Friday, February 24, 2006

Clean it up or shut it down!

Listeners may recall Tina Clark from Clean Water Action was on our show a few months back. She's sending around the letter below to encourage more folks to submit testimony on the Mt. Tom coal-burning power plant (cough, gag) that's making such a mess of this valley. March 6 is the deadline for letters. Clean it up or shut it down!

Dear Friends,

Our hard-won regulation to reduce global warming gas emissions from the Filthy Five coal-burning power plants is being gutted by the Gov. Romney administration. These old, dirty plants produce about 17% of greenhouse gas emissions from the state! They are the SINGLE LARGEST SOURCE of global warming gases. We won a modest reduction of 10% by 2008 in 2001. Romney s proposed changes to the Filthy Five CO2 regulation would let power plant owners off the hook

Please send written testimony using the heading below. We must flood the MA Department of Environmental Protection with written comments to STOP this violation of the public trust and democratic process. Please FORWARD THIS MESSAGE to everyone you can.

Send your Written Comments to Sharon Weber at or: Sharon Weber, Department of Environmental Protection, Bureau of Waste Prevention, One Winter Street, Boston, MA 02108. Comments must be received by March 6, 2006.

Use this heading:

Written comments

RE: Proposed Greenhouse Gas Amendments to 310 CMR 7.29 & 310 CMR 7.00: Appendix B

Then write:
[your name], [organization name - if you re representing an organization]



SUGGESTIONS for your message:

[who you are. If you are writing on behalf of an organization, explain what the organization is about.]

[statement of opposition to the proposed changes to the regulation]

[why this matters to you - your personal perspective: concern for the kind of world your children and grandchildren will have, concern for the changes that could happen to the New England lifestyle and the nature of New England, etc.]

[Any Specific Concerns with Proposed Changes to the Regulation, such as:]

- Global warming is a massive challenge facing us and our children, and we must be sure that we are making real reductions in global warming pollution. This version of the regulations adds uncertainty to those reductions.

- If gone unchecked, global warming threatens New England s economy, food supply, public health, and community well-being. Weather disasters will intensify floods, heat waves, ice storms, high winds that damage homes and energy supply, etc., etc. In addition, we will damage forests, wildlife, foliage, coastline, lobster catch, and winter recreation some of the defining characteristics of our region.

- DEP not only has an opportunity to make a strong regulation that significantly reduces CO2 pollution from our oldest and dirtiest power plants, but it can also set an important precedent for other states and regions on how to structure their programs.

- Our state will not be able to meet its climate protection goals without effectively tackling power plant pollution. If Governor Romney is serious about the commitments he made to those goals, he should stop attacking this regulation.

- The public health, security, and environmental risks of nuclear power are well documented, and the this global warming regulation is not the appropriate place for the state to decide whether it wants to encourage such a controversial energy source as nuclear power. (Though in the draft regulations nuclear power is excluded from being an offset, DEP has asked for comment on whether it should be included.)

- The proposed changes to this regulation mean we may not get the pollution reductions promised in the regulation. Offsets programs are difficult enough to manage when they are well-designed, and adding loopholes to the Filthy Five CO2 regulation will only add more uncertainty to the program. The major loopholes:

- With the $6.50 price trigger for offsets, the geographic scope for offsets expands to the entire globe, and we lose the co-benefits of having the offsets in our region. Many offset projects would be happening in far-off regions, so we wouldn t enjoy, for example, the reductions in non-GHG air pollution that often come with offset projects. Also, accepting offsets from the entire globe further complicates oversight of the system especially determining when and how to enforce penalties.

- With the $10.00 Trust price trigger for offsets, power plant owners can simply pay into a state trust fund at a discount instead of continuing to make pollution reductions. They get to buy their way out of having to meet the emissions standard in the regulation at a cut price. The Trust price trigger also takes away the incentive for plants to invest in new, cleaner technology.

- The altering of the definition of permanent gives the power plant owners a loophole for avoiding their commitments and protesting DEP rulings. DEP should only be allowing offsets that can reasonably be called permanent, instead of giving plant owners leeway to argue for projects that have questionable staying power.

For more information: download the hearing kit at
If you have questions, please contact Brian Thurber, Clean Water Action, 617-338-8131, He ll be delighted to support you.

This is a critical time to express your opinion! Please be sure to mail or email your comments so that the DEP receives them by Monday, March 6.

THANK YOU for taking action.

Tina Clark
Clean Water Action
office/home: (413) 549-6834
cell: (413) 658-8165

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