From: Lederman, Jesse <JLederman@springfieldcityhall.com>
Sent: Friday, July 26, 2019 4:02 PM
To: RPS, DOER (ENE)
Subject: Re: Public Comment on Proposed Revisions to the Renewable
Portfolio Standard
Categories: Has Not Been Sumarized
Re:
Public Comment on Proposed Revisions to the Renewable Portfolio Standard
Dear Mr. Wassam,
My name is Jesse
Lederman, I am an At-Large Member of the Springfield City Council, where I
Chair the Committee on Sustainability and Environment, and the Committee on
Health and Human Services.
In June, I attended
your hearing in Springfield along with Councilors Justin Hurst, Michael Fenton,
Melvin Edwards, and Timothy Allen to state our opposition to the DOER proposal
to revise the existing Renewable Portfolio Standard to allow for taxpayer
subsidies to be granted to large scale wood burning incinerators.
I hope you will accept
this written testimony as a follow up to our statement that night.
We were both surprised
and disconcerted that the state would be considering such an action in light of
the clear empirical evidence that these types of large scale electrical
generation incinerators are inconsistent with the Commonwealth’s stated goals
for greenhouse gas reductions in the ongoing effort to combat climate change,
and the fact that this very issue was debated at length several years ago, and
the current compromise that exists in the regulations reached.
I would specifically
draw the panels attention to the 2010 Manomet Study, which was Commissioned by
the state for this very reason, which clearly stated that large scale
electrical biomass burning was in fact not carbon neautral or renewable, and
could be more accurately compared to emissions from a coal power plant.
Given that the
Renewable Portfolio Standard, for which the goals are established most recently
in the Green Communities Act of 2008, is specifically mandated to support
generation of renewable energy, it is unclear why DOER is suddenly interested
in rehashing this debate.
These proposed
revisions would obviously create a scenario in which the Renewable Portfolio
Standard evolves into a sham, selling a bill of goods in terms of its mission
to the rate payers of Massachusetts that it will be set up to fail to deliver.
In addition, the
process your department has utilized up to this point has been highly
questionable, rolling out these proposed revisions within just the last several
months, and failing to schedule a hearing in our city, a designated
Environmental Justice community located in a region with a history of these
types of large scale biomass proposals. It was not until members of the public,
the state legislature, and the City Council requested such a hearing that your
office schedule one.
Finally, well DOER may
be under no statutory obligation to consider the public health of our
constituents, we are - our city and region continue to be subjected to some of
the worst air quality in the country, consistently earning failing grades from
the American Lung Association and most recently being named the most
challenging region to live with asthma in the United States. This is the result
of a combination of factors, including our geographic location in a valley,
historic inequities in access to healthcare, and our subjection to additional
pollution producing industries and actions that target urban communities.
Because of our region’s
geographic location and the history of multiple large scale biomass proposals
in the area, it is not unreasonable for us to assume that the granting of
taxpayer subsidies could spur a wide scale resurgence of such projects across
Western Massachusetts, which would undoubtedly have a deleterious impact on the
public health of our community and add to the emissions generated in our area.
This coming at a time
when our city and region have worked to make strides in improving air quality,
such as through our local Climate Action and Resilience Plan.
In conclusion, common
sense, historical evidence, and the law, would dictate that clean, renewable
energy does not come out of a smoke stack. It is preposterous to assert
otherwise, and it is an affront to our constituents and the rate payers of the
commonwealth for tens of millions of their tax dollars to be used for the
subsidization of an industry that statewide would lead to more, not less,
pollution.
Respectfully submitted,
Jesse Lederman
City Councilor At-Large
Springfield, Massachusetts