From: Gabriel Robinson <robinsongabriel64@gmail.com>
Sent: Friday, July 26, 2019 9:59 AM
To: RPS, DOER (ENE)
Subject: comment on proposed changes to RPS Class I and II
regulations
Dear
Mr. Wassam,
I
am writing to express my opposition to the proposed changes in the RPS Class I
and RPS Class II regulations.
We
need to be treating climate change as the serious, existential threat that it
is and working in earnest to cut CO2 emissions, foster non-polluting sources of
energy, and protect and extend carbon-locking systems such as forests. The
changes proposed by the DOER demonstrate that it is NOT serious about our health,
safety, and future. The proposed changes would roll back the protections built
into our current biomass regulations, give support to a polluting industry, and
turn forests that are currently carbon sinks over to biomass developers—moving
headlong in the wrong direction.
We
need to cut our carbon emissions in half over the next ten years. Yet the
DOER’s proposed changes would increase carbon emissions, by eliminating
the definition and reporting requirements for lifecycle greenhouse gas
emissions, extending the timeframe for demonstrating a greenhouse gas “benefit”
from 20 to 30 years, reducing efficiency requirements for plants burning forest
residues and thinnings (while increasing the amount of wood classified as
“residues”), eliminating the efficiency requirements for salvage wood (while
greatly expanding the definition of what counts as “salvage”), and eliminating
the requirement that plants demonstrate they can meet air pollution emissions
criteria.
It
is a massive giveaway to a polluting industry, and it is utterly disingenuous
to count the energy generated in this manner, with such non-serious standards,
toward meeting the RPS goals.
Please
do not make these changes, and instead work toward making Massachusetts a
leader in renewable energy and truly sustainable forestry.
Thank
you,
Gabriel
Robinson
26
McTernan St. #3
Cambridge,
MA 02139
(617)
955-3487