From: Paul M Martin <paulmmartin46@gmail.com>
Sent: Friday, June 7, 2019 5:50 AM
To: RPS, DOER (ENE)
Subject: Comments re: proposed rule changes
Attachments: IPCC-2018-report-summary-for-policymakers.docx;
Manomet_Biomass_Report_ExecutiveSummary_June2010.pdf
Paul M. Martin
46 Oxford Street
Springfield, MA 01108
413-737-4471
When the Regional Greenhouse Gas Initiative (RGGI) was
first written in 2005, the inclusion of woody biomass as a category in the
Renewable Portfolio Standard (RPS) was a naïve error in the understanding of
the timeframe within which the problem of greenhouse gases needed to be
solved. At that time, the simple thought that trees can be re-grown must
have seemed enough to justify woody biomass as a “renewable” fuel source for
energy generation.
Then in 2010, Massachusetts DOER commissioned a study
by the Manomet Center for Conservation Sciences. References to Manomet in
the following are from the Executive Summary of the Biomass Sustainability
and Carbon Policy Study published by Manomet in June 2010. Manomet
took into account that burning a tree in an industrial furnace might take a
matter of minutes and growing a replacement tree would take 20 to 40 years;
thus at the beginning of the cycle, the generator is emitting CO2 into the
atmosphere that will not be reabsorbed by new growth for many years. The study
compared this cycle of emissions and re-capture of CO2 with generation by
several different fossil fuels which have no means of re-capturing the
CO2. Coal and natural gas for generating electricity are the only ones
relevant to this discussion.
The first thing to note in the comparison is that
using woody biomass to generate electricity is much less efficient any fossil
fuel. Manomet refers to this excess CO2 emission as the “carbon debt” of
using wood rather than a fossil fuel to generate a given amount of power.
Manomet found that generating electricity from woody biomass as fuel repays the
debt compared to coal after 21 years of generation along with a faithful
program of re-planting trees. However, electricity generation using fossil
fuels in Massachusetts has already transitioned from coal to natural gas, a
much cheaper and more efficient fuel. The Manomet reports states on page
7 “When biomass is assumed to replace natural gas electric capacity, carbon
debts are still not paid off after 90 years.” That is to say: for
almost the first century of operation, generation by woody biomass will produce
MORE CO2 than would natural gas for an equivalent amount of electric
power! The only reasonable conclusion from this is that woody biomass
is NOT in any realistic, practical, effective way a renewable fuel.
But
it gets worse. In 2018 the Intergovernmental Panel on Climate Change
(IPCC) published a study titled Global Warming of 1.5⁰C.
References here are from the Summary for Policymakers part of that
document. This report carefully documents:
1)
the current status of close to 1⁰C of warming above the historical average,
2)
the risks associated with an increase beyond 1.5⁰C and
3)
an analysis of pathways to limit warming to that 1.5⁰C goal.
From
page 14 of the IPCC report “In model pathways with no or limited overshoot of 1.5⁰C,
global net anthropogenic CO2 emissions decline by about 45% from 2010 levels by
2030”. The analysis calls for continued reductions until net zero
emissions are achieved by 2050: 31 years from now. And this goal would
not even reverse the recently increasing power of storms, extent of wildfires,
recurrence of floods in some regions and droughts in others. It is only
an attempt to stabilize our climate at a level somewhat worse than the current
situation as global average temperature increases from 1 to 1.5⁰C above the
historical average.
With this in mind, it should be clear that any method
of energy generation that puts more carbon into the atmosphere than currently operating
fossil fuel plants should not qualify for a subsidy via Renewable Energy
Credits (RECs). This error in judgement of including woody biomass power
generation as eligible for RECs may not have been foreseeable by the authors of
the RGGI agreement in 2005, but it should have been corrected after the
publication of the Manomet study in 2010. Now in 2019 after publication
of the IPCC report, the continued presence of woody biomass as a fuel
qualifying for RECs is a travesty.
Those RECs are financed by charges on electric bills
across Massachusetts making this not only a travesty, but an insult to the
ratepayers of this state. Diverting those funds into an activity that is
now known with a high degree of certainty to put the lives and property of those
ratepayers at greater risk than other possible uses of the funds is
irresponsible at best, malfeasance at worst.
While it may take a change in
law by the legislature to completely eliminate woody biomass from the RPS, any
proposed rule change by the DOER should be designed to make it MORE difficult
for a generator to receive RECs by using that fuel. The proposed changes
to eliminate capacity requirements, lessen the administrative burden, and lower
the efficiency standards are wrong and should be rejected.