HomeMy WebLinkAbout2021-01-19 Select Board Packet
Command Meeting Notes Dec 28, 2020
Goal 1:
A. Discuss Testing in Schools.
a. Lexington will begin pool testing next week . Funding in a variety of ways, care
Act, Education Foundation, some donations. Saliva testing – starting with staff
and expanding to students. This is a way of bridging the gap between now and
the vaccine – not available to students under 18 until the Fall. Will get volunteers
to put testing kids together. Cost is a factor. Procedure is testing a pool, if
negative, move to the next pool. Testing folks combines the samples, if there is a
positive result, then they drill down to individuals within the pool. Need to more
investigation on what other school districts are doing. Lexington is using a third-
party company. Tufts doing pool testing as well – this is not a novel approach.
Cheaper option than individual testing with significant cost savings, effective at
assessment and containment. Lexington will do it on Mondays, assumes quick
turnaround. They are on a week on/week off schedule. 24 hour turn around.
Phase 1 - $100K for the first 4-week program, $109,000 for 2nd 4 weeks.
Wellesley is also doing pool testing.
If it is optional then there are less HR/legal hurdles. As cases are going up it
seems like a good bridge to the vaccine. Tuition paying students can be denied
services. Public school students cannot. There is a statistical validity , money
won’t be a big issue once Cares Act funds renewed.
Testing is a precursor – what is difficult is the contact tracing. It’s become more
complicated. From contact tracing standpoint, this will help us. Sign in sheets fo r
every adult in classrooms, in case we have students and staff in rooms. Testing –
can it reduce some of the workload? Nurses are not yet overwhelmed; the
alternatives are not better. Nurses are doing an amazing job. The behavior of
public, and the season doesn’t’ help everyone is inside. People’s behavior is a
problem.
Would the testing help keep kids in hybrid? JD was getting really concerned last
week and shut down 3 days before Xmas, contact tracing at the high school
because of class changes.
Testing – its one piece along with distancing, masks, contacts and useful
For asymptomatic cases quarantine time can be reduced from 14 days to 10.
JD – Two in school transmission cases. They weren’t wearing masks and weren’t 6 feet apart.
KD – people get comfortable in behaviors, I see this person everyday and its fine. I feel Safe. Its
tiring to think restrictively every day.
Increased household spread – its exponential spread – not 1:1, more like 1:2, or 1:3.
Helpful – what info is in MAVEN – understanding these webs and looking strategically at
populations. Pre-K, push out into concentric circles of transmission and can make some
decisions about costs and effectiveness.
Paul Jackson – Pool testing better for schools. We are seeing it is a whole family, and sports are
spreading it. Schools can mandate that sports are tested. If we can’t change the behavior we
have to figure out how to protect people from others or from themselves. Does it make sense to
go regionally? Wellesley is regional. We could plan, see if any economies of scale if we bring in
another community.
Procurement requirement – testing thinking to May, about 4-5 months.
Discussion of regionalization for vaccine distribution, regions 3A, B, C. These regions aren’t for
testing, just vaccines. Discussion about how to get out to our Public Safety personnel.
1B: After Winter Break: Plan is to reopen in the typical hybrid model. Meeting w/Mary again on
Wednesday. Preschool was hit hard over the last few days. Preschool is in three locations, some
staff and some students. Two classes decided to have recess together which contributed to this
spread. Schools are looking at the town and the school numbers. Kristine and Mary work
closely together and are trying to capture the full picture.
IC: Winter Sports Cases
Gymnastics – 6 positive cases. Hockey shut down twice. Basketball had to be shut down until
today for boys. No cases in girls bball. Spectators are an issue. Some public discussion about
spectators. Not comfortable with spectators. Tom Zaya working with Luke at RCTV to air the
games, but there is an apparent RCTV fiber link issue at Burbank. No access to gymnastics
studio but can help with bball and hockey. Changes have impacted a lot of students,
particularly 6 high school students ill and others that had to be quarantined because they do
gymnastics at the same gym. Discussion about data sharing across communities and with the
public to help illustrate the extent of the spread.
Communication is a challenge in terms of reported, trending. More info is better. Getting to
close to 5% of the community infected and then 5% of those diagnosed are dying.
Start work on charts and graphs, bullet points to help convey info.
Does MAVEN show neighborhoods that are hotspots?
Social gatherings are driving infections. Kids are getting it from adults.
Jan 5th SB meeting with BOH Chair.
Peter and Kerry will look closer at improving information.
BL asked John now that the holidays are over and college kids are home, could we start to see
clusters go down? Comments about college kids could be home until Feb 5, other than sports,
all the other classes are remote. Chorus can only meet outside, Band can play inside with special
masks, Drama is remote.
ID – impact of clusters on family gatherings. Looking for more information on this to convey to
website via Jayne.
However, there is a bit of a shift to the current issue, which is vaccines.
IE- Communication plan for new Governor’s orders:
• Are restaurants complying?
• Peter – we can do more, send out a mass communique.
• Town received one complaint about one new housing development not being safe
enough.
• Box Stores? Staff now working beyond regional managers with Home Depot to stop
seeing repeated violations.
• Aim to target restaurants for outreach
• 25% of occupancy – restaurants have not been subject to the 25%, they are hurting quite
badly and no one wants to see that continue. The 25% does not include staff.
• New Years gatherings at restaurants – take out is the big trend. Some restaurants may
close for the winter and revisit in the spring. A small capacity restaurant with a 25%
limit cannot meet overhead.
• May want to see what comes out of the federal government with unemployment
insurance, etc. Many are considering closing. Bertucci’s is selling virtual food.
2A: Protect the Health of Employees:
A. Discuss Andover’s plan – application to be a host community went in on the 23rd.
Andover will truck it, bill it for us, bring it to Reading, and run it as a free clinic. Inviting
Lynnfield as well.
B. This is the DEPOT MODEL – Andover houses it, tracks it, but haven’t heard yet if it’s
arrived in Andover.
C. Likely it’s the Moderna vaccine. Better for the public because it is easier to distribute.
CVS and Walgreens planning to do Pfizer for senior citizens.
D. Public Safety – Police, Fire, Dispatchers, be best to give to staff going on their days off to
allow for recovery time.
E. Discussion of logistics around vaccine distribution. If frozen, shelf life about six months.
30-day window for Moderna when thawed.
F. Once we have it, how do we want to vaccinate and what would a schedule be for fire,
police, etc.
G. PJ: I think we have the capability to vaccinate, if we can pull it off. Lynnfield would be
great to work with. Wilmington good to work with. 194 staff to vaccinate in a day, have
to figure out the throughput, where is the observation area, who will do the observation.
H. Peter M. Anything that comes down – that will be communicated to first responders
whenever it happens. Peter will communication that. Paul has a preliminary plan for
how to start the vaccines for first responders. He will send it out. There is a small
window for the second dose medically, only a couple of days.
Couple of scenarios:
• Just Reading First Responders
• Regional – Reading/Lynnfield
• Wakefield coalition they have 3 days and set up another three days.
• Have to make sure it works with other communities
• Have to ensure works for the venue
• Peter says have to take care of ourselves first
• No commitments to other communities
3 Assistance to residents
A. Review Rental and Mortgage assistance Program: as of last week, it was about $50K.
Deadline was last Monday. Did gather info for a lot of people who didn’t meet the
criteria. It went well. People were appreciative. And it came off really fast – great work
with Reading Coop.
B. Food/Pantry - historically January is the toughest month for the pantry. Over 300 people
last week for the school distribution, had several new families. Continued through June
unless the money runs out. Gail needs volunteers for the food distribution, most
volunteers are CORI’d. Good to get folks CORI’d ahead of time.
C. CARES FUNDS – Not heard much yet. Likely or possible that part of the omnibus bill,
which has lots attached to it, but not clear if the CARES ACT funding is extended. We
are in a period that is closing out, should roll over as in ex tra years. Schools COVID
funding was attached to federal but that funding has run out. Some new schools funding
is geared toward HVAC.
D. Parent inquired into having BONFIRE for the senior class. 350 kids, s’mores, music…
This would require approval from the Select Board and a permit from the Fire
Department. It will go to Command. The BOH wants to review all public gathering
permits and social gatherings as well and this request ought to go before that board.
The group was not aware of what they were going to burn or how they would do it.
Another group expressed interest in doing a car parade again. Staff want to ask parents
to pull together a full list of requests that can be reviewed as a comprehensive plan
rather than piecemeal.
Reading COVID- 19
Command Meeting Agenda
January 4, 2021
Attendance:
Mark Dockser – Selectboard Chair
Kerry Dunnell – BOH
Bob LeLacheur – Town Manager
John Doherty – Superintendent of Schools
Jean Delios – Assistant Superintendent of Schools
Greg Burns – Fire Chief
David Clark – Police Chief
Peter Mirandi – Interim Fire Chief
Paul Jackson – Deputy Fire Chief
Gail Dowd – Chief Financial Officer for School Department
Jayne Wellman – Business Administrator, PIO
Goal: 1 Protect the Health of Residents
Implications of Reading being a red community for 3 weeks.
Kerry Dunnell – because the town has been more than 3 weeks in the red the intention
of the law is to pause and look at the status and consider dropping back to Phase 2. It
would primarily impact athletics and gyms – no games, drop back to skills and drills.
It is a community-based decision. It wouldn’t necessarily impact restaurants as there
was indoor dining allowed.
GB – what would be the benefit to Reading?
There are clusters along sports teams, not sure where the exposure is. It seems the
denser communities are the ones that moved backward a step in the phases.
JD – discussions with Mary over the last week, the primary transmission is through
families. There is a social piece of gatherings with kids, and one cluster at the
gymnastics academy that impacted a lot of kids. Over the last month the positivity
rate has doubled… is 6.13% positivity rate, and on Nov. 30 about 3.1%.
Contrast – the state is over 8 right now.
Peter Mirandi – Christine is getting a report ready for the BOH and the SB. There is
some preliminary discussion in prep for the board meeting on Thursday. It will come
up with some recommendations from Peter.
BL shared a chart on the phases, which doesn’t show much of an impact in Reading
aside from gyms and fitness centers.
What does the data tell us? Does anything point to increased transmission to the
athletics and gyms. It sounds like there is connection, but not necessarily the source
of transmission.
Event on the common yesterday, said about 100 people, not really political, and in
violation of any rule in place for outdoor gatherings.
KD – not hearing any conclusive data that would drive this decision to move to Phase
2 at this time. Would need to see more informatio n along these lines. Christine is
working on some info for meetings this week.
BL – Making decisions without data can create an issue. Getting out ahead of the
issue is important, but may encourage the behavior we don’t want to see, such as
gathering publicly.
MD – what about reinforcing what the current rules are – cannot have large
gatherings, should not take place.
PM – the gathering on the town square, they didn’t have a permit, wouldn’t want to
respond to that protest specifically.
KD – There is a right to assemble – they are protesting the decision of a government
organization. I wouldn’t want to pick that fight. It is political and therefore protected.
Noted that the School Committee may have attended the Square. May be judicious to
have a join BOH and SC meeting.
KD – there is a struggle with how to manage the mental health aspect – fear that
people have regarding the wellbeing of their children. Trying to understand how to
balance that is difficult for many folks.
MD – still feels like two pieces, playing and watching. The article in the Globe this
morning focuses on playing, and then it quickly goes to spectating. There is an
opportunity to broadcast if there is an opportunity for a compromise.
JD – we are working on that with RCTV – esp with the link to Burbank but that work
is ongoing.
KD is open to a joint SC and BOH meeting, and there is some merit to that.
Goal – we want to keep people safe.
Data – we need to have the data to support decision making.
SC and BOH Workshop? Chairs and Vice and staff members to open dialogue for SC
and BOH and try to understand the thinking of the SC.
Discussion about mental health concerns parents are having.
The biggest reason JD didn’t have sports was because they are in remote learning and
if you cannot have school, then cannot have athletics. JD had already seen the spikes
happening and some in-school transmissions just before school vacation, three they
knew of, and in preschool, and that was part of the decision making. Numbers in
quarantine were going up significantly. Consensus from Command that JD is being
consistent and handling this well.
What are the clusters for Reading, two more cases connected to a - bulk are
households as far as we know. Looking like the weekly report that the state puts out.
We do not publish the quarantine data in the town.
PM is preparing some quarantine data. Christine will have some hot spot data. How
many are household cases. MAVEN isn’t so helpful with identifying how the clusters
work.
BL – Call with the LT GOV this afternoon- JW question for that call – what are the
key factors for suburban communities to drive moving back to Phase 2. MD – need
for coordinated action and the state is the best position to do that.
Transmission is going up, suggests new variant may be here. Its about the students
and the staff being able to keep all these pieces operating.
Jayne to work on data and develop the graph TODAY.
This doesn’t capture the info about staff that are testing positive and impacting the
ability to deliver educational services.
Discuss COVID-19 testing in the schools.
John presented a spreadsheet on the testing cohort management. Estimating 5 testing
dates each. Multiple companies that are offering testing. It can be done, but how to do
it? Testing in pools, can isolate if a positive result, then use PCR to narrow down to
an individual. Its doable, but what is the best way to do it. Wellesley is doing it – how
is it working? It may help get the high school students more in perso n – they are now
at 2 days per week.
Do we have enough staff capacity for contact tracing? Is there anything that we can
tell staff and students to help keep track of their movements. Feb 1 is the estimated
first date of the next semester and may be a good time to start.
Grocery stores are counting customers again.
Update on School return plans
So JD’s biggest concern is the highest need students who cannot access remote
learning. Met this morning to see if we can bring them back – about 25 students at
Wood End, Birch Meadow, and RISE, and perhaps Coolidge, because they cannot
access remote learning. They will look at the numbers on WED to see what the
indicators are. The aim is to create a 14-day transition. Does New Year’s Eve create
another issue for another 14 days. PD had to go to Oye’s to tell people to separate.
Update on School athletics
When we have a positive case on a team, and they come to a practice without
knowing they are positive, they have to shut down the whole team for being close
contacts. They have had to shut down boys and girls hockey already. If we start re-
opening school then certainly he would allow athletics again.
Goal 2 Protect the Health of Employees.
Update on vaccination distribution for first responders. We have a medical director
and now we can start signing orders and getting enrolled, and that will allow us to
accept the vaccine, and otherwise it stays under the control of Andover. Timeline is
still the same. Peter is going to a prep-mod meeting today, it helps track the vaccine.
Can we handle the billing – Andover is set up to do the billing for us and they are
willing to do it. So things are falling into place, and it is still hurry up and wait. They
are looking at next week– Police, Fire, Dispatchers, and people who are going face to
face. CVS and Walgreens has been doing assisted living and long term nursing
facilities.
Vaccines would come out not before Jan 11 so it should be out next week.
The state is indicating that they DO have the vaccines.
What about the billing – what is being billed? If insurance will cover the cost of the
vaccine? Vaccines are coming free of charge, and coming from the federal
government free of charge, and perhaps to the general public.
Who is keeping track of who is receiving the vaccination? If first responders go into
an assisted living facility, will they know that those folks have received a vaccine.
There is required training for those who will administer the vaccine. The training is
paid by the state. We have 10-12 that could give the vaccine, but they need to take the
training online. Class is about an hour. Charge the overtime covid number needed.
GB plan is to train all paramedics so that they are capable. PM will send links to the
training to GB.
We were looking at a model where we could give the vaccine ourselves so that we
could coincide with the staffing. Offline discussion regarding scheduling.
If there are 200 or more they could do it themselves, join with other communities, and
they can do it themselves, those options were on the table. This seems like something
Andover is putting on top of it. Reading Public Health can take custody and put it in
the fridge in the Police Station where we store vaccines. Just got a medical director
this morning. The fridge at the police station is secured.
Need to discuss the first vaccine clinic offline. If tested positive, cannot take the
vaccine for three mo nths? What is the specific time frame? Prescreening out those
who are not eligible is key.
PIO – getting calls through the senior center about pulling a list together, we need
one single message. The message should be coming from command through Jayne.
We need to lay out the groundwork that things are in flux. We will be wearing masks and
maintaining distance even after vaccinations are administered.
Other items:
FROM JAYNE: Can we get folks to take photos of staff in masks that we can use in
campaigns?
Phase 2 and Phase 3 – we need to be ready and planned out – Planning Division is going to
coordinate with Health Staff Offline to be prepped.
Town of Reading
Resolution Condemning Violence at the U.S. Capital Building
1/19/21
The Town of Reading Select Board vehemently condemns the assault and violent takeover of
the U.S. Capitol on January 6, 2021. We join people around the Commonwealth and the country
in calling for an end to the hateful, divisive, and false rhetoric that led to domestic terrorism. This
is not what we want America to represent. We repudiate the wholly false narrative that led to
this assault and any effort to perpetuate it.
This Select Board strongly encourages ALL of our town leaders within our municipal
government, local boards, our first responders, and the Reading Schools to join us in speaking
out to reject falsehoods, conspiracy theories, and incitement of violence. We stand united in
unshakable support of the processes laid out in our Constitution for the peaceful and orderly
transfer of power.
We express our gratitude to all law enforcement officials who put their lives on the line
defending our Nation. We send grat itude and heartfelt condolences to the family of Capitol
Police Officers Brian Sicknick and Howard Liebengood, who died as a result of their service to
protect the Capitol from domestic terrorists.
The Reading Select Board stands resolute in continuing o ur work for the greater good of
residents, our town and our nation.
I have been working with our Town Counsel, consultants, public safety, planning, and CPDC on this
project trying to make our bid deadline. I expect a timeline schedule from W&S soon outlining our
path. There were a few things that we needed to iron out for the timeline. The following is a list of
things that we have done since the last update:
• Worked with Town Counsel to provide a letter to the SB on the options for the cell carrier
equipment.
• Worked with Town Counsel on drafting a license agreement fo r T-Mobile. Discussed planning
and outcome strategies with Counsel on how to proceed with the carriers based on the directive
from the SB.
• Public Safety and Engineering have been reaching out to various vendors on options for
relocating the Town’s Public Safety and Facilities equipment
o Numerous options were discussed and ultimately based on layout constraints the option
before us now is a self-supporting monopole that sits in a 25’x25’ ballast, which sits on a
level ground surface. The trick here is going to be the placement of this temp structure.
o It is unlikely that the carriers will be able to place any temp equipment onsite, such that
the COWs take up too much room. I am trying to limit the cutting of trees as much as
possible.
• Met with Julie Mercier and the chair of the CPDC to discuss the project and what would be
needed for the site plan review and permitting process.
o The Town is currently scheduled for the Feb 22, 2021 CPDC agenda.
• Met with one of the Water Tank manufactures onsite with W&S (who drove out from Syracuse,
NY) to discuss construction logistics and planning for construction.
o Primarily the laydown area requirements and the area needed for the crane. The site is
very limited and the laydown area alone needs to be roughly 75’ in diameter.
o The need to take down trees along Auburn Street and on site was discussed. We will be
proposing replanting where possible.
• Met with the Water division to discuss site preparation including the leveling of the old tank
foundation to make room for the laydown area. This would help facilitate the construction (I
sent you an email request on this earlier).
• Met with the Town’s tower consultant, Bergman Assoc.
• I have been in constant communication with W&S and they will be providing us with a schedule
very soon. Some actions of importance are:
o Bid date May
o CPDC meeting 2/22/21
o Information for CPDC the week of Feb 8.
o DEP application review will be sent mid-March
o Bid documents and specs will be drafted as we go so we will be ready when all
comments and permits have been obtained so they can be attached in the bid package.
Ryan Percival
Town Engineer
From: Percival, Ryan
Sent: Monday, January 04, 2021 11:48 AM
To: LeLacheur, Bob <blelacheur@ci.reading.ma.us>
Cc: Kinsella, Jane <jkinsella@ci.reading.ma.us>; Mercier, Julie <jmercier@ci.reading.ma.us>; Isbell, Peter
<pisbell@ci.reading.ma.us>
Subject: Fwd: Auburn St clean up
Bob,
Please see the email below. Peter I. will be removing the old tank foundation to the right of the current
tank in anticipation for the lay down area needed for the existing tank to be replaced. The old
foundation will only be removed such that the ground can be level. No soil will leave the site. This is
only site clean up and by no means change our plan to file a plan with CPDC for the tank replacement
and 911 radio tower.
This work helps to prepare the site for the upcoming project. Please let me know if feel there will be an
issue with this. Would it be worth emailing the SB in case they receive calls? Peter will wait to proceed
until we hear back.
Thank you,
Ryan
Sent from my iPhone
Begin forwarded message:
From: "Isbell, Peter" <pisbell@ci.reading.ma.us>
Date: January 4, 2021 at 11:17:42 AM EST
To: "Percival, Ryan" <rpercival@ci.reading.ma.us>
Subject: Auburn St clean up
Ryan,
I was going to have a crew go up to the Auburn tank site and remove the old rotted foundation from the
old standpipe. This is needed in preparation of the new tank build and lay down area we discusses a few
weeks ago, also it has been an eye sore and I wanted to clean up the site as best we can.
Please let me know if you think there will be any issues with this.
Thank you,
Peter
Wine and Malt Beverages Only Package Store Liquor Licenses
Public Comments Requested
The Select Board, acting as the Liquor Licensing Authority for the Town, is seeking comments on
whether the Board should obtain authorization to grant liquor licenses to sell wine and malt
beverages only for off-premises consumption pursuant to M.G.L. c.138, §15 (also known as a wine
and malt beverages only package store license). Currently, the Select Board is not empowered to
issue licenses of this type. Thus, before the Board can entertain an application for a wine and malt
only package store license, the following would need to occur:
1. Town Meeting approval to submit a petition to the legislature for a Special Act to issue
wine and malt beverages only package store licenses; and
2. Legislature approval of the Special Act.
Additionally, depending on the language of the Special Act approved by the legislature, voter
approval at the ballot may also be required.
License History and Quota
In 2016, Town Meeting directed the Select Board to petition the legislature for a Special Act
authorizing the issuance of certain types of liquor licenses within Town.1 See Chapter 464 of the
Acts of 2016. The Special Act contains two essential provisions.
First, the Special Act authorizes the issuance of the following liquor licenses:
1. Section 12 license for the sale of all alcoholic beverages for on -premises consumption;
2. Section 12 licenses for the sale of wine and malt beverages only for on -premises
consumption; and
3. Section 15 licenses for the sale of all alcoholic beverages for off-premises consumption.
Notably, the Special Act does not authorize the issuance of a license for the sale of wine and malt
beverages only for off-premises consumption. This restriction is in keeping with the Town’s
historic practice and a 2005 Town Meeting vote defeating an article seeking to sanction the issuance
of such licenses.2
1 Article 4 of the November 21, 2016 Special Town Meeting.
2 Article 25 of the 2005 Annual Town Meeting sought Town Meeting authorization to petition the legislature for a
Special Act that would allow issuance of licenses for the sale of wine and malt beverages only not to be drunk on the
premises. The article failed 12 to 112.
Second, the Special Act establishes that the Town’s license quota is governed by M.G.L. c.138, §17,
and a 2010 Special Act, which grants one all alcohol package store license for use at 30 Haven
Street. See Chapter 459 of the Acts of 2010. Accordingly, the Select Board may issue the following
number of licenses:
License Type Section 17 Quota Reading’s
Quota3
Currently
Issued
Section 12: All
Alcoholic Beverages
One license for each population
until of 1,000 persons, or fraction
thereof. For populations of more
than 25,000 people, one additional
license may be issued for each
addition 10,000-person unit, or
fraction thereof. Minimum of 14.
25 16
Section 12: Wine
and Malt Beverages
Only
One license for each population unit
of 5,000 or fraction thereof.
Minimum of 5.
5 1
Section 15: All
Alcoholic Beverages
One license for each population unit
of 5,000, or fraction thereof.
Minimum of 2.
5; plus 1
pursuant to
2010 Special
Act
6
Section 15: Wine
and Malt Beverages
Only
One license for each population unit
of 5,000 or fraction thereof.
Minimum of 5.
0 N/A
As reflected above, the Town’s five all alcoholic beverages package store licenses, as well as the
license restricted to 30 Haven Street, are currently in use.
Public Input
The Select Board seeks feedback from the public on whether the Town should offer wine
and malt beverages only package store licenses to interested individuals. Comments regarding
impacts on the local economy, diversion to minors, mental health, and licensee diversity are greatly
appreciated.
Comments may be submitted to selectboard@ci.reading.ma.us
3 M.G.L. c.138, §17 states that the population of any city or town shall be that enumerated in the most recent federal
census. Until the 2020 census population figures are certified, the Town’s population is based on the 2010 census,
which reflect a population of 24,757 in Reading. It is anticipated that Reading’s quota of all alcoholic beverages
package store licenses will increase by at least one after the census is certified.
To: Select Board
From: Rick Lopez, MD – Chair, Board of Health
Re: Alcohol Licenses
Date: January 8, 2021
In response to a request from the Select Board, the Board of Health had a discussion at its
January 7, 2021 meeting regarding the public health implications of expanding alcohol licenses
for off-site consumption, such as in convenience stores or gas stations. The purpose of this
memo is to briefly summarize the outcome of that discussion.
A partial review of the public health literature (references available on request) revealed that
the geographic density of liquor licenses is directly correlated with a host of public health issues
including increased alcohol consumption, violent crime, domestic violence, poorer health
outcomes, etc. This correlation in general is higher for licenses allowing off-site consumption
(i.e. package stores) as compared to on-site consumption (i.e. restaurants, bars).
With this background, and realizing that there is no right or wrong answer, the Board would like
to offer following conclusions and suggestions:
1. Reading is a suburban town in a densely populated area and as such it would not be
advisable to strictly limit alcohol licenses to our residents . There are many options in
surrounding communities to obtain alcohol and such restrictions would be a burden to
community in terms of convenience, development, and the economy.
2. That said, the literature suggests as noted above that the more locations where alcohol
can be purchased (especially for off-site consumption), the greater the potential risk to
public health and under-age drinking.
3. The Board of Health discussed the need to weigh the risk noted in #2 against the reality
noted in #1 and recommends careful consideration by the Select Board of thes e factors
when considering additional licenses for convenience stores and gas stations in
particular.
4. Additional alcohol licenses for on-site consumption such as restaurants are the least
likely to impact the public health with respect to alcohol consumpti on.
5. Finally, specialty stores that sell alcohol in addition to other products (such as
Pamplemousse), in our opinion, fall somewhere in between restaurants/bars and
convenience stores/gas stations. While they do provide for off-site consumption, they
would seem to be less risky in terms of the clientele that they typically serve. In
addition, these kinds of stores provide a segment of economic and development activity
that may be beneficial to the town for other reasons.
December 24, 2020
Martin Suuberg
Commissioner
Massachusetts Department of Environmental Protection
One Winter Street
Boston, MA 02108
Dear Commissioner Suuberg,
We write to urge the Massachusetts Department of Environmental Protection (MassDEP) to
consider suspending the Conditional Approval for Comprehensive Plan Approval (Conditional
Approval) issued to Palmer Renewable Energy LLC (Palmer) for a proposed biomass-fired
power plant in Springfield, Massachusetts, so that the new Biden administration can review and
potentially issue new regulations for biomass pollution and climate impact. In addition to
suspending the approval, MassDEP should conduct a new review of the proposed plant’s air
quality impacts that accounts for the ongoing respiratory health pandemic, new public health
data, and the accelerating climate crisis. Springfield residents deserve an updated air quality
analysis that reflects the city’s current health and environmental justice issues, which have
become more acute in the decade since MassDEP initially issued the Conditional Approval.
Springfield already suffers from extremely high rates of respiratory illness. Nearly one in five
children in Springfield have asthma—a rate more than twice the national prevalence rate of 8
percent.1 In 2018 and 2019, the Asthma and Allergy Foundation of America ranked Springfield
as its top “Asthma Capital” and the most challenging place in the U.S. to live with asthma.2 The
proposed Palmer biomass plant would only exacerbate this serious problem. The plant is
expected to burn approximately one ton of wood per minute and emit fine particulate matter,
nitrogen oxides, sulfur dioxide, and other harmful pollutants,3 which can damage the human
respiratory system and make breathing difficult.4
Additionally, COVID-19 has continued to spread throughout the region, with more than 7,730
cases and 145 deaths in Springfield over the course of the pandemic.5 Recent research has linked
1 Pioneer Valley Asthma Coalition, https://pvasthmacoalition.org/asthma_facts__awareness (last visited Dec. 8,
2020).
2 Springfield, Massachusetts: Why It’s the #1 Asthma Capital, https://community.aafa.org/blog/springfield-
massachusetts-why-it-s-the-1-asthma-capital (last visited Nov. 23, 2020).
3 David Abel, In the nation’s asthma capital, plans to burn wood for energy spark fury, Boston Globe (Oct. 20,
2020), https://www.bostonglobe.com/2020/10/20/science/nations -asthma-capital-plans-burn-wood-energy-spark-
fury/.
4 U.S. Environmental Protection Agency, https://www.epa.gov/so2-pollution/sulfur-dioxide-basics#effects (last
visited Dec. 7, 2020).
5 Peter Goonan, New COVID-19 cases in Springfield jump 73% in single week, MassLive.com (Dec. 7, 2020),
https://www.masslive.com/coronavirus/2020/12/new-covid-19-cases-in-springfield-jump-42-in-single-week.html.
Commissioner Martin Suuberg
December 24, 2020
Page 2 of 3
poor air quality to a disproportionately high rate of coronavirus illness and death, 6 and a report
by the Office of Massachusetts Attorney General Maura Healey found that COVID-19 has had a
disproportionate effect on communities of color in Massachusetts’ largest municipalities.7 As the
third-largest city in Massachusetts, with high levels of air pollution, and nearly 90 percent of
residents categorized as living within an environmental justice population, 8 Springfield has
multiple intersecting factors that combine to heighten the citywide risk of COVID-19. In
reassessing the Palmer biomass plant proposal, MassDEP needs to account for the latest research
into the spread of COVID-19, the respiratory health risks in the surrounding population, and the
historic burden of air pollution on the local community.
Furthermore, the body of scientific evidence on climate change and biomass energy has grown
significantly since MassDEP originally issued the Conditional Approval. A wood-burning power
plant has a carbon dioxide emissions rate that is approximately fifty percent higher than that of a
coal-fired power plant, emitting approximately 3,000 pounds of carbon dioxide per megawatt-
hour.9 Scientific studies, including one commissioned by the Commonwealth of Massachusetts,
have found that it takes decades of forest regeneration to offset these emissions.10 The proposed
Springfield biomass plant would therefore undermine Massachusetts’ climate, environmental
justice, and clean energy goals.
The Clean Air Act allows the federal government to delegate authority to state agencies to
regulate intrastate sources of air pollution, in line with federal standards.11 The U.S.
Environmental Protection Agency has approved Massachusetts’ State Implementation Plan for
air quality standards, giving MassDEP the authority to review air quality impacts and issue
permits to polluting facilities. And since 2013, MassDEP has had the legal authority under 301
CMR 7.02(3)(k) to revoke the 2011 Conditional Approval for the proposed biomass-fired power
plant in Springfield based on Palmer’s failure to commence construction of the plant. As our
understanding of the threats posed to air quality, public health, and the climate increases—and as
the new Biden administration develops its air and climate policies—we urge MassDEP to use its
6 Antonio Frontera et al., Severe air pollution links to higher mortality in COVID-19 patients: The “double-hit”
hypothesis, J Infect. (Aug. 2020), published online May 21, 2020,
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7240268/.
7 Office of Massachusetts Attorney General Maura Healey, COVID-19’s Unequal Effects in Massachusetts (2020),
https://www.mass.gov/doc/covid-19s-unequal-effects-in-
massachusetts/download#:~:text=COVID%2D19%20is%20disproportionately%20impacting,residents%20are%20p
eople%20of%20color.
8 MA Executive Office of Energy and Environmental Affairs, 2010 Environmental Justice Populations,
https://www.mass.gov/doc/ej2010communitystatisticspdf/download (last visited Nov. 23, 2020).
9 Mary S. Booth, Trees, Trash, and Toxics: How Biomass Energy Has Become the New Coal , Partnership for Policy
Integrity (Apr. 2, 2014), https://www.pfpi.net/wp-content/uploads/2014/04/PFPI-Biomass-is-the-New-Coal-April-2-
2014.pdf.
10 Thomas Walker et al., Carbon Accounting for Woody Biomass from Massachusetts (USA) Managed Forests: A
Framework for Determining the Temporal Impacts of Wood Biomass Energy on Atmospheric Greenhouse Gas
Levels, J. Sustainable Forestry, 32:1-2, 130-158 (2013); John D. Sterman et al., 2018 Environ. Res. Lett. 13 015007,
https://iopscience.iop.org/article/10.1088/1748-9326/aaa512/pdf..
11 42 U.S.C. §§ 7401-7671 (1990).
Commissioner Martin Suuberg
December 24, 2020
Page 3 of 3
authority to consider suspending the Conditional Approval and reconsider its decade-old
decision to grant Palmer an air quality permit for the biomass-fired power plant in Springfield.
Sincerely,
____________________________
Edward J. Markey
United States Senator
____________________________
Elizabeth Warren
United States Senator
THE COMMONWEALTH OF MASSACHUSETTS
OFFICE OF THE ATTORNEY GENERAL
ONE ASHBURTON PLACE
BOSTON, MASSACHUSETTS 02108
(617) 727-2200
(617) 727-4765 TTY
www.mass.gov/ago
December 23, 2020
The Honorable Michael J. Barrett,
Senate Chair, Joint Committee on Telecommunications, Utilities & Energy
State House, Room 109-D
Boston, MA 02133
The Honorable Thomas A. Golden
House Chair, Joint Committee on Telecommunications, Utilities & Energy
State House, Room 473B
Boston, MA 02133
RE: Comments on Draft Regulations Amending Renewable Portfolio Standard Class I
and II Regulations, 225 C.M.R. §§ 14.00 et seq. and 15.00 et seq. (H.5169)
Dear Chairmen Barrett and Golden and Members of the Joint Committee:
The Massachusetts Attorney General’s Office (AGO) offers the following comments to
aid the Joint Committee on Telecommunications, Utilities, and Energy’s (Committee)
consideration of the Department of Energy Resources’s (DOER) draft regulations amending 225
C.M.R. §§ 14.00 and 15.00 et seq. and associated guidelines 1 (collectively, Draft Regulations),
which significantly amend the eligibility criteria and procedures for biomass generation units
under the Commonwealth’s Renewable Energy Portfolio Standards (RPS) program.
While unique to this Committee and DOER, the long-honored obligation to review and
issue a report on draft DOER regulations is a purposeful cross-check on the regulatory
implementation of the energy policy developed by this Committee. G.L. c. 25A, § 12.
In light of the significant public concern and scientific evidence regarding the climate and
public health impacts of DOER’s Draft Regulations,2 the AGO encourages the Committee
to recommend that DOER initiate a public stakeholder process, including a period for
public comment, on the Draft Regulations and accompanying analyses of the final
1 225 C.M.R. §§ 14.00 et seq.: Renewable Energy Portfolio Standard – Class I; 225 C.M.R. §§ 15.00 et seq.:
Renewable Energy Portfolio Standard – Class II; Guideline on Eligible Biomass Fuel for Renewable Generation
Units; Guideline on Overall Efficiency and Lifecycle Greenhouse Gas Analysis.
2 See, e.g., Springfield City Council, Unanimous Resolution in Opposition to State Subsidies & Incentives for
Biomass Incinerating Power Plants in Massachusetts (Dec. 21, 2020).
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 2 of 12
regulatory package. Further, the AGO requests that prior to issuing its report on the Draft
Regulations, the Committee hold a hearing to consider those well-founded concerns.
The Commonwealth was prescient in stringently constraining biomass participation in the
RPS program, and we should not reverse course now. In this letter, the AGO explains that
(1) forest biomass energy production—the burning of woody fuel from forests to generate
electricity—will only exacerbate the climate and public health crises facing the Commonwealth;
(2) DOER’s Draft Regulations and their complex accompanying analyses, which stakeholders
have not had sufficient time to review, raise important substantive and procedural legal concerns;
and (3) the Draft Regulations contain numerous provisions that may increase—not decrease—
greenhouse gas and other harmful pollutant emissions, and the analyses purporting to support the
Draft Regulations appear to overlook important considerations, make unsupported assumptions,
reach dubious conclusions, and in any event show the regulations may indeed have troubling
emissions impacts. For example:
• DOER analyzed the emissions, forest, and electricity sector impacts of only
the regulations as proposed in April 2019, not the Draft Regulations submitted
to this Committee, which contain significant changes from DOER’s proposal;
• DOER continues to inflate its emissions-reduction calculations by employing
a biomass lifecycle greenhouse gas calculator that determines emissions over
time based on only a single year’s worth of data;
• DOER proceeded with its misguided proposal to limit forest salvage through
vague, unenforceable “Sustainable Forestry Management” practices, leaving it
to third-party foresters to police compliance;
• DOER failed to account for the significant soil carbon emissions associated
with tree harvesting and forest thinning;
• DOER acknowledged that three percent of New England forests will be
permanently lost to development over the next fifty years, but failed to assess
the additional and cumulative impacts of climate change on those forests and
lifecycle greenhouse gas emissions;
• The Draft Regulations may indeed pave the way for increased generation and
construction of new, polluting biomass facilities, including the proposed
facility in Springfield; and
• The analyses accompanying DOER’s Draft Regulations suggest that, in order
to participate in the Massachusetts RPS market, units would have to increase
their “supply radius,” importing qualifying feedstocks from farther away and
potentially putting greater pressure on forests and increasing transportation
emissions.
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 3 of 12
In short, the scientific and technical bases for DOER’s conclusions that expanding RPS
eligibility for burning woody biomass will lead to an increased reduction in greenhouse gas
emissions, not result in a significant increase in biomass plant operations across the region, and
have no significant impact on the region’s forests are, at best, unsubstantiated and, at worst,
erroneous and contradicted by the findings of DOER’s own consultants. As a general rule, those
analyses also fail to reflect the current scientific understanding of the climate impact of burning
wood for fuel and continue to set as a benchmark for efficiency combined cycle natural gas
plants—another highly emitting fossil fuel energy source on which, science tells us, we must
rapidly reduce reliance. We request that the Committee’s review address these concerns.
1. Climate and Public Health Impacts of Biomass Electricity Generation
As this Committee understands well, we are in the midst of a rapidly accelerating climate
crisis. This summer, we endured prolonged significant or critical drought conditions in every
corner of the Commonwealth,3 and the nation watched in horror as skies over California turned
orange and thousands were displaced due to unprecedented mega forest fires.4 Wind storms and
an unusually active hurricane season also exacted a grim toll,5 and 2020 is on track to be the
hottest year on record.6 The Intergovernmental Panel on Climate Change (IPCC) has warned
that, to have a roughly 50 percent chance of limiting warming to 1.5-2.0 degrees Centigrade,
global emissions must be reduced by nearly half in the next ten years, at least 80 percent by
2050, and then decline to zero or become net negative.7 Recognizing the urgency of the climate
crisis, the Commonwealth has imposed nation-leading statewide greenhouse gas emission targets
under its Global Warming Solutions Act (GWSA). See G.L. c. 21N, § 3(b). And just this year
the Secretary of the Executive Office of Energy and Environmental Affairs (EEA) issued a draft
determination establishing net zero as the Commonwealth’s new greenhouse gas emissions limit
for 2050.8
Policies that subsidize wood burning, like the revised RPS eligibility requirements for
biomass set forth in DOER’s Draft Regulations, move the Commonwealth in the wrong
direction. Our forests are one of our first lines of defense against climate change because of their
3 See Massachusetts September 2020 Drought Status (Oct. 9, 2020), https://www.mass.gov/doc/september-
2020/download.
4 See, e.g., Joseph Serna, Changes Caused by Worsening Wildfires in California Forests Will Last Centuries,
L.A. Times (Dec. 21, 2020), https://www.latimes.com/california/story/2020-12-21/worst-california-wildfire-season-
has-altered-forests-for-centuries-to-come; Kendra Pierre-Louis & John Schwartz, Why Does California Have So
Many Wildfires, N.Y. Times (Dec. 3, 2020), https://www.nytimes.com/article/why-does-california-have-
wildfires.html.
5 See 2020 Atlantic Hurricane Season takes infamous top spot for busiest on record, NOAA (Nov. 10, 2020),
https://www.noaa.gov/news/2020-atlantic-hurricane-season-takes-infamous-top-spot-for-busiest-on-record.
6 See Andrea Thompson, 2020 Will Rival 2016 for Hottest Year on Record, Sci. Am. (Dec. 15, 2020),
https://www.scientificamerican.com/article/2020-will-rival-2016-for-hottest-year-on-
record/#:~:text=As%20of%20the%20end%20of,records%20go%20back%20141%20years).
7 Intergovernmental Panel on Climate Change, Global Warming of 1.5° C – Summary for Policy Makers, SPM-
14,16 (Oct. 6, 2018), http://report.ipcc.ch/sr15/pdf/sr15_spm_final.pdf.
8 See Sec’y of Energy and Envtl. Affs., Request for Comments (Feb. 26, 2020), https://www.mass.gov/doc/draft-
letter-of-determination-on-the-2050-emissions-limit-revised-342020/download.
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 4 of 12
ability to sequester carbon.9 Yet DOER’s new regulations threaten their integrity and will result
in increased greenhouse gas emissions almost certainly in the short term—when we need to be
drastically reducing emissions—and most likely over the longer term, notwithstanding the
flawed analyses accompanying DOER’s Draft Regulations. Per BTU, wood has about the same
carbon content as coal,10 and, according to the Environmental Protection Agency, wood contains
about 75% more CO2 per British thermal unit (BTU) than natural gas.11 As a result, wood that is
harvested and burned for energy immediately increases CO2 emissions—even where it is
displacing fossil fuels.12
Moreover, while it is generally true that forest regrowth can partially offset greenhouse
gas emissions generated from wood burning in some circumstances, in New England, in general,
and in Massachusetts, in particular, that regrowth can take up to a century or longer.13 In the
meantime, biomass energy production will accelerate irreversible harms associated with climate
change that render rates of future forest regrowth even less certain, including extreme weather
events like ice storms and hurricanes,14 increased insect populations, droughts, and changing
rainfall patterns.15 Additionally, though some burned biomass fuel, like forest-derived salvage,
would decay and generate greenhouse gas emissions if left in place, that process, too, would
unfold slowly over time, as compared to the immediate release of greenhouse gas emissions from
9 See William Moomaw et al., Intact Forests in the United States: Proforestation Mitigates Climate Change and
Serves the Greatest Good, 2 Front. For. Glob. Change 27, 4-5 (June 11, 2019) (concluding that Western
Massachusetts forests have a “particularly high untapped capacity for carbon storage and sequestration” because of
“high growth,” “low decay rates,” and no significant harvest in the last 75-150 years).
10 John D. Sterman et al., Does Replacing Coal with Wood Lower CO2 Emissions? Dynamic Lifecycle Analysis
of Wood Bioenergy, 13 Envtl. Res. Letters 1, 2 (2018), https://iopscience.iop.org/article/10.1088/1748-9326/aaa512.
11 U.S. Envtl. Prot. Agency, Emission Factors for Greenhouse Gas Inventories (Mar. 26, 2020),
https://www.epa.gov/sites/production/files/2020-04/documents/ghg-emission-factors-hub.pdf.
12 Sterman at 2 (“Burning wood instead of coal creates a carbon debt—an immediate increase in atmospheric
CO2 compared to fossil energy.”); see Philippe Leturcq, GHG Displacement Factors of Harvested Wood Products:
The Myth of Substitution, 10 Sci. Rep. 20752, 4 (Nov. 27, 2020), https://doi.org/10.1038/s41598-020-77527-8 (“The
combustion emission of wood is clearly higher than that of other fuels.”); Mary S. Booth, Not Carbon Neutral:
Assessing the Net Emissions Impact of Residues Burned for Bioenergy, 13 Envtl. Res. Letters 035001, 1 (Feb. 21,
2018), https://iopscience.iop.org/article/10.1088/1748-9326/aaac88/pdf (“Biomass power plants tend to emit more
CO2 than fossil fueled plants per MWh, and as shown by a number of studies, net emissions from bioenergy can
exceed emissions from fossil fuels for decades.”).
13 See Tara W. Hudiburg et al., Meeting GHG Reduction Targets Requires Accounting for All Forest Sector
Emissions, 14 Envtl. Res. Letters 095005, 7 (Aug. 23, 2019) (“While it is theoretically possible that a replacement
forest will grow and absorb a like amount of CO2 to that emitted decades or a century before, there is no guarantee
that this will happen, and the enforcement is transferred to future generations.”); Moomaw at 2 (“[N]ewly planted
forests require many decades to a century before they sequester carbon dioxide in substantial quantities.”).
14 See U.S. Global Change Research Program, Impacts, Risks, and Adaptation in the United States: Fourth
National Climate Assessment, Volume II, 179 (2018) (rev’d 2020) (“Fourth National Climate Assessment”),
https://nca2018.globalchange.gov/downloads/NCA4_2018_FullReport.pdf (explaining that extreme weather, such as
“high winds, thunderstorms, hurricanes, heat waves, intense cold period, intense snow events, ice storms, and
extreme rainfall” will likely increase over the next century).
15 See id. at 206-07, 234, 236-37 (describing likelihood of changes in insect activity, drought, and rainfall as a
result of climate change); see Sterman at 8 (“The carbon debt incurred when wood displaces coal may never be
repaid if development, unplanned logging, erosion or increases in extreme temperatures, fire, and disease (all
worsened by global warming) limit regrowth or accelerate the flux or carbon from soils and the atmosphere.”).
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 5 of 12
burning such materials.16 And beyond stack emissions, wood harvesting also significantly
increases greenhouse gas emissions by releasing carbon stored in soil into the atmosphere,17 and
climate change may further increase the release of soil carbon resulting from wood harvest.18
Critically, biomass combustion also emits “traditional” harmful pollutants, including
particulate matter, that present serious health threats, especially to the communities in which
these plants are sited.19 Small particulate matter, which consists of liquid or solid particles
“small enough to be inhaled deeply,”20 accounts for most of the health impacts of air pollution in
the United States 21 and is connected to a multitude of adverse health consequences, including
premature death, cardiovascular effects, asthma, bronchitis, pneumonia, chronic obstructive
pulmonary disease,22 and, most recently, a higher COVID-19 death rate.23 Black and Latinx
communities in Massachusetts experience disproportionately higher particulate matter
exposure.24 As a result, environmental justice communities with higher concentrations of
particulate matter experience these adverse health consequences at higher rates.25 Incentivizing
biomass combustion in the Commonwealth would further burden communities already
disproportionately affected by pollution with dangerous additional particulate matter emissions.
The proposed biomass facility in Springfield, for example, would jeopardize the health of an
16 Booth at 2.
17 Steven P. Hamburg et al., Losses of Mineral Soil Carbon Largely Offset Biomass Accumulation 15 Years
After the Whole-Tree Harvest In a Northern Hardwood Forest, 144 Biogeochemistry 1, 1 (June 15, 2019) (“If . . .
the extent of forest harvesting is expanded to meet demand for bioenergy or to manage ecosystem carbon
sequestration, then it will take substantially longer than previously assumed to offset harvest- or bioenergy-related
carbon dioxide emissions with carbon uptake during forest regrowth.”); Fourth National Climate Assessment at 244
(“Increased disturbances such as harvesting, wildfire, and insect and disease damage can also release carbon stored
in soils, especially where multiple disturbances occur over a short time span.”); see Moomaw at 4 (“Some older
forests continue to sequester additional soil organic carbon and older forests bind soil organic matter more tightly
than younger ones. If current management practices continue, the world’s forests will only achieve half of their
biological carbon sequestration potential; intensifying current management practices will only decrease living
biomass carbon and increase soil carbon loss.” (citations omitted)).
18 David L. Achat et al., Forest Soil Carbon Is Threatened By Intensive Biomass Harvesting, 5 Sci. Reps. 1, 6
(Nov. 4, 2015) (“[Soil organic carbon (“SOC”)] losses in topsoils due to conventional harvests increased with
increasing initial SOC, the latter being itself partly controlled by climate. . . . Climatic influence was clearer for
intensive harvests, as demonstrated by the positive relationships between SOC losses and mean annual temperature
and evapotranspiration.”).
19 See, e.g., Fourth National Climate Assessment at 519 (discussing particulate matter emission from wildfires);
Luke P. Naeher et al., Woodsmoke Health Effects: A Review, 19 Inhalation Toxicology 67 (2007).
20 Fourth National Climate Assessment at 518.
21 Id. at 520.
22 Id. at 517-19.
23 See Off. Mass. Attorney Gen. Maura Healey, COVID-19’s Unequal Effects in Massachusetts 6 (2020)
(“Mass. AGO COVID-19 Report”), https://www.mass.gov/doc/covid-19s-unequal-effects-in-
massachusetts/download (citing Xiao Wu et al., Air pollution and COVID-19 ortality in the United States, 6 Sci.
Advances 45 (2020), https://advances.sciencemag.org/content/6/45/eabd4049?utm_source=newsletter&
utm_medium=email&utm_campaign=newsletter_axiosfutureofwork&stream=future).
24 Mass. AGO COVID-19 Report at 5 (citing Anna Rosofsky, et al., Temporal Trends in Air Pollution Exposure
Inequality in Massachusetts, 161 Envtl. Res. 76 (2018), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5761067/
pdf/nihms917702.pdf).
25 See Mass. AGO COVID-19 Report at 6-7 (citing Wu at 46).
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 6 of 12
environmental justice community already deemed the nation’s “asthma capital.”26 In sum, the
science shows that biomass energy generation only exacerbates climate and public health harms.
2. Potential Legal Issues Raised by DOER’s Draft Regulations and Analyses
Like DOER’s proposed regulations published in April 2019, the Draft Regulations raise
several substantive and procedural legal concerns that warrant further consideration during
Committee review and before DOER finalizes amendments to its RPS biomass program.
First, to the extent the Draft Regulations could lead to an increase in greenhouse gas
emissions, see infra Section 3, the Draft Regulations would run counter to both the
Commonwealth’s obligation to “attain actual, measurable, and permanent emissions reductions”
under the GWSA, Kain v. Dep’t of Envtl. Prot., 474 Mass. 278, 300 (2016), and the low-
emission eligibility requirements set forth in the RPS statute, G.L. c. 25A, § 11F. The GWSA,
for its part, “is designed to make Massachusetts a national, and even international, leader in the
efforts to reduce the greenhouse gas emissions that cause climate change.” New England Power
Generators Ass’n v. Dep’t of Envtl. Prot., 480 Mass. 398, 399 (2018). The statute accordingly
requires the Commonwealth and its agencies to reduce statewide greenhouse gas emissions by at
least eighty percent below 1990 levels by 2050 and to meet interim declining limits every decade
along the way to maximize the Commonwealth’s ability to meet the 2050 target. G.L. c. 21N,
§ 3(b); see also id. § 6 (“In implementing its plan for statewide greenhouse gas emissions limits,
the commonwealth and its agencies shall promulgate regulations that reduce energy use,
increase efficiency and encourage renewable sources of energy in the sectors of energy
generation, buildings and transportation.” (emphases added)).27 The Secretary of EEA
accordingly has directed that Massachusetts reduce statewide greenhouse gas emissions by at
least twenty-five percent below 1990 levels by 2020,28 and has issued a draft determination
establishing net zero greenhouse gas emissions as the Commonwealth’s new emissions limit for
2050—a public process that is still underway.29
DOER’s RPS program is a key component of the Commonwealth’s efforts to meet the
GWSA’s interim and 2050 limits by incentivizing renewable energy sources while phasing out
dirtier fuel. Indeed, it is important not only as a climate policy in its own right, but also as a
foundation for EEA and the Department of Environmental Protection’s implementation of the
GWSA through its declining emissions cap on the electric sector and Clean Energy Standard.
See G.L. c. 21N, § 3(c)-(d); 310 C.M.R. §§ 7.72-7.75 & 60.05-60.06. If the Draft Regulations
would, by expanding subsidies for biomass energy, increase greenhouse gas emissions, the RPS
program would be inconsistent with the GWSA’s near- and long-term emissions-reduction
26 Asthma and Allergy Found. Am., Asthma Capitals 2019: The Most Challenging Places to Live with Asthma,
33 (2019), https://www.aafa.org/media/2426/aafa-2019-asthma-capitals-report.pdf.
27 The AGO is also aware of ongoing efforts by the Committee Chairs to reach agreement on wide-ranging
climate proposals intended to further the Commonwealth’s efforts to meet GWSA targets.
28 See Sec’y of Energy and Envtl. Affs., 2015 Update of the Clean Energy and Climate Plan for 2020 (Dec. 31,
2015), https://www.mass.gov/doc/clean-energy-and-climate-plan-for-2020/download.
29 See Sec’y of Energy and Envtl. Affs., Request for Comments (Feb. 26, 2020),
https://www.mass.gov/doc/draft-letter-of-determination-on-the-2050-emissions-limit-revised-342020/download.
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 7 of 12
mandates and its core “anti-backsliding” purpose. See G.L. c. 21N, § 3(b), (d) (requiring
adoption of declining statewide emissions limits and declining source category emissions limits,
respectively); Kain, 474 Mass. at 287 (GWSA’s “central purpose” is “reducing emissions in the
Commonwealth”).30
Additionally, to the extent the Draft Regulations would increase greenhouse gas
emissions, they may be in significant tension with the RPS statute. In particular, the statute
requires that qualifying renewable energy generating sources include only those biomass
facilities that use “low emission advanced biomass power conversion technologies.” G.L.
c. 25A, § 11F(b)(8), (c)(7), and (d)(8). If DOER weakens its existing biomass eligibility and
efficiency requirements, its regulations may exceed the scope of their enabling legislation and
newly eligible facilities may no longer actually qualify as “low emission” and “advanced” within
the meaning of the statute.
Second, DOER’s promulgation of the Draft Regulations appears to be in conflict with the
administrative rulemaking procedures set forth in Chapter 30A. In particular, the Draft
Regulations contain potentially significant changes from the regulations proposed for public
comment that arguably warrant further public process. Cf. G.L. c. 30A, § 2 (public “notice shall
. . . either state the express terms or describe the substance of the proposed regulation”). For
example, the Draft Regulations include an entirely new provision expanding eligible forest
salvage to include damaged trees “harvested through a [Department of Conservation and
Recreation] approved cutting plan.”31 That change, DOER recognized, “will allow a greater
amount of Forest Salvage to qualify for the RPS”32 even though, DOER noted elsewhere, the
“appropriate calculation of carbon emissions of Forest Salvage is an evolving topic.”33
Additionally, the Draft Regulations for the first time “create a phased approach to reduction in
the cap” on Class I Alternative Compliance Payments (ACP) that electricity suppliers may pay to
the Massachusetts Clean Energy Center in lieu of demonstrating RPS compliance, setting a
declining Alternative Compliance Payment that starts at $60 per megawatt hour (MWh) in 2021
and declines to $40 per MWh in 2023.34 But the proposed regulations would have capped the
ACP at $70 per MWh and gave no indication that a declining cap was under consideration.35
DOER’s insufficient notice of such major changes, if not remedied before finalizing the Draft
Regulations, would subvert the purpose of notice and comment rulemaking to provide
meaningful opportunity for public review and input.
30 Cf. Sierra Club v. Ruckelshaus, 344 F. Supp. 253, 256 (D.D.C. 1972) (interpreting Federal Clean Air Act’s
purpose to prohibit degradation of existing air quality), aff’d sub nom. Fri v. Sierra Club, 412 U.S. 541 (1973).
31 Draft Regulations at 225 C.M.R. § 14.02 (definition of “Forest Salvage” within definition of “Eligible
Biomass Woody Fuel”).
32 DOER, Response to Comments at 13 (§ VII.D) (Dec. 4, 2020), https://www.mass.gov/doc/rps-reponse-to-
comments-12-04-20/download.
33 Id. at 10 (§ VII.B.).
34 Id. at 3 (§ V.A.); see Draft Regulations at 225 C.M.R. § 14.08(3).
35 See Proposed Regulations at 225 C.M.R. § 14.08(3), https://www.mass.gov/files/documents/2019/04/08/
225%20CMR%2014.00%20Draft%20RPS%20Class%20I%20CLEAN%20%28030119%29_0.pdf; DOER, RPS
and APS Stakeholder Announcement, RPS Class I § 3.b. (May 15, 2019), https://www.mass.gov/files/documents/
2019/05/15/RPS%20and%20APS%20Stakeholder%20Announcement.pdf.
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 8 of 12
Relatedly, DOER has not provided any opportunity for public input or review of the
highly complex analyses, assumptions, or conclusions of the studies accompanying its Draft
Regulations. In 2019, the AGO actively participated in DOER’s stakeholder process on the
proposed regulations preceding the Draft Regulations, including submitting comments
identifying numerous proposed changes that appeared to be inconsistent with Massachusetts
climate policy and DOER’s statutory mandate to incentivize low-emission, advanced renewable
energy.36 In those comments, the AGO also urged DOER to comprehensively assess and model
through a transparent, iterative public process both the effect of further biomass subsidies on
electricity sector demand for biomass energy and the likely short- and long-term emissions
impacts of each of its proposed changes against an accurate baseline.
Following public comment, DOER commissioned a technical analysis by Sustainable
Energy Advantage, LLC, of the potential impact of the proposed regulations on biomass
generation (SEA Report) and conducted assessments of the proposal’s potential impact on
lifecycle greenhouse gas emissions (GHG Analysis) and state and regional forests (Forest Impact
Assessment).37 But DOER did not engage with the public in designing, commissioning, or
conducting those complex analyses or publish their results for public comment—in stark contrast
to DOER’s approach in other regulatory proceedings in which each progressive step includes
stakeholder comment. Instead, DOER for the first time publicly released the results of the
analyses when it submitted the final Draft Regulations to this Committee this month, nearly a
year and a half after the comment period closed. DOER has thus cabined public review to the
tail end of a busy legislative session, during conference committee discussions of the climate bill,
over the holidays, in the height of the global COVID-19 pandemic, and just before the Executive
Office of Energy and Environmental Affair’s release of its 2030 Clean Energy and Climate Plan
and roadmap identifying pathways to meet the Commonwealth’s ambitious and critical 2050
emission-reduction goals.38
Accordingly, the AGO believes that further stakeholder process, including opportunity
for public comment, is needed to allow meaningful consideration of the significant emissions
implications of the Draft Regulations, including changes that appear for the first time in the Draft
Regulations and the analyses undergirding DOER’s approach. The Committee’s report is an
appropriate opportunity to emphasize that need.
36 Massachusetts Attorney General’s Office Comments to the Department of Energy Resources regarding
Proposed Amendments to Renewable Portfolio Standard Class I and II Regulations, 225 C.M.R. §§ 14.00 et seq.,
15.00 et seq. (July 26, 2019) (Mass. AGO Comments) (incorporated herein as Attachment A).
37 See Sustainable Energy Advantage, Renewable Portfolio Standard Technical Analysis of Biomass (Dec. 4,
2020), https://www.mass.gov/doc/rps-technical-analysis-of-biomass-report/download; DOER, Renewable Energy
Portfolio Standard-Forest Impact Assessment (Dec. 2020), https://www.mass.gov/doc/rps-forest-impact-
assessment/download.
38 Indeed, it appears that stakeholder input and review of DOER’s analyses would have been helpful by
identifying issues like those set forth in this letter, including that the analyses assess only the regulations as
proposed, not as submitted to this Committee, and appear to rely on questionable assumptions and yield troubling
conclusions, as discussed infra Section 3.
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 9 of 12
3. AGO Concerns Regarding the Draft Regulations and Analyses
Finally, though the AGO has not had sufficient time to comprehensively review and
evaluate the regulatory package submitted to the Committee, the Draft Regulations and
accompanying analyses of their impact appear problematic in important ways.
First, the Draft Regulations inexplicably retain many of the provisions in the proposed
regulations that have the potential to increase greenhouse gas emissions and harm public health,
as explained in AGO’s comments on the proposal.39 To be sure, the AGO appreciates that
DOER has abandoned several of its damaging proposed amendments, validating some
stakeholder concerns that the regulations as proposed would have hindered the Commonwealth’s
emissions-reduction and public health goals.40 But those concerns unfortunately did not drive
DOER’s revisions to the vast majority of its regulatory package. For example, DOER continues
to employ a biomass greenhouse gas “tool” (i.e., calculator) that determines emissions over time
based on a single year’s worth of data and thus arbitrarily inflates its emissions-reduction
calculations.41 And DOER proceeded with its misguided proposal that forest-derived residues
and forest-derived thinnings may be sourced from forests meeting vague, unenforceable
“Sustainable Forestry Management” practices, resting the integrity of its entire program on the
say-so (“independent[] verifi[cation]”) of third-party foresters.42
Second, as discussed supra Section 2, the Draft Regulations include new provisions that
may reduce RPS compliance and expand eligible fuel and thereby potentially increase
greenhouse gas emissions. But the SEA Report, GHG Analysis, and Forest Impact Analysis
evaluate only the regulations as proposed and not the Draft Regulations as submitted to the
Committee.43 In other words, it appears that no analyses have been performed in connection
with the actual Draft Regulations DOER now plans to implement. Because the analyses do not
include any projections with respect to the Draft Regulations’ new provisions and do not provide
sufficient data to isolate the impact of any particular regulatory change in the proposal, it is
impossible even to approximate the potential impact of the Draft Regulations from the
information provided. For example, the Draft Regulations would likely substantially increase
eligible forest salvage to include salvage from DCR-approved cutting plans, without any
39 See Mass. AGO Comments at 6-9.
40 See, e.g., Draft Regulations at 225 C.M.R. §§ 14.05(1)(a)7.c., 14.05(8)(b)1. & 15.05(1)(a)8.c., 15.05(5)(b)1.
(abandoning proposals to reduce overall efficiency requirement from sixty percent to fifty percent and to waive
efficiency requirement for units burning more than ninety-five percent forest salvage), 14.05(1)(a)7.d. &
15.05(1)(a)8.d. (abandoning proposal to extend period for calculating lifecycle greenhouse gas emissions from
twenty to thirty years).
41 See Mass. AGO Comments at 8; DOER, RPS: Guideline on Overall Efficiency and GHG Analysis (last
updated Dec. 4, 2020), https://www.mass.gov/doc/rps-guideline-on-overall-efficiency-and-ghg-analysis.
42 See Mass. AGO Comments at 9; Draft Regulations at 225 C.M.R. §§ 14.02, 14.05(8)(a) & 15.02, 15.05(5)(a).
DOER undertook this revision, despite its prior consultant’s conclusion that “the sustainable management of forests
is critical to ensuring carbon can be sequestered.” SEA Report, App. B: DOER RPS Lifecycle Greenhouse Gas
Analysis, at 2 (Dec. 2020), https://www.mass.gov/doc/rps-technical-analysis-of-biomass-appendix-b/download
(citing Manomet Ctr. for Conservation Scis., Biomass Sustainability and Carbon Policy Study (June 2010),
https://www.manomet.org/wp-content/uploads/2018/03/ Manomet_Biomass_Report_ Full_June2010.pdf).
43 See SEA Report at 8, 26 (describing and assessing “proposed policy changes”).
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 10 of 12
assessment of the amount of eligible salvage available under such cutting plans or its impact on
forests and greenhouse gas emissions if burned.44
Third, the analyses of the proposed regulations themselves appear to omit key
considerations, rely on questionable assumptions, draw unsupported conclusions, and in any
event disclose troubling emissions and forest impacts. For example, the GHG Analysis
appended to the SEA Report appears to leave unanswered the extent to which the regulations as
proposed would lead to increased greenhouse gas emissions from disturbing forest soil,45 despite
soil’s well-documented role as a carbon sink.46 Additionally, DOER’s Forest Impact
Assessment noted that, at current annual loss rates, 1.2 million acres, or three percent, of New
England forests could be permanently be lost to development over the next fifty years, yet DOER
failed even to mention—let alone account for—the additional and cumulative impact of climate
change on forests, including increased extreme weather events, drought, changes in rainfall
patterns, and increased damage from insects.47
The SEA Report also assumed that only six of the forty-six existing biomass generation
units in New England might increase generation materially as a result of the regulations and
therefore expressly does not study the impact of the proposed regulations on the forty remaining
units.48 But the SEA Report’s stated reasons for excluding those forty facilities from the analysis
may not hold up. It is unclear, for example, whether the proposed changes, including expansion
of eligible fuel and relaxation of compliance procedures, could nonetheless result in increased
generation at already eligible biomass facilities or entice retired units to come back online.
Additionally, even with respect to the six units actually studied, the SEA Report acknowledged
that “the market and policy landscapes and supply responses to those landscape [sic] are
constantly shifting,” undermining its core conclusion that the proposed regulations would not
cause those units to participate in the Massachusetts RPS market because other states’ markets
are currently more lucrative. 49
Further, the SEA Report’s conclusion that RPS revenue under the proposed regulations is
“extremely unlikely to be sufficient to finance a new biomass facility” answers the wrong
question.50 The pertinent question is whether the incentives available under the amended RPS
program would move the needle for a new biomass facility that has other sources of financing
available, like federal funding and long-term municipal contracts. Of particular concern to the
AGO, the SEA Report claimed that the “exact status” of the proposed biomass generation plant
in Springfield is “not known” and so did not assess the impact of the proposed regulations on the
viability of that facility taking into account its current, knowable contracts and financing.51 And,
indeed, it appears the Draft Regulations may prove lucrative for that facility, as they altogether
44 See, e.g., Draft Regulations at 225 C.M.R. § 14.02.
45 See generally SEA Report, App. B.
46 See supra nn.15-16.
47 See Forest Impact Assessment at 3.
48 See SEA Report at 12-13.
49 Id. at 1-2, 33.
50 Id. at 2, 24, 32.
51 Id. at 10 & n.15.
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 11 of 12
waive the efficiency requirement for facilities using more than ninety-five percent non-forest-
derived residues 52—the fuel stock the facility is permitted to burn. See In re Palmer Renewable
Energy, LLC, Dkt. Nos. 2011-021 &-02, 2012 WL 5377276, at *1-2 (Mass. Dep’t Envtl. Prot.
July 9, 2012) (Recommended Final Decision after Remand).
Finally, the SEA Report, taken at its word, actually suggests that the regulations may
yield increased emissions. Specifically, the SEA Report suggests that changes to biomass
requirements may increase overall biomass generation at the six marginal plants studied by four
to thirteen percent, over 2019 levels.53 The SEA Report also suggests that biomass output will
increase over the study period, with 2025 generation at these facilities increasing by as much as
63.8 percent over 2019 levels.54 Increases in biomass generation might be higher still, if some
fraction of the forty units excluded from SEA’s analysis do, in fact, respond to the policy
changes.55 And were new production to come online, the SEA Report acknowledged, “an
increase in production from zero to greater than zero would, under DOER’s greenhouse gas
accounting methods, show an increase in greenhouse gas emissions in early years.”56
Additionally, the Biomass Resource Evaluation appended to the SEA Report concluded that,
because none of the facilities deemed to be candidates for participation in the new RPS biomass
market are likely to be able to meet the fifty percent overall efficiency requirement, participation
will require those plants to increase their “supply radius” to secure ninety-five percent of their
fuel from non-forest residues and forest salvage—apparently by importing those feedstocks from
farther away and potentially putting greater pressure on forests and increasing emissions from
transporting such fuel.57
In sum, DOER’s Draft Regulations and accompanying analyses raise more questions than
they answer—questions that warrant further, in-depth review.
52 See Draft Regulations at 225 C.M.R. §§ 14.05(1)(a)7.c., 14.05(8)(b)2. & 15.05(1)(a)8.c., 15.05(5)(b)2.
53 The six marginal generators produced a total of 994,073 MWh from “wood and wood waste” in 2019
according to government sources. See U.S. Energy Info. Admin., Form-923, Schedules 3-5, 1,
https://www.eia.gov/electricity/data/eia923/archive/xls/f923_2019.zip. SEA estimates that policy changes would
increase biomass output by 247,907 MWh to 800,186 MWh over the six-year study period. SEA Report at 32. On
an annualized basis, therefore, the changes would increase output by between 41,317 MWh (4.2%) and 133,364
MWh (13%) over 2019 levels.
54 SEA’s analysis indicates that in 2025, output would increase by 634,000 MWh over the baseline. See Id. at
Table 10. If the 2025 output figures are representative of longer-term trends, then the policy changes would increase
biomass output at these facilities by 63.8 percent, over 2019 levels.
55 Id. at 12-13.
56 Id. at 30.
57 SEA Report App. A: Biomass Resource Evaluation, at 21 (Dec. 4, 2020), https://www.mass.gov/doc/rps-
technical-analysis-of-biomass-appendix-a/download.
AGO Comments on 225 C.M.R. §§ 14.00
et seq. and 15.00 et seq. (H.5169)
December 23, 2020
Page 12 of 12
Conclusion
As the Supreme Judicial Court has emphasized, Massachusetts climate policy “is
designed to go well beyond business as usual in terms of reducing emissions: to upend, rather
than to uphold, the status quo.” New England Power Generators Ass’n, Inc., 480 Mass. at 406.
And the Commonwealth has both a legal and a moral obligation to protect our most vulnerable
communities from harmful air pollution. Incentivizing additional forest biomass energy
production would be a step backward, not forward, in those critical efforts.
For the reasons described herein, we encourage the Committee to recommend that DOER
initiate a public stakeholder process, including a period for public comment, on the Draft
Regulations and analyses supporting those regulations. Further, the AGO requests that, prior to
issuing its report on the Draft Regulations, the Committee hold a hearing to consider the well-
founded public concern and scientific evidence regarding the significant climate and public
health impacts of biomass generation in the Commonwealth.
Sincerely,
Melissa Hoffer
Chief, Energy and Environment Bureau
ATTACHMENT A
THE COMMONWEALTH OF MASSACHUSETTS
OFFICE OF THE ATTORNEY GENERAL
ONE ASHBURTON PLACE
BOSTON, MASSACHUSETTS 02108
(617)727-2200
(617) 727-4765 TTY
www.mass.gov/ago
July 26, 2019
BY ELECTRONIC MAIL
Department of Energy Resources
100 Cambridge Street, Suite 1020
Boston, MA 02114
Attn: Attention John Wassam
DOER.RPS@mass.gov
Re: Comments on Amendments to Renewable Portfolio Standard Class I and II
Regulations, 225 C.M.R. §§ 14.00 et seq., 15.00 et seq.
The Office of Attorney General Maura Healey (the “AGO”) appreciates the opportunity
to offer these comments on the woody biomass provisions of the Massachusetts Department of
Energy Resources’s (“DOER”) proposed amendments to 225 C.M.R. §§ 14.00 et seq.:
Renewable Energy Portfolio Standard – Class I, 225 C.M.R. §§ 15.00 et seq.: Renewable Energy
Portfolio Standard – Class II, and its proposed Renewable Energy Portfolio Standard Guideline
on Eligible Biomass Fuel for Renewable Generation Units and Draft Guideline on Overall
Efficiency and Lifecycle Greenhouse Gas Analysis (together, the “Proposed Amendments”).1
The Proposed Amendments raise significant concerns about the potential for increased
greenhouse gas emissions from biomass energy under the Commonwealth’s vital Renewable
Energy Portfolio Standard (“RPS”) program and may undermine the Commonwealth’s nation-
leading efforts to address climate change by achieving significant reductions in emissions over
the short and long terms.
In these comments, the AGO provides (1) background information regarding
Massachusetts’ climate policy and the emissions implications of woody biomass, (2) brief
concerns about the legal implications of the Proposed Amendments to DOER’s RPS regulations,
and (3) specific recommendations regarding the Proposed Amendments. The AGO urges DOER
to reconsider its proposed changes to the woody biomass provisions of the Proposed
Amendments as they appear to be inconsistent with Massachusetts climate policy and DOER’s
statutory mandate to incentivize low-emission, advanced renewable energy.
1 The AGO’s comments solely concern the Proposed Amendments related to woody biomass and do not address
the other provisions of the Proposed Amendments.
2
Background
The AGO strongly supports Massachusetts’s efforts to lower greenhouse gas emissions
and promote clean, renewable energy. As the Fourth National Climate Assessment makes clear,
the Earth’s climate system is rapidly changing, almost wholly due to human activity, like
deforestation and combustion of fossil fuels, that results in the emission of greenhouse gases.2
Global annual average surface air temperature increased by 1.8 °F from 1901 to 2016, making
this period “the warmest in the history of modern civilization.”3 Climate change presents a
serious threat to the Commonwealth and its residents. According to recent research by the
University of Massachusetts, the Northeast, including Massachusetts, will continue to see
temperatures rise higher and more quickly than the rest of the United States and the world.4 Sea
level rise, too, is projected to be higher on the East Coast of the United States than the global
average.5 By 2100, Massachusetts is projected to experience between 4.0 and 7.6 feet of sea
level rise relative to mean sea level from the year 2000, with up to 10.2 feet possible under a
high-emissions scenario.6 Warmer temperatures, extended heat waves, flooding, changing
precipitation, and increasingly severe weather events are already having significant impacts on
public health, the environment, and agriculture in Massachusetts, causing billions in property
damage and straining key infrastructure like the electrical grid.7
These accelerating climate harms underscore the need to reduce greenhouse gas
emissions in the near term, as quickly as possible. According to the 2018 report of the
Intergovernmental Panel on Climate Change, limiting global warming to 1.5 °C will require
rapid—within the next ten to fifteen years—and far-reaching economy-wide transitions,
including massive electrification of the economy with carbon-free fuels.8 Massachusetts law
2 USGCRP, IMPACTS, RISKS, AND ADAPTATION IN THE UNITED STATES: FOURTH NATIONAL CLIMATE
ASSESSMENT, VOLUME II: REPORT-IN-BRIEF 4 (D.R. Reidmiller et al. eds., 2018),
https://nca2018.globalchange.gov/downloads/NCA4_Report-in-Brief.pdf. The Fourth National Climate Assessment
is a two -volume peer-reviewed assessment released by the U.S. Global Change Research Program coordinated by
thirteen federal agencies and representing the work of over 200 governmental and nongovernmental experts. See
USGCRP, CLIMATE SCIENCE SPECIAL REPORT: FOURTH NATIONAL CLIMATE ASSESSMENT, VOLUME I (D.J.
Wuebbles et al. eds., 2017), available at https://science2017.globalchange.gov/ (“FOURTH ASSESSMENT, Vol. I”);
USGCRP, IMPACTS, RISKS, AND ADAPTATION IN THE UNITED STATES: FOURTH NATIONAL CLIMATE ASSESSMENT,
VOLUME II: REPORT-IN-BRIEF 1 (D.R. Reidmiller et al. eds., 2018), available at
https://nca2018.globalchange.gov/downloads/NCA4_Report-in-Brief.pdf.
3 FOURTH ASSESSMENT, Vol. I, at 10, 13, 17 (Exec. Summ.), 39, 40 (Ch. 1), 78, 80-84
(Ch. 2).
4 Horton et al., Northeast, in CLIMATE CHANGE IMPACTS IN THE UNITED STATES: THE THIRD NATIONAL
CLIMATE ASSESSMENT, 373 (2014), available at http://nca2014.globalchange.gov/report/regions/northeast.
5 FOURTH ASSESSMENT, Vol. I, at 10 (Exec. Summ.).
6 See NORTHEAST CLIMATE ADAPTATION SCIENCE CTR., MASSACHUSETTS CLIMATE CHANGE PROJECTIONS-
STATEWIDE AND FOR MAJOR DRAINAGE BASINS 15 (Mar. 2018), https://nescaum-dataservices-
assets.s3.amazonaws.com/resources/production/MA%20Statewide%20and%20MajorBasins%20Climate%20Project
ions_Guidebook%20Supplement_March2018.pdf.
7 See, e.g., id. at 4-6; MASSACHUSETTS DEP’T OF PUB. HEALTH, CAPACITY TO ADDRESS THE HEALTH IMPACTS
OF CLIMATE CHANGE IN MASSACHUSETTS, 6 (Apr. 2014), available at
http://www.mass.gov/eohhs/docs/dph/environmental/exposure/climate-change-report-2014.pdf; Horton, supra, at
379; Runkle et al., Massachusetts State Summary, NOAA TECHNICAL REPORT NESDIS 149-MA, 4 (2017),
available at https://statesummaries.ncics.org/MA.
8 IPCC. 2018. GLOBAL WARMING OF 1.5 °C - SUMMARY FOR POLICYMAKERS, SPM-15-16, Sec. C.1.3.
(approved by IPCC Oct. 6, 2018), available at http://report.ipcc.ch/sr15/pdf/sr15_spm_final.pdf.
3
accordingly requires sweeping immediate and long-term emission reductions within the
Commonwealth, mostly notably under the Global Warming Solutions Act (GWSA), G.L. c. 21N.
Working in collaboration with Massachusetts agencies, the AGO has a long history of
legal advocacy to secure reductions in the greenhouse gas emissions that are the key driver of
climate change. The AGO led the federal litigation that resulted in the United States Supreme
Court’s determination in Massachusetts v. EPA that greenhouse gases are pollutants and that
EPA was obliged to regulate greenhouse gas emissions under the federal Clean Air Act if it
found such emissions endanger public health or welfare. See 549 U.S. 497 (2007). In
subsequent administrative proceedings and litigation, the AGO has worked closely with other
states to advocate for and defend federal findings and regulations addressing climate change and
to fight now-pending rollbacks of those policies.9
Here at home, the AGO has supported Massachusetts agencies’ critical efforts to lower
greenhouse gas emissions from numerous sources, including successfully defending the
Massachusetts Executive Office of Energy Affairs (“EEA”) and Department of Environmental
Protection’s (“DEP”) recently promulgated declining emissions cap on the electric sector and its
Clean Energy Standard (“Cap and CES Regulations”), 310 C.M.R. §§ 7.74-7.75, under the
GWSA. See New England Power Generators Ass’n v. Department of Envtl. Prot., 480 Mass.
398 (2018). And through its advocacy on behalf of ratepayers, the AGO has sought to ensure
that utilities and other participants in the energy markets make reasonable and prudent
investments in clean energy initiatives while avoiding ratepayer subsidies for costly and
unneeded fossil fuel infrastructure. With the timing and substance of federal climate action now
in question, it is more critical than ever that the Commonwealth maintain and strengthen its
leadership in cost-effectively reducing greenhouse gas emissions while demonstrating that the
transition to clean energy promotes good-paying jobs, economic growth, and consumer savings.
It is in this context of climate crisis and the Commonwealth’s and the AGO’s shared
interest and commitments to address that crisis that the AGO’s concerns regarding DOER’s
Proposed Amendments arise. Unlike the zero-carbon technologies recognized under the RPS,
forest biomass energy production—the burning of woody fuel from forests to generate
electricity—is not a sustainable climate solution. It is not “carbon neutral,” as EPA has recently
claimed.10 In fact, burning forest biomass to generate electricity has the potential to increase
greenhouse gas emissions if technologies, forest management, and fuel sources are not carefully
9 See, e.g., California et al. v. EPA, No. 18-1114 (D.C. Cir. filed May 1, 2018); New York et al. v. EPA, No. 18-
1174 (D.C. Cir. filed June 26, 2018); Comments of the Attorneys General of Massachusetts et al. on EPA’s
Proposed Revisions to the Refrigerant Management Program’s Extension to Substitutes (Nov. 15, 2018), Doc. ID
No. EPA-HQ-OAR-2017-0629-0300; Comments of the Attorneys General of New York et al. on EPA’s Proposed
Emission Guidelines for Greenhouse Gas Emissions from Existing Electric Utility Generating Units; Revisions to
Emission Guideline Implementing Regulations; Revisions to New Source Review Program (Oct. 31, 2018), Doc. ID
No. EPA-HQ-OAR-2017-0355-24817; Comments of the Attorneys General of California et al. on EPA’s Proposed
Review of Standards of Performance for Greenhouse Gas Emissions from New, Modified, and Reconstructed
Stationary Sources: Electric Utility Generating Units (Mar. 18, 2019), Doc. ID No.EPA-HQ-OAR-2013-0495-
12736.
10 Scott Pruitt, Administrator, Envtl. Prot. Agency, Policy Statement: EPA’s Treatment of Biogenic Carbon
Dioxide Emissions from Stationary Sources that Use Forest Biomass for Energy Protection, available at
https://www.epa.gov/air-and-radiation/epas-treatment-biogenic-carbon-dioxide-emissions-stationary-sources-use-
forest.
4
understood and regulated. As DOER’s own groundbreaking 2010 Manomet Study explains, net
cumulative emissions in 2050 of biomass electricity are approximately equal to those from
equivalent electricity generated by coal burning, and cumulative total emissions are substantially
higher with biomass electricity generation than equivalent electricity generated by natural gas
combustion—the dominant and marginal fuel in the New England electric grid.11 Although
some of the emitted carbon can eventually be resequestered through forest regrowth, that process
takes decades and some emissions—like those resulting from the cutting, processing,
transportation, and drying of woody biomass fuel—will never be offset.12
Harvesting of Massachusetts forests for bioenergy facilities also can have significant
impacts on ecosystems and the long-term sustainability of important state industries such as
recreation, tourism, and even forestry.13 And burning of biomass materials releases particulate
matter and other harmful pollutants that have serious health effects in surrounding communities,
especially in combination with other local pollution commonly experienced in environmental
justice communities and in regions like western Massachusetts where wood-fired heating is
widespread.14
Expanding subsidies for polluting biomass energy production without appropriate
safeguards through a program meant to promote clean “renewable energy” would be inconsistent
with the Commonwealth’s greenhouse gas emission reduction mandate. And, in light of the
critical role forests play in mitigating emissions, the Commonwealth should be working to
preserve and replenish our forests as important carbon sinks, not putting incentives in place to
burn them as fuel. As discussed in more detail below, the AGO is concerned that the Proposed
Amendments would promote and subsidize forest biomass energy production under the RPS
program by removing or weakening the restrictions on woody biomass eligibility established in
2012, notwithstanding the legal and scientific imperatives to reduce greenhouse gas emissions as
rapidly as possible.
Questions AGO Urges DOER to Consider Before Finalizing the Proposed Amendments
The Proposed Amendments raise several legal concerns that DOER should assess
carefully before finalizing any rule, many of which relate to the central question whether the
Proposed Amendments would result in increased greenhouse gas emissions. That complex
question, however, has not yet been answered by DOER, because DOER has not yet modeled or
assessed the likely emissions impacts of its proposed action. At the very least, DOER should
take this opportunity to further extend the rulemaking process to comprehensively assess and
model through a transparent, iterative public process both the effect of further biomass subsidies
on electric market demand for biomass energy and the likely short- and long-term emissions
impacts of each of its proposed changes against an accurate baseline. It is critically important for
11 MANOMET CTR. FOR CONSERVATION SCIENCES, BIOMASS SUSTAINABILITY AND CARBON POLICY STUDY 7
(June 2010), available at https://www.manomet.org/wp-content/uploads/old-
files/Manomet_Biomass_Report_Full_June2010.pdf (“MANOMET STUDY”).
12 See, e.g., Philip Duffy, Woods Hold Research Ctr., Burning wood for energy is not “carbon neutral” (Apr. 25,
2018), https://whrc.org/burning-wood-for-energy-is-not-carbon-neutral/.
13 MANOMET STUDY at 8.
14 See, e.g., Naeher, L.P., Brauer, M., Lipsett, M., Zelikoff, J.T., Simpson, C.D., Koenig, J.Q. & Smith, K.R.,
Woodsmoke health effects: a review, Inhalation Toxicology 67-106 (2007).
5
the Commonwealth to have an accurate understanding of the actual greenhouse gas emissions
impacts of each of the Proposed Amendments in isolation and in combination, because finalizing
any rule that would result in an emissions increase would likely conflict with the
Commonwealth’s legal frameworks for reducing emissions in both the near and long terms—a
course that would benefit neither DOER nor the Commonwealth’s ability to rapidly decarbonize
its electric sector in the face of an ever more urgent climate emergency.
First, to the extent the Proposed Amendments could lead to an increase in greenhouse gas
emissions, they would run counter to the Commonwealth’s obligation to “attain actual,
measurable, and permanent emissions reductions” under the GWSA. Kain v. Department of
Envtl. Prot., 474 Mass. 278, 300 (2016). The GWSA “is designed to make Massachusetts a
national, and even international, leader in the efforts to reduce the greenhouse gas emissions that
cause climate change.” New England Power Generators Ass’n, Inc., 480 Mass. at 399. The
statute accordingly requires the Commonwealth and its agencies to reduce statewide greenhouse
gas emissions by at least eighty percent below 1990 levels by 2050 and to meet interim declining
limits every decade along the way to maximize the Commonwealth’s ability to meet the 2050
target. G.L. c. 21N, § 3(b); see also id. § 6 (“In implementing its plan for statewide greenhouse
gas emissions limits, the commonwealth and its agencies shall promulgate regulations that
reduce energy use, increase efficiency and encourage renewable sources of energy in the sectors
of energy generation, buildings and transportation.” (emphases added)). And, pursuant to that
mandate, the Secretary of EEA has directed that Massachusetts reduce statewide greenhouse gas
emissions by at least twenty-five percent below 1990 levels by 2020.15
DOER’s RPS program is a key component of the Commonwealth’s efforts to meet the
GWSA’s interim and 2050 limits by incentivizing renewable energy sources while phasing out
dirtier fuel. Indeed, it is important not only as a climate policy in its own right but also as a
foundation for EEA and DEP’s implementation of the GWSA through its Cap and CES
Regulations and DEP’s regulations of other sources of emissions. See id. § 3(c)-(d); 310 C.M.R.
§§ 7.72-7.75 & 60.05-60.06. If the Proposed Amendments would, by expanding subsidies for
biomass energy, increase greenhouse gas emissions, the RPS program would be inconsistent with
the GWSA’s near- and long-term emissions-reduction mandates and its core “anti-backsliding”
purpose.16
Second, to the extent the Proposed Amendments would increase greenhouse gas
emissions, they may be in significant tension with the RPS statute. In particular, the statute
requires that qualifying renewable energy generating sources include only those biomass
facilities that use “low emission advanced biomass power conversion technologies.” G.L.
c. 25A, §§ 11F(b)(8), (c)(7), and (d)(8). If DOER weakens its existing biomass eligibility and
15 See generally Secretary of Energy and Envtl. Affs., 2015 Update of the Clean Energy and Climate Plan for
2020 (Dec. 31, 2015), available at
https://www.mass.gov/files/documents/2017/12/06/Clean%20Energy%20and%20Climate%20Plan%20for%202020.
pdf.
16 See G.L. c. 21N, § 3(b), (d) (requiring adoption of declining statewide emissions limits and declining source
category emissions limits, respectively); Kain, 474 Mass. at 287 (noting GWSA’s “central purpose” is “reducing
emissions in the Commonwealth”); see also Sierra Club v. Ruckelshaus, 344 F. Supp. 253, 256 (D.D.C. 1972)
(interpreting Federal Clean Air Act’s purpose to prohibit degradation of existing air ambient air quality), aff’d sub
nom. Fri v. Sierra Club, 412 U.S. 541 (1973).
6
efficiency requirements, its regulations may exceed the scope of their enabling legislation and
newly eligible facilities may no longer actually qualify as “low emission” and “advanced” within
the meaning of the statute.
Third, DOER has not fully explained its rationale for or the impact of many of the
changes in the Proposed Amendments. For example, DOER has not explained why “align[ing]”
the RPS requirements with Alternative Energy Portfolio Standard requirements or “simplify[ing]
and streamlin[ing]” the regulatory requirements is important or preferable notwithstanding
potential emissions increases.17 Additionally, as set forth above, DOER has not yet completed
any rigorous assessment of the energy market and greenhouse gas emissions impacts associated
with the Proposed Amendments, including any analysis of whether the proposed changes would
affect Massachusetts’ ability to achieve its statutory emission-reduction mandates. In this regard,
EEA and DEP’s recently promulgated Cap and CES Regulations may serve as a useful
guidepost. Before finalizing those rules, EEA and DEP compiled an extensive rulemaking
record and commissioned an independent analysis of the electricity bill and greenhouse gas
emissions impacts of the regulations 18—analyses on which the Supreme Judicial Court relied in
upholding the regulations. See New England Power Generators Ass’n, Inc., 480 Mass. at 408-
10. The AGO urges DOER to conduct a similarly robust assessment—informed by public input
and review—to ensure any final amendments comport with the GWSA, the RPS statute, and the
Commonwealth’s nation-leading emissions-reduction and public health goals.
Specific Recommendations – 225 C.M.R. §§ 14.00 et seq., and 15.00 et seq.
As the above discussion makes clear, it is critical that any changes to DOER’s RPS
regulations do not increase greenhouse gas emissions. The AGO appreciates that DOER’s
Proposed Amendments in some respects appear to tighten the regulations and potentially
strengthen eligibility requirements for RPS Class I and II Renewable Generation Units.19 But
multiple proposed changes appear to relax regulatory requirements and efficiency standards and
may, for example, allow units with increased greenhouse gas emissions to qualify for Renewable
Energy Credits or to receive more Renewable Energy Credits per megawatt hour of generation,
thus potentially increasing emissions overall.
The AGO is particularly concerned about the following proposed changes and urges DOER
to carefully assess and explain their impact before finalizing any rule:
17 DOER Memorandum to RPS/APS Stakeholders, available at
https://www.mass.gov/files/documents/2019/05/15/RPS%20and%20APS%20Stakeholder%20Announcement.pdf.
18 EEA and DEP Response to Comments on 310 C.M.R. §§ 7.74-.75 (Aug. 2017), available at
https://www.mass.gov/files/documents/2017/08/zo/3drtc-electricity.pdf; Synapse Energy Economics Inc., Analysis
of Massachusetts Electricity Sector Regulations: Electricity Bill and CO2 Emissions Impacts (Aug. 2017), available
at https://www.mass.gov/files/documents/2017/08/zw/3dapp-study.pdf.
19 See, e.g., Proposed 225 C.M.R. § 14.02 (defining eligible biomass woody fuel to include trees incapable of
yielding an eight-foot, rather than a twelve-foot, saw log; eliminating current eligibility for yard waste and trees cut
during non-agricultural land use change); id. § 14.05(8)(f) (replacing five-year probationary period with one-year
period followed by revocation of Statement of Qualification if compliance not achieved; eliminating facilities’
ability to pay DOER to retain Statement of Qualification in lieu of compliance).
7
• Adding “Eligible Biogas Fuel,” 225 C.M.R. §§ 14.02, 15.02: The AGO urges DOER
to specifically list the types of biogas that would be eligible under this definition beyond
the currently eligible anaerobic digester gas and derivative biogases.
• Expanding “Eligible Biomass Woody Fuel,” 225 C.M.R. §§ 14.02, 15.02:
o The AGO is concerned that DOER’s proposed addition of trees collaterally
damaged during harvesting and entire trees and portions of trees harvested during
rare species restoration and management could significantly expand the pool of
eligible forest-derived residues, threatening to increase net greenhouse gas
emissions from related energy production.
o The AGO further urges DOER to retain the clear limitation that an injurious agent
be a “major” threat to forest health or risk to private or public resources to render
trees damaged by that agent eligible forest salvage. This qualifier is particularly
important to ensure that the increased risks to forest health from climate change—
like insect infestations—do not drastically expand the pool of available forest
salvage fuel.
o Additionally, adding agricultural wood waste (including whole trees) and post-
consumer wood, as well as eliminating the concrete list of eligible forest products
industry residues in favor of a general, vague definition, would increase the pool
of eligible non-forest derived residues with new fuels that, again, could increase
net greenhouse gas emissions.
o Importantly, the Proposed Amendments’ expansion of forest salvage and non-
forest derived residues is particularly concerning in light of DOER’s proposal to
altogether eliminate the efficiency requirement for facilities burning such
materials, as discussed below. See 225 C.M.R. § 14.05(1)7.c., (8)(b)1.-2. As the
chief author of the Manomet Study explained in his comments on this rulemaking,
the Manomet Study did not assess the complex question of how burning forest
salvage will affect greenhouse gas emissions. 20 And DOER has not assessed how
much wood might qualify as eligible salvage. DOER must fully understand these
issues before finalizing the Proposed Amendments.
• Deleting definition of “Dedicated Energy Crops,” 225 C.M.R. §§ 14.02, 15.02:
Deletion of the limitation that wood purposefully grown to produce fuel may not be
grown on land that sequestered significant amounts of carbon, such as a forest, could
result in deforestation of valuable carbon-rich lands, particularly in light of the vague
sustainable forestry management standards and reduced efficiency standards discussed
below.
• Amending definition of “Eligible Liquid Biofuel,” 225 C.M.R. §§ 14.02, 15.02:
o The AGO urges DOER to clarify that it intends to incorporate only the Federal
Clean Air Act’s definition of advanced biofuels, 42 U.S.C. § 7545(o)(1)(B)
(requiring 50% reduction in lifecycle greenhouse gas emissions from a 2005
baseline), and not to incorporate any other EPA standards for such fuels, EPA
accounting methods, or EPA determinations that specific fuels so qualify.
o The AGO also urges DOER to (1) retain the requirement that DOER consult with
EEA and DEP in determining whether fuels meet that definition in light of EEA
and DEP’s expertise and statutorily mandated role in designing and implementing
20 Comments of Thomas H. Walker, Consulting Resource Economist, on DOER RPS Class I & II Rulemaking
2-3 (June 4, 2019).
8
the Commonwealth’s emissions-reduction policies, G.L. c. 21N, §§ 2-5; and
(2) retain the requirement that DEP determine whether hazardous waste may be
used as eligible fuel, again given DEP’s expertise and statutory role in regulating
such materials, G.L. c. 21C, § 4.
o Finally, the AGO is also concerned that deletion of the limitations on derivative
waste feedstocks could increase the available pool of eligible fuels.
• Deleting definition of “Lifecycle Greenhouse Gas Emissions,” 225 C.M.R. §§ 14.02,
15.02: The AGO urges DOER to retain the existing definition of “Lifecycle Greenhouse
Gas Emissions” to provide clarity within the regulation itself on what such emissions
must include and to retain the requirement that DOER consult with DEP—again, as an
expert agency in emissions impacts—in determining lifecycle emissions.
• Expanding definition of “Useful Thermal Energy,” 225 C.M.R. §§ 14.02, 15.02:
DOER should clarify that a facility is not permitted to count energy used to dry biomass
fuel as useful thermal energy—whether the produced fuel is then used at that same
generating unit or at any other unit.
• Deleting air permit compliance requirement, 225 C.M.R. § 14.05(1)(a)7.: To ensure
the RPS program does not subsidize environmental harm in the Commonwealth, DOER
should retain in the Class I regulations the requirement that certain generating units
affirmatively demonstrate not only that they have obtained—but also that they have
complied with—air permits to qualify as an RPS Class I Renewable Generation Unit.
• Lengthening timeframe for calculating lifecycle greenhouse gas emissions, 225
C.M.R. §§ 14.05(1)(a)7.d., 15.05(1)(a)7.d.: The AGO strongly urges DOER to abandon
its proposal to extend from twenty to thirty years the period for evaluating the reduction
of lifecycle greenhouse gas emissions as compared to a new natural gas combined cycle
unit. Such extension could inflate the offsetting benefits from forest regrowth and the
foregone carbon emissions resulting from decomposition over the longer period,
potentially making biomass energy appear more efficient overall. Additionally,
extending the timeframe would contradict recent science confirming the need to reduce
emissions in the very near term.
• Calculating Lifecycle Greenhouse Gas Emissions, Draft Guideline on Overall
Efficiency and Lifecycle Greenhouse Gas Analysis: DOER’s Draft Guideline on
Overall Efficiency and Lifecycle Greenhouse Gas Analysis likewise appears to
overestimate the efficiency of biomass energy by calculating the emissions associated
with burning biomass fuel based on a single year of emissions rather than the cumulative
emissions over the full revised thirty-year period. Instead, as the chief author of the
Manomet Study explained in his comments on this rulemaking, the calculation of
lifecycle greenhouse gas emissions should assess the actual future levels of greenhouse
gases in the atmosphere, including the continued release and build-up of emissions in the
atmosphere over the full twenty- or thirty-year period at the same time that it assesses
reabsorption over that period.21
• Reducing and eliminating efficiency requirements, 225 C.M.R. §§ 14.05(1)(a)7.c.,
14.05(8)(b)1.-2., 15.05(1)(a)8.c., 15.05(5)(b)1.-2.: The AGO strongly urges DOER to
abandon its proposal to reduce the Class I eligibility efficiency requirement from 60% to
50% for units that have 5% or more fuel sourced from forest-derived residues and forest-
21 See id. at 2-3.
9
derived thinnings and to altogether eliminate any efficiency requirement for Class I or II
units that utilize fuel that has over 95% of its fuel sourced from forest salvage and non-
forest derived residues. As noted above, this proposed change is particularly troubling in
light of the Proposed Amendments’ significant increase in the pools of such eligible
fuels—including the potentially massive additional forest salvage that may result from
climate change—and the poorly understood emissions impacts of burning such
materials.22 DOER’s proposed efficiency requirements would plainly relax the emissions
standards applicable to RPS Class I or II Renewable Generation Units and be a step in the
wrong direction for the Commonwealth.
• Incorporating vague sustainable forestry provisions, 225 C.M.R. §§ 14.02,
14.05(8)(a), 15.02, 15.05(5)(a): While DOER’s sustainable forestry management
provisions reflect important concerns like conservation of biological diversity and
maintenance of forest contributions to global carbon cycles, they appear to lack any
enforceable detail. The AGO urges DOER to revisit the definition of “Sustainable
Forestry Management” in consultation with EEA, DEP, and the Division of Fisheries and
Wildlife to add concrete, measurable requirements for forest management for each listed
criterion.
• Reducing oversight, 225 C.M.R. §§ 14.05(8), 15.05(5): The Proposed Amendments
would appear to eliminate the advisory panel consisting of representatives of EEA and
DEP, among others, to monitor processes for verification of compliance with the
regulations and to report on the success of DOER’s verification and enforcement. The
Proposed Amendments also appear to eliminate the requirements that DOER’s forest
impact assessment evaluate the appropriateness and accuracy of greenhouse gas
accounting and that its report be provided to EEA and the public by a date certain. The
AGO urges DOER to retain these important provisions to ensure agency and public
oversight and accurate accounting of the regulations’ emissions impacts.
22 See id. at 4.
10
Conclusion
As the Supreme Judicial Court recently emphasized, Massachusetts climate policy “is
designed to go well beyond business as usual in terms of reducing emissions: to upend, rather
than to uphold, the status quo.” New England Power Generators Ass’n, Inc., 480 Mass. at 406.
Incentivizing additional forest biomass energy production would be a step backward, not
forward, in this effort. The AGO looks forward to further productive dialogue with DOER
toward addressing climate change and securing a clean energy future for the Commonwealth.
Respectfully submitted,
OFFICE OF ATTORNEY GENERAL
MAURA HEALEY
Melissa Hoffer
Chief, Energy and Environment Bureau
Christophe Courchesne
Chief, Environmental Protection Division
Rebecca Tepper
Chief, Energy and Telecommunications
Division and Office of Ratepayer Advocate
Turner Smith
Assistant Attorney General
Environmental Protection Division
February 2, 2021 Tuesday
Overview of Meeting Dockser 7:00
Covid-19 Response Command 7:05
Liaison Reports Board 7:10
Public Comment Board 7:15
Outdoor Dining - Placeholder for Tier II
applications (if needed) Schaeffer 7:30
Birch Meadow Master Plan Update
Recreation &
Consultant 7:40
Open Space Plan Update (Feb 1st public
meeting)
Conservation
& Consultant 8:00
Maillet Land update Conservation 8:20
Discuss Draft DPW Protocols - Tree Safety
within Conservation Jurisdictional Areas Kinsella 8:40
Town Manager Goals Update LeLacheur 9:00
Approve Meeting Minutes Board 9:30
Future Meeting Agenda Topics Dockser
February 16, 2021 Tuesday
Overview of Meeting Dockser 7:00
Covid-19 Response Command 7:05
Liaison Reports Board 7:10
Public Comment Board 7:15
Outdoor Dining - Placeholder for Tier II
applications (if needed) Schaeffer 7:30
Walker's Brook Drive: Corridors &
Intersections Delios 7:40
8:30
Approve Meeting Minutes Board
Future Meeting Agenda Topics Dockser
February 24, 2021 FINCOM Budget Meeting Wednesday
March 2, 2021 Tuesday
Overview of Meeting Dockser 7:00
Covid-19 Response Command 7:05
Liaison Reports Board 7:10
Public Comment Board 7:15
Outdoor Dining - Placeholder for Tier II
applications (if needed) Schaeffer 7:30
HEARING Vote to Approve Verizon cable TV contract Kraunelis 7:40
Appoint Town Accountant (deadline 3/31)Board 8:00
Town Accountant Quarterly Update Angstrom 8:05
MassDOT - Update on Main Street Road Diet 8:30
Vote to close Warrant - Local election & state
primary Board 9:30
Vote to close Warrant - Annual Town Meeting Board 9:35
9:40
Approve Meeting Minutes Board
Approve Meeting Minutes Board
Future Meeting Agenda Topics Dockser
March 3, 2021 FINCOM Budget Meeting Wednesday
March 10, 2021 FINCOM Budget Meeting Wednesday
March 17, 2021 FINCOM Budget Meeting Wednesday
March 23, 2021 Tuesday
Overview of Meeting Dockser 7:00
Covid-19 Response Command 7:05
Liaison Reports Board 7:10
Public Comment Board 7:15
Review Town Personnel Policy and SB
Policies: Article 6 Personnel Related Policies Donahue 7:30
8:15
Approve Meeting Minutes Board
Future Meeting Agenda Topics Dockser
April 6, 2021 Local Elections Tuesday
April 20, 2021 Tuesday
Select Board Vote to Reorganize 7:00
April 26, 2021 Annual Town Meeting I Monday
April 29, 2021 Annual Town Meeting II Thursday
May 3, 2021 Annual Town Meeting III Monday
May 4, 2021 Tuesday
May 6, 2021 Annual Town Meeting IV Thursday
1
Saunders, Caitlin
From:LeLacheur, Bob
Sent:Thursday, January 14, 2021 6:44 PM
To:Saunders, Caitlin
Subject:FW: Communication Policies — RFI
this can go in the next SB packet
From: Bacci, Carlo
Sent: Thursday, January 14, 2021 5:53 PM
To: Walt Tuvell; Bacci, Carlo
Cc: LeLacheur, Bob
Subject: RE: Communication Policies — RFI
Hello,
Thanks for your email and reaching out to the Select Board. Your
>> comments will become public record and will be published in the
>> packet for the next board meeting. We appreciate your thoughts and
>> concerns and will address them if it is part of the agenda.
>> We are doing doing the best we can during this Covid-19 virus to
>> address all concerns of residents.
> Thank you,
>>
>> Carlo Bacci
>> Select Board Secretary
Sent from my Verizon, Samsung Galaxy smartphone
-------- Original message --------
From: Walt Tuvell <walt.tuvell@gmail.com>
Date: 1/14/21 4:03 PM (GMT-05:00)
To: "Bacci, Carlo" <carlo.bacci@ci.reading.ma.us>, "Herrick, Karen" <karen.herrick@ci.reading.ma.us>,
"Alvarado, Vanessa" <vanessa.alvarado@ci.reading.ma.us>, "Dockser, Mark"
<mark.dockser@ci.reading.ma.us>, "Landry, Anne" <anne.landry@ci.reading.ma.us>
Subject: Communication Policies — RFI
Hello, Reading MA Select Board —
I read with great interest the lead article in yesterday's Chronicle (Jan 13, 2021), regarding the SB work
item concerning Communication Policies (§1.4.1 of Operating Procedures
https://www.readingma.gov/sites/g/files/vyhlif1116/f/uploads/article_1_-
_operating_procedures_final_clean.pdf). That article was the first I've heard about this subject. Can you
2
please point me to the appropriate documentation and/or other resources where I can learn more about
it?
I note that, heretofore, I have not been seriously involved in town affairs (though I'm currently in the
process of trying to rectify that situation). In particular, I am not plugged-in to how I should be going
about finding various information, such as what I'm now seeking — which is why I am writing you this
very RFI (request for information) letter. Therefore, please forgive me if I'm now writing about "things
that are well-known to those who know such thing well."
Nevertheless, while bearing that in mind, here are some initial (no doubt under-informed) observations
I'd like to share:
I visited the town website (https://ReadingMA.gov), and used its "search" tool for
"communications policy." I found nothing that seemed to be remotely relevant to my current
query. The Chronicle article mentions last week's SB meeting, but the minutes aren't posted on the
town website yet (insofar as I can find). Which is why I'm now writing you this RFI.
o That is, I think, a failure. It should be easier for me to find important information
(important enough to be a front-page lead article in the town newspaper!) more easily.
o The Chronicle article says the issue has been undergoing consideration for more than a
year, so I'd expect something to be posted on the town's website, in a findable place.
But in order to formulate this RFI, I wanted to query all relevant parties (8 in total) simultaneously
(in a single email). I was able to find the individual email addrs (pubic, not private) of the 5 SB
members (at https://www.readingma.gov/select-board), so that's why you're the direct
addressees of this email. However, I was not able to find the email addrs of 3 others (R. LaLacheur,
L. Gemme, C. Saunders) — for them, all I could find was individual "web mail forms." Therefore,
I'm sending to them separately.
o That also seems like a failure. It should be possible for me to send to all relevant addresses
simultaneously, instead of piece-meal like this. That cannot be done using the web email
forms on the website.
Finally (for now), I ask why you're restricting your attention only to email, as opposed to more
suitable communications mechanisms? I'm thinking, of course, of the kind of a dedicated
communications website (as opposed to mere "document dump," as most of the town's current
website sees to be)?
o This isn't intended to be a "slime," since email and doc-dumps were the only things
available, probably, when the town previously visited these things.
o Example of "doc-dump" failure: The versions of Operation Procedures cited above appear
to be the current one, but when I search the town's website for "operating procedures," the
first hit I get is
https://www.readingma.gov/sites/g/files/vyhlif1116/f/file/file/bos_policy_article1_-
_operating_procedures.pdf, which appears to be out of date.
o Yes, the Chronicle article does make a passing reference to "social media policy," but it's
minimal ("on hold for now"), and it's now past time you could be addressing things such as
this, don't you think? SB Policy §1.4.1 was last visited/revised in 2007!
o Yes, I understand Open Meeting Law can get in the way, but c'mon, really??
As you probably know, I've been working on a website (totally independently of the SB's Comms
Policy work, which I was unaware of) that tries to address some of these problems:
https://ReadingMA.us. There, I've opened up a "forum topic" regarding this SB Comms Policy
work
(https://ReadingMA.us/ForumSpace/Category:TownAffairs/Forum:SelectBoard/Topic:Communi
cationsPolicies), and this email will be posted there (in a "comment") immediately after I send it.
3
o My website has gotten some interest/attention, but only minimal traction (actual usage) so
far, but that's to be expected of course.
Thank you in advance.
— Walter Tuvell, 836 Main St.
1
Saunders, Caitlin
From:National Civic League <ncl@ncl.org>
Sent:Friday, January 15, 2021 12:42 PM
To:Reading - Selectboard
Subject:Inauguration Day Dialogue - Working Towards a More Perfect Union
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Inauguration Day Dialogue -
Working Towards a More Perfect Union
Join the National Civic League and Well Being In the Nation (WIN) Network for a
dialogue about how we work toward a more perfect union.
Wednesday, January 20th at 11am PT/12pm MT/1pm CT/2pm ET
Register Now
Dialogue Description
On this historic Inauguration Day, we invite you to engage in a deep dialogue about how
we might work toward a more perfect union, based on a foundation of truth and
reconciliation about the relationship between racism and democracy. Dialogues will be
facilitated by Estrus Tucker and Monte Roulier.
Agenda:
Welcome and reflection
Conversation on race and democracy
Conversation on rebuilding our civic commons
National Civic League | 190 E. 9th, Suite 200, Denver, CO 80203
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1
Saunders, Caitlin
From:DLS Alerts <dls_alerts@dor.state.ma.us>
Sent:Friday, January 15, 2021 12:48 PM
To:Reading - Selectboard
Subject:DLS Alert: Eviction Diversion Initiative
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Eviction Diversion Initiative
Department of Housing and Community Development
The Department of Housing and Community Development wishes to share some important updates to the
Governor’s Eviction Diversion Initiative and ask that you share widely with your colleagues in community
development and affordable housing. In the last six weeks, the Department of Housing and Community
Development (DHCD) has made several important changes to the program, including:
Creating an application process for landlords, who own up to 20 units in Massachusetts, to apply
directly for RAFT/ERMA on behalf of tenants. More information here.
DHCD has increased the maximum benefit for all RAFT/ERMA eligible households to $10,000.
DHCD removed all sustainability requirements, including the recent rule that a landlord had to
commit to preserving tenancy for 6 months to access more than $4,000 in RAFT.
NEW free legal services are available to eligible tenants and low-income landlords in owner-
occupied 2-3 family homes through the Covid Eviction Legal Help Program (CELHP). More
information available here.
NEW free community mediation services for eligible tenants and landlords who need help in
reaching agreements that work for both of them. More information available here.
We encourage you to share this information widely. For questions, please contact Ryan Ambrose at
ryan.ambrose@mass.gov.
You are receiving this message through the Massachusetts Department of Revenue's Division of Local Services DLS Alerts system.
These periodic notices include our City & Town e-newsletter, IGRs, Bulletins, Cherry Sheets and other municipal finance-related
information. To unsubscribe to DLS Alerts and the City & Town e-newsletter, please email dls_alerts@dor.state.ma.us.
2
This email was sent to selectmen@ci.reading.ma.us
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Massachusetts Department of Revenue - Division of Local Services · 100 Cambridge Street · Boston, MA 02114 · USA
1
Saunders, Caitlin
From:MWRA Advisory Board <James.Guiod@MWRAAdvisoryBoard.com>
Sent:Friday, January 15, 2021 1:59 PM
To:Reading - Selectboard
Subject:January 2021 Advisory Board Meeting
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January 2021 MWRA Advisory Board
Meeting
The next meeting of the Advisory Board will be held on Thursday, January 21,
2021, at 10:00 AM remotely via GoToMeeting.
The meeting will include a presentation from MWRA Tunnel Redundancy
Director, Kathy Murtagh, on the status of the Metropolitan Tunnel Redundancy
Project.
Click here to access the meeting packet
Visit web site
2
Connect with us!
MWRA Advisory Board | 617-788-2050 | mwra.ab@mwraadvisoryboard.com
This email was sent to selectmen@ci.reading.ma.us
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MWRA Advisory Board · 100 1st Ave Bldg 39 · 4th Floor · Boston, MA 02129-2043 · USA
1
Saunders, Caitlin
From:Burns, Greg
Sent:Friday, January 15, 2021 3:59 PM
To:Delios, Jean; Jackson, Paul; Kraunelis, Matthew; LeLacheur, Bob; Martel, Justin; Paul
Guarino (pfguarino@comcast.net); Reading - All Fire Department; Reading - Police
Dispatchers; Reading - Selectboard
Subject:Reading Fire Department's Weekly Notes
Weekly Notes
January 15, 2021
1. Thank you to all personnel who have assisted with the COVID-19 vaccinations this week and received a
vaccine this week! Assistant Chief Jackson, Captain Nelson, Lieutenant Pouliot, EMS Coordinator
Lapolla and EMS Liaison Dyer were heavily involved in the success of this project.
2. We have moved the Health Department refrigerator to Assistant Chief Jackson’s office to allow two
daily checks of the medication storage. This is temporary move and will end when we no longer need to
store COVID-19 vaccinations. The unit is set for a low temperature of 38 degrees F and for a
maximum of 42 degrees F. There is an alarm set to activate at 35 degrees and 45 degrees. We request a
paramedic check the unit on weekends and holidays at approximately 0730 hours after the morning
truck check and at 1700 hours and fill in the date, time and temperature in the log book on top of the
unit. If this unit fails the medication must be moved to the refrigerator in the spare ambulance and notify
the Chiefs.
3. The North Reading Ladder Truck is out of service. North Reading Fire Department may request our
Ladder Truck to respond if needed.
4. New boots have an arrived for all personnel. If your boots do not fit properly please notify Captain
Nelson and do not use them.
5. The Fire Alarm truck is in and we have set up appointments for lettering and radio installation.
Chief Gregory J. Burns
Reading Fire Department
757 Main Street
Reading, MA 01867
(P) 781.944.3132
(F) 781.942.9114
www.readingma.gov
1
Saunders, Caitlin
From:cmsmailer@civicplus.com on behalf of Contact form at Reading MA
<cmsmailer@civicplus.com>
Sent:Sunday, January 17, 2021 3:05 PM
To:Reading - Selectboard
Subject:[Reading MA] Industrial Composting of Food Waste (Sent by Louise Ward, louiseward27
@hotmail.com)
Attachments:gs_bec_composting_projectionspdf.pdf
Hello Select Board,
Louise Ward (louiseward27@hotmail.com) has sent you a message via your contact form
(https://www.readingma.gov/user/475/contact) at Reading MA.
If you don't want to receive such e-mails, you can change your settings at https://www.readingma.gov/user/475/edit.
Message:
Dear Select Board Members and Director Kinsella,
We are writing as members of the Composting Team, part of the Green Sanctuary Committee of the Unitarian
Universalist Church of Reading. The Composting Team has been very active over the past year. Our primary mission has
been to provide grassroots education to Reading residents about the benefits of food-waste composting and to
encourage them to consider curbside pickup of their food waste. With this outreach, 170 households in Reading now
subscribe to a pickup service; our initial goal is 300 subscribers, at which point the subscription cost will go down for all
Reading residents.
Here is a link to an April 2019 Boston Globe article on benefits of food-waste composting and specifically curbside pickup
programs. http://realestate.boston.com/news/2019/04/17/push-curbside-composting-programs/
To save the earth, and cash, the push for curbside composting - Boston.com Real Estate You may think of compost as
brown muck or, if you’re an avid gardener, “black gold.’’ But it’s also something of a silver bullet — with the potential to
save both money and the environment.
realestate.boston.com
We believe Reading can reduce money spent on garbage removal by diverting tonnage of food waste from the general
waste stream into industrial-level composting with curbside pickup. We have put together some figures based on our
targets and the current JRM contract that show the savings possible for the Town of Reading in reduced tipping fees, as
heavy food waste is removed from the municipal trash stream The figures are based on Black Earth Compost’s (BEC’s)
estimate that 11.41 pounds of food waste are generated by each subscribing household per week.
We would welcome the chance to meet with you to
(1) present the municipal and environmental benefits of food-waste composting and
(2) outline and discuss ideas for wider participation in a curbside program. A simple first step, for instance, could be to
put a note on the spring recycling events flyer, encouraging residents to subscribe to curbside pickup of food waste via
Black Earth Compost.
Thank you for your attention and feel free to contact us with any questions.
2
Sincerely,
Anne Mark
Louise Ward
1
Saunders, Caitlin
From:Jackie McCarthy <j.r.e.mccarthy@gmail.com>
Sent:Monday, January 18, 2021 3:17 PM
To:Saunders, Caitlin
Cc:mark delaney; Reading - Selectboard
Subject:Speaking at Jan. 19 Select Board meeting
Hello,
We would like to speak during the public comment portion of the Jan. 19 Select Board meeting.
Thank you,
Mark Delaney and Jackie McCarthy
26 Beacon Street
1
Saunders, Caitlin
From:Walt Tuvell <walt.tuvell@gmail.com>
Sent:Monday, January 18, 2021 4:28 PM
To:Reading - Selectboard; j.r.e.mccarthy@gmail.com; anndillaway@hotmail.com;
davedillaway@hotmail.com; baystatescubaschool@gmail.com;
jamie.diclemente@gmail.com; hayes_associates@yahoo.com;
bethanntowsley@yahoo.com; forbes1997@aol.com; 13award13@gmail.com;
readingbobc@gmail.com; info@galanteinsurance.com; Carolyn Whiting; mplacey89
@gmail.com; bateyc3@yahoo.com; jpmartel@gmail.com; dmpenney@gmail.com;
jdasilva12285@gmail.com; carolynreopel.okeefe@gmail.com;
joanna.moulton@outlook.com; goodhuewhitney@gmail.com; jenriley@gmail.com;
hkemery3@gmail.com; pjmorje@yahoo.com; vpmorje@yahoo.com; annamolettieri19
@gmail.com; gmolettieri@gmail.com; bucketlist23@comcast.net;
llcooltique@gmail.com; nickersonfamily@verizon.net; lizwitham11@gmail.com;
michelle.a.ferraro@gmail.com
Subject:Re: Select Board & Cell Tower: Failure to communicate
Attachments:Re__Select_Board___Cell_Tower__Failure_to_communicate.pdf;
Select_Board___Cell_Tower__Failure_to_communicate.pdf
Hello (again), Everybody —
This is another follow-up to the note I sent to this same set of recipients back on Oct 22, 2020, with a follow-up on Oct
24 (both attached hereto).
Today (Jan 18, 2021) I've been looking at the Select Board Packet for its meeting tomorrow
(https://www.readingma.gov/sites/g/files/vyhlif1116/f/agendas/2021-01-19_sb_packet.pdf ), and I observed an action
item involving electronic media communications concerning the Cell Tower issue (quoted below).
Therefore, I wrote the email included inline below to the SB, suggesting to use my website for this purpose. My
suggestion may or may not have merit, and it would be good to discuss that, which is why I'm writing this note to all of
you.
BTW, I'd prefer to do this on the website itself, but that's not feasible at this moment, for obvious reasons. So please feel
free to contact me via email, collectively or individually, to discuss.
Just trying to help out here. Cheers to all!
— Walt
************************************************************************
Hello SB —
I've been perusing the Jan 19 SB packet (https://www.readingma.gov/sites/g/files/vyhlif1116/f/agendas/2021-01-
19_sb_packet.pdf) today, and noticed the following passage regarding communications:
2
I have a suggestion: Use my website. There's already a "forum topic" set up for the Cell Tower issue, at
https://readingma.us/ForumSpace/Category%3ATownAffairs/Forum%3ASelectBoard/Topic%3ACellTower (where "#3A"
is simply the web-safe URL hex-encoding for the colon character, ":").
That way, you'd have automatic multi-dimensional all-to-all immediate communications amongst all principals, on all
sides of the issue (including residents).
How difficult is it to set this up? Easy: The only thing participants need to do is create an account for themselves, so that
they're authorized to use the forum/topic/comment communications facilities on the site. Accounts are of course need
to avoid spamming.
Creating accounts is supported on the website itself, see the home page https://readingma.us/Home, where the
following is written (and the "detailed instructions" link there does indeed give very detailed instructions):
3
Alternatively, I could myself create accounts for everyone (using an individually chosen initial password, which they
would then change upon first login). For me to do this, everyone would simply have to send me three simple pieces of
information:
Name (real-world name, anonymity disallowed to support accountability and avoid spamming)
Email addr (either private or work, doesn't matter, as long as it reaches the person)
Icon/avatar picture (doesn't have to be photo of person, just need to be distinguishing image)
I hope you consider this in the context of helpfulness in which it is offered. And too, it could become a "proof-of-
concept" for further town/resident participation in town affairs in future.
Cheers.
PS: If appropriate, I could speak to this proposal at tomorrows SB meeting (assuming I can figure out how to login to it
…).
— Walt Tuvell, 836 Main St.
— https://ReadingMA.us
1
Saunders, Caitlin
From:Lisa Egan, Reading-North Reading Chamber of Commerce <legan@rnrchamber.com>
Sent:Tuesday, January 19, 2021 7:11 AM
To:Reading - Selectboard
Subject:PPP Phase 2: Your Questions Answered
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What is Your Favorite Calendar Tool or
App?
Calendar.com
Select
Outlook
Select
Old Fashioned Paper Planner
Select
Apple Calendar
Select
Have another favorite? Reply and we
will share the results
Select
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Capture Hearts with
Your Website: How
to Attract, Engage,
and Win Over Clients
2
Thursday, January 21th
10 am - 11:15 AM
via Zoom
If you saw your website at a cocktail
party, would you want to get to know it?
Or would you slowly inch toward the
bathroom?
We decide in 1/10th of a second whether a
person possesses important traits such as
likeability and competence. It takes even
less time for someone to decide whether to
stay or leave your website. Only after you
capture their interest can you begin
working to win their hearts. And to do that,
you have to get them there in the first
place! Presented by Lisa Linard and Jenny
Belanger.
Member Tickets: $10
Non Member Tickets: $20
Payroll Protection
Program: Phase 2
Friday, January 22
10 am - 12 pm
via Zoom
What's the scoop with the PPP Phase 2?
Can you re-apply if you already got money
in Phase 1? What if you were declined -
should you reapply? Get these answers
and more by joining this informational
session with the SBA. Co-hosted with the
Needham Newton Chamber.
Members: Register here
Non members: Register here.
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Dementia Friendly
Training: How to
Make Your Business
and Team Dementia
Friendly
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3
Thursday, January 28th
9 - 9:30 AM Networking and
Introductions
9:30 - 10:30 Dementia Training
Join the global movement to change the
way people think, act, and talk about
dementia! A dementia friendly business or
community organization is committed to
supporting clients, customers and
employees on how to recognize signs of
dementia and how to best support them
and their caregivers.
This training will begin with networking and
introductions from 9 am - 9:30 am. The
Dementia training will last 1 hour and
provide practical tips for you and your staff
to identify and support customers with
dementia. This session will share five key
messages about living with dementia and
the simple things you can do to make a
difference in your community.
Members: Free tickets
Non members: $10
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The MC:
MultiChamber
Happy Hour
January 27th
3:30 pm - 5pm
via Zoom
Join us for a MultiChamber networking
featuring a tutorial on making a craft
cocktail (or mocktail) with Nobility Hill of
Stoneham. We will kick off learning from a
master mixologist and then expand our
networks via breakout rooms and small
group introductions. These events have
been drawing 50 - 70 people - so it's a
great way to expand your network and
have some fun via zoom.
Member Tickets: $10
Non Member Tickets: $20
4
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Support and
Resources for Small
Businesses with the
SBA
February 3rd
9:30 - 10:30 AM
via Zoom
While many businesses continue to pivot
during the pandemic, know that help is
available. Join us to hear about the various
programs and funding sources available
from the SBA and other state agencies.
Bring your questions and we will tackle
them at this interactive session. Presenters
will include:
SBA, SCORE, the Center for Women &
Enterprise and the Small Business
Development Center (SBDC).
This event is free, please register in
advance to get the zoom link.
Member Tickets here.
Non Member Tickets: here
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Want to Help?
The Chamber is directed by a group of
invested volunteers who support our
events, programs and initiatives.
We invite you to consider getting
involved as a fun way to give back and
support local businesses and the
community.
Join an Event Committee
Event committees meet for 3 months
weekly prior to events. Our major events
include Jun 4th: North Reading Town Day,
Summer Outdoor Movies and Nov 28th:
Holiday Tree Lighting Celebrations.
Consider Applying for a Board Seat
Board seats are a monthly, 3-year
commitment. We have an application
5
process and have several seats open for
2021.
Send Lisa an email to learn more and get
involved.
Chamber Platinum Partners
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Lisa Egan
Executive Director
Reading-North Reading Chamber of Commerce
PO Box 771
Reading, MA 01867
legan@rnrchamber.com
www.readingnreadingchamber.com
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Reading-North Reading Chamber of Commerce | PO Box 771, Reading, MA 01867
Unsubscribe selectmen@ci.reading.ma.us
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1
Saunders, Caitlin
From:April <april@peakbusinessfinancing-now.com>
Sent:Tuesday, January 19, 2021 11:06 AM
To:Reading - Selectboard
Subject:Trearsurer // Reach the Peak
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this picture from the Internet.Peak Business
(800) 540-2119
Hi Business Owner,
Our records show you spoke to one of our partner companies about funding for Trearsurer back in
September 2019. We still can still get you guys pre-approved for a line of credit up to $195k. Rates
start at 3.9%. If you need any working capital or any business funding now click the link here to
find out more about what we can do for Trearsurer. Looking forward to hearing from you soon.
Feel free to call me today or apply at the button below.
My best,
April Moore
Account Executive
Peak Business Financing
(800) 540-2119
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Peak Business Financing
980 9th Street Sacramento, CA 95814
< ![endif]--> Get More Info
Here
2
Stop All Future Mailings Here
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1
Saunders, Caitlin
From:LeLacheur, Bob
Sent:Tuesday, January 19, 2021 10:50 AM
To:Reading - Selectboard
Subject:FW: Senator Lewis' statement on Palmer Biomass Plant
As requested:
From: Herrick, Karen
Sent: Tuesday, January 19, 2021 10:49 AM
To: LeLacheur, Bob <blelacheur@ci.reading.ma.us>
Subject: FW: Senator Lewis' statement on Palmer Biomass Plant
Good morning Bob,
Could you please share with the full Select Board?
Thank you,
Karen.
From: Granoff, Emily (SEN) [Emily.Granoff@masenate.gov]
Sent: Tuesday, January 19, 2021 10:01 AM
To: Granoff, Emily (SEN)
Subject: Senator Lewis' statement on Palmer Biomass Plant
Good morning all,
Please find below Senator Lewis' statement on RMLD and Palmer Biomass, which he issued this morning.
Massachusetts has been, and must continue to be, a national and global leader in urgently combating
climate change; replacing dirty fossil fuels with clean, renewable energy as quickly as possible; and
building a green economy that creates good new jobs and prioritizes environmental justice and
sustainability.
I believe that the agreement entered into last year by Reading Municipal Light Department (RMLD) to
purchase a substantial amount of power from the proposed Palmer biomass plant in Springfield is
wholly inconsistent with these goals for our state.
First proposed in 2008, the Palmer plant has been vehemently opposed by the local community and
environmental activists. If built, it would be the state's only large-scale biomass plant, and it would
burn more than 1,000 tons of wood each day in a city that already has an astronomically high asthma
rate and whose population is mostly people of color. It would be a dirty, carbon-emitting plant and an
insult to environmental justice.
I appreciate that RMLD is strongly committed to making the transition to clean, renewable energy
(and, notably, in 2019 installed the largest stand-alone battery energy storage unit in Massachusetts).
I hope that RMLD will reconsider its decision to purchase power from the Palmer plant.
2
I will continue to advocate at the state level against any weakening of current regulations that would
make large-scale biomass plants like Palmer more financially viable in Massachusetts.
As always, please reach out with any questions or feedback you would like to share. We look forward to continuing
to work with all of you on this issue.
Best regards,
Emily
Emily Granoff
District Director
Pronouns: She/her/hers
Office of Senator Jason Lewis
State House, Room 511B
Boston, MA 02133
O: (617) 722-1206
C: (781) 261 0509
Need help or advice during the COVID-19 pandemic? You can find our COVID-19 Resource Guide for Residents here; our
COVID-19 Resource Guide for Small Businesses and Non-Profits here; information on Unemployment Assistance here; and
our Housing Resource Guide here.