In accordance to the Massachusetts Global Warming Solutions Act (GWSA), the Massachusetts Department of Environmental Protection (MassDEP) has proposed 6 new regulations (or changes to regulations) that limit or reduce greenhouse gas (GHG) emissions. The GWSA requires a reduction of (GHG) emissions in the state to “a 2050 statewide emissions limit that is at least 80 per cent below the 1990 level.”

We submitted comments to MassDEP today on 4 of the 6 regulations.

Read the full comments letter >>

Here is a summary of our comments:

  • MassDEP should not only consider emissions, but the total impact caused by the technology (especially environmental impacts), when determining which technologies can be labeled as as clean energy.
  • MassDEP’s Clean Energy Standard (CES) should be designed to retire destructive technologies ahead of schedule, to reduce risk and cleanup costs that accompany poor performing energy producers.
  • New generation nuclear plants (post 2010) should also not be eligible under the CES until the long list of complex problems associated with this power source are resolved, most notably the disposition of the highly toxic nuclear waste that is now vulnerable on our Cape Cod Bay shoreline.
  • Nuclear power, whether new generation or older plants, should not be considered a “clean” source of energy due to the tremendous uncalculated costs and consequences to the environment and nearby populations.
  • State financial incentives should not be used for the installation of large, ground mounted solar installations that significantly affect environmental resources, or when they conflict with other established state goals and programs for protecting natural resources. Large solar farms should be sited in already disturbed areas and no clearing of forestland should occur.
  • Moving away from diesel use in the state’s trains and trucks would greatly help reduce emissions and help the state reach its longer-term goals; We fully support efforts to move to an all-electric vehicle fleet.
  • What is deemed eligible as clean energy by MassDEP and receives subsidies should be based on a clean “do no harm” standard, not just an emission standard. If taxpayer money is spent on clean and renewable energy, then the sources should truly be clean and healthy.
  • It’s time the state takes its leadership role in the clean energy sector to the next level, and becomes a global leader in smart, meaningful expansion of clean energy. Until gas and nuclear can stop contamination and avoid waste byproducts, the Commonwealth’s first choice should always be responsibly sited sun, wind, and tidal sources.