From: Betsy Cook <betsy.b.cook@gmail.com>
Sent: Thursday, June 6, 2019 11:31 AM
To: RPS, DOER (ENE)
Subject: Biomass
To John Wassam
Here are my comments regarding proposed rule changes that would allow Biomass to receive the credits as a "renewable" energy and allow taxpayer money to go towards CO2 producing and air polluting biomass plants.
I don't approve of this! This is counter to all the available information that can be found about climate change progress and Massachusetts commitment to the Paris Accords. At the rate we are going, the 2% attempt increase to reduce carbon is clearly not enough. This wood burning fiasco would move us in the opposite direction.
Recently the report came out that atmospheric C02 was measured at its HIGHEST in the 61 years that it has been recorded. That was in May 2019. We need to move forward in this State and be a LEADER for the environmental movement to fight Climate Change!
Building such a plant in Springfield will increase air pollution and we don't need that. Springfield children already suffer high rates of asthma.
MA needs to focus on reducing our carbon footprint. One way to do that is increase ride sharing, promote fuel efficiency, require new building projects to have solar panels, support the solar industry and increase rail service. These things DON'T hurt air we breathe the way biomass does.
I'm sure the lobbyists are doing their best to get this shoved down our throats but let me tell you what I think. What they say is FAKE NEWS so they can make a profit and pretend like Climate Change isn't a real concern.
Betsy Cook
South Hadley, MA
PS this is what you propose to do to our State!
Need more info?
WE ARE IN A CLIMATE EMERGENCY. Does anyone think we need more CO2 in
the atmosphere now? But that's what the Baker administration's proposed changes
to the RPS will do – send more forest carbon into the atmosphere. We
need the public to weigh in on these programs NOW – because bottom line, we all know it’s never
been more urgent to reduce greenhouse gas emissions and protect forests, even
if the Baker administration doesn’t.
Climate science shows that to avoid
catastrophic warming, we must reduce emissions and take CO2 that’s
already in the atmosphere out –
most likely by restoring and expanding forests. We need to cut our net
emissions in half in the next ten years, and reach emissions neutrality – with
emissions balanced by uptake – by 2050. (See our summary of the latest climate
science from the IPCC – including the call for a reduction in bioenergy
generation! – here).
That’s why
burning forest wood for energy is so counterproductive. Wood is technically
renewable, but wood-burning power plants emit more CO2 per unit
energy than fossil-fired plants, pumping greenhouse gases into the atmosphere
just when we need most to reduce emissions. Forests cut for fuel may grow back
eventually to offset those emissions, but this takes decades to more than a
century. The result is a net increase in CO2 emissions to the
atmosphere just when it’s most important to reduce emissions.
This was
the big finding of the Manomet Report that was commissioned by Massachusetts to
inform the state’s biomass energy policy. The study concluded that net
emissions from wood-burning power plants that burn a mixture of trees and
forestry residues exceed emissions
from a same-sized coal or gas plant for years to decades (even under a
best-case scenario that assumes forests grow back perfectly). The study was
published in a peer-reviewed journal – you can download it here.
See Table 2
for the outcomes of Manomet; see further below for an explanation of why it
matters if fuel is sourced from whole trees or residues.
Table 2.
The main conclusions of the Manomet Study: Even assuming efficiency of 80% or
more for thermal-only units, it takes 15 – 30 years for net CO2 from
biomass units to be drawn down to the same level of an oil burner, and 60 – 90
years for gas. For electricity-only plants, where efficiency is around
24%, it takes much longer for net emissions to fall to the same level as net
emissions from a fossil-fired plant.
The Manomet
Study was commissioned by the state because back in 2008 or so, there were three
big wood-burning power plants proposed Massachusetts (in Russel, Greenfield,
and Springfield. The Springfield plant, confusingly named “Palmer Renewable
Energy,” may still be built – see below). Scientists and activists came
together to defeat these proposals, in part by launching the “Stop Spewing
Carbon” campaign, a petition drive for a ballot measure that would have taken
most polluting energy sources out of the state’s Renewable Portfolio Standard
(RPS). The petition drive collected over 100,000 signatures and qualified
for the ballot. In the meantime, however, DOER had realized there was a problem
with CO2 pollution from wood-burning plants, and had
commissioned the Manomet Study to inform state policy. When the Manomet Study
was completed, the state agreed to issue a science-based set of rules
eliminating subsidies to the most polluting biomass plants, and the ballot
measure was set aside.
Finalized
in 2012, the Massachusetts biomass rules became the first in the nation and the
world to recognize that burning trees for energy increases emissions just when we should
be reducing them. The whole process took about four years, and
involved the multi-investigator Manomet study, many public meetings, and
thousands of hours of time by citizens and concerned scientists who weighed in
to make sure the state’s rules were based in science.
Now,
unbelievably, we have to defend those rules, AGAIN – because
they are under attack by the Baker administration. DOER is proposing rolling
back the rules enacted in 2012, with changes that will lead to more forests being cut
for fuel, more CO2 in
the atmosphere, and more climate damage. It even seems likely the rule changes
will help at least one of the three large biomass plants be built (Palmer
Renewable Energy in Springfield.). Adding insult to injury, all of this
will come at great cost to ratepayers, who pay millions to support this
polluting technology – money that could be allocated instead to residential
heating efficiency (nega-watts!) and lower/zero emissions technologies.
The 2012
RPS rules still allowed biomass power plants to get subsidies, but the plants
would have to meet strict efficiency criteria, so that only efficient
combined-heat-and-power (CHP) plants would qualify, and not the large
inefficient electricity-only plants that had been proposed. Biomass power plant
operators were required to provide fuel supply plans that would demonstrate
they were getting the majority of their fuel from “forestry residues,” not
whole trees (see appendix below for why the type of wood matters). The
cumulative net carbon impact of biomass power plants had to be 50% that of a
natural gas plant after 20 years, which
at this point seems absurdly long.
Now, the
Baker administration wants to rewrite those rules to make them more favorable
to the biomass industry, including weakening and even eliminating plant
efficiency requirements, removing fuel supply requirements to allow burning
more whole trees, and the requirement to show a “benefit” relative to fossil
fuels in 20 years (the Baker administration is changing it to 30 years,
because apparently, they know better than the climate scientists, and
think addressing global warming isn’t that urgent). They’re also weakening
requirements for emissions of “conventional” pollutants (e.g. particulate
matter) and removing requirements for citizen oversight and oversight by the MA
Dept. of Environmental Protection (DEP), the agency that safeguards our air
quality. The rules will even increase subsidies to garbage-burning!
These changes
represent a total betrayal of a hard-won compromise and agreement from 2012, to say nothing of the 100,000+ people who signed a petition to
take ALL biomass out of the RPS. DOER apparently got an earful from the
forestry and biomass industries that the biomass rules were too restrictive –
so now they’re rewriting them. (Not unlike the Trump administration, the Baker
administration DOER seems to contain people who advocate for the industries
they represent, rather than regulating them.)
It’s a
similar story with the Alternative Portfolio Standard (APS). After the RPS
rules went into place in 2012, and it became clear that the large wood-burning
plants would probably not be built, the forestry and biomass lobby went into
high gear, and working with DOER, added biomass thermal energy to the APS,
which had previously been a catch-all program that provided subsidies to a few
technologies that the state wanted to incentivize, but that did not really
qualify as “renewable” energy (such as combined heat and power). Along with
solar and geothermal heating, biomass heat-only units were made eligible for
public subsdies (as were biomass combined heat and power plants, just like in
the RPS – except the APS contained none of the protective rules the RPS
contained. Click here for an
overview of the differences between the programs).
It took a
few years to get the APS regulations finalized. Scientists and activists fought
to keep the APS “clean” by advocating that it only include zero-emissions
thermal sources (like solar and geothermal) but the wood industry was powerful,
and they got biomass thermal added. It seemed like at every round of public
comment, the DOER had further weakened the APS regulations (you can see some of
our comment letters here). We
ended up with lax regulations that promote the wood fuel that can be the most
carbon-intensive – wood pellets. (Click here for a
presentation summarizing some of the problems with the APS).
We’ll be
sharing our summary of the impacts of the proposed rule changes to the RPS, and
how the new rules will combine with the newly enacted APS thermal standard to
undermine forest and climate protection in Massachusetts. Please stay tuned for
that. In the meantime, though, legislators need to hear from you that you support the bill to take biomass OUT of the Alternative Portfolio Standard.
You can find your legislator’s contact information here. DOER’s lax standards for biomass in the APS, and DOER’s
proposal to gut the hard-won biomass RPS rules from 2012, shows the Baker
administration can’t be trusted to put the interests of forests and the climate
above the biomass industry demands. They had their chance to show they take
climate change seriously, and they've blown it, so now we the people need to
act.
Determining the carbon impact of burning these for fuel requires
comparing the emissions from combustion to the emissions from an alternative
fate. The type of wood burned is thus important to the net CO2 emissions
impact. There are four main categories of fuel.
Mill residues: wood
shavings, sawdust, bark. “Clean” mill residues can be burned directly or made
into wood pellets.
Forestry residues: tree tops
and limbs left over after sawtimber harvesting.
Trees: Whole trees that are cut
specifically for fuel, or trees that are “thinned” because now there is a
market for the wood.
Construction and Demolition Debris wood (CDD): This
material tends to contain relatively high concentrations of toxics like lead,
the pressure-treatment chemicals arsenic and chromium, pentachlorophenol, and
other contaminants that are released by burning chemically treated and glued
wood. Proponents of burning this material say it can be sorted to remove
the most contaminated materials, but there is no evidence this produces a clean
fuel source.
Table 2. Th