From: Anne O'Connor <aoconnor@williamstownma.gov>
Sent: Wednesday, June 5, 2019 12:48 AM
To: RPS, DOER (ENE)
Cc: anne.she.can@gmail.com; Barrett, John - Rep. (HOU);
adam.hinds@masenate.gov
Subject: Withdraw the eligibility changes to RPS Class I and II
John Wassam
Department of Energy Resources,
100 Cambridge Street, Suite 1020,
Boston, MA 02114
Re: RPS Class I and Class II regulations
Date: June 5, 2019
Dear Mr. Wassam and the DOER,
I am writing in opposition to the DOER’s proposed eligibility
changes to the RPS Class I and Class II regulations concerning biomass.
In 2011, residents of my town—Williamstown, MA—rallied in
opposition to a proposal from Beaver Wood Energy to construct a biomass plant
in neighboring Pownal, VT. Concerned residents were quick to be alarmed about
the noxious effects of biomass pollution, and their opposition was fierce and
effective.
Our town is now being invited to join the Mohawk Trail Woodlands
Partnership, an initiative purportedly designed to protect our forests, while
giving property owners tools to derive revenue from them. This proposal, too,
has been met with concern among those who fear it will incentivize increased
timber harvesting for the biomass industry.
Today, the DOER’s proposed changes to the biomass component of the
RPS regulations would seem to support this suspicion. Almost a decade ago,
Massachusetts established strong forest-harvesting criteria that were designed
to protect our forests, maintain soil fertility and prevent overharvesting. At
that time, the state determined that biomass is not carbon neutral, yet this
regulatory change would roll back every protection that helps limit CO2
emissions and protect forests.
As a concerned citizen and a member of the Williamstown Select
Board, I urge the DOER to abandon its proposal to weaken the state’s RPS
regulations on biomass. Among other ills, this misguided proposal would:
- let terms such as “forest salvage,” “residues” and “thinning,”
become tools to facilitate the harvesting of healthy, mature trees;
- eliminate our strong harvesting criteria and replace it with
vague, unenforceable language about “sustainable harvesting”;
- weaken efficiency requirements for biomass electricity plants;
- disregard the greenhouse gas emissions associated with wood
pellet manufacture.
And, in a textbook example of environmental injustice, the
proposal would pave the way for a large-scale biomass plant to be inflicted
upon the residents of Springfield—a fate my own community managed to
avoid.
I ask the DOER to withdraw the proposed eligibility changes to the
RPS Class I and II regulations.
Sincerely,
Anne O’Connor
201 Cole Ave, Apt 103
Williamstown, MA 01267
413 884 2598
--
Anne O'Connor
Member, Williamstown Select Board
she | her | hers
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