From:                                         LaRocque, Regina C.,M.D.,M.P.H. <RCLAROCQUE@mgh.harvard.edu>

Sent:                                           Thursday, July 25, 2019 1:36 PM

To:                                               RPS, DOER (ENE)

Subject:                                     RPS Class I (225 CMR 14.00) and RPS Class II (225 CMR 15.00) Regulations Changes

 

Categories:                              Saved as HTML

 

John Wassam

Department of Energy Resources

100 Cambridge Street, Suite 1020

Boston, MA 02114

 

Dear Mr. Wassam,

 

I am writing to share my objection to the proposed changes to RPS Class I and II regulations that would allow for increased burning of biomass.

 

I recently co-authored an op-ed outlining these concerns that was published in the Worcester Telegram (see here). The text is below:

 

Burning Wood is No Way to Fight Climate Change

 

By Nisha Swinton and Regina LaRocque

 

If you want to put out a fire, you don’t throw more fuel on the flames. And so it goes with our warming planet; climate policy can be complicated, but one part is straight-forward: We literally need to stop burning things.

 

Unfortunately, Governor Charlie Baker’s administration is gearing up to literally throw some wood on the fire, rolling back rules for the use of biofuels as an energy source in Massachusetts. In other words, the state could use subsidies to build additional wood burning plants-- all under the banner of growing the state’s renewable energy program.

 

A 2018 law sets a course for slowly expanding Massachusetts’ renewable portfolio standard (RPS). These state-based programs are among the most effective tools we have to encourage more clean energy. But when they are poorly designed, they can actually throw money at dirty power sources--anything from burning wood to animal waste and landfill gas. The current proposal would benefit powerful special interests, while spewing carbon into the atmosphere and leaving nearby communities to suffer from the effects of increased air pollution.

 

So how exactly does dirty energy get transformed into clean energy? Simple: the state changes how it calculates the impact that burning biofuels will have on warming the planet. Right now, Massachusetts has a stringent, scientifically robust process for understanding the full scope of biofuels and greenhouse gas emissions. This proposal will eliminate these lifecycle standards, and replace them with ‘regulatory guidance’ that simply compares biofuels to fuel oil or gas power plants. By changing the rules, biofuels come out looking like a cleaner alternative to fossil fuels.

 

While this new test is designed to show that burning wood represents a reduction in greenhouse gases, ‘slightly better than the status quo’ is not what we need to do to stabilize the climate. The recent Intergovernmental Panel on Climate Change (IPCC) report states that we need to achieve net zero greenhouse gas emissions in 30 years. That means we must dramatically drive down those planet-warming emissions in the next decade, not switch from one type of emissions to another.

 

Beyond considering these climate goals, burning biofuels should not be considered renewable energy--in Massachusetts or anywhere else. In Europe, a jump in the use of biomass for energy saw a 10% to 30% increase in particulate matter across different regions of the continent. Biomass is also associated with a range of harmful emissions like nitrogen oxides, sulfur dioxide, lead and mercury, some of which are as bad or worse than coal. These emissions can increase rates of lung cancer, asthma, and heart disease. That’s why community activists in Springfield have been so tenacious in opposing a massive new biomass plant; they will be the ones directly impacted by the dirty emissions.

 

As the state expands its renewable energy program, approving this biomass proposal would create a foothold for an industry that will push hard for other profitable polluting schemes. Factory farms would have an additional incentive to increase herd sizes, since they would sell animal waste for a profit. Facilities that burn wood trimmings from forestry waste would seek to weaken limits on where they operate in order to expand their fuel sources. And we would also create competition for land that could otherwise be used for food production or preservation of natural habitats.

 

Increasing the burning of biomass is not a transition to clean renewable energy, but rather a dangerous distraction that will cost ratepayers money while undermining efforts to enact real clean energy policies. Rep. Denise Provost has introduced a bill that would remove biomass from the state’s Alternative Portfolio Standards program. Passing that bill would be a good first start; but Governor Baker should withdraw this proposal and implement a plan to stop the expansion of dirty energy sources that pollute our air and warm our planet.

 

Thank you for your consideration.

 

Regina LaRocque, MD MPH FIDSA

Division of Infectious Diseases

Massachusetts General Hospital GRJ 520

55 Fruit Street, Boston, MA 02114

(617) 643-5557

 

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