From:                                         Dale LaBonte <dale.labonte@gmail.com>

Sent:                                           Thursday, June 6, 2019 4:22 PM

To:                                               RPS, DOER (ENE)

Cc:                                               jo.comerford@masenate.gov; lindsay.sabadosa@mahouse.gov

Subject:                                     Proposed changes to Renewable Portfolio Standards

 

Date: June 6, 2019

To: John Wassam, DOER.RPS@mass.gov

Re: Renewable Portfolio Standards

From: Dale LaBonte, 32 Crabapple Lane, Northampton MA 01060 dale.labonte@gmail.com

 

I am writing to oppose the roll-back of standards on biomass as part of the renewable portfolio standards (RPS) in Massachusetts. This is based on three concerns:

 

Greenhouse gas emissions:

The purpose of increasing renewables is to reduce the emitting of greenhouse gases (GHG) that fuel climate change. Carbon is one of those gases. Burning wood, wood pellets, “forest residues,” etc. produces more carbon than coal or natural gas. Biomass used to generate electricity emits 150% of the CO2 of coal plants and 300-400% the CO2 of natural gas plants. It is counterproductive to the purpose of reducing GHGs to promote technologies which increase those emissions exponentially. It is also inappropriate to subsidize plants in other New England states which do the same.

 

Air quality:

While burning wood in place of fossil fuels does nothing to reduce greenhouse gas emissions, it will add more particulates to already compromised environments in both urban and rural communities. This is especially true in Springfield, but would also be a factor in other cities where truck and auto emissions, manufacturing, and trash-to-energy incinerators exist. Bad health outcomes attributable to pollution have already been documented along traffic corridors. There is no way to prevent biomass smoke from adding to these hazards. Rural areas, where wood cutting occurs, will experience increased dust and diesel emissions from logging and transport activities.

 

Carbon sequestration:

Recent evidence that the climate crisis would be much worse without the mitigating effect of existing forests is remarkable. Add forest protection to the RPS and the state will have solved one of its dilemmas--how to increase renewables from year-to-year. This could be achieved by changing the model from forests managed for timber harvest to forests managed for sequestration. It would ensure the continued and increasing ecosystem services of cooling and providing wildlife habitat. Let the larger trees continue to take more carbon out of the atmosphere and store it in the soil. Use carbon taxes to pay owners of land-locked forest tracts to preserve these natural carbon sinks.

 

Instead of subsidizing inefficient burning and scientifically unsound forest practices, retain the 2012 RPS rules. These allow biomass power plants that meet strict efficiency criteria (like combined-heat-and-power plants). They also require biomass power plant operators to provide fuel supply plans that show they are getting the majority of their fuel from “forestry residues” rather than whole trees.