From:                                         mhh777@verizon.net

Sent:                                           Thursday, July 25, 2019 12:41 PM

To:                                               RPS, DOER (ENE)

Subject:                                     your proposed changes to biomass wood-burning regulations

 

Categories:                              Saved as a common PDF

 

15 Silverwood Terrace

South Hadley, MA 01075-1231

 

                                                                                                                                                July 25, 2019

 

 

Massachusetts Department of Energy Resources

doer.rps@mass.gov

 

 

Dear People:

 

                I regret that other commitments have precluded my giving the Department’s changes to biomass wood-burning regulations the attention that they require.

 

                Where we are in a time of climate emergency, I recognize all of us must do what we can to address the emergency.  

 

                I see, in a June 14 Greenfield Recorder article, that the changes you have drafted “include eliminating efficiency requirements for biomass facilities that receive credits for using fuel that’s more than 95 percent damaged or dead trees.”  

 

                While I sympathize with concerns over the disposal of diseased trees in the Commonwealth, I am concerned that moving infected wood around can increase contagion.

 

                I further note some claims of the Partnership for Policy Integrity, in their comments on a submission to your office from the Biomass Power Association, to the effect that decomposing wood produces relatively less greenhouse gas emissions than come from, first, forming wood chip piles that can go anaerobic, and then, burning the wood.

 

                I am also aware of the small particle pollution resulting from wood burning that is very damaging to human health.

 

                In view of the importance of trees as carbon sinks, I am in support of there being tax credits for landowners who allow their healthy trees to stand and grow.

 

                I am interested in exploring how we may best manage and maintain our forests in the Commonwealth.  I understand that, in this time of climate emergency, we must seek to avoid burning wood as much as possible.  For the sake of our having a future, and for the sake of human health, I would like you to retain in place current efficiency requirements for biomass facilities that receive credits for using fuel that’s more than 95 percent damaged or dead trees.  More than this, I would like you to open a conversation with all of those who seek to maintain current efficiency standards for wood-burning biomass facilities, to work collaboratively with us on finding solutions to the problems that foresters bring forward.

 

                                                                                                                                                Very Sincerely,

 

                                                                                                                                                Mary H. Hall