From: Richard Parker <parkerrg@comcast.net>
Sent: Friday, July 26, 2019 4:16 PM
To: RPS, DOER (ENE)
Subject: RPS Changes - Classification and Burning of Biomass
Dear Department of Energy
Resources,
I am concerned at DOER’s
consideration of RPS regulatory changes to allow lowering clean energy
standards for biomass plants, which would result in a substantial net increase
in greenhouse gas production through their operation and in the selection of fuel.
Instead, we should be focused on reducing greenhouse gas emissions attributable
to Massachusetts’ energy usage.
- The current energy efficiency
standards for biomass plants should not be reduced, and should not be
adjusted to encourage new biomass plants within the Commonwealth or to
accommodate existing dirty biomass plants existing outside of
Massachusetts.
- Whole trees should not be
allowed as biomass plant fuel. Mature trees in diverse forests
represent huge existing safe stores of carbon and are much more efficient
at storing additional carbon than the immature monoculture plantations
that they would be replaced with. Given the IPCC’s conclusions on
the necessary time frame to achieve carbon neutrality to avoid climate
change disaster (i.e. world average temperature rise > 1.5 degrees C.),
we do not have the luxury of time (50-100 years) necessary to re-sequester
carbon released by burning existing mature whole trees. Further, the
balance of carbon stored in forest soils and the fertility of those soils
should be protected through harvesting standards. Vague forest
industry language referring to “sustainable harvesting” is not adequate.
- DOER’s calculations for
determining bioenergy lifecycle CO2 emissions should include fossil fuels
used in harvesting, processing, and transport of biomass
- Clean energy subsidies should
not be extended to encourage additional biomass plants and garbage
incinerators.
- Specifically, in acknowledgment
of the needs of environmental justice communities, the Palmer Renewable Energy
biomass plant proposed for East Springfield should not be encouraged and
should not be eligible for RPS subsidies.
- Instead of encouraging
relatively inefficient wood burning biomass electrical generating plants,
focus should be on smaller and higher efficiency CHP plants.
Thank you for your consideration.
Respectfully,
Richard Parker
153 Crane Neck Street
West Newbury, MA 01985
Selectman - West Newbury, MA
Member West Newbury Energy Advisory Committee
Small Business Owner