From:                                         Climate Coalition of Somerville <info@ccsomerville.org>

Sent:                                           Friday, June 7, 2019 8:45 AM

To:                                               RPS, DOER (ENE)

Subject:                                     Comments to the proposed changes in the RPS class I & II rulemaking (225 CMR 14.00 and 225 CMR 15.00)

 

Dear John Wassam:

 

We, the Climate Coalition of Somerville (CCS, https://www.ccsomerville.com/), send this letter to you today in earnest request that the Mass DOER re-examine the recently proposed changes to the Renewable Portfolio Standard (i.e. biomass burning) and, as an entity responsible to Massachusetts communities and for supporting energy sources that benefit environmental and public health, adamantly reject these changes.

 

CCS is a coalition of advocacy groups collectively invested in driving environmental sustainability in Somerville, MA, and beyond. We work to accelerate equitable climate mitigation and resilience efforts across our city. We care about clean renewable energy, green space, environmental justice, energy efficient buildings, and sustainable transportation.

 

We are troubled by the proposed changes in the Renewable Portfolio Standard (RPS) Class I & II (225 CMR 14.00 and 225 CMR 15.00). These changes would effectively weaken the existing restrictions on the use of biomass burning in our RPS, something that we strongly oppose, and with good reason.

 

Biomass burning is a well-recognized contributor to both air pollution and climate change due to emissions of particulate matter (in the form of both organic and black carbon) and toxic gases. These gases include carbon dioxide, carbon monoxide, nitrogen oxides, and carcinogens such as formaldehyde and dioxins. Any biomass combustion process – no matter how ‘clean’ or ‘efficient’ it may be labeled – inevitably emits air pollutants and greenhouse gases (GHG). We believe that biomass burning should not be incentivized in any of the energy portfolios in Massachusetts and certainly should not increase in the Class I RPS. We need clean, not dirty renewables.

 

The implications of wood and biomass burning for climate change are well known. A 2017 study already explained how the use of biomass as fossil fuel replacement can rebound negatively in terms of GHG emissions and a more recent study suggests that wood burning is as bad as coal. Research done across Europe, where residential burning is very common, has shown that biomass burning is an unsustainable form of energy. Broad scientific consensus exists on the fact that we are at a pivotal moment in terms of deciding the fate of our planet. Disruptive climate change is well underway across the world and we believe that purposely allowing more biomass burning to generate energy that should be created by clean sources is simply irresponsible at this point in time.  

 

Biomass burning also impacts human health. Incinerators that produce electricity at industrial scale from biomass and waste burning produce large amounts of pollution that is highly toxic to humans. Moreover, these facilities are often located in low income communities, exacerbating the health outcome of a population that is already taking the brunt of our cumulative pollution.

We are aware that the suggested RPS changes would open the doors to giving subsidies to the proposed Palmer “Renewable Energy" plant in Springfield, which would dramatically increase pollution in an area that has already been defined as the ‘asthma capital of America’. The American Lung Association (ALA) has already rated Massachusetts poorly in their most recent report, pointing out the progressively degrading air quality across the state.

 

Loosening the definition of Class I renewables would represent an enormous setback from all the progress that Massachusetts made in cleaning the electric grid in the last 20 years.

 

We encourage the Baker administration to abandon this RPS change proposal and, instead, focus its efforts on increasing the amounts of clean renewables, solar and wind.

 

Respectfully,

 

The Climate Coalition of Somerville