From:                                         Gabriel Robinson <robinsongabriel64@gmail.com>

Sent:                                           Friday, July 26, 2019 9:59 AM

To:                                               RPS, DOER (ENE)

Subject:                                     comment on proposed changes to RPS Class I and II regulations

 

Dear Mr. Wassam,

 

I am writing to express my opposition to the proposed changes in the RPS Class I and RPS Class II regulations.

 

We need to be treating climate change as the serious, existential threat that it is and working in earnest to cut CO2 emissions, foster non-polluting sources of energy, and protect and extend carbon-locking systems such as forests. The changes proposed by the DOER demonstrate that it is NOT serious about our health, safety, and future. The proposed changes would roll back the protections built into our current biomass regulations, give support to a polluting industry, and turn forests that are currently carbon sinks over to biomass developers—moving headlong in the wrong direction.

 

We need to cut our carbon emissions in half over the next ten years. Yet the DOER’s proposed changes would increase carbon emissions, by eliminating the definition and reporting requirements for lifecycle greenhouse gas emissions, extending the timeframe for demonstrating a greenhouse gas “benefit” from 20 to 30 years, reducing efficiency requirements for plants burning forest residues and thinnings (while increasing the amount of wood classified as “residues”), eliminating the efficiency requirements for salvage wood (while greatly expanding the definition of what counts as “salvage”), and eliminating the requirement that plants demonstrate they can meet air pollution emissions criteria.

 

It is a massive giveaway to a polluting industry, and it is utterly disingenuous to count the energy generated in this manner, with such non-serious standards, toward meeting the RPS goals.

 

Please do not make these changes, and instead work toward making Massachusetts a leader in renewable energy and truly sustainable forestry.

 

Thank you,

Gabriel Robinson

26 McTernan St. #3

Cambridge, MA 02139

(617) 955-3487