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RPS Class I and Class II Regulations Stakeholder Comments Submitted by William Gleason, President, Chinook Energy
October 10th, 2008

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I would like to comment on the second question raised for Class I Regulations regarding eligible technologies or fuels. Specifically, I believe that the definition of Eligible Biomass Fuel should include most forms of landfilled waste including municipal solid waste (MSW). I base this belief on two basic reasons:

- Firstly, while it is true that landfilled waste such as MSW is not a "renewable" resource like crops, sun light or wind, it is difficult to conceive of a state of the world where we will not be generating this waste. So long as there are people populating the planet, large quantities of waste will be generated, and for the most part that waste is imposing a cost on society.

- Secondly, as a public policy matter, including landfilled waste in the definition of Eligible Biomass Fuel will create incentives that should be viewed as unambiguously desirable. Landfilling waste, particularly waste such as plastic that does not naturally decompose, damages the environment and imposes a cost on society. It can only be viewed as positive to create an incentive through public policy to divert that waste from landfills to a productive use such as producing clean energy. In fact, I would argue that it is more desirable to divert landfilled waste, for which there are no other productive uses, to the production of energy than to divert agricultural crops that are used to feed people. We are currently experiencing unintended negative consequences from government incentives around the production of biofuels. Producing clean energy from landfilled waste is a "double win" in that it reduces the quantity of waste sent to landfill and reduces our reliance on fossil fuel.

I would ask you to seriously consider including landfilled waste in the definition of Eligible Biomass Fuel. We are very serious about investing in capital equipment to allow us to produce power from such waste in Massachusetts, but without RECS it becomes an economically unattractive investment that we probably will not make.

Source: www.mass.gov