100 signatures reached
To: Representatives Tonko & Pallone & Speaker Pelosi, United States Congress
No CLEAN Future with Dirty Energy! Drop Waste Incineration from CLEAN Future Act
Note: Full annotated letter here: tinyurl.com/WTEisDirty
Dear Representative Pallone and Representative Tonko/Speaker Pelosi:
The undersigned organizations appreciate your efforts on the CLEAN Future Act to begin addressing the climate crisis. We are especially pleased that inclusion of waste issues in this act recognizes the important connection between waste production and climate change. Specifically, we applaud the provisions pausing the permitting of new plastics production facilities as these facilities cause plastic pollution and climate emissions. We were also glad to see the requirement of essential environmental justice protections for communities on the frontlines of the waste and climate crisis, and proposed investments in zero waste solutions that have the potential to create thousands of jobs and revitalize communities across the country that have been disproportionately impacted by past waste policies.
Unfortunately, the bill also promotes false solutions that contradict efforts to fight climate change and promote equity. The CLEAN Futures Act of 2021 allows waste incineration, aka "waste to energy" to be considered a clean electricity source. Waste to energy (WTE) facilities, particularly municipal solid waste (MSW) incinerators are the dirtiest source of energy production on the grid today and the majority are located in environmental justice communities. The inclusion of WTE as “clean electricity” undermines the very positive environmental justice protections in the bill. WTE facilities add to the cumulative burden of pollution on low-income, and Black, Brown, and Indigenous communities that causes long-term, multi-generational health impacts from toxic air pollution. These same communities are also the hardest hit by the impacts of climate change whether from severe storms and hurricanes, deadly heat waves, wildfires, rising sea level, spikes in food prices, or pollution, allergy, and pollen-induced asthma attacks, and are less resilient to these impacts. The most recent winter storms in Texas and Mississippi left hundreds of thousands of Americans without homes, power, and clean, safe drinking water, a sight that has become all too familiar after Hurricanes Katrina, Sandy, and Maria and the wildfires in Washington, Oregon, Colorado, and California.
Why is this important?
WTE accounted for 8.3% of total waste-related GHG emissions and U.S. waste generation is on the rise. WTE facilities are the most polluting energy source in operation today, worse than coal-fired power plants. Incinerators only contribute 0.3% of the energy supplied to the grid, yet emit nearly quadruple the grid average for greenhouse gases (GHGs) per unit of electricity generated. Specifically, WTE facilities emit almost twice as much carbon dioxide as is emitted from burning coal, and nearly three times as much as oil and gas. In addition, WTE facilities emit 15 times as much nitrous oxide and methane as the grid average, as well as 14 times as much nitrogen oxides and 1.3 times as much sulfur dioxide, which are significant contributors to air pollution and acid rain.
While biomass power plants are also major sources of air pollution and GHG emissions, MSW incinerators stand out as the only generation source that emits large quantities of both fossil and biogenic emissions. Even if the biogenic portion of the municipal waste stream were entirely removed, WTE plants would still emit more GHG than oil and gas. The nation’s power grids are increasingly moving away from coal, recognizing its tremendous contribution to climate change and air pollution, and inability to compete against the cost of renewable sources such as solar and wind, yet the CLEAN Future Act classifies WTE incinerators and biomass power plants, which are even more polluting than coal, as clean energy sources.
Incinerators and landfills are most often sited near environmental justice communities or primarily low-income communities and communities of color. In fact, 79% of MSW incinerators are located in environmental justice communities. Along with GHG emissions, MSW incinerators emit co-pollutants that are harmful to human health at greater rates than fossil fuel power plants, including particulate matter, dioxins, lead, and mercury. Ten of the twelve incinerators in the US that produce the greatest amount of lead emissions are in environmental justice communities that are already heavily burdened with pollution. Nearly one-third of WTE facilities exceeded pollution emissions limits from 2016-2019, resulting in 126 federal violations under the Clean Air Act. Decades of data reveal that EPA’s emissions reporting and auditing rules allow WTE facilities to exploit loopholes created by federal and state policies and take advantage of under resourced state agencies delegated to inspect WTE every five years. Many WTE facilities often receive permit approvals with few requirements to upgrade emissions standards or invest in improvements. For example, the Hennepin County Recovery Center, one of Minneapolis/ Hennepin County’s worst air polluters, has been operating under a federal air emissions permit that has been administratively approved without inspection since 2004. The facility emits close to 2 million pounds of pollutants per year including dioxin, mercury, lead, fine particles, carbon monoxide, “NOx,” other heavy metals, and dozens of other hazardous pollutants. In addition, for every pound of garbage that is burned, 1/3 pound of ash laden with heavy metals and dioxins is produced. The ash produced from incineration must then be landfilled adding to the environmental burden of those communities and risking exposure through air and water contamination. The certification requirement for WTE facilities to earn clean energy credits in the bill will not address the decades of policies that have left communities breathing dirty, toxic air.
While the CLEAN Future Act takes important steps to address plastic pollution and promote zero waste initiatives, the waste production trend needs to be reversed with upstream measures while downstream measures to achieve zero waste need to be much more aggressive.The total U.S. waste stream tripled from 1960-2015 and plastic waste alone has doubled over the past 30 years. Plastic manufacturing is expected to increase 40% by 2050, releasing methane and other greenhouse gases across its life cycle from extraction to production to incineration at the end of its life. Only 25% of all municipal solid waste was recycled and only 10% composted. Of the remaining municipal solid waste (MSW), 12.7% or 34 million tons was incinerated. Hydraulic fracturing and the production of plastic is incompatible with avoiding catastrophic climate change and the legislative goal of the CLEAN Future Act must consider reducing plastics’ emissions at the source and investing heavily in reuse, recycling, and remanufacturing systems.
Just because Americans produce a lot of waste, does not make it renewable. Nor should we continue on this pathway of endless waste production. For these reasons, we are pleased with the inclusion of investments in zero waste solutions, a pause of plastic production facilities, and a national bottle bill, but the bill must go further and urge the bill be amended to remove waste-to-energy incineration and biomass combustion as a clean energy source, ban hydraulic fracturing, and end the production of single use plastic.