From:                                         Alison M. Leary <aleary@newtonma.gov>

Sent:                                           Thursday, June 6, 2019 2:01 PM

To:                                               RPS, DOER (ENE)

Cc:                                               John.Lawn@mahouse.gov; Robert.DeLeo@mahouse.gov; Karen.Spilka@masenate.gov; Ruthanne Fuller; cynthia.creem@masenate.gov; Emily Norton; hbrown@clarku.edu

Subject:                                     RPS Class I and RPS Class II Rulemaking - 225 CMR 14.00 and 225 CMR 15.00

 

Massachusetts Department of Energy Resources
Attn: John Wassam
100 Cambridge Street, Suite 1020

Boston, MA 02114

 

 

Dear Mr.Wasserman,


It has come to my attention that the Baker Administration is considering changes to the Massachusetts’ Renewable Portfolio Standard (“RPS”) Class I and RPS Class II Regulations. The proposed change includes renewable energy regulations to increase incentives for biomass and trash incinerators in Massachusetts.  I am very unhappy about DOER’s proposals. These are contrary to all our climate goals. Burning woody biomass and incinerating trash for electricity without adequate lifecycle standards results in GHG emissions that undercut climate gains. These technologies also cause harmful local air pollution that compromises public health.

 

Burning garbage is not “clean.”  Garbage burners emit more carbon dioxide and conventional air pollutants per unit of energy than coal plants, and are significant sources of hazardous emissions such as mercury, dioxin, volatile organic compounds (VOCs), and heavy metals. They are also very expensive to operate. In fact, it is one of the most inefficient and expensive methods to dispose of trash which is why the incinerator industry is perpetually seeking additional renewable energy subsidies – even though they already receive revenue from both tipping fees and sales of electricity. We are already producing some 750,000 tons of incinerator ash containing heavy metals, furans, and dioxin each year, which must be disposed of rapidly dwindling landfills.  



Climate change is occurring at an accelerated rate. Increasingly, its impacts are being felt in communities and across all sectors of the Commonwealth. Decarbonization of the electric sector is the most cost-effective way to achieve deep greenhouse gas (“GHG”) emission reductions required to comply with mandates set by the Global Warming Solutions Act (“GWSA”)  Accordingly, Massachusetts’ RPS—one of the longest-standing, most science-based standards in the nation—has not only been an essential driver of clean energy development in the state and the region, but it is also a critically important component of the Commonwealth’s GWSA compliance strategy. Now is not the time to ease its stringency. And yet, that is what has been put forth by DOER as part of this rulemaking.



The Governor and House and Senate leadership should flex some political muscle to send the right policy signals that encourage waste reduction, re-use and recycling. We must also require that the manufacturers and producers of consumer products part of the solution instead of giving them a free pass.  The private sector is integral to solving our waste problem yet they historically have made little effort to work with the recycling processors to optimize recyclability of the materials they are putting on the market and take more ownership over the end use of their products.  This has been frustrating for the recycling industry as well as the cities and town which are forced to take on much of the costs for recycling programs.  We must make more progress on policies like requiring more recycled content, or for manufacturers to be responsible for the proper management of their products at the end of their useful life. 

 

Weakening standards to allow more burning is short sighted, counterproductive and a simply a very poor policy decision which is a direct result of our failure to achieve more sustainable solutions to our “use it once and throw it out” consumer mentality. We can and must do better.

 

 

Kind regards,

 

Alison M. Leary

Newton City Council

Ward 1

617-821-5619


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