From: Chris Dwan <chris@dwan.org>
Sent: Tuesday, July 23, 2019 8:51 PM
To: RPS, DOER (ENE)
Cc: CCS; Somerville's Friends of the Urban Forest
Subject: Burned biomass is neither clean nor renewable
To the Department of Energy Resources,
I am writing to express strong disagreement with the
inclusion of burned biomass, particularly trees, in our state's definition of
"clean" or "renewable" energy.
First: Burning, whatever the
fuel, cannot be clean. No matter what filtration or sequestration
mechanisms are used, burning results in a net release of carbon into the
atmosphere. The DOER website (https://www.mass.gov/service-details/biomass)
says exactly this: "Modern Wood Heat is now able to demonstrate efficiency
and emissions profiles similar to fossil fuels."
Using emissions standards from fossil fuels as a benchmark for clean energy would be laughable if it were not so dangerous and disingenuous.
Beyond this, the idea that our state's trees are a "renewable" resource is simply incorrect over any timescale that matters. Even the fastest growing trees take a decade or more to mature enough to provide significant cooling, carbon sequestration, and other benefits. One might use the same flawed thinking to claim that fossil fuels are "renewable" because they form over time through natural processes.
Any regulation that provides financial incentives to cutting and burning mature trees at an industrial scale has nothing to do with either clean or renewable energy.
Sincerely,
Chris Dwan
Somerville, MA