Anyone who has had an interest in this subject, and has been reading about it here and elsewhere, already understands that it's a serious, significant and, in many ways, very complicated issue.
Put simply, the basic question has generally been: Should Frederick County approve a Waste-to-Energy facility as part of our overall, long term waste management strategy?
Over the last few years, immense volumes of information has been gathered or generated, shared, discussed and debated by a growing number of people with an interest in the issue.
In no particular order, a few of the questions and concerns that have been raised include:
• How much will Waste-to-Energy really cost, and how certain can we be about such projections given anticipated and unanticipated new regulations, required upgrades and other changes that may apply over the next few decades?
• Is it wise to invest more money than the county has ever spent on anything to lock ourselves into this particular approach for 25 or 30 years (or more), especially when so many related and important elements are rapidly changing, such as the nature of our wastestream (and how much of it can be recycled or composted), the market value of recycled/recovered materials, and more?
• Are the potential public health and environmental effects adequately addressed by noting that, in the manner in which the emissions are monitored, the facility will meet current EPA standards?
• What effect will a Waste-to-Energy incinerator have on local property values?
• Will a 1,500 tons per day Waste-to-Energy facility for Frederick and Carroll Counties be too large for our current and projected population (and the expected, but changing wastestream that population will generate)?
• If it is not operating at capacity (and therefor operating less efficiently and more expensively, with lower revenues from the sale of electricity to offset a portion of the costs) why wouldn't our WTE facility create a significant disincentive for future commissioners to ratchet up recycling and recovery efforts to the maximum extent possible?
• If no community in the entire country has chosen to embark down the WTE path for almost fifteen years, why not, and how have they resolved their solid waste management issues?
• If we examined the WTE option using a broader life cycle analysis, or taking a more system-wide perspective, and compared it to other alternatives, would we confirm that the proposed WTE facility is not a net generator of energy (and does not help with our energy crisis), that it will not reduce our contribution to greenhouse gases, and that it will not reduce other hazardous and persistent emissions associated with our solid waste management?
• If that is not the case, why is it that no credible environmental organization in the country has supported or endorsed WTE as either a primary option or as part of an integrated approach?
• If we know that more than eighty percent of our wastestream is recyclable or compostable, and that there is a market for most of it, and that the market value of those materials has been increasing at unprecedented rates (especially as energy prices have risen), and we are seeing more and more communities setting and achieving (or making rapid progress toward) ambitious levels of recycling and recovery (seventy, seventy-five, even eighty percent), why have we based our long term plan on taking sixteen years to reach sixty percent, with no goals established above and beyond that?
• In a rapidly changing environment, with dramatically increasing values for recovered materials, major changes coming to our materials economy, strong prospects for major new emissions controls (including carbon dioxide), the continuing development of new and more efficient (and less expensive) technologies, and much more, are we substantially undervaluing (or ignoring altogether) the value of alternatives that are inescapably more dynamic, flexible and adaptable?
• If a total commitment was made to a more flexible and adaptable, integrated combination of policies, practices and technologies that did not include a Waste-to-Energy incinerator, and the residual waste still had to be dealt with through a combination (at least, for a while) of landfilling (an amount equivalent to the ash we are currently proposing to put in our own landfill) and hauling (to landfills and/or other facilities elsewhere, by truck or rail), would the cost be less, and perhaps substantially less, than the cost of the currently-favored proposal with WTE?
By no means is that a complete list of the questions and issues that have been raised and debated. But they are all questions and issues that have not been adequately examined and answered (insofar as it is possible and reasonable to do so).
Clearly, there are those who believe that the important questions have been adequately addressed, and who are satisfied that the answers - from an economic and environmental perspective - still point to the wisdom of spending hundreds of millions of dollars to build and operate a large Waste-to-Energy incinerator in Frederick County for the next few decades.
And I fully appreciate that no amount of study, no level of additional details, will lead everyone to the same conclusion.
But, rather than attempt to further address any of the questions above, or others, I'd like to concentrate for a moment on the decision-making process to date. For me, at this point, that is the real "bottom line."
There are those, including some of my fellow commissioners, that have adamantly and unreservedly defended the process the county has engaged so far.
Those who defend the process point to how long it has been, noting that we've been discussing a combination of solid waste disposal alternatives for several years.
They refer to the number of BOCC worksessions and public hearings that have touched on or been dedicated to the subject over the last few years.
They are quick to point out the lengthy list of things the county has done, and is doing, to improve recycling and composting efforts.
They point to trips some commissioners and staff have taken to Europe, Seattle, Boulder...and Montgomery County (the last county to have chosen WTE...almost fifteen years ago).
They mention the Solid Waste Forum the county held some fourteen months ago.
All of the points above are true. The issue has been discussed and debated for quite some time. There have been a number of BOCC worksessions and a few related public hearings. The county has made significant strides toward improving recycling and composting efforts. Commissioners and staff have taken a variety of trips. And the BOCC did sponsor a public forum on the issue.
But that list - and more - is not evidence that the Board of County Commissioners has commissioned or received the information necessary to make a responsible decision to build a 1,500 tons per day, two-county, Waste-to-Energy facility - at a cost of hundreds of millions of dollars, and with a commitment to operate it for decades.
For all that has been considered and discussed, the process has not included a reasonable and responsible analysis of a Resource Recovery Business Park-focused alternative plan that does not include WTE.
In fact, as noted in my previous column, throughout the entire process, not a single outside expert or consultant or forum participant has been part of the official county information-gathering and decision-making (on the county's time or dime) who has either been opposed to WTE incineration or has been actively supporting any alternative that does not include WTE. Not one.
It is quite clear that a significant and growing number of citizens are concerned about or opposed to Waste-to-Energy incineration. More to the point, however, their concern and/or opposition reflects increasing frustration that the county commissioners would be willing to make this critical decision without the benefit of a detailed, thorough and complete evaluation of a more flexible and adaptable alternative that could be fairly compared to a plan with a WTE facility.
At the very least, the county should perform an evaluation and comparison comparable to what any private business would conduct before making such a large investment and long term commitment.
Though I have been outspoken in my criticism of the process (and WTE) for quite some time, I have also received some criticism for not making a detailed motion about a specific alternative approach or proposal before now. But there is no benefit to making motions that will not pass (admittedly, a judgement call, albeit one based on many separate discussions). I believe the broader public discussion, and the expanding interest and involvement of citizens in that discussion over time, has been valuable and essential.
It is time now - before it is too late - for the county commissioners to respond to the concerns of the community by investing the necessary time, and money, to commission the sort of meaningful study citizens have been asking for. And I am hopeful and optimistic that will happen now.
At the very least, our evaluation should include a county-based, state-of-the-art Materials Recovery Facility (MRF). It could be sited at our current landfill, converting our investment in the new transfer station into a substantial cost-saving head start, and allowing the county to accrue all the benefit of the increasing value of the separated materials. Such a MRF could also be built and put into operation relatively quickly, and, in combination with a total commitment to increased recycling, could be less expensive than the money saved by reducing the amount of waste we are tentatively planning to haul long distance in the years before a WTE facility could ever be approved, permitted, built and begin operation.
Such a study should include an up-to-date consideration of the dramatically increasing market value of separated materials, as mentioned above. It is noteworthy how much these values have already changed since the county commissioned the narrowly-focused Beck Report in 2005. And we should produce a range of reasonable scenarios for what those values will be over the next decade or two. Unless you think that the days of cheap oil and other energy are going to return, we can anticipate the value of recovered materials will be further increasing as time passes.
We should include a range of timelines for reaching more ambitious rates of recycling, recovery and composting. Even though there is not a long history of other communities diverting seventy percent (and more) of their waste, we only need to look around to find a variety of communities, of different sizes, and operating with various constraints, that are proving what is possible today. It would not be reasonable to only consider alternative options based on a sixteen year timeline for achieving a sixty percent diversion rate.
We should re-examine the assumptions that have been made about our projected population growth, if only to broaden the range of scenarios considered, particularly in light of changing goals and policies at the state level, not to mention changes in our own approach to growth and the revision of our comprehensive plan, and other factors in the broader society (energy/commuting costs, demographic changes, etc.). It is ironic that this board is considering a plan that relies on a rate of growth that we would not support, and that our changing policies would not enable.
Our examination should, of course, be based on a realistic appraisal of our legal authority, but also include some creative problem-solving, such as how we can use the authority and tools we do have to make recycling more convenient and create significant incentives. Too often, a variety of obstacles we face have been described as reasons we can't do more, rather than as challenges we can meet. One of a number of examples is the fact that we do not have the ability to license haulers at the county level, while little has been said about how we can accomplish much the same thing with the ability to establish conditions on those who use our landfill (and related facilities).
There is more to evaluate and compare, of course. But, for now, I'll end with a very heartfelt word of encouragement that the county commissioners genuinely consider the subjective, but real, value of alternatives that preserve our flexibility. We risk more than some seem to appreciate by selecting a path that heads backwards, and fails to account for the rapid changes - even major paradigm shifts - we are seeing in the world around us today.
We can be the last community - or one of the last - in the entire country to choose Waste-to-Energy incineration, permanently converting limited resources to ash (because our plan does not include only incinerating what can not be recycled or composted). Or we can show real leadership, and become one of a growing number of communities that will serve as working models of a better, more flexible and adaptable, more environmentally-friendly, and less economically-risky path.
Kai Hagen is a member of the Frederick County, Maryland Board of County Commissioners
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