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Comments Submitted on Proposed Final Biomass Regulations for Massachusetts, June 18, 2012
NRDC filed formal comments on the Proposed Final Regulations Regarding Eligibility of Biomass under Massachusetts RPS. We argued that the rules provide a robust and pragmatic set of standards and guidelines to ensure that the state meet its greenhouse gas reduction goals while protecting critical forest resources. The regulations provide a model for future policies at the state, utility, and federal level. In particular, we applauded the state's joint framework for greenhouse gas accounting, plant efficiency thresholds, and forest protection measures that restrict eligible biomass largely to residues from timber harvest. We were, however, very critical of the state's addition of "salvage from fire adapted forest ecosystems" to the list of eligible biomass. While this addition will have little impact in the northeastern states where fire is not predominant, it is a very bad precedent for other states in the west that may be considering the Massachusetts model.