From: Diane Nassif <dianenassif@gmail.com>
Sent: Monday, May 20, 2019 6:49 PM
To: RPS, DOER (ENE)
Subject: Comments on the RPS Class I and RPS Class II regulations
for John Wassam, DOER
Dear Mr. Wassam,
My name is Diane Nassif and I live in Petersham, MA. I moved to this area, the North Quabbin, nine years ago from Medford, MA, an inner suburb of Boston. Since moving here I have become aware of the importance of conserved land and trees, not only to this local area, but to the entire Commonwealth and the New England region. I have also become aware of the amount of logging that takes place here and have been researching forestry best practices and how the resulting wood is used. This has informed my comments on the RPS Class I and RPS Class II regulation changes proposed by the DOER.
I also attended the DOER hearings held at Mount Wachusett Community College on May 17 on the topic of the changes that are being proposed by the current administration to the RPS Class I and Class II regulations. I did not speak but instead listened to the oral presentations. As a result I feel moved to provide you with my own comments here.
We are living in the midst of a climate crisis of huge proportions that threatens to cause devastating harm to our country and the world. Future generations, such as the life and well-being of my granddaughter, are threatened. We need to take action, radical action, immediately, to counteract the impact that years of dependence on fossil fuels have had on our world. I do not say this casually. We need to recognize that our lifestyles, indeed our economy, must change in order for us to have a chance for survival as a species on a planet that bears any resemblance to what I have become accustomed to in my lifetime. This is an emergency. Business as usual is not an appropriate response.
The Renewable Portfolio Standard that is in place today was crafted over several years of collaboration among scientists, environmentalists, and state legislators in an effort to promote the use of clean renewable energy in the Commonwealth. These participants wanted to support the Paris Climate Change Agreement to reduce greenhouse gas emissions and protect forests as natural carbon sinks.
The changes to the RPS that are proposed by DOER do not reduce greenhouse gas emissions and do not protect our forest resource, and in addition will make people who live near the subsidized facilities sick. This is clearly an example of business as usual thinking in which government bows to the requests of private corporate interests and loosens regulations that protect the people who live in the Commonwealth. Now, today, a more radical approach needs to be taken in order to mitigate the climate crisis and protect our forests, water supply, air quality, and people.
The intention of the RPS regulations that are currently in place was to encourage the development and implementation of new technologies that do not depend on fossil fuels or combustion -- solar and wind come to mind. The point is to subsidize innovative technologies that can reduce greenhouse gases. Massachusetts is a state where new technology predominates, for business, healthcare, and the environment. The proposed changes by DOER do not take advantage of the expertise that is available in our Commonwealth. Rather they build on outdated incinerator technology and the myth that burning trees as biomass can simultaneously protect our carbon sink and not contribute to increased greenhouse gases. This is outrageously untrue and a scientific approach should take precedence.
In addition, the location of trash incinerators for waste energy as well as biomass plants for burning wood chips is typically in low-income communities, like Springfield, that are already faced with high rates of asthma and other environmentally-caused diseases. Clean energy does not come from a smokestack. The proposed subsidies to be provided to biomass and incineration industries will come at the expense of electricity ratepayers who pay a surcharge for renewable energy. How can trash be considered renewable? It is surely abundant but that waste stream could be reduced significantly if the infrastructure for recycling and composting were subsidized instead.
The news gets worse when I dive deeper into the regulations that will be undermined by the proposed changes Coordination of monitoring with the Department of Environmental Protection of hydro-electric plants and emissions from incineration and biomass burning is to be restricted. This is a clear threat to the environment and public health; it should not be contemplated.
There are alternatives. There are wood products that might be created in Massachusetts that would maintain a carbon sink and be useful alternatives to products like steel, concrete, and foam insulation that are costly in terms of their creation and distribution. Cross laminated timber and wood fiber-based insulation could be produced by local mills if these industries were subsidized.
Clearly the good minds of the folks at DOER have not been asked to engage imaginatively and spiritedly to come up with regulations that will support the movement of the Commonwealth in the morally right direction for all of our inhabitants. Its time to stop subsidizing business interests and start protecting our environment and populace. Please withdraw the proposed changes to the regulations.
Sincerely,
Diane Nassif
Petersham
North Quabbin Energy