From:                                         Karen Martin <karen.martin711@gmail.com>

Sent:                                           Friday, June 7, 2019 1:05 PM

To:                                               RPS, DOER (ENE)

Subject:                                     Comment opposing the proposed changes to the 2012 bioenergy rules

 

 

Dear Mr. Wassam, 

I oppose the changes to the 2012 RPS bioenergy rules proposed by DOER.  The RPS was enacted to reduce the carbon emissions in Massachusetts. As you know, the IPCC report issued last fall said we have precious little time (~11 years from now) to reduce carbon emissions 45% from 2010 levels.  Since burning wood is worse, from both a climate crisis and air pollution point of view, than burning any fossil fuel including coal, it makes no sense to roll back the requirements for burning biomass.

Reducing the required efficiency for biomass burning plants will increase the emissions and particulate matter from these plants. Carbon emissions must be reduced quickly and within 30 years be eliminated, not only to keep our planet livable for its current and future occupants but to satisfy the Global Warming Solutions Act.

The increased particulate matter emission will exacerbate asthma and other lung conditions that only stand to worsen as the climate crisis continues. Reducing the required efficiency of plants will encourage more inefficient plants to be built, worsening the climate emergency.

Allowing whole trees to be included in the biomass mix, will encourage more clearing of forests. I love to walk my dogs in the woods, even woods whose trees are not lumber quality.  Walking in the woods, I breathe air made clean by those trees. Trees have value other than for lumber and burning. They sequester carbon, reducing the level of global heating. As the climate crisis intensifies, more and more people will seek solace in the woods, benefiting from the cooler temperature and the cleaner air. There is no such thing as “sustainable harvesting.” We need to protect trees, not threaten them.

Changing the timeframe over which facilities must show a net reduction in emissions over fossil fuels from 20 to 30 years is absurd. The IPCC says we have ELEVEN years to reduce GHG emissions. Twenty years is too long. Thirty years is folly.

Additionally, biomass plants are not financially viable without subsidies, subsidies taken from the Massachusetts taxpayer. Since biomass is not a renewable energy source (over the period of time where we might have the ability to extract ourselves from the climate crisis) biomass should not be included in the RPS even as the rules are written now and certainly not as you propose to change them.

I oppose your proposed changes to the RPS regulations. 

 

Sincerely,

Karen Martin

179C Lakeshore Rd

Boxford, MA 01921