On April 7, 2009, GBB President Harvey Gershman wrote to President Obama about the inclusion of Waste-to-Energy (WTE) facilities in the definition of “renewable energy.”
April 7, 2009
President Barack Obama
The White House
1600 Pennsylvania Avenue NW
Washington, DC 20500
Dear President Obama:
I have been involved with solid waste management since the first Earth Day in 1970, working primarily for local governments on their solid waste issues. I want to share my perspective on what is a very important issue and one that can provide reliable alternative energy to help our nation reach an energy independence goal.
I understand the Senate will be considering “renewable energy” legislation in the near future that includes landfill gas recovery projects in the definition of “renewable energy” (which is good policy). It is very important that municipal solid waste (MSW) landfill gas recovery systems are defined as renewable energy. This helps offset costs to recover and convert methane generated and avoid significant harmful methane releases into the environment. Waste-to-Energy (WTE), sometimes referred to as incineration, is the beneficial combustion of MSW to produce usable energy in the form of steam and/or electricity. If WTE is more widely implemented, less waste goes to landfills to begin with, greater energy resources are recovered, and we are at a better place environmentally, too. However, draft legislation excludes WTE facilities from the “renewable” category.
According to the U.S. EPA (2007), 254 million tons of municipal solid waste is generated annually. This waste is managed in three ways, generally: 33.4 percent is recycled, 12.6 percent goes to WTE facilities, and the remainder of 54 percent goes to landfills. The 32 million tons that are processed through WTE facilities are reduced by 70+ percent by weight and 90 percent by volume as the energy is recovered. These facilities, reliable base load electrical generators, generate for export to the grid the equivalent of 2,300 megawatts of electricity. Their emissions meet or exceed air pollution standards under the Clean Air Act, as amended, and they dispose of their ash products in regulated Subtitle D landfills safely without undue impact on the environment. Some ash is used in construction applications, too.
Criticism of WTE facilities has been in two areas. One is related to environmental concerns with the emissions from these facilities. The environmental performance of these facilities speaks for itself. If you wonder how they can co-exist in either an urban or suburban area, please look at the facilities nearby in the City of Alexandria and Fairfax County, Virginia; City of Baltimore, Maryland; or Montgomery County (Dickerson), Maryland, as examples. The second criticized area is that these facilities hold back recycling. This is a myth. Communities with WTE facilities generally have higher recycling rates than those without. The key is to set the capacity allotted for WTE for the wastes left over after recycling program goals are met. Unfortunately, our waste quantities continue to grow as our population grows, so there is plenty of waste for both higher levels of recycling as well as more WTE.
My hope is that WTE can be included in the national renewable energy standard so that this homegrown renewable energy can be more fully utilized. This will change nearly 30 years of federal law, as well as acknowledge laws in 25 states that recognize WTE as renewable. Including all renewable resources respects regional differences, provides flexibility for states to comply with the renewable energy standards, and will help stabilize renewable energy prices. Inclusion of WTE will rightfully place the communities that own or rely upon these facilities on a level playing field with other renewable resources. In addition, inclusion will expedite the reduction of greenhouse gases and support efforts to increase use of alternative and renewable homegrown fuel sources.
Let me suggest a couple of conditions under which WTE facilities (both current and new) can be included in the definition of renewable energy and under stand-alone renewable energy legislation as well as the alternative of combined energy and climate change:
WTE facilities continue to meet the most stringent state and/or federal environmental regulations applicable; and
50 percent of any incremental financial benefit received due to being designated as a renewable facility is directed to participating local governments for the purposes of assisting those local governments plan, implement, and maintain reduce/reuse/recycling programs and services designed to reach at least 50 percent diversion levels. When 50 percent diversion is reached or exceeded, the sharing of benefits can end, and could be restored if the recycling level falls below 50 percent.
With a 50-50 partnership between recycling and WTE, our nation could see the amount of electricity produced increase by another 6,800 megawatts and, at the same time, accelerate growth in recycling programs as well.
If there is interest to discuss more with me and others knowledgeable in the solid waste industry, please let me know and I will be pleased to arrange.
Harvey W. Gershman, President
Gershman, Brickner & Bratton, Inc.
Solid Waste Management Consultants
cc: Carol Browner, Assistant to the President for Energy and Climate Change