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Dear Mike,
The deadline for commenting on the new biomass public subsidy regulations is tomorrow, October 21st. Please Speak Up!
It is very important that comments are submitted by Thursday, October 21 to: doer.b...@state.ma.us.
Commenting on these regulations is one of the most important things people can do at this time to help protect Massachusetts’ forests, the environment and public health.
Please take this opportunity to set aside a small amount of your time and make this a priority.
DOER BIOMASS ELIGIBILITY REVISIONS– OVERVIEW
The following points may be helpful in formulating your comments:
1. Why should companies receive "green" public subsidies or preferential treatment to build wood-burning biomass plants given the significant and negative forest, global warming, environmental and public health impacts? Burning wood to create electricity is one of the most inefficient and polluting sources of energy that exists. Should we be using valuable taxpayer “clean” energy subsidies promoting this dirty technology?
2. At a time of stressed forests, polluted air, a carbon overloaded atmosphere, near epidemic levels of asthma, and bankrupt governments, should the public subsidize increased burning of wood and trees?
3. Wood cutting and burning is very difficult to monitor and control. Forests, air-quality, carbon dioxide emissions, public health will all suffer if wood burning is subsidized.
Regarding the draft changes of 225 CMR 14.00 Renewable Energy Portfolio Standard – Class I
The Requirements outlined by Secretary Bowles in the letter to DOER dated July 7. 2010 (http://www.mass.gov/Eoeea/docs/eea/biomass/070710_biomass_sustainablity_carbon_regs_letter.pdf) have already been weakened by DOER before the public comment period had even begun!
1. Please ask DOER to restore the following elements to ensure that the new regulations are held to a basic level of credibility and effectiveness that mark a step forward and reflect the intent of Secretary Bowles' letter:
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The efficiency threshold of biomass plants was lowered to 40% and must be restored to 60%. 40% is much too low and means most of the wood burned will go up in smoke, not into energy production.
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The environmental and health impacts of the items falling under the broad definition of "bio products" are unknown, and bio-products, such as ash, should not count towards the calculation of the overall efficiency level of the facility.
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No “partial credits” should be given for a facility that cannot meet the minimum efficiency requirements.
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As stated in the original letter, the eligibility for renewable energy credits for construction and demolition debris should be specifically prohibited.
2. The 50% reduction in greenhouse gas emissions per unit of useful energy over a 20 year lifecycle requirement should be benchmarked, in all cases, against the cleanest comparable natural gas system using the most efficient commercially available technology.
3. Wood from permanently clearing forest for development and other land use changes is not a “renewable” activity and should not be subsidized by taxpayers as “Renewable Energy”.
4. Only wood obtained from land under a permanent irrevocable conservation restriction should meet the eligibility criteria for biomass REC’s.
5. Wood taken from state public forests should not be eligible for biomass REC’s
6. The clause stipulating a 15% maximum of harvest as eligible biomass fuel must pertain to any wood extraction project including “thinnings”, “improvements”, “cutting allegedly to “help” wildlife” etc., not just commercial timber sales, or forest product sales.
7. The enforcement of these regulations should not be trusted to vested interests.
8. The time period for the “Forest Impact Assessment” of 5 years is much too long. At a minimum there should be an annual assessment done by an independent body.
Here is a helpful link if you prefer to use a push-button form for submitting your comments from StopSpewingCarbon.com
DOER Renewable Portfolio Standard - Biomass Policy Regulatory Process
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