From: Peter Lowitt <peter.lowitt@verizon.net>
Sent: Wednesday, July 17, 2019 8:48 AM
To: RPS, DOER (ENE)
Subject: Comments on proposed changes to Class RPS I and RPS II
Regulations
To the commissioner,
I object to adding wood-chip biomass into the Renewable Power
Standard, for a number of reasons outlined below.
Summary of objections:
1)
Biomass
is not a low-emissions fuel source, for a number of reasons
a.
Relatively
low efficiency plant
b.
CO2
emissions higher than coal, oil or natural gas
c.
Energy
intensive to harvest and prepare fuel
d.
Replacement
trees take several decades to regrow
2)
Wood
biomass is being considered for the RPS, which is a bad idea for several
reasons
a.
Previous
administration decided not to include it, because it isn’t carbon neutral
b.
Exportation
of biomass to the UK (since included in their equivalent of RPS) is devastating
forested parts of the southeast US. This could happen in the Commonwealth and
New England
c.
Biomass
industry presents itself as ‘environmentally friendly’ but it considers forest
resources not put to productive use as lost income.
3)
We
are currently in a biodiversity crash (“the sixth extinction) during our
lifetime
a.
Population
of wild vertebrates and insects down by 70% from 30 years ago
b.
Million
species may be lost in next decades
c.
Need
for wildlife corridors to be expanded and protected (EO Wilson)
d.
Growing
wood chip market will put pressure on forests throughout New England
4)
Wood
chip biomass emits particulate emissions
a.
PM2.5
levels lead to higher levels of Asthma
b.
Why
are biomass plant being planned for disadvantaged communities such as
Springfield and Palmer?
c.
Original
intention was to burn construction and demolition debris, aggravating emissions
5)
If
you consider allowing these changes please include conditions to require
reforestation (including bonding to assure replanting) and the use of
sustainable certified forestry methods. The problem is the lag time
between replanting and the production of carbon offsetting growth (30-50 years)
that we do not have.
Summary:
I commend Belmont, Concord, Holden and Middleborough municipal
utilities for deciding against the purchase of biomass electricity.
I ask the Baker administration to not add wood chip biomass to the
Renewable Power Standard. We are in a climate crisis. It doesn’t
make sense to adopt a policy that encourages the destruction of our largest
carbon sinks, our forests.
5 Westvale Drive
Concord, MA 01742