From: Christine Labich <clabich77@gmail.com>
Sent: Wednesday, May 15, 2019 11:05 AM
To: RPS, DOER (ENE)
Subject: Public Comment on RPS Class I and RPS Class II Regulations
Christine Labich
948 East Pleasant St.
Amherst, MA 01002
John Wassam
Massachusetts Department of Energy
Resources
100 Cambridge Street,
Suite 1020
Boston, MA 02114
Public Comment on April 5, 2019
draft regulations to amend portions of 225 CMR 14--Renewable Energy
Portfolio Standard – Class I (“RPS Class I”) and 225 CMR 15--Renewable Energy
Portfolio Standard – Class II (“RPS Class II”).
I am here to speak against the
dismantling of the scientifically-based, protective regulations that restrict
biomass and waste incineration as part of Massachusetts’ Renewable Portfolio
Standard. I am frankly amazed at this attempt to undermine the fundamental
goals of the RPS and to weaken provisions that protect public health and the
health of ecosystem functions upon which we all depend.
In it’s October, 2018 Summary for
Policymakers, the Intergovernmental Panel on Climate Change offers clear
guidance on what steps are needed immediately to prevent the earth from
catastrophic warming and climate disruption. In short, drastic reductions in
Greenhouse Gasses (GHG) are required immediately. These proposed changes to the
RPS allow net GHG emissions to exceed those of fossil fuel plants within the
very time horizon that represents our only chance to meaningfully address
climate change. In addition, they fail to take into consideration the total
carbon impact of harvesting, transporting, and processing biomass, and they
open the door to harvesting the very trees that could be helping us sequester
carbon—instead releasing it into the atmosphere. It is clear that healthy
forests are our ally in both sequestering carbon and providing ecosystem
services such as improving water quality, but these proposals eliminate
specific protections designed to protect forests and maintain soil fertility.
Climate Change is a public health
issue in itself. But, in addition, these proposed changes threaten respiratory
health by weakening requirements for controlling particulate matter and opening
the door to burning contaminated and hazardous materials. Massachusetts already
has a higher rate of asthma than the national average. Several members of my
family have asthma, and I know that it affects all aspects of life. Weakening
these protections would affect the most vulnerable in our commonwealth and
beyond—children, the elderly, the health-compromised, and people living with
low income. These are the very populations that a clean energy portfolio should
be geared toward protecting.
Given the clear scientific evidence
that these proposed changes would undermine the RPS as a meaningful policy that
addresses net GHG emissions and public health, I, and many others who could not
be here today, ask that you keep the protective measures that restrict biomass
incineration intact. Please resist the potential give-away of citizen funds to
companies that seek to profit off of biomass incineration in the state at the
expense of our public health, our climate, and the integrity of the RPS
program.
Christine Labich