Indivisiblehocomd FAV SB560 Uploaded By: ALEXANDER, PETER Position: FAV

Total Page:16

File Type:pdf, Size:1020Kb

Indivisiblehocomd FAV SB560 Uploaded By: ALEXANDER, PETER Position: FAV IndivisibleHoCoMD_FAV_SB560 Uploaded by: ALEXANDER, PETER Position: FAV Bill No. SB560 – RPS – Eligible Sources to Eliminate Waste Incineration Name: Peter Alexander, PhD Position: Favorable RE: Testimony before the Senate Finance Committee Date: February 25, 2020 Madame Chair, Mr. Vice Chair, and members of the Committee, My name is Peter Alexander and I represent the 700+ members of IndivisibleHoCoMD. I am writing in support of SB560, Renewable Energy Portfolio Standard - Eligible Sources, which removes trash incineration from Maryland’s Renewable Energy Portfolio. IndivisibleHoCoMD is a member of the Maryland Legislative Coalition, and SB560 is a high priority for MLC. Burning trash is not clean energy and shouldn’t qualify for RPS subsidies which are intended for energy sources such as wind and solar. Trash incineration currently receives the same subsidies as these truly clean energy sources. The fact that trash incineration receives any utility rate payer-funded subsidies is a misappropriation of those utility bill dollars. To produce the same amount of energy, trash incinerators emit more greenhouse gasses than coal plants do (1). Air pollutants from waste incinerators have also been shown to increase the risk of pre- term births, and lung and blood cancers (2). An Environmental Integrity Project assessment shows that Maryland’s incinerators emit higher levels of mercury, lead, nitrogen oxides, carbon monoxide, and carbon dioxide than our coal plants per kilowatt of energy produced (3). A Chesapeake Bay Foundation study found that Baltimore City’s trash incinerator emits particulate matter that creates adverse health effects that cost people in our region over $55 million every year (4). Burning and burying our waste are not the only options. Recycling, composting, re-use, and source reduction can eliminate the need to burn or bury so much waste. Composting is a sustainable alternative to landfills and incinerators, with many benefits to air and water quality, soil health, local business development, and fighting climate change. A waste characterization study by Prince George’s County found that 77% of its landfilled waste could be composed, recycled or diverted (5). The county has adopted successful zero waste strategies that have extended the life of the county’s landfill and the county is now home to the East Coast’s largest municipal composting facility, a profitable revenue stream for the county. Last year, the Frederick County Compost Workgroup launched a pilot program to work with students in three county schools to divert their waste for composting (6). This year, they’ve expanded to 14 schools. In a waste separation study at Urbana Sugarloaf Elementary School, they found that 87% of the school’s trash could be diverted from the landfill (7). Composting Maryland’s organic waste could reduce our waste stream while creating exciting opportunities for local business development. As an added benefit, compost sequesters carbon and builds healthy soils. Composting even creates jobs: composting a ton of waste in Maryland employs twice as many people as landfilling it, and four times as many people as incinerating it. Let’s stop subsidizing trash incineration as a so-called clean energy source and use those subsidies to support truly clean energy sources while developing viable alternatives for diverting waste from our landfill. We urge a favorable report. References (1) http://www.energyjustice.net/incineration/climate (2) Tait, et. al., (2020). The health impacts of waste incineration: a systematic review. Australian New Zealand J. Publ. Health. 44(1):40.48. (3) EIP Report: Waste-to-Energy Incinerators Pollute More Per of Hour of Energy than Coal-Fired Power Plants and Are Not Renewable; Oct 2011. (4) Thurston, G.D. (2017). Written Report of George D. Thurston Regarding the Public Health Impacts of Air Emissions from the Wheelabrator Facility. (5) SCS ENGINEERS (2016). Waste Characterization Study Summary of Results 2014/2015, File No. 02201056.95. June 2016. (6) https://frederickcountymd.gov/1739/Composting (7) https://www.fredericknewspost.com/news/education/schools/public_k-12/elementary/foodwaste- biggest-hurdle-still-to-come-as-fcps-expands/article_a6d398f5-0bee-54bf-9524254e6f4331e5.html TerrelAskew_FAV_SB560 Uploaded by: ASKEW, TERREL Position: FAV Testimony Supporting HB438 / SB560 House Economic Matters Committee / Senate Finance Committee February 20, 2020 / February 25, 2020 Position: SUPPORT My name is Terrel Askew and I'm a Leadership Organizer with United Workers. I'm a lifelong Baltimorean, residing in the 43rd district. I have at least two people in my family who suffered from asthma: my aunt and her son. They lived in East Baltimore, along the truck routes where the trash is hauled to the incinerator. They are both gone now, I may never know just how much the trash burning affected them. Maryland needs to remove Incineration from its RPS because incineration is a 19th century solution to a 21st century problem. We are producing more goods than at any other time in history. A great deal of these products are not reusable and have a limited shelf life, which is completely unsustainable. Their production is a drain on our natural resources and their consumption provides more waste for landfills. Incineration does nothing to address this growing problem, and to the contrary, encourages us to buy more. What it does do is take away precious resources from alternatives like composting and recycling, which would reduce our current waste; and policymaking that would reduce our litter stream. If this was all the harm, these subsidies would be fiscally irresponsible; but no, it gets worse. Burning our waste releases harmful toxins such as mercury, lead, carbon monoxide, nitrogen oxide, and fine particulate matter into the air we breathe and the water sources we depend upon. These substances are known to cause respiratory issues such as asthma, as well as birth defects, cancer, heart problems, and even death. Given their locations, the communities that suffer the most are usually low income and persons of color; not to mention animal life, who have little say in the matter. The Environmental Integrity Project released a report that showed that Baltimore City’s rate of asthma hospitalizations is more than twice the state's, and nearly 3x the nation’s. So what we as ratepayers are actually subsidizing is the decimation of our own communities, both marine and human. And for what? Due to the by-products of incineration, we are still using landfills to bury the two types of ash created. Amounting to about a third of the total waste, fly ash and bottom ash require special hazardous landfills to dispose of them properly. This creates a possibility for further contamination of the soil we use to grow our food. This is a recipe for disaster, one that we could be minimizing by building up our zero waste infrastructure. We in Baltimore City have already started to do just that. The Commission on Sustainability has released a plan for zero waste, the Mayor is focused on doubling recycling rates and there is ongoing discussion about locating a public composting facility in the city. Actual clean, green energy sources like wind and solar provide more jobs than incineration, and are healthier choices for us and our planet. Similarly, zero waste jobs such as recycling and composting create five to ten times more jobs than incineration ever could. We need only to act: to stop subsidizing our fears and misinformation, put that money toward strengthening the zero waste infrastructure we already have, and to stand firm with the communities, human and animal, man-made and nature-made, with whom we share our most basic resource...the earth. Please support HB438/SB560. Thank you. EllenBarfield_FAV_SB560 Uploaded by: BARFIELD, ELLEN Position: FAV Testimony Supporting HB438 / SB560 House Economic Matters Committee / Senate Finance Committee February 20, 2020 / February 25, 2020 Position: SUPPORT As a resident of District 43 and a Maryland ratepayer, I am writing to express my VERY strong support for HB438/SB560 and the effort to remove trash incineration from Maryland’s Renewable Portfolio Standard. Burning trash is NOT clean energy, and Maryland’s renewable energy subsidies should ONLY be used to support TRULY green energy like wind, solar, geothermal, tidal, NOT trash incineration which pollutes our air. My beloved husband, a long-time and worsening asthma sufferer, died in June of 2016 of a heart attack while he was trying to use the asthma nebulizer he had had to use for the last few years as his breathing got worse. Mercury, particulates, ozone, all result from burning mixed trash. That is in NO WAY CLEAN. A Chesapeake Bay Foundation-commissioned study showed that over $55 million a year in adverse health effects are caused by fine particulates emitted by the BRESCO incinerator. Of course there is NO price which can be placed on my sorrow. That study also showed that living near the incinerator is like living with a smoker. Neither he nor I smoke or smoked, but we couldn't and can't help breathing the incinerator's foul emissions. Cells in our bodies damaged by pollution sadly don't have little flags showing what poison or poisons did the damage, but I have absolutely NO doubt the BRESCO incinerator contributed to my husband's death. For all of these reasons and many more, I STRONGLY urge the House Economic Matters Committee and Senate Finance Committee to support HB438/SB560 and END subsidies for trash incineration in Maryland. Thank you. Sincerely, Ellen E Barfield 814 Powers St Baltimore, MD 21211-2510 EmilyBryson_FAV_SB560 Uploaded by: BRYSON, EMILY Position: FAV Testimony Supporting HB438 / SB560 House Economic Matters Committee / Senate Finance Committee February 20, 2020 / February 25, 2020 Position: SUPPORT As a resident of Baltimore City and a Maryland ratepayer, I am writing to express my strong support of HB438/SB560 and the effort to remove trash incineration from Maryland’s Renewable Portfolio Standard.
Recommended publications
  • An Industry in Decline
    U.S. Municipal Solid Waste Incinerators: An Industry in Decline May 2019 Acknowledgements This report was prepared by Ana Isabel Baptista, PhD, and Adrienne Perovich, MPA, with assistance from Amanda Sachs, Anna Yulsman, Brandon Jordan, Claudia Rot, and Kevin Capuno, Research Assistants at the Tishman Environment and Design Center at The New School with support granted by Global Alliance for Incin- erator Alternatives (GAIA) in collaboration with Ahmina Maxey. Contributors to the report include Doun Moon, Aiko Fukichi, Claire Arkin, Denise Patel, and Monica Wilson at GAIA as well as Destiny Watford at United Workers, KT Andresky at Breathe Free Detroit, and Whitney Amaya at East Yard Communities for Environmental Justice. This report was produced with generous support from: The JPB Foundation The Overbrook Foundation For more information: tishmancenter.org thenewschool.edu no-burn.org About the Tishman Environment and Design Center The Tishman Environment and Design Center at The New School fosters the integration of bold design, policy, and social justice approaches to environmental issues to advance just and sustain- able outcomes in collaboration with communities. Tishmancenter.org Report Design: Claudia Rot and Anna Yulsman © Tishman Environment and Design Center 2019 Table of Contents Chapter 1: History of the Incineration Industry 7 Consumption, Waste Management and the Growth of the Incineration Industry: 1970s – 2000s 8 Incineration and Environmental Justice Communities 13 Chapter 2: Economic Indicators of Decline in the Incinerator Industry 18 Construction and Maintenance Costs 19 Life-Extension of Incinerators 22 Vulnerability in Revenue Stream 25 Closures and a Future in Decline 31 Chapter 3: Public Health and Community Impacts 33 Incineration Regulations and Public Health 34 Environmental Justice and Incinerator Health Risks 35 Existing Health Studies 35 Incinerators as Major Sources of Air Pollutants 37 Diesel Emissions from Waste Hauling to Incinerators 44 Conclusion 46 Endnotes 47 APPENDIX A: List of 73 MSW Incinerators in the U.S.
    [Show full text]
  • Epa Directs State of Maryland to Tighten Emission Limits and Monitoring for Baltimore Area Incinerator, Contributor to Chesapeake Bay Pollution
    EPA DIRECTS STATE OF MARYLAND TO TIGHTEN EMISSION LIMITS AND MONITORING FOR BALTIMORE AREA INCINERATOR, CONTRIBUTOR TO CHESAPEAKE BAY POLLUTION Federal Agency Finds that State Did Not Respond to Environmental Groups’ Concerns WASHINGTON, D.C.//April 19, 2010// The U.S. Environmental Protection Agency (EPA) ruled Friday that the Maryland Department of the Environment (MDE) acted improperly when it issued a Clean Air Act permit that relaxed short-term emission limits for the Wheelabrator incinerator in Baltimore, and failed to show that emissions of mercury and other pollutants would be accurately measured. The EPA action came about as a result of a petition filed with the federal regulator by the Environmental Integrity Project (EIP), Baltimore Harbor Waterkeeper, Clean Water Action (CWA), and Chesapeake Climate Action Network (CCAN) after the MDE ignored the groups’ concerns. Highly visible alongside the western I-95 approach to Baltimore, the Wheelabrator incinerator is a major source of nitrogen oxide (NOx) emissions, which contribute to smog and Chesapeake Bay pollution. When MDE proposed renewing the Clean Air Act operating permit for the facility, EIP, Baltimore Harbor Waterkeeper, and Clean Water Action submitted comments opposing increases in NOx emission limits, and asking for better monitoring of emissions of NOx, mercury, lead, particulate matter, dioxins, and hydrogen chloride as required by the Clean Air Act. When the state failed to revise the permit, the groups asked EPA to object, which the federal agency has a right to do under the Clean Air Act. The case is being closely watched not only for its Baltimore implications, but also because of plans for a new Wheelabrator incinerator in Frederick, Maryland.
    [Show full text]
  • September 21, 2018 Via E-Mail Mr. Randy Mosier Chief of The
    September 21, 2018 Via e-mail Mr. Randy Mosier Chief of the Regulation Division Air and Radiation Administration Department of the Environment 1800 Washington Boulevard, Suite 730 Baltimore, Maryland 21230-1720 [email protected] RE: Public Comments on Proposed Action on Regulation for Incinerator NOx Limits, COMAR 26.11.08 Dear Mr. Mosier: The Environmental Integrity Project (“EIP”) and the Chesapeake Bay Foundation (“CBF”) (collectively, “Commenters”) respectfully submit these comments on the Maryland Department of the Environment’s (“MDE’s”) Notice of Proposed Action for revising its air quality regulations at COMAR 26.11.08 (Control of Incinerators), as published in the Maryland Register on August 17, 2018.1 Commenters are appreciative of the effort that MDE has put into this rulemaking and the relatively transparent nature of the public stakeholder process. However, we do not believe that the proposed regulation lives up to MDE’s statement to the Baltimore Sun, as reported in July of 2017, that MDE would issue a “‘very tough, aggressive’ rule [for the Wheelabrator incinerator in Baltimore] that [will] force the plant to invest in technology to clean up its exhaust.”2 The NOx limits that take effect in 2019 and 2020 for this incinerator, also known as “BRESCO,” are based on optimizing its existing pollution control technology, and, as explained more fully in Section I below, Commenters think that the facility could achieve lower NOx limits than those proposed just by further optimizing the existing system. In addition, neither MDE nor Wheelabrator has 1 45:17 Md. R. 809-814 (Aug. 17, 2018).
    [Show full text]
  • Takoma Park Mobilization Environment Committee (TPMEC)
    Takoma Park Mobilization Environment Committee (TPMEC) [email protected] (email) ​ ​ Committee: Finance Testimony on: SB 0560 - “Renewable Energy Portfolio Standards -- Eligible Sources” Position: Favorable Hearing Date: February 25, 2020 Madame Chairwoman and Members of the Committee, Thank you for allowing our testimony today. The Takoma Park Mobilization Environment Committee (TPMEC), a grassroots organization of over 200 members and a member of two state-wide coalitions (Maryland Climate Coalition and the Earth Coalition) and the Montgomery County 80 x 27 Coalition (a county-wide group focused on aiding the county achieving its goal of reducing its greenhouse gas emissions by 80 per cent by 2027). TPMEC strongly urges you to support the proposed Act to remove incineration from the Renewable Portfolio Standards for three reasons: 1) burning trash is not clean; 2) burning trash is not healthy; and 3) the incinerators should not be subsidized by the lungs and lives of Marylanders. Burning Trash is Dirtier Than Coal ​ ​ Burning trash is not clean energy: to produce the same amount of energy, trash incinerators emit more greenhouse gases than coal plants do. Trash incinerators are the dirtiest way to make electricity by most air ​ pollution measures. Even with air pollution control equipment in place, trash incinerators emit more pollution than (largely uncontrolled) coal power plants per unit of energy produced. To produce the same amount of energy as coal power plants in Maryland, the Montgomery County incinerator -- operated by Covanta -- releases 15% more fine particulate matter, 60% more arsenic, 68% more greenhouse gasses, and 94% more nitrogen oxide (which triggers asthma), 3.5 times the amount of chromium, 11 times more lead, 21 times more cadmium, 26 times more mercury, and 50 times more hydrochloric acid.
    [Show full text]
  • Maryland Power Plants and the Environment (Ceir-19)
    PPRP – CEIR-19 DNR Publication No. 12-102920-260 Maryland Power Plants and the Environment A review of the impacts of power plants and transmission lines on Maryland's natural resources December 2017 Lawrence J. Hogan, Jr., Governor u Boyd K. Rutherford, Lt. Governor The Maryland Department of Natural Resources (DNR) seeks to preserve, protect and enhance the living resources of the state. Working in partnership with the citizens of Maryland, this worthwhile goal will become a reality. This publication provides information that will increase your understanding of how DNR strives to reach that goal through its many diverse programs. Mark J. Belton, Secretary Maryland Department of Natural Resources The facilities and services of the Maryland Department of Natural Resources are available to all without regard to race, color, religion, sex, sexual orientation, age, national origin or physical or mental disability. This document is available in alternative format upon request from a qualified individual with a disability. Maryland Department of Natural Resources Tawes State Office Building 580 Taylor Avenue Annapolis, Maryland 21401-2397 Toll Free in Maryland: 1-877-620-8DNR x8660 Outside Maryland: 1-410-260-8660 TTY users call via the Maryland Relay www.dnr.maryland.gov Printed on Recycled Paper PPRP – CEIR – 19 DNR Publication No. 12-102920-260 Maryland Power Plants and the Environment A review of the impacts of power plants and transmission lines on Maryland's natural resources December 2017 MARYLAND POWER PLANTS AND THE ENVIRONMENT (CEIR-19) Table of Contents Chapter 1 – Background ............................................................................................................................. 1 1.1 The Role of PPRP ............................................................................................................................. 2 1.2 Power Plant and Transmission Line Licensing ................................................................................
    [Show full text]
  • 1 May 11, 2018 Via E-Mail George (Tad) Aburn Director Air & Radiation Administrations Maryland Department of the Environmen
    May 11, 2018 Via e-mail George (Tad) Aburn Director Air & Radiation Administrations Maryland Department of the Environment 1800 Washington Boulevard Baltimore, MD 21230 [email protected] RE: Maryland Rulemaking for Limits for Nitrogen Oxides Emissions from Large Municipal Waste Combustors Dear Mr. Aburn: The Environmental Integrity Project (“EIP”) and the Chesapeake Bay Foundation (“CBF”) (collectively “Commenters”) respectfully submit these comments on the new regulation limiting emissions of nitrogen oxides (“NOx”) from large municipal waste combustors (“MWCs” or “incinerators”) that the Maryland Department of the Environment (“MDE”) has been considering. MDE started holding public stakeholder meetings in August 2016 on this new regulation and, according to the information presented at the December 11, 2017 meeting of MDE’s advisory board on air regulations – the Air Quality Control Advisory Council (“AQCAC”) - MDE intends to formally issue a proposed rule for public comment in the Maryland Register in May of 2018.1 Introduction Commenters appreciate the time that MDE’s staff has put into this rulemaking and the relatively transparent nature of the public stakeholder process that MDE has held as it considered the rule. During public stakeholder meetings, MDE has provided significant information to interested stakeholders about the legal standards involved, the affected facilities, the emission limits that the agency has considered at different stages of the process, and the basis for those limits. MDE has also made important information, including stakeholder presentations and audio recordings of stakeholder meetings, accessible to the public on its website. In addition, we 1 MDE PowerPoint, NOx RACT for Municipal Waste Combustors (MWCs), AQCAC Meeting - December 11, 2017, at http://mde.maryland.gov/programs/workwithmde/Documents/AQCACMWCNOxRACT121117.pdf.
    [Show full text]
  • Dirty Decade Report (2007)
    Dirty Decade A Look at 10-Years of the Dirty Dozen Awards Toxics Action Center November 2007 1 Acknowledgements We would like to thank all of the Dirty Dozen Award selection committee members over the last decade for their assistance in choosing the sites to recognize. We would also like to thank the community members who nominated sites selected to receive Dirty Dozen Awards. For 20 years, Toxics Action Center has assisted residents and community groups across New England to address toxic pollution issues. For more information about Toxics Action Center, please contact our offices at the number below or online at www.toxicsaction.org. Eastern Massachusetts Office Connecticut Office 44 Winter Street, 4th floor 198 Park Road, 2nd floor Boston, MA 02108 West Hartford, CT 06119 Phone: (617) 292-4821 Phone: (860) 233-7623 Fax: (617)292-8057 New Hampshire Office Western Massachusetts Office 30 S. Main Street, Suite 301-B 233 N. Pleasant Street, Suite 32 Concord, NH 03301 Amherst, MA 01002 Phone: (603) 229-1331 Phone: (413) 253-4458 Fax: (603) 229-3221 Fax: (413) 256-6435 Rhode Island Office Maine Office 11 South Angell Street #337 39 Exchange Street, Suite 301 Providence, RI 02906 Portland, Maine 04101 Phone: (401) 421-0007 Phone: (207) 871-1810 Fax: (401) 331-5266 Fax: (207) 253-1966 Vermont Office 141 Main St., Suite 6 Montpelier, VT 05602 Phone: (802) 223-8422 Fax: (802) 223-6855 2 Table of Contents Acknowledgements……………………………………………………………………………...2 Table of Contents………………………………………………………………………………..3 Introduction……………………………………………………………………………………...4
    [Show full text]
  • Order Partially Granting and Denying the Petition for Objection to The
    BEFORE THE ADMINISTRATOR UNITED STATES ENVIRONMENTAL PROTECTION AGENCY ) IN THE MATTER OF: ) WHEELABRATOR BALTIMORE, L.P. ) BALTIMORE, MARYLAND ) ORDER RESPONDING TO ) PETITIONERS' REQUEST THAT ) THE ADMINISTRATOR OBJECT Permit Number 24-5 10-01 886 ) TO THE ISSUANCE OF A ) TITLE V OPERATING PERMIT ISSUED BY MARYLAND DEPARTMENT OF ) THE ENVIRONMENT ) JUNE I, 2009 ) ORDER PARTIALLY GRANTING AND PARTIALLY DENYING THE PETITION FOR OBJECTION TO PERMIT I. INTRODUCTION On May 29, 2009, the United States Environmental Protection Agency (EPA) received a petition from Environmentallntegrity Project (EIP), the Baltimore Harbor Waterkeeper, Inc., and Clean Water Action (petitioners) pursuant to section 505(b)(2) of the Clean Air Act (CAA or Act), 42 U.S.C. § 766 Jd(b)(2). The petition requests that EPA object to the CAA title V operating permit (the title V pennit) issued by the Maryland Department of the Environment (MDE) on June I, 2009, to Wheelabrator Baltimore, L.P. (Wheelabrator) for the operation of a municipal solid waste incinerator located at 1801 Annapolis Road, Baltimore, Maryland 21230. As discussed in greater detail below, the Petitioners allege that (I) the title V permit 1 illegally weakens the PSD pounds per hour limits for CO and N02 by allowing Wheelabrator to demonstrate compliance with a 24-hour rolling average and (2) the title V permit fails to include monitoring sufficient to assure compliance with short-term emission limits because (a) it does not specify the methodology for demonstrating compliance with the PSD pounds per hour limits for sulfur dioxide (S02), carbon monoxide (CO), and nitrogen dioxide (N02) and (b) it fails to include adequate monitoring for short-term emissions limits for particulate matter (PM), mercury, cadmium, lead, hydrogen chloride, and dioxins/furans.
    [Show full text]
  • 1 Testimony Supporting SB560 Senate Finance Committee
    Testimony Supporting SB560 Senate Finance Committee February 25, 2020 Written testimony to the Finance Committee in support of SB 560 provided by the Environmental Integrity Project. The Environmental Integrity Project supports SB 560 because burning trash does not produce clean or renewable energy. There are two trash-burning incinerators, sometimes called waste-to-energy (WTE) incinerators, that operate within the State of Maryland: the Wheelabrator incinerator in Baltimore City and the Montgomery County Resource Recovery Facility (MCRRF) in Montgomery County. Currently, Maryland classifies these incinerators as Tier-1 renewable energy sources under its Renewable Portfolio Standard (RPS), which should not be allowed. Trash incinerators typically emit more air pollution per unit of energy (measured in megawatt hours (MWh)) for many harmful pollutants than coal-fired power plants. Incinerator emissions include pollutants like mercury and lead that disproportionately harm children, are harmful even in small doses and bioaccumulate over time. In 2018, Maryland’s two incinerators emitted, on average, seventeen (17) times more of the neurotoxin mercury per unit of energy than Maryland’s four largest coal plants: Chalk Point, Morgantown, Brandon Shores, and Herbert A Wagner. In addition to mercury, the incinerators emitted on average five times as much nitrogen oxides (NOx) per unit of energy as those coal plants. NOx is the primary pollutant that causes ground-level ozone to form, and parts of Maryland do not meet federal air quality standards for ozone.1 Our analysis also showed that the incinerators emitted two times as much carbon monoxide per unit of energy generated than the previously mentioned coal-fired power plants.
    [Show full text]
  • Aburn Director Air & Radiation Management Administration
    1000 Vermont Avenue, NW Suite 1100 Washington, DC 20005 Main: 202-296-8800 Fax: 202-296-8822 www.environmentalintegrity.org May 9, 2017 Via E-mail George (Tad) Aburn Director Air & Radiation Management Administration Maryland Department of the Environment 1800 Washington Boulevard Baltimore, MD 21230 [email protected] RE: Public Stakeholder Process for Setting Reasonably Available Control Technology Limits for Nitrogen Oxides Emissions from Large Municipal Waste Combustors Dear Mr. Aburn: The Environmental Integrity Project (“EIP”) submits the following comments as part of the public stakeholder process on the Maryland Department of the Environment’s (“MDE’s”) development of new Reasonably Available Control Technology (“RACT”) limits for the pollutant nitrogen oxides (“NOx”) from Maryland’s two large municipal waste combustors (“incinerators”). Time constraints prevented us from sending these comments to the environmental, health, and community groups that signed onto EIP’s October 26, 2017 letter regarding this rulemaking. However, we expect that these groups will adopt this set of comments, or similar comments, in the future. We know that our partner groups remain very concerned about the emissions from the Baltimore Resource Energy Systems Company (“BRESCO”) incinerator operated by Wheelabrator Baltimore, L.P. and committed to participating in this rulemaking process. The NOx emissions from the BRESCO incinerator are extremely high for the amount of energy and steam that is produced by this plant. EIP is concerned about the health impacts of these emissions, discussed in more detail below, on residents living in the area immediately surrounding the incinerator and elsewhere in the Baltimore area. It is critical that MDE require significant NOx reductions at this facility.
    [Show full text]
  • September 21, 2018 Via E-Mail Mr. Randy Mosier Chief of the Regulation Division Air and Radiation Administration Department O
    September 21, 2018 Via e-mail Mr. Randy Mosier Chief of the Regulation Division Air and Radiation Administration Department of the Environment 1800 Washington Boulevard, Suite 730 Baltimore, Maryland 21230-1720 [email protected] RE: Public Comments on Proposed Action on Regulation for Incinerator NOx Limits, COMAR 26.11.08 Dear Mr. Mosier: The Environmental Integrity Project (“EIP”) and the Chesapeake Bay Foundation (“CBF”) (collectively, “Commenters”) respectfully submit these comments on the Maryland Department of the Environment’s (“MDE’s”) Notice of Proposed Action for revising its air quality regulations at COMAR 26.11.08 (Control of Incinerators), as published in the Maryland Register on August 17, 2018.1 Commenters are appreciative of the effort that MDE has put into this rulemaking and the relatively transparent nature of the public stakeholder process. However, we do not believe that the proposed regulation lives up to MDE’s statement to the Baltimore Sun, as reported in July of 2017, that MDE would issue a “‘very tough, aggressive’ rule [for the Wheelabrator incinerator in Baltimore] that [will] force the plant to invest in technology to clean up its exhaust.”2 The NOx limits that take effect in 2019 and 2020 for this incinerator, also known as “BRESCO,” are based on optimizing its existing pollution control technology, and, as explained more fully in Section I below, Commenters think that the facility could achieve lower NOx limits than those proposed just by further optimizing the existing system. In addition, neither MDE nor Wheelabrator has 1 45:17 Md. R. 809-814 (Aug. 17, 2018).
    [Show full text]
  • ILSR Waste Incineration
    WASTE INCINERATION: A DIRTY SECRET IN HOW STATES DEFINE RENEWABLE ENERGY Marie Donahue December 2018 ACKNOWLEDGEMENTS Thanks to John Farrell, Neil Seldman, Mike Ewall, and Hibba Meraay for their thoughtful review and patience as this report was written. All errors are my own. Marie Donahue, [email protected] RELATED ILSR PUBLICATIONS Reverse Power Flow: How Solar + Batteries Shift Electric Grid Decision Making from Utilities to Consumers John Farrell, July 2018 Mergers and Monopoly: How Concentration Changes the Electricity Business John Farrell & Karlee Weinmann, October 2017 Choosing the Electric Avenue – Unlocking Savings, Emissions Reductions, and Community Benefits of Electric Vehicles John Farrell & Karlee Weinmann, June 2017 OTHER RECENT ILSR PUBLICATIONS Profiles of Monopoly: Big Cable & Telecom Hannah Trostle and Christopher Mitchell, July 2018 Amazon’s Next Frontier: Your City’s Purchasing Stacy Mitchell and Olivia LaVecchia, July 2018 Yes! In My Backyard: A Home Composting Guide for Local Government Brenda Platt, May 2018 Cover photo credit: takomabibelot via Flickr (CC 2.0) Since 1974, the Institute for Local Self-Reliance (ILSR) has worked with citizen groups, governments and private businesses to extract the maximum value from local resources. Non-commercial re-use permissible with attribution (no derivative works), 2018 by the Institute for Local Self-Reliance. Permission is granted under a Creative Commons license to replicate and distribute this report freely for noncommercial purposes. To view a copy of this license, visit http://creativecommons.org/licenses/by-nc-nd/3.0/ P A G E 2 ACKNOWLEDGEMENTS WWW.ILSR.ORG EXECUTIVE SUMMARY Burning garbage to generate power is neither clean nor renewable.
    [Show full text]