From:                                         Andra Rose <amherstamr@gmail.com>

Sent:                                           Thursday, June 6, 2019 3:35 PM

To:                                               RPS, DOER (ENE)

Subject:                                     RPS Class I and RPS Class II Rulemaking - 225 CMR 14.00 and 225 CMR 15.00 - Mothers Out Front Stakeholder Comments

 

June 6, 2019

 

Massachusetts Department of Energy Resources

Attn: John Wassam

100 Cambridge Street, Suite 1020

Boston, MA 02114

 

--- submitted electronically via doer.rps@mass.gov ---

 

Re: RPS Class I and RPS Class II Rulemaking - 225 CMR 14.00 and 225 CMR 15.00 - Mothers Out Front Stakeholder Comments

 

Dear Mr. Wassam:

 

We, the mothers of Massachusetts’ children, thank you for the opportunity to provide comments regarding the proposed changes to Massachusetts’ Renewable Portfolio Standard (“RPS”) Class I and RPS Class II Regulations. Mothers Out Front is a national grassroots organization committed to creating a swift, just and complete transition to a clean energy future for our children. We have over 7000 members in Massachusetts alone.

 

We oppose the changes the Department of Energy Resources has proposed to the Renewable Portfolio Standard Class I and Class II regulations. Wood burning power plants harm our children’s health, as they do the earth’s. Environmental justice communities are particularly impacted because biomass plants sited in their neighborhoods add to existing health threats. Wood burning electricity generation would increase our state’s GHG emissions. Woody biomass is not renewable in the short window we have for dramatically reducing the carbon intensity of our electricity.

 

We oppose the rule changes for the following reasons:

  • The proposed regulations roll back or eliminate all of the 2012 science-based standards by expanding what types of wood can qualify. By subsidizing new and existing polluting biomass power plants in MA and New England, these regulations will be a windfall for the biomass industry but make the people of Massachusetts sick.
  • The 2012 Massachusetts RPS biomass rules were developed based on a scientific study of bioenergy carbon impacts (the “Manomet Study”). They were the first standards in the nation and the world to recognize that burning living trees for energy increases greenhouse gas emissions.
  • Changing the efficiency criteria for biomass power plants and other rule changes will enable the construction of polluting infrastructure such as the Palmer Renewable Energy biomass plant in East Springfield. This plant, currently permitted to be constructed under the original rules, would only add more pollution to a city that was named the “Asthma Capital” of the US in 2018 by the Asthma and Allergy Foundation of America based on asthma prevalence, emergency room visits, and asthma-related deaths.
  • Emissions from biomass power plants contribute not only to asthma but to heart disease, diabetes, and cancer. Burning wood emits similar levels and a similar range of pollutants as burning coal, including sulphur dioxide and mercury, as well as Volatile Organic Compounds. The largest volume of air pollutants are oxides of nitrogen (NOx), carbon monoxide (CO), small particulates (PM10, including PM2.5) and sulphur dioxide (SO2). Burning wood can also result in a wide range of other pollutants. These include antimony, arsenic, aadmium, chromium, copper, dioxins and furans, lead, anganese, mercury, nickel, polycyclic aromatic hydrocarbons (PAHs), selenium, vanadium and zinc.
  • The proposed rules eliminate all the Massachusetts-specific forest harvesting criteria that were designed to protect forests, maintain soil fertility, and protect from overharvesting and instead replace them with vague and unenforceable forest industry language about “sustainable harvesting.” Trees and soil are the best carbon capture technology we have today. Carbon needs to stay in our trees, not in the air we breathe.

 

We count on the DOER to do what is right for our children’s future and their health. Taxpayers contribute an estimated $10 to $12 million per year to subsidize clean renewable energy. We must not be forced to pay incentives for dirty energy that damages our health and the health of the planet, which we now know are closely connected. We urge you not to implement the proposed changes to the RPS.

Thank you,

Andra Rose, for Massachusetts Mothers Out Front

amherstamr@gmail.com