From:                                         Ava Gips <avagips@comcast.net>

Sent:                                           Friday, June 7, 2019 4:10 PM

To:                                               RPS, DOER (ENE)

Cc:                                               natalie.blais@mahouse.gov; jo.comerford@masenate.gov

Subject:                                     Proposed changes on biomass regulations

 

Dear Sir, 

 

I wholeheartedly oppose the DOER’s proposed changes that would weaken the protective regulations that currently restrict biomass, the burning of wood, in the Renewable Portfolio Standard.  These proposed changes would provide incentives for burning biomass and TRASH, and would likely promote the development of the East Springfield “Palmer “biomass plant.  The changes would also eliminate efficiency standards for burning biomass.

 

I attended the Amherst hearing at UMASS on May 16, 2019, but decided not to speak because there were so many speakers, almost all of them against the proposed changes.

 

I wholeheartedly support three important pieces of state legislation (H853, H897, and S438/H873).  

 

The Partnership for Policy Integrity, PFPI, http://www.pfpi.net/rps-biomass-overview, has a concise overview of the proposed RPS changes regarding biomass.  I am quoting them below.  

 

Thank you for your consideration.

 

MA  Resident and Taxpayer,  Ava Gips  617 River Road, Deerfield, MA 01342

 

 

Key Takeaway:  The betrayal of the 2012 compromise on bioenergy, forests, and climate

Proposed changes would roll back every meaningful protection in the MA biomass rules

Will allow the Palmer Renewable Energy plant (35 MW electricity-only) to be built in Springfield

Financial support for a polluting industry, when we should be focusing on non-emitting power

            DOER’s “wood availability” study cedes the forest carbon sink to biomass developers

The biomass regulations should be strengthened to reflect climate urgency, not weakened

 

Current state of MA bioenergy, forests, and climate science

Climate scientists say we need to cut emissions in half in the next ten years

Biomass power plants emit more CO2 pollution than coal or gas plants; the impact lasts decades

Massachusetts biomass rules lead the nation and the world; DOER wants to roll them back

MA and New England are already falling short of our emission reduction goals

Renewable energy in MA and New England is dominated by wood and garbage-burning

 

DOER’s proposal will increase CO2 emissions from wood-burning power plants

Eliminates definition and reporting of lifecycle GHG emissions

Changes timeframe for bioenergy GHG “benefit” from 20 years to 30 years (should be 10 or less!)

Reduces plant efficiency requirement for plants burning forest residues and thinnings

Eliminates efficiency requirement for “salvage” wood and non-forest residues

Counts fuel-drying as “useful” energy, thereby increasing net CO2 emissions

Allows “offsetting” of emissions violations from year to year

 

Proposal will increase air pollution from bioenergy

Eliminates requirement that plants demonstrate they can meet emissions criteria

 

Proposal increases wood treated falsely as having “low” or “zero” emissions

Over-represents benefits of forestry residues, then broadly classifies fuels as residues

Defines trees damaged during logging operations, trees harvested for restoration as “residues”

Defines more trees as “thinnings” 

Massively increases amount of wood classified as “salvage”

Expands definition of mill residues

Post-consumer wood & agricultural wood waste: Classified as non-forestry residues with minimal carbon impact

Retains classification of trees cut for agriculture as non-forest residues

Abolishes definition of energy crops

 

Proposal would increase emissions from liquid/gaseous biofuels 

Adopts carbon accounting that treats all biomass as having zero carbon emissions

 

Reduces accountability, transparency, & citizen oversight of GHG accounting

Reduces and eliminates protections for forests adopted in the 2012 rules 

Replaces real metrics with bogus “Sustainable Forestry” provisions