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Incinerator Alternatives* Grassroots Recycling Network * Greenwich Citizens Committee * Hopewell Junction Citizens for Clean Water * Institute for Local Self-Reliance * New York Public Interest Research Group * Real Majority Project of the Hudson Valley
August 2, 2010 Tara Stickles Office of the Town Clerk Town of Montgomery 110 Bracken Road Montgomery, New York 12549 firstname.lastname@example.org Charles T. Bazydlo, Esq. Attorney to Town Board of Town of Montgomery Law Office of Charles T. Bazydlo 5 Howard Seely Road Thompson Ridge, NY 10985 email@example.com Re: Taylor Biomass Gasification Draft Environmental Impact Statement Dear Ms. Stickles and Mr. Bazydlo, We are writing to express our serious concern about this ill-advised, polluting project. We believe the Town Board should not allow this DEIS to move forward in the absence of the complete permit review by the DEC. It is our understanding that the DEC requested additional information from the applicant for these permits in December 2009, which has not yet been received by DEC Region 3. The DEIS contains an air permit application and a solid waste permit application that are obviously incomplete if the DEC is seeking more information. As a result any public or Town Board review of this application will be missing adequate technical detail to reach any reasoned conclusion about this project. Under SEQRA, the town should not act in the absence of necessary supporting technical information, and for that they must wait for DEC to act. Given the late date that we learned about this DEIS, we are listing for the Town Board’s review the numerous serious problems with this proposal and provide supporting documents that discuss some of the history of these newer versions of solid waste incinerators-- gasification, pyrolysis and plasma arc. A large number of these facilities
have been defeated across the country once public officials have been confronted with the facts instead of the representations of the vendor. • There are currently no commercially operated facilities in the US using gasification technology for solid waste. These facilities have not succeeded in the free market on their own, and it is doubtful that they are commercially viable without substantial government subsidies. The Taylor proposal is completely experimental. No one has done this before at this scale and Taylor has no experience at all with this kind of combustion facility. Taylor’s DEIS states that “the purpose of this project is to demonstrate that the Taylor MSW gasification can be commercially viable at a scale of 500 TPD MSW and approximately 24 MW of electricity.” P.1-29 It should be in the interest of the Town of Montgomery and the public to expect and require much more –- proven technology with good emissions data and demonstrated experience for the operator. The proposal is being advanced as renewable energy. However the majority of the waste to be burned is municipal solid waste (MSW) and construction and demolition debris, neither of which are considered renewable energy in NY State. In terms of waste more energy is obtained from zero waste strategies including waste reduction, reuse, recycling and composting/anaerobic digestion. Incineration is not a solution to global warming; recycling alone saves 3-5 times the energy incineration recovers. Per unit of electric energy incineration puts out 30% more CO2 than a coal plant. The DEIS claims implausibly low air emissions for hazardous air pollutants and particulate emissions. This is largely because the DEIS uses emissions data from natural gas combustion. This is not a natural gas plant; it is going to be burning large quantities of mixed solid waste and potentially contaminated C&D materials. Regulators have in general determined that gasification facilities have an emissions profile similar to MSW incinerators. The input to the gasifier shows that only 100 TPD of relatively clean wood waste will be going into this process – less than 10% of the waste input (500 TPD MSW, 450 TPD C & D, construction and demolition debris, and 100 TPD unadulterated wood waste). Both MSW and C&D debris are heterogeneous mixtures containing toxic constituents and plastics. Dioxin is one of the most toxic substances emitted, and is formed when PVC plastics and wood products are burned together. Treated and painted wood can be contaminated with arsenic, chromium, pentachlorophenol and other toxic substances. 2
There are very good markets for most C&D debris and for clean wood waste. The real problem lies with contaminated wood and other materials for which there are no markets. As a result there will be a financial incentive to burn increasing amounts of contaminated materials.
It should be noted that following a Tellus Institute review of these newer types of incinerator technologies—gasification, pyrolysis and plasma arc—that the Massachusetts DEP decided to extend their moratorium on incinerators. We wish to leave you with a brief history of a gasification facility that was operated in Germany. A major German energy company contracted for two gasification facilities from Thermoselect. Its operation was so plagued by problems that the town and press referred to it as the Thermo Defect facility. It operated commercially from 2002-2004. Finally it had a major release of toxic emissions from an emission point that had never been disclosed to regulators. The German energy company cancelled further dealings with Thermoselect after losing $500 million. The facility was only able to process 1/5 of the waste it contracted for and despite using additional natural gas for one year produced no electricity to the grid. The facility had excessive dioxin and other hazardous emissions. As you are probably aware the state budget situation is dire. You may be less aware of how seriously budget cuts have impacted the Department of Environmental Conservation and its already limited staffing from years of cuts during the Pataki administration. The Town may have the idea that it can rely on DEC to monitor and oversee problems at any difficult facility. We caution the Town against reliance on DEC for this kind of truly experimental facility. We have attached a full 2009 report, An Industry Blowing Smoke, that discusses the problems with these newer incinerators. An earlier report, Incinerators in Disguise, clarified the similarities between these newer thermal treatments and incinerators. In addition we include the New Yorkers for Zero Waste Platform, which calls for a moratorium on incineration, like that in Massachusetts. Please note the large numbers of national, statewide and local groups that are supporting that platform. A factsheet from another report, Stop Trashing the Climate, is also included. Sincerely,
Barbara Warren, Executive Director Citizens’ Environmental Coalition www.cectoxic.org 845-754-7951 H
Paul Connett PhD, Director Ellen Connett, Former Waste Not editor American Environmental Health Studies Project www.Americanhealthstudies.org Margaret Sheehan, Attorney at Law Biomass Accountability Project www.nobiomassburning.org Sam Tesh, President Citizens' Alliance for a Clean,Healthy Economy Kathy A. Curtis, Policy Director Clean NY Ananda Tan, Coordinator US & Canada Global Alliance for Incinerator Alternatives www.no-burn.org Gretchen Brewer, Director Grassroots Recycling Network www.grrn.org Tracy Frisch, President Greenwich Citizens Committee Debra Hall, Founder Hopewell Junction Citizens for Clean Water Neil Seldman, President Institute for Local Self-Reliance www.ilsr.org Laura Haight Senior Environmental Associate New York Public Interest Research Group Joel Tyner, Founder Real Majority Project of the Hudson Valley Attachments: An Industry Blowing Smoke, Report New Yorkers for Zero Waste Platform
Stop Trashing the Climate Factsheet