From: David Greenberg <david.greenberg3@gmail.com>
Sent: Friday, June 7, 2019 6:59 AM
To: RPS, DOER (ENE)
Subject: Proposed Changes in RPS regulations
Dear Mr. Wassam,
I am extremely disappointed to see Massachusetts, a leader in taking action to protect the environment and combat global warming, proposing to substantially weaken the RPS regulations by eliminating efficiency criteria for biomass power plants. The 2012 Massachusetts RPS biomass rules were developed based on the results of a scientific study of bioenergy carbon impacts and that science has not changed in the intervening years.
Furthermore, extending the timeframe for biomass facilities to show a net reduction in GHG emissions relative to fossil fueled plants from 20 years to 30 years is totally irresponsible when climate scientists are telling us we only have 10 years to slash GHG emissions in order to prevent catastrophic climate change.
The proposal 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, is thoroughly inconsistent with the Manomet definition of residues which was confined to tops and limbs from sawtimber harvesting.
DOER is proposing that the Commonwealth take a huge step backward in the fight against global warming and these regulations will do irreparable harm to our Commonwealth, its natural resources and its people. I urge you to abandon these proposed changes to the RPS regulations.
Respectfully submitted,
David Greenberg
Colrain MA