To: John Wassam, Department of Energy Resources
From: Mothers Out Front
RE: Opposition to rule changes to weaken biomass standards in the Renewable Portfolio Standard
We are writing on behalf of mothers and children in Massachusetts in opposition to the rule changes the Department of Energy Resources (DOER) has proposed to the state’s Renewable Portfolio Standard (RPS)
for two main reasons – wood burning power plants are bad for human health and wood burning electricity generation would contribute to our state’s GHG emissions and therefore does not belong in our RPS.
Mothers Out Front is a national grassroots organization committed to creating a complete, just and swift transition to a clean energy future for our children. We have over 7000 members in Massachusetts. We oppose the rule changes for the following reasons:
- The proposed regulations roll back or eliminate all of the 2012 science-based standards, expand what types of wood can qualify, and will be a windfall for the biomass industry by subsidizing new and existing polluting biomass power plants in MA and New England.
- The 2012 Massachusetts RPS biomass rules were developed based on a scientific study of bioenergy carbon impacts (known as the “Manomet Study”), and were the first in the nation and the world to recognize that burning trees for energy increases greenhouse gas emissions.
- DOER’s proposal would eliminate efficiency criteria for biomass power plants and thus enable the 35 megawatt Palmer Renewable Energy biomass plant to be constructed in East Springfield and collect an estimated $10 million to $12 million per year from electricity ratepayers, adding more pollution to an already overburdened environmental justice community. Springfield was named “Asthma Capital” of the US in 2018 by the Asthma and Allergy Foundation of America based on asthma prevalence, emergency room visits, and asthma-related deaths.
- Emissions from biomass power plants contribute to acute and chronic health problems including asthma, heart disease, diabetes, and cancer.
- Burning wood emits similar levels and a similar range of pollutants as burning coal, including sulphur dioxide and mercury, as well as Volatile Organic Compounds. The largest volume of air pollutants are oxides of nitrogen (NOx), carbon monoxide (CO), small particulates (PM10, including PM2.5) and sulphur dioxide (SO2). Burning virgin wood also results in a wide range of other pollutants. These include Antimony, Arsenic, Cadmium, Chromium, Copper, Dioxins and Furans, Lead, Manganese, Mercury, Nickel, Polycyclic Aromatic Hydrocarbons (PAHs), Selenium, Vanadium and Zinc.
- In addition to negatively impacting human health, the RPS was developed to decrease our Greenhouse Gas emissions and get to an 80% reduction by 2050. Not only does wood burning increase CO2 but the DOER has eliminated all the Massachusetts-specific forest harvesting criteria that were designed to protect forests, maintain soil fertility, and protect from overharvesting, and replaced them with vague and unenforceable forest industry language about “sustainable harvesting.” Trees and soil are the best carbon capture technology we have today.
We count on the DOER to do what is right for our children’s future and their health and therefore that you do not implement the proposed changes to the RPS.
Andra Rose, for Massachusetts Mothers Out Front