

- The Commonwealth should be proud of its commitment to reducing greenhouse gasses as set forth in the Global Warming Solutions Act (GWSA).  Unfortunately, we are falling further and further behind in meeting our own self-prescribed goals.  ANY relaxation of emissions rules legally or de facto is irresponsible and immoral in the context of our climate crisis and our GWSA commitments.

 

- There is no guarantee that fuel for the proposed Palmer Renewable Energy plant in Springfield would not include forest-derived wood.  The history of DCR supported logging on public and private lands is short-sighted and political, so it is reasonable to assume that logging contracts in Massachusetts would, in part, feed that plant.  The climate crisis demands that we conserve all of the forests we are blessed with in this beautiful state, for maximized carbon sequestration and storage, as well as environmental cooling, natural water purification and biodiversity.

 

- Proposed changes turn science-based carbon accounting into DOER's looking the other way in regard to various emissions.  Improper and inaccurate accounting for carbon and GHG emissions is all over the proposed regulations changes.  Not counting the following is dishonest and harmful to our land and all its residents:

  1. biomass drying by heat;
  2. green woodchip methane emissions;
  3. emissions from production, transport and processing of biomass fuel;
  4. liquid biomass emissions that fall between current standards of 50% in relation to petroleum distillate fuel sold in 2005 and EPA RFS2 standards which would be mimicked by the proposed changes.

Furthermore, counting woody biomass offsets based on regrowth of trees manipulates the figures without regard for realistic life cycle considerations.  In other words, the rate of consumption would immediately and in a sustained way overtake the rate of regrowth.  Furthermore, where development or maintenance in developed areas would be the source of woody fuel, regrowth would not occur at all.  Still, under proposed changes, all trees cut and subsequently used for "renewable energy" would be counted as renewable.

Biomass is not truly a renewable energy fuel, so it should not be included in RPS incentives at all.


- Salvage wood can be highly toxic and regulation of material broken down for biomass fuel is impossible.  Claims that burning salvage wood is an efficient use of waste matter are misleading.  Salvage wood left to decompose does not emit greenhouse gasses as quickly as combustion, nor does it create particulate matter pollution.  Rather, decomposition returns much of the freed carbon to the soil, along with nutrients that support life.

 

- One area of concern for which the Commonwealth cannot be proud is our record of dangerous air quality in the city of Springfield. Biomass power plants have only proposed sites within our most vulnerable communities.  It is our state government's responsibility to protect the health and wellbeing of all of its residents. especially our most vulnerable.  Any action which would lead to additional particulate matter pollution in that city would be reprehensible.

 

Please strike down 225 C.M.R. 14.00 and maintain current RPS standards.  And please do more for our future.  We need to modify standards to incentivize only the cleanest energy production methods which have growth potential in our region, such as solar and wind, and reward reductions in energy consumption.  Thank you for your consideration.

 

Sincerely,

Gia Neswald

393 Montague City Rd.

Turners Falls, MA  01376