From: Rebecca <rebhu7@gmail.com>
Sent: Wednesday, June 5, 2019 8:45 PM
To: RPS, DOER (ENE)
Subject: BioMass discussion for Massachusetts
To
All Lawmakers in Massachusetts:
As a
person living in Western Mass. it is imperative that the 2012 RPS
rules
be adhered to, pursuant to: " The Massachusetts Department of Energy
Resources (DOER) is proposing to
substantially roll back hard-won 2012 environmental and health protections
governing woody biomass in the state’s Renewable Portfolio Standard (RPS)"
My
response along with many others living in the state, who might not be able to
attend a hearing date
that
was changed at the last minute. Please note the bold print:
●
The 2012 Massachusetts RPS biomass rules were developed based on a
scientific study of bioenergy carbon impacts (known as the “Manomet Study”),
and were the first in the nation and the world to recognize that burning trees
for
energy increases greenhouse gas emissions. GREAT.
●
DOER is proposing to reduce or completely eliminate all the core requirements
of
the 2012 RPS rules. VERY BAD!
●
DOER is proposing to eliminate efficiency criteria for biomass power plants
that
burn broadly defined categories of “salvage” wood and residues. This will allow
construction of massive electric-only plants, such as a proposed 35-megawatt
biomass power plant in East Springfield, instead of the small, efficient
combined
heat and power (CHP) plants that were promoted under the 2012 rules.
●
DOER is proposing to extend the timeframe for biomass facilities to show a net
reduction in GHG emissions relative to fossil fueled plants from 20 years to 30
years -- when climate scientists are telling us we only have 10 years to
slash
GHG emissions in order to prevent catastrophic climate change. Actually,
at a
recent
Climate Reality Leadership conference with Al Gore, a panel of climate
scientists
recommend that we think in terms of ONE YEAR, not 10 or 12! Too much
is
not understood and things are happening fast.
● DOER is proposing to allow biomass power plants to burn a huge variety of
woody fuels, including whole trees, that DOER is re-classifying as “residues”
to
allow calculation of a minimal carbon impact, even though the Manomet
definition
of residues was confined to tops and limbs from saw/timber harvesting.
Whole
trees are Not residue! They are perhaps one of our most efficient
sequestration
agents for CO2.
●
DOER’s calculations for determining the life cycle CO 2 emissions from
bio-energy
ignores fossil fuels burned during harvesting, processing, and transport of
biomass – even though such emissions can be considerable for certain fuels,
especially wood pellets. And the subsequent shipping and transfer of wood
pellets
to
outside markets in totally unsustainable in terms of usage of energy per
gain. We, in
Massachusetts
and the planet lose terribly in this industry that masquerades as
"green".
For more information about the impacts of biomass energy visit www.pfpi.net
● DOER is proposing to treat liquid biofuels as having zero emissions, abandoning
the MA protocol for counting CO2 emissions from these fuels.
●
DOER has eliminated all the Massachusetts-specific forest harvesting criteria
that were designed to protect forests, maintain soil fertility, and protect
from
over harvesting, and replaced them with vague and unenforceable forest industry
language about “sustainable harvesting.” This is ignorant of all that we
know about
the
Climate Crisis and the way that trees serve to sequester CO2 emissions.
●
DOER’s proposal will enable the 35 megawatt Palmer Renewable Energy
biomass plant to be constructed in East Springfield and collect an estimated
$10
million to $12 million per year from electricity ratepayers, adding more
pollution to
an already overburdened environmental justice community. Springfield was
named “Asthma Capital” of the US in 2018 by the Asthma and Allergy
Foundation of America based on asthma prevalence, emergency room visits, and
asthma-related deaths.
threaten public health and the
environment. Emissions from biomass power
plants contribute to acute and
chronic health problems including asthma, heart
disease, diabetes, and cancer.
● Climate scientists warn us
that to avoid catastrophic warming, we must cut GHG
emissions in half in the next
ten years and take CO 2 that’s already been emitted out of
the atmosphere – most likely by restoring and expanding carbon
sequestration in forests. DOER’s proposal heads us in the wrong direction – it incentivizes logging and burning trees for energy, which will increase CO 2 emissions and decrease carbon sequestration.
Please
act for a good future to be possible and pay attention to agreements made under
good guidance from climate science! Our lives depend on it!
Sincerely,
Rebecca Hull
76 Stony Hill Road
Amherst, MA 01002