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