Dear John Wassam, DOER Staff,
I'm writing in opposition to any changes to the RPS Class
I and RPS Class II regulations that would make bioenergy more harmful to health,
forests, and climate change. The 2012 regulations were designed to be rigorous
and science-based. My own models and research have
shown that most bioenergy today is detrimental to the climate and public
health. To be clear, most bioenergy today is NOT carbon neutral. That is why
there are lawsuits in the EU and other jurisdictions against bioenergy
industry.
The current Mass RPS regulations are some of the most
scientifically sound. Changing them and "streamlining" them would
make them worse, not better.
Please don't change the regulations. If bioenergy power
plants are having a tough time meeting the scientifically rigorous rules, it is
because bioenergy is bad for the planet and Massachusetts communities. We don't need more of something that is bad.
Respectfully,
Travis Franck
PhD, MIT
Belmont, MA