Dear Governor Baker,
The proposed changes to RPS Class I, especially the
changes that reduce or eliminate the core requirements of the 2012 RPS bioenergy
rules, are alarming. In particular, the DOER plans reductions in facility
efficiency criteria, increases in the allowed variety of wood, including whole
trees, increasing from 20 years to 30 years the time frame for plants to show a
net reduction in GHG emissions relative to fossil fuels, calculation of
lifecycle CO2 emissions that ignore fossil fuels used in harvesting, processing
and transport, elimination of requirements for liquid fuels to show a real
reduction in GHG’s, and the removal of Massachusetts-specific forest harvesting
criteria.
Your administration is aware that the climate crisis is
real, is urgent, and that the time window for dramatic action is just a few
years. These proposals are entirely contrary to the public good, contrary to
everyone's health, and especially contrary to the health of children and older
adults.
Clean energy does not come out of a smokestack. Burning
wood is a highly emitting source of energy, and there is no longer time to grow
new forests to recapture the emissions. Moreover, living forests sequester CO2.
Health impacts are an immediate consequence of wood burning. The Commonwealth
and its citizens cannot afford increased health care costs and reductions in
quality of life due to illness caused by particulate matter pollution.
I urge you to withdraw the proposed eligibility changes
to RPS Class I and Class II.
Thank you for your support,
David Miller