DPL Comment letter to DOER re Manomet 081210

Mr. Phil Giudice Commissioner Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs Department of Energy Resources 100 Cambridge Street, Suite 1020 Boston, MA 02114 Dear Commissioner Giudice: I am pleased to have this opportunity to provide comments on the recently-completed Biomass Sustainability and Carbon Policy Study. Maine applauds the initiative taken by Massachusetts to encourage research into biomass sustainability, and the rigor with which Manomet has conducted that research. Manomet has previously participated with Maine DEP and the Maine Forest Service in other important forestry policy efforts, including the development of proposed forestry offsets for the Regional Greenhouse Gas Initiative. The results of the Manomet study have been widely interpreted and reported. Some analysts have focused on the study’s findings of long-term payback of carbon debt under certain biomass source and combustion scenarios, especially compared to the payback of carbon debt associated with coal combustion. Maine does not agree with those who argue that the carbon footprint for the combustion of forest biomass is as bad as coal under all scenarios. In fact, numerous researchers -- including the World Energy Council, the U.S. National Renewable Energy Laboratory, and the International Energy Agency – have documented significant reductions in 1,2,3greenhouse gas emissions when biomass for energy is compared to ...