Mass Sign-On Letter

Berkshire Environmental Action Team * Clean Water Action * Climate Action Now – Western MA * Concerned Citizens of Franklin County * Conservation Law Foundation * Green Berkshires, Inc. * Massachusetts Climate Action Network (MCAN) * No Fracked Gas in Mass * Partnership for Policy Integrity * RESTORE: The North Woods *    Toxics Action Center Campaigns * Woods Hole Research Center 

December 2, 2019 

Letter in Opposition to the Biomass Carbon Neutrality Budget Rider (S.2580, Section 427) 

Honorable Members of the Massachusetts Congressional Delegation: 

We urgently request that you oppose all of the “poison pill” anti-environmental riders that the Senate passed in its 2020 Interior & Environment Appropriations bill, in particular the rider on biomass energy. We are grateful that the House did not include these harmful riders in its budget proposal and urge you to work to ensure that they are not included in the final budget that is being negotiated. 

Attached is a letter sent last week to House and Senate leaders by 16 national environmental organizations, including Natural Resources Defense Council, Sierra Club, League of 

Conservation Voters, EDF Action, and the Union of Concerned Scientists, opposing a damaging “legacy” rider in the Senate budget bill that has wrongly been interpreted by the Trump EPA to declare as a matter of law that all forest bioenergy from managed forests is categorically “carbon neutral.” It is scientifically indefensible to characterize forest biomass energy as “carbon neutral” and inappropriate for Congress to legislate the science of biomass and climate change. Numerous studies have shown that carbon dioxide emissions from wood-burning power plants exceed fossil fuels for decades to over a century,[1][2] well past the time that climate scientists agree we need to take action to sharply reduce greenhouse gas emissions.2

Massachusetts has long recognized that forest bioenergy can have significant net carbon emissions, as evidenced by a requirement that in order to qualify for the MA Renewable Energy Portfolio Standard (RPS), a biomass power plant must meet strict efficiency criteria and demonstrate that its cumulative net carbon impact will be 50% that of a natural gas plant after 20 years.3 MA’s first-in-the-nation biomass standards were informed by a biomass sustainability and carbon policy study commissioned by MA Department of Energy Resources in 2009.[3]  

Today we know much more about the lifecycle carbon emissions from forest bioenergy and the importance of protecting standing forests for carbon sequestration and storage, and policies are beginning to reflect this shift in awareness. For instance, New York recently enacted a climate law that excludes biomass energy entirely from its definition of renewable energy and calls instead for measures to protect forests for their carbon sequestration and ecosystem values.[4]

We would welcome the opportunity to sit down with you and your staff to discuss these concerns in more detail. Laura Haight, US Policy Director with Partnership for Policy Integrity, will follow up with your office on this request and can be reached at or 518-949-1797. 


Jane Winn, Executive Director 

Berkshire Environmental Action Team           

Elizabeth Saunders, Massachusetts Director 

Clean Water Action     

Adele Franks, Steering Committee 

Climate Action Now – Western MA  

Janet Sinclair 

Concerned Citizens of Franklin County          

Caitlin Peale Sloan, Staff Attorney 

Conservation Law Foundation             

Eleanor Tillinghast, President Green Berkshires, Inc. 

Carol Oldham, Executive Director 

Massachusetts Climate Action Network 


cc:        Honorable Elizabeth Warren 

Honorable Edward J. Markey 

Rosemary Wessel, Program Director

No Fracked Gas in Mass          

Mary Booth, President and Director 

Partnership for Policy Integrity           

Michael Kellett, Executive Director 

RESTORE: The North Woods            

Claire Miller, Lead Community Organizer and Climate Justice Director 

Toxics Action Center Campaigns        

Philip B. Duffy, President and Executive 


Woods Hole Research Center  

[1] Ter-Mikaelian MT, Colombo SJ, Chen J (2015) “The Burning Question: Does Forest Bioenergy Reduce Carbon Emissions? A Review of Common Misconceptions about Forest Carbon Accounting.” Journal of Forestry 113 57-68; Booth, M.S. (Feb. 21, 2018). “Not Carbon Neutral: Assessing the Net Emissions Impact of Residues Burning for Energy.” Environmental Research Letters 13 (2018) 035001. 2 IPCC, October 2018. Special Report: Global Warming of 1.5o C: Summary for Policymakers. 

[2] CMR 14.00 and 225 CMR 15.00

[3] Walker, T., P. Cardellichio, J. S. Gunn, D. S. Saah and J. M. Hagan (2013). “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.” Journal of Sustainable Forestry 32(1-2): 130-158.

[4] NYS Climate Leadership and Community Protection Act, NYS Laws of 2019, Chapter 106.