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Wednesday, August 27, 2008

“Waste-to-Energy” = a risky waste of energy, resources and money (part 2)

Kai Hagen

Picking up where I left off...


WTE proponents often point out that even the best recycling and recovery efforts will still leave "residuals" that have to be dealt with in another manner. That's true. But contrary to the impression some still have, WTE incineration does not make everything go "away." Incineration does reduce the weight and volume of the materials burned. But it is, nevertheless, important to note that the remaining ash still leaves us with twenty-five to thirty percent of the original weight and ten to fifteen percent of the original volume. If we are only asking how much incineration can stretch out the existing capacity of our landfill, that is a significant reduction. But when we start to compare this approach to other alternatives, we have to remember that even with incineration we are left with a great deal of ash that needs to be shipped out of state (as Montgomery County does) or placed in a landfill. The current plan is to use it as "cover" in our own landfill. If we did nothing else, that would still use up our landfill capacity, and leave the county with the need to haul it out of state or site another landfill in the future (something that will only get more difficult and more expensive over time, and which we are not considering at this time).


Many people who are concerned about a new WTE incinerator in our back yard are concerned about the potential and uncertain effects on public health and the environment in our community. This is a lively and challenging part of the broader debate, with a wide variety of studies and reports offering a wide variety of results.

Efforts to address the concern many residents have about local emissions have always included the assurance that the emissions would be monitored and would meet current EPA standards. I appreciate that, and there's no doubt that an incinerator built today would have better emissions controls than those in the past. Of course, in the past, many communities were assured that everything was fine, because those incinerators met the EPA standards of the time. That is what people were told in Minneapolis, for instance, where a huge incinerator was built in the middle of the city. After the incinerator had been in operation twenty-four hours a day, three hundred and sixty-five days a year, for years, continuing research about the health effects of mercury led the federal government to make the new standards one hundred times tougher. While it remains to be seen whether the current mercury standard is adequate, it is small consolation to those elsewhere who were assured that meeting EPA standards was a sufficient response to their concerns.

In any case, there is no question about the fact that old and new incinerators pollute: All incinerators release pollutants through air emissions and ash. These include acid gases, particulate matter, carbon monoxide, nitrogen oxides, metals (such as mercury and lead), dioxins and furans, and at least 190 volatile organic compounds. Even at lower levels of emissions than in the past, it's worth noting that some of these are extremely dangerous, and that some of them do not break down - they will be persistent and bioaccumulative in our local environment.

We should not simply write off or dismiss the concerns and warnings from people like Marie Lynn Miranda of Duke University's Nicholas School of the Environment (and many others). The school released a comprehensive international study on waste incineration. According to Ms. Miranda, one of the researchers, "uncertainties about the toxicities of some chemicals emitted by even the best incinerators raise questions about the technology's environmental viability… We don't even know what some of those air toxins can do in the lab, much less in an uncontrolled environment." And "the problem with incinerators is that we don't know as much about the potential impacts associated with their pollutants."

The effects of "air toxics," a variety of incompletely investigated chemicals like benzene and trichloroethylene, is a major uncertainty. Waste incinerators emit more of these chemicals than do fossil-fueled power plants. Today there are emerging concerns about the health effects of extremely fine particles, or nanoparticles, which are emitted from incinerators, and can get deeper into the lungs than most things we have been exposed to in the past. Some available scientific reports suggest that nanoparticles pose a significant threat to human health and to the environment.

As I was writing this I received an email about a recent study published in Environmental Science & Technology, entitled "Occurrence and Profiles of Chlorinated and Brominated Polycyclic Aromatic Hydrocarbons in Waste Incinerators." I'm not a scientist, and it is not easy to discern the absolute truth from such a range of research and results from credible sources, but it is clear that many highly credible sources have serious concerns. If nothing else, this does seem like an area where we would be well advised to err on the side of caution, especially when we have good alternatives.

I'll add that even though I believe there are genuine concerns about the public health and environmental effects of a large, local WTE incinerator, my opposition to such a facility does not rely on those concerns. Based on a still lengthy list of other concerns, I would object just as strongly if I could be 100% certain that there were no risks to local residents and the immediate environment. To quote Paul Connett: "Remember, even if you made incineration safe (doubtful) you would never make it sensible. It simply doesn't make sense to spend so much money destroying resources we should be sharing with the future."


Just as the continuing research into the health and environmental effects of various substances continues to add to the information available, a decision about WTE will be made in a world where many other related elements are rapidly-changing. Certainly, this is true about almost any major decision we are facing. But it's a particular concern when the decision comes with such great costs and entails a decades-long commitment, and when some of the key factors relevant to the decision are changing faster and more dramatically then ever.

It's clear that the economic viability of WTE depends on a twenty-five or thirty year horizon. Only, unlike a 30 year mortgage on a house, we won't have the option to matter how much things change in the coming years. That would be serious concern under any circumstances. That is not likely a concern to the company that will be paid to build and operate the facility, however, since there is little or no risk for them. No private business would make the decision to invest such a sum, and lock themselves into that decision for decades, without a far more thorough and detailed analysis than the county has done, and most certainly not without an equally thorough comparison to reasonable alternatives. But a private business is willing to build and operate our facility because their customer (the county) would be fully committed, AND because local government has the ability - and, in this case, the obligation - to raise rates and fees as necessary to ensure the enterprise is profitable, almost no matter what. The risk is all ours - the residents and taxpayers of Frederick County.

And the risk that this is an ill-advised investment and commitment is significantly greater than we are being led to believe.

Even the relatively rosy scenarios that have been described to date, and used to justify the WTE option, are based on - and rely on - a number of assumptions (as they must be) that are questionable in the short term, and get increasingly likely to be highly inaccurate in the long term. These include assumptions about the county's population, per capita waste generation rates, the nature of our wastestream, the costs of inevitable upgrades (to meet new standards), the revenues from the electricity generated, the market values of a broad range of recoverable (recycled) materials, and more. A responsible evaluation of the risks would examine outcomes with a broader range of realistic scenarios. After all, once we head down this road, there's no turning back (at least not without major financial penalties to the county).

Thirty-years is a long time. Thirty years ago was 1978. The world has changed a great deal during that time. And, even more, the rate of change has accelerated over those decades, and continues to accelerate today. We're seeing major changes - even striking paradigm shifts - in a number of categories that could or would have a direct and major effect on the economic viability and wisdom of WTE incineration. Many of these changes deserve entire columns of their own, but I hope a quick look at a few of them should suffice to make the broader point.

During the course of the next two or three decades, we are certain to see new and (almost always) tougher standards for many of the pollutants associated with WTE incineration, and new ones we don't even know about yet. Once you commit to an incinerator, you commit to doing (spending) whatever it takes to retrofit the facility in order to meet the new and tougher standards, whether they apply to mercury, lead, dioxins, furans, etc., or something newly regulated, such as CO2 or ultra fine particles. Big changes are likely with regard to carbon dioxide emissions. Carbon dioxide is not considered "hazardous," but it the primary greenhouse gas we are pumping into the atmosphere. It is almost certain we will see limits on CO2 emissions, perhaps in the form of caps for the entire state or specific regions. Interestingly, a recent Supreme Court decision found that CO2 could be treated as a "pollutant" for purposes of regulation. Any requirement to substantially reduce CO2 emissions from an incinerator could be very expensive.

In many respects, the United States has not been on the forefront of some of the legislative and regulatory changes we are seeing in Europe and elsewhere. But we only need to look at what has been happening in those places (and other places in this country) to get a sense of what will happen here in areas such as manufacturer take-back laws, outright bans on certain materials and products, restrictions about what can be burned at all, and a lot more. Anyone paying attention to related developments in this country already knows that nearly every day brings news of a development along these lines, large and small (such as bans on plastic bags, or styrofoam packaging, and so on). Given the rapid development of high quality and economically-competitive alternatives, it's only a matter of time before either government or the marketplace brings about the end of petroleum-based plastics for many one-time uses, in favor of fully recyclable or compostable alternatives. Much of this will be happening quickly, and the pace of change will only accelerate. We are not talking about a few minor changes that are decades away.

These are just a very few examples of changes that are coming. And that leads to one of the most relevant and significant changes we are already seeing...


For a long time, one of the elements that held back major commitments to recycling was the lower and/or uncertain and volatile market value of recovered materials. In just the last year or two or three, we have seen dramatic increases in the market value of a wide variety of recovered materials. A few weeks ago, there was a major article published in "Business Week," entitled "Cash for Trash: Recyclers are devising dazzling new ways to mint fortunes from America's mountains of waste." In many ways, it solidly reinforced the point that "Trash is no longer just an environmental liability. It is becoming a financial asset."

One part of the article talked about how "The possibilities have venture capitalists and buyout firms scrambling to invest in a melange of quirky startups that might have provoked belly laughs from these same financiers five years ago." I highlight that particular sentence to emphasize the point that highly relevant factors we must consider are already much different then they were when the county started down the road to WTE incineration a few years ago.

Some might respond that such changes are ephemeral, or that, at the very least, the price volatility creates too much uncertainty. But unless you honestly believe that a variety of commodities, most particularly oil, are going to get a lot less valuable and expensive, the better bet is that we've only seen the beginning of a dramatic increase in the value of recycled/recovered materials. The article continues by saying: "The calculus is simple: As the prices of oil and other raw materials rise, recycled products become more attractive. Consider that 8% of global oil production is siphoned off to make plastic each year. Recycled plastic, however, requires 80% less energy to produce. Recycled aluminum burns up 95% less energy. Recycled iron and steel use 74% less, while paper requires 64% less. The money piles up quickly: One ton of recycled aluminum saves an average of $700 in electricity."

We are already experiencing the early stages of a major shift, one that suggests that alternatives to WTE would likely "cost" far less. And more and more evidence suggests that a well developed system that can provide high quality materials, may very well be able to pay for itself. Obviously, we don't have to bank on that happening soon or at all. We only need to have good evidence that it is a better and less risky approach.

Which brings me to...


Frederick County has an important decision to make. And the limited capacity of our landfill. combined with the cost of hauling our waste out of state, have contributed to a sense of urgency in this process. That is understandable.

But a decision to make the largest investment in the county's history, and to commit to this approach for the next three decades, is too important a decision to make without having completed a full and thorough analysis of the alternatives. It is often said that the county has looked at this for a long time and in great detail. But our efforts so far are flawed and incomplete, and include only an inadequate comparison of WTE incineration to hauling-only and landfilling-only alternatives (which nobody is advocating!).

If you are skeptical about that, please ask for documentation that shows a reasonable and responsible analysis of a Resource Recovery Business Park-focused alternative plan. One that is based on our wastestream and volume, takes into account the value of recovered materials today, includes a county-based, state-of-the-art Materials Recovery Facility, and so on. We haven't done anything remotely like that yet. If you ask that question, you might also want to ask for a single example - just one - of an outside expert/consultant that has been part of the official county information-gathering and decision-making process (on the county's time or dime) who has either been opposed to WTE incineration or has been actively supporting any alternative.

In any case...

The ability to continue to transport what would be a diminishing volume of waste out of state, while we ratchet up planned (and other) recycling efforts, gives us the time and space we need to engage this critical decision-making process in a more complete and responsible manner. It is more important to make a decision about this well, than to make it quickly. And we do have time.

I'm convinced there are viable alternatives that are far more economically-responsible, more environmentally-friendly, and, generally, much more in tune with the way the world is moving. As contentious and frustrating and stressful as this process has been, I have to believe that we will not make this decision and commitment without a fair and thorough examination of the basic concept that so many (and more all the time) have been asking for.

One of the most critical differences between WTE incineration and potential alternatives is that the alternatives would be inherently more flexible and adaptable and dynamic in our changing world, and much less risky as a result. The county commissioners owe it to the people of Frederick County to be more diligent and certain before giving up that flexibility, and locking the next six or seven boards, and the residents and taxpayers, into a very expensive, unpopular, outdated, and irretrievably inflexible "solution."

Thank for getting this far, and for your interest in this important subject.

NEXT COLUMN: Recommended next steps for the process, and the possibility of a much better alternative.

Kai Hagen is a member of the Frederick County, Maryland Board of Commissioners

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