From: Tom Chamberland <tchamberland@town.sturbridge.ma.us>
Sent: Friday, June 7, 2019 8:26 AM
To: RPS, DOER (ENE); tchamberland301@gmail.com
Subject: Comments on RPS Class 1 & 2 reg changes
Department of Energy Resources,
100 Cambridge Street, Suite 1020, Boston, MA 02114
From: Thomas A.
Chamberland,
Town of Sturbridge Tree Warden,
Sturbridge MA 01566
RE: Comments on amending 225 CMR 14.00 & 15.00
Dear Sir,
I would like to express my support for the
changes to 225
CMR 14.00--Renewable Energy Portfolio Standard – Class I and 225 CMR
15--Renewable Energy Portfolio Standard – Class II. As a municipal Tree
Warden for over 35 years, of one my primary concerns in expending taxpayer funds is
the current and future costs of woody debris disposal, from both routine and
emergency/natural disaster events.
Currently, every community I know (I am a Past
President of the Massachusetts Tree Warden’s and Foresters Assoc. the oldest
tree protection organization in the United States) has stockpiles of wood
debris and chips originating from routine tree trimming operations and electric
utility line clearance maintenance work. In Sturbridge that pile now
exceeds 4250 Cu Yards. Some of it is composted, some is used for road
shoulder stabilization/erosion control and trail work. However, the
supply is far greater that the demand. Consequently, the Town of
Sturbridge now restrict utilities from dumping their chips at our site and we
encourage our tree contractors to find other disposal methods, which increase
our “down time” due to transportation and reducing the productivity of the tree
crew, and it now costs the town $10 per cubic yard to dispose of large woody
debris material, when previously we paid nothing.
During FEMA-declared natural disasters, disposal
of woody debris, which may also include grindings of larger wood parts, is a
part of the reimbursable cost structure. However not all-natural
disasters rise in scope to be FEMA eligible/declared. A prime example of
the latter is our current gypsy moth/drought tree mortality situation. Due to
this natural event, the town of Sturbridge in the unfortunate process of
removing over 650 public street trees, at a cost exceeding $270,000 (estimated
wood disposal cost is $40,000). I feel most of these costs could have
been avoided had the changes proposed in the draft regulations been in place
already.
As a member of the US Forest Service Urban
Forest Strike Team national advisory committee, (UFST) I train Arborists to
help communities recover following natural disasters, I am well aware that
contractors who bid this work are finding it increasing harder to “market” and
re purpose/use this woody debris. I see several reasons for this situation.
Of prime concern is a lack of regional demand for and ability to use wood
debris in co-generation/utility heating, the oversupply in the mulch market,
and lack of marketability for communities from routine tree work and localized
natural disasters.
I attended several of the public hearings and
noted the concern expressed by some of the potential degraded air quality, etc.
if these regulations were to be adopted. When there is no viable
market for municipal large wood debris, if left along the side of the road is
usually picked up by local residents for burning in old wood stoves, thus
increasing air quality concerns. If a viable market is created, as envisioned
by the regulatory changes, even though burned, thru much more refined
equipment, would result in improved air quality, and a financial return to the
communities, by having a market for this wood.
It is clear to me that the intent of this
regulatory change it to recognize the fossil fuel displacement value of the
woody material that we make every day. With that recognition in mind, to
better capture actual events I recommend the following word changes to the regulations:
1: I am concerned that chips from land
clearing have removed from RPS eligibility. As an elected
official within my community I can attest to the rigor my town considers any
proposed land clearing (schools, ballfields, other municipal expansions).
While I do not like the fact that this is a land use change, I
recognize that these chips are unavoidable. Thus, like the wood
originating from other non-forest activities, I recommend the re-inclusion of
this unavoidable material within the RPS.
2: 225 CMR 14.00: 14.02 definitions, eligible
biomass woody fuel (d) 3: Wood waste: Post-consumer wood products from Clean Wood; pruned
branches, stumps, and whole trees removed during the normal course of
maintenance of public or private roads, highways, driveways, utility lines,
rights of way, and parks. After the words “normal course of maintenance” may preclude
storm/natural disaster/insect infestations response, please add: “, or other
natural events”
I fully support the amended changes to portions of 225 CMR
14--Renewable Energy Portfolio Standard – Class I and 225 CMR 15--Renewable
Energy Portfolio Standard – Class II and recommend their adoption.
Respectfully:
Thomas A. Chamberland
Thomas A. Chamberland
Sturbridge Tree Warden
Email: DOER.RPS@mass.gov