CEO & President
Erving Paper Mills
Erving Paper Mills operates 24 hours a day, 355 days per year and has done so continuously since 1905.
We employ 120 people in Central Massachusetts and we buy almost all of our purchased goods and
services from other Massachusetts / New England companies. As a 120 tons per day manufacturer of
recycled napkin, toweling and tissue paper, our operations are energy intensive. In fact, each year we
use almost 50 million kilowatts of electricity (enough to power 4,500 average homes) and about 2.9
million gallons of oil (enough to heat 4,000 average homes).
Erving Paper Mills is committed to environmental stewardship. Every day, we recycle 9 truckloads of
wastepaper that would otherwise go to a Massachusetts landfill. We constantly manage our system
of pumps and motors to ensure that they are optimized for energy efficiency and we recycle the water
used in our production process in order to minimize our ecological footprint.
The time has come for all of us, including Erving Paper Mills, to transition away from fossil fuels and
towards local renewable fuel sources. To this end, in late 2008, our plant commissioned an exhaustive
study to look at energy alternatives. The study found that a biomass-powered combined heat and
power (CHP) system would meet our needs perfectly. Biomass delivers a solution that is both the most
economically viable solution and, unlike solar and wind power, leverages the only renewable source of
energy that can provide a continuous stream of power within a reasonable amount of real estate. We
would need 46 acres of solar panels or 15 industrial-sized wind turbines and a steady 30 – 55 mph wind
to meet our electricity needs alone.
What is biomass? Biomass is organic material, primarily waste wood and brush that is generated during
proper forest management and unusable as timber, which can be used to power an industrial facility
such as ours. The shift is analogous to switching from heating one’s house with oil to heating one’s
house with a wood-burning stove. Yet, we would not just heat our factory, but actually power our
entire process with waste wood. In Central New England, we are surrounded by a natural, abundant,
sustainable and renewable supply of waste wood, clearly a compelling energy source for us.
Two months ago, in September, the Massachusetts Department of Energy Resources (DOER) released
draft rules on the qualification of biomass as it relates to the state’s renewable energy portfolio. The
original purpose of these rules was to properly incentivize the more efficient and appropriate use of
biomass and other alternate fuel sources. Unfortunately, due to political meandering, the effect of the
rules as currently drafted will prevent us and others like us from moving away from fossil fuels. Even
though, biomass (32% efficient) is more efficient than wind (25%) or solar (17%) power, its use is being
singled out and unfairly targeted by legislators. Efficiency benchmarks are being established that will
restrict biomass installations in the Commonwealth.
We strongly urge Massachusetts lawmakers to amend the draft rules. We suggest that the
Commonwealth implement an efficiency standard that is achievable for alternative energy sources
like biomass and provide a full renewable energy credit for CHP facilities. We also suggest that
thermal RECS be introduced that will specifically incentivize CHP plants Without attending to these
changes, the ability of Erving Paper Mills and Massachusetts companies like ours to transition away
from fossil fuels will be severely hampered. Our companies will be less competitive, economic value
to the Commonwealth will be lost and an opportunity to reduce our carbon footprint will have been
squandered.
In addition, we support science-based forest sustainability standards and believe that the proposed 15%
limit on what can be counted as biomass is arbitrary and does not allow for site-specific conditions to
be taken into account. We believe that a better approach would be the recommendations made by the
Forest Guild in the Manomet Study.
Erving Paper Mills is fully committed to deepening our investment in the local community and to
providing environmental stewardship by transitioning away from fossil fuels towards a renewable,
locally-sourced alternative that will not only lower our future emissions but also make us more
competitive. This is exactly the type of energy strategy that the DOER and the Patrick Administration
should want to encourage. Unfortunately, the rules, as currently proposed, would not allow us to make
this transition. A significant change is needed so that the final rules will take our situation and that of
companies in a similar situation into account.
Sincerely,
Erving Paper Mills, Inc.
Morris Housen
CEO & President
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