To: John Fischer, Mass Dept of Environmental Protection and Governor Charlie Baker

Keep The Incinerator Moratorium in Massachusetts

Do not lift the moratorium on incinerators in Massachusetts as long as there are far better alternatives to incineration.

Why is this important?

From 10 Reasons Why Gasification, Pyrolysis & Plasma Incineration are Not "Green Solutions" www.no-burn.org/downloads/BlowingSmokeReport.pdf

The core impacts of all types of incinerators remain the same: they are toxic to public health, harmful to the economy, environment and climate, and undermine recycling and waste reduction programs.

In the Tellus Report, commissioned by the Commonwealth and posted on its web site, there is all the necessary information on why the moratorium should not be lifted. Not only did Massachusetts commission this report, but the link takes you to the report posted on the Massachusetts web site. www.mass.gov/dep/recycle/priorities/tellusmmr.pdf

From a lifecycle environmental emissions and energy perspective, source reduction, recycling and composting are the most advantageous management options for all (recyclable/compostable) materials in the waste stream.
From a lifecycle environmental emissions and energy perspective, source reduction, recycling and composting are the most advantageous management options for all (recyclable/compostable) materials in the waste stream.
Several factors lead us to conclude that gasification and pyrolysis facilities are unlikely to play a major role in MSW management in Massachusetts by 2020. Key issues informing this conclusion include: the lack of experience in the U.S. with large-scale alternative technology facilities successfully processing mixed MSW and generating energy; the long lead times to plan, site, construct, and permit such facilities; the significant capital costs required and the loss of solid waste management flexibility that is associated with the long-term contractual arrangements that such capital-intensive facilities require; and the relatively small benefit with respect to greenhouse gas emissions compared to diversion or landfilling.
The prospects for anaerobic digestion facilities appear to be more favorable given the extensive experience with such facilities in the U.S. for the processing of sewage sludge and farm waste and the fact that no significant human health or Materials Management Options for MA Solid Waste Master Plan Review Final Report 2 environmental impacts have been cited in the literature.
From a life-cycle net energy perspective, waste diversion through recycling provides the most benefit, saving an estimated 2,250 kWh per ton of solid waste.
In considering potential sources of energy to meet the Commonwealth’s electricity needs, if 100% of MSW currently landfilled or exported (about 3.5 million tons) were processed by pyrolysis facilities, the maximum potential electricity production would be 2.3 million MWh per year or about 4% of the state’s 2005 electricity consumption.
For both pollutant and energy impacts, the scenario analysis points to the significant benefits of broadening and strengthening the Commonwealth’s recycling and composting diversion programs and the modest additional benefits associated with shifting non-C&D MSW from landfills to new thermal processing facilities.

Given the minimal benefits and large hazards of incinerators, the department that commissioned this report owes us all an explanation of why they would take action that is contrary to the technical, environmental, and economic information that they already have at their disposal.

Until such explanation is forthcoming, the moratorium should remain or perhaps be turned into a permanent ban.