A chance to weigh in on garbage incineration in Minnesota

[Alan Muller]

A chance to weigh in on expansion of HERC garbage incinerator

Comments needed by email before 9:00 am Tuesday, December 8, 2009

Comments can be emailed to:  jho...@mn-ei.org or posted here. (Send Neighbors Against the Burner, and MPCA Commissioner Paul Eger, a copy.)

Suggested comments to make:

o       "Remove Strategy 4.11, promoting more garbage incineration, from the final report;" and

o         "The 'stakeholders' should produce a plan that complies with the MCAG recommendations of 70 million tons cumulative carbon dioxide equivalent reductions through 2025."

o       "The stakeholder group should recommend that Minnesota enact a permanent legislative moratorium on construction or expansion of garbage incineration capacity in Minnesota."
        
Background:

The Minnesota Pollution Control Agency wants to increase the amount of garbage burned in Minnesota by 50-60 percent, and in pursuit of that hired the"Minnesota Environmental Initiative," (MEI) to run a " stakeholder process."

The supposed purpose was to "Develop the elements of a plan based on the recommendations from the Minnesota Climate Change Advisory Group (MCCAG)."  But the MPCA and its allies in the burner industry have a little problem:  The MCAG report showed that there are big opportunities for greenhouse gas reductions through source reduction, recycling, and composting, and essentially none through incineration (details below).

The stakeholder process is nearing its end.  A set of  38 " draft recommended strategies" has been developed, and "public comment" is being accepted on them until December 8, 2009.  "Comments received during this period will be shared and discussed with the Work Group during their December 9 meeting and will be included in the final report submitted to the MPCA, due by December 31, 2009."

Thanks to the effective work of several public interest participants, only one of the "strategies" openly promotes incineration and that doesn't have unanimous support.  Most of the "strategies" are desirable or at least harmless.  (One of the "waste to energy strategies," No. 4.9, is actually a recycling strategy, "Maximize Recovery of Recyclable Material Prior to Disposal ...." ["preprocessing"])

The key bad "strategy" is No. 4.11 "Existing Waste-to-Energy Infrastructure is Operated at High Efficiency".  Sounds harmless, doesn't it?  Who can be against "high efficiency?"  But like many burner industry statements, this one is deceptive.  The real meaning is found on pages 62-63 [comments in brackets]:

"Several WTE facilities have not been operated at capacity due to the failure of waste assurance through subsidy programs." [Not enough money is going into subsidizing incineration.]

"By 2011 all WTE facilities are [we want them to be] operating at capacity, have long-term delivery agreements, ...." [Taking sides in the HERC expansion controversy and sending more garbage to the Great River Energy Elk River burner, now in danger of closing due to lack of garbage to burn].

"... provide long term commitments of mixed municipal solid waste (MMSW) [to incinerators] to create investments" [in more incineration capacity rather than source reduction and recycling].

"Waste generators [households and businesses] would bear the cost of WTE and waste processing as it may be priced higher than landfills."  [Assumes that dumping is the only alternative to burning; source reduction and recycling aren't to be taken seriously....]

In other words, the intent of Strategy 4.11 is to increase burning, increase public subsidies for incineration and force garbage to be taken to incinerators.

So the key comment to make is "Remove Strategy 4.11" from the final report."

The MCCAG report called for reducing greenhouse gas emissions through better waste management by 75 million metric tons of carbon dioxide equivalent, cumulatively, by 2025.  The MPCA unilaterally reduced that to 52.5 million tons "To ensure efficiency and effectiveness and a workable plan coming out of the process...." by including only "the four population centroid regions of Minnesota."

So, another suggested comment is that:

 The "stakeholders" should produce a plan that complies with the MCAG recommendations" of 70 million tons cumulative carbon dioxide equivalent reductions through 2025.

Incineration increases greenhouse gas emissions while source reduction, recycling, and composting reduce them.  This is not really hard to understand:  Conserving and reusing resources is pretty obviously more sustainable than burning them up.

The details of the MCAG report are not always easy to follow, and arguable in some cases, but the conclusions are striking:

        Cumulative reduction in greenhouse gas emissions through 2025 (Table I-65).
        (millions of metric tons carbon dioxide equivalent)

Source reduction, recycling, and composting:    70      costing-$0.20/ton*
"End of pipe" methods such as burning:           5.1      costing $51/ton **
total                                                         75.1

"current MPCA goals"                                 7.4   costing $117/ton                                            

*       recycling saves money
**      essentially all from landfill gas burning, not garbage incineration as such

It would seem that something other than logic and the public interest must be driving the present leadership of the Minnesota Pollution Control Agency.

Third suggested comment: 

"The stakeholder group should recommend that Minnesota enact a permanent legislative moratorium on construction or expansion of garbage incineration capacity in Minnesota."

The final meeting of the "stakeholder process:"

December 9, 2009
9:00 AM - 3:00 PM

Agenda

MINNESOTA POLLUTION CONTROL AGENCY
Central Board Room
520 LAFAYETTE ROAD, ST. PAUL, MN 55155
Click here for directions

Alan Muller
Red Wing