Governor Baker,
The proposed changes to RPS Class I, especially the
changes that reduce or eliminate the core requirements of the 2012 RPS bioenergy
rules are unacceptable. As you know, the DOER plans reductions in efficiency
criteria, increases in the allowed variety of wood, including whole trees from
our State forests, increasing from 20 years to 30 years the time frame for
plants to show a net reduction in GHG emissions relative to fossil fuels,
calculation of lifecycle CO2 emissions that ignore fossil fuels used in
harvesting, processing and transport, elimination of requirements for liquid
fuels to show a real reduction in GHG’s, and the removal of
Massachusetts-specific forest harvesting criteria.
Your administration is aware that the climate crisis is
urgent and that the time window for dramatic action is just a few years.
Clean energy does not come out of a smokestack. Burning
wood is a highly emitting source of energy, and there is no longer time to grow
new forests to recapture the emissions.
I urge you to withdraw the proposed eligibility changes
to RPS Class I and Class II and to fully support H. 897 An Act Relative to
Forest Protection
Thank you for your consideration,
Don Ogden
01062