From:                                         Tom Chamberland <tchamberland@town.sturbridge.ma.us>

Sent:                                           Friday, June 7, 2019 8:26 AM

To:                                               RPS, DOER (ENE); tchamberland301@gmail.com

Subject:                                     Comments on RPS Class 1 & 2 reg changes

 

TO:     John Wassam                                                              5 June 2019

Department of Energy Resources,

100 Cambridge Street, Suite 1020, Boston, MA 02114

 

From:  Thomas A. Chamberland,

Town of Sturbridge Tree Warden,

Sturbridge MA 01566

 

RE: Comments on amending 225 CMR 14.00 & 15.00

 

Dear Sir,

I would like to express my support for the changes to 225 CMR 14.00--Renewable Energy Portfolio Standard – Class I and 225 CMR 15--Renewable Energy Portfolio Standard – Class II.  As a municipal Tree Warden for over 35 years, of one my primary concerns in expending taxpayer funds is the current and future costs of woody debris disposal, from both routine and emergency/natural disaster events.

 

Currently, every community I know (I am a Past President of the Massachusetts Tree Warden’s and Foresters Assoc. the oldest tree protection organization in the United States) has stockpiles of wood debris and chips originating from routine tree trimming operations and electric utility line clearance maintenance work.  In Sturbridge that pile now exceeds 4250 Cu Yards.  Some of it is composted, some is used for road shoulder stabilization/erosion control and trail work.  However, the supply is far greater that the demand.  Consequently, the Town of Sturbridge now restrict utilities from dumping their chips at our site and we encourage our tree contractors to find other disposal methods, which increase our “down time” due to transportation and reducing the productivity of the tree crew, and it now costs the town $10 per cubic yard to dispose of large woody debris material, when previously we paid nothing.  

 

During FEMA-declared natural disasters, disposal of woody debris, which may also include grindings of larger wood parts, is a part of the reimbursable cost structure.  However not all-natural disasters rise in scope to be FEMA eligible/declared.  A prime example of the latter is our current gypsy moth/drought tree mortality situation. Due to this natural event, the town of Sturbridge in the unfortunate process of removing over 650 public street trees, at a cost exceeding $270,000 (estimated wood disposal cost is $40,000).  I feel most of these costs could have been avoided had the changes proposed in the draft regulations been in place already.

 

 As a member of the US Forest Service Urban Forest Strike Team national advisory committee, (UFST) I train Arborists to help communities recover following natural disasters, I am well aware that contractors who bid this work are finding it increasing harder to “market” and re purpose/use this woody debris. I see several reasons for this situation.  Of prime concern is a lack of regional demand for and ability to use wood debris in co-generation/utility heating, the oversupply in the mulch market, and lack of marketability for communities from routine tree work and localized natural disasters.

 

I attended several of the public hearings and noted the concern expressed by some of the potential degraded air quality, etc. if these regulations were to be adopted.   When there is no viable market for municipal large wood debris, if left along the side of the road is usually picked up by local residents for burning in old wood stoves, thus increasing air quality concerns. If a viable market is created, as envisioned by the regulatory changes, even though burned, thru much more refined equipment, would result in improved air quality, and a financial return to the communities, by having a market for this wood.

 

It is clear to me that the intent of this regulatory change it to recognize the fossil fuel displacement value of the woody material that we make every day.  With that recognition in mind, to better capture actual events I recommend the following word changes to the regulations:

1: I am concerned that chips from land clearing have removed from RPS eligibility.    As an elected official within my community I can attest to the rigor my town considers any proposed land clearing (schools, ballfields, other municipal expansions).   While I do not like the fact that this is a land use change, I recognize that these chips are unavoidable.  Thus, like the wood originating from other non-forest activities, I recommend the re-inclusion of this unavoidable material within the RPS.

2: 225 CMR 14.00: 14.02 definitions, eligible biomass woody fuel (d) 3: Wood waste: Post-consumer wood products from Clean Wood; pruned branches, stumps, and whole trees removed during the normal course of maintenance of public or private roads, highways, driveways, utility lines, rights of way, and parks.  After the words “normal course of maintenance” may preclude storm/natural disaster/insect infestations response, please add: “, or other natural events”

 

I fully support the amended changes to portions of 225 CMR 14--Renewable Energy Portfolio Standard – Class I and 225 CMR 15--Renewable Energy Portfolio Standard – Class II and recommend their adoption.

 

Respectfully:  

Thomas A. Chamberland

Thomas A. Chamberland

Sturbridge Tree Warden



Email: DOER.RPS@mass.gov