Good Morning, by 9h9O9MR


Boston, MA December 9, 2008

Comments of: David Minott, CCM, QEP
             Environmental Resources Management (ERM)
             Boston, MA

Good Morning,

My name is Dave Minott and I am with the consulting firm, Environmental Resources
Management, ERM. I’m an air quality meteorologist by training and have focused for the
past 25 years in solid waste management and biomass energy.

First off, I concur strongly with DEP’s goals for achieving much greater success in waste
reduction, recycling, and composting. In terms of personal commitment, I established
the curbside recycling program in my community of residence and managed it for many

My comments this morning are directed to two of the nine questions that DEP has asked
us to consider for this forum:

The first question is: How effective is the waste combustion moratorium at meeting our
goals? The answer is clear – the combustion moratorium has failed to promote
increased recycling in Massachusetts. I’ll speak further to this in a moment.

The second question is: How can we get the most value from the materials that cannot
be recycled or reused? In my view, that is a fundamental question, and the answer is
straightforward: lift the moratorium on waste-to-energy.

I was an active stakeholder participant in the process nearly 20 years ago by which the
moratorium policy was first developed and implemented. There were two primary
rationales cited at the time for implementation of the moratorium:
 The first was concern that waste-to-energy would compete with recycling, thereby
    discouraging achievement of a high recycling rate in Massachusetts.
 The second concern was over emissions of dioxin and mercury.

Now, let’s fast-forward 20 years, and consider what has happened in the interim and
what have we learned.

First, the modern waste-to-energy facilities of today control emissions of dioxin and
mercury to minor fractions of what they were 20 years ago, and pose no significant risk
to either our health or the environment. EPA has explicitly recognized this dramatic
evolution, and accordingly, has moved its regulatory focus for mercury abatement onto
other types of emissions sources.

Another important lesson learned over the past 20 years is that the moratorium failed as
a strategy for promoting recycling in Massachusetts. In retrospect, trying to achieve a
high recycling rate by banning waste-to-energy was a bit like trying to eliminate all
disease in Massachusetts simply by closing our hospitals. We now know that waste-to-
energy and recycling are complements, not enemies. That is, it is well-demonstrated
nationally that states which rely on waste-to-energy also tend to have higher-than-
average recycling rates. A compelling example is Minnesota. Clearly, most would agree
that Minnesota, like Massachusetts, has a reputation for being a politically progressive
state. Minnesota has one of the highest recycling rates in the country, nearly 50%. At
the same time, Minnesota, by policy, strongly encourages waste-to-energy. Existing
energy recovery plants in Minnesota have recently expanded, and planning for new,
greenfield waste-to-energy facilities has been undertaken in several counties there, with
the aid of state grant monies. Contrast Minnesota, which has a 49% recycling rate and
actively promotes waste-to-energy, with Massachusetts that has a 35% recycling rate
and has banned energy recovery for two decades.

The third lesson learned over the past 20 years is that, due in large part to the
moratorium on waste-to-energy, the amount of solid waste that Massachusetts exports
for disposal has climbed dramatically. This creates a mounting environmental burden
from transportation emissions and also from greenhouse gas emissions that occur when
our exported waste is landfilled. Much of the environmental burden from exporting our
waste for disposal has its impact in someone else’s back yard. Accordingly, wouldn’t it
be fair to suggest that this reflects a measure of hypocrisy on our part, and perhaps even
a hint of elitism?

The overarching objective of the solid waste plan should be to minimize the amount of
waste that is landfilled, especially degradable waste that causes landfill gas emissions.
That is the law for European Union nations, and it is the objective of the State of
Minnesota. Europe and Minnesota have achieved recycling rates far greater than has
Massachusetts, while embracing waste-to-energy. We should learn from and emulate
the solid waste management policies of Europe and Minnesota, namely:
 First, maximize waste reduction, recycling, and composting,
 And then second, recover valuable energy from the remaining waste, which at the
   same time, minimizes the amount of untreated waste that must be landfilled.

The time has come for DEP and Governor Patrick to lift the moratorium and allow those
waste-to-energy projects to proceed that can pass the rigorous environmental reviews
required in Massachusetts under MEPA rules and DEP permitting regulations. In lifting
the moratorium, however, DEP should avoid any temptation to micro-manage by
deeming some waste-to-energy technologies acceptable and others not. Both modern
combustion technology and the latest technology advancements such as gasification are
demonstrated to operate without adverse environmental impact. Accordingly,
technology acceptability should be based on the ability to meet environmental
performance requirements under DEP permitting rules, and following that, on factors that
are locally determined such as technology preferences and economics.

I greatly appreciate the opportunity you have given me this morning to provide input to
DEP on these important policy issues.


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