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.

 

  1. 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.
  2. 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.
  3. DOER’s calculations for determining bioenergy lifecycle CO2 emissions should include fossil fuels used in harvesting, processing, and transport of biomass
  4. Clean energy subsidies should not be extended to encourage additional biomass plants and garbage incinerators.
  5. 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.
  6. 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