From: Ezzell Floranina <ezzellfloranina@gmail.com>
Sent: Wednesday, June 5, 2019 4:20 PM
To: RPS, DOER (ENE)
Subject: BioMass Hearing and decisions
To All Lawmakers in Massachusetts:
As a person making their home in the forest of W. Mass. it is imperative that the 2012 RPS
rules be adhered to, pursuant to: " The Massachusetts
Department of Energy Resources (DOER) is proposing to
substantially roll back hard-won 2012 environmental and health protections
governing woody biomass in the state’s Renewable Portfolio Standard (RPS)"
My response along with many others living in the state, who might not be able to attend a hearing date
that was changed at the last minute. Please note the bold print:
● The 2012 Massachusetts RPS biomass rules were developed
based on a
scientific study of bioenergy carbon impacts (known as the “Manomet Study”),
and were the first in the nation and the world to recognize that burning trees
for
energy increases greenhouse gas emissions. GREAT.
● DOER is proposing to reduce or completely eliminate all
the core requirements of
the 2012 RPS rules. NOT Great!
● DOER is proposing to eliminate efficiency criteria for
biomass power plants that
burn broadly defined categories of “salvage” wood and residues. This will allow
construction of massive electric-only plants, such as a proposed 35-megawatt
biomass power plant in East Springfield, instead of the small, efficient
combined
heat and power (CHP) plants that were promoted under the 2012 rules.
● DOER is proposing to extend the timeframe for biomass
facilities to show a net
reduction in GHG emissions relative to fossil fueled plants from 20 years to 30
years -- when climate scientists are telling us we only have 10 years to
slash
GHG emissions in order to prevent catastrophic climate change. Actually,
at a
recent Climate Reality Leadership conference with Al Gore, a panel of climate
scientists recommend that we think in terms of ONE YEAR, not 10 or 12! Too much
is not understood and things are happening fast.
● DOER is proposing to allow biomass power plants to burn a huge variety of
woody fuels, including whole trees, that DOER is re-classifying as “residues”
to
allow calculation of a minimal carbon impact, even though the Manomet
definition
of residues was confined to tops and limbs from saw/timber harvesting.
Whole trees are Not residue! They are perhaps one of our most efficient
sequestration agents for CO2.
● DOER’s calculations for determining the lifecycle CO 2
emissions from bio-energy
ignores fossil fuels burned during harvesting, processing, and transport of
biomass – even though such emissions can be considerable for certain fuels,
especially wood pellets. And the subsequent shipping and transfer of wood
pellets
to outside markets in totally unsustainable in terms of usage of energy per gain. We, in
Massachusetts and the planet lose terribly in this industry that masquerades as "green".
For more information about the impacts of biomass energy visit www.pfpi.net
● DOER is proposing to treat liquid biofuels as having zero emissions, abandoning
the MA protocol for counting CO2 emissions from these fuels.
● DOER has eliminated all the Massachusetts-specific forest
harvesting criteria
that were designed to protect forests, maintain soil fertility, and protect
from
overharvesting, and replaced them with vague and unenforceable forest industry
language about “sustainable harvesting.” This is ignorant of all that we
know about
the Climate Crisis and the way that trees serve to sequester CO2 emissions.
● DOER’s proposal will enable the 35 megawatt Palmer
Renewable Energy
biomass plant to be constructed in East Springfield and collect an estimated
$10
million to $12 million per year from electricity ratepayers, adding more
pollution to
an already overburdened environmental justice community. Springfield was
named “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.
threaten public health and the environment. Emissions from biomass power
plants contribute to acute and chronic health problems including asthma, heart
disease, diabetes, and cancer.
● Climate scientists warn us that to avoid catastrophic warming, we must cut GHG
emissions in half in the next ten years and take CO 2 that’s already been emitted out of the atmosphere – most likely by restoring and expanding carbon
sequestration in forests. DOER’s proposal heads us in the wrong direction – it incentivizes logging and burning trees for energy, which will increase CO 2 emissions and decrease carbon sequestration.
Please act for the future to be possible and pay attention to agreements made under good guidance from climate science! Our lives depend on it!
Sincerely,
Ezzell Floranina
Artistic Director, The Rainbow Players
http://www.etta-international.org
Empowerment Through The Arts
http://etta-international.blogspot.com/
413-256-1205