CitizenConcernswithWastetoEnergyIncinerators

APresentationtotheCanadianInstituteConferenceon

Waste‐BasedEnergy

ByJohnJackson

GreatLakesUnitedandCitizens’NetworkonWasteManagement

jjackson@glu.org

November23,2009MypresentationwillbebaseduponfactsheetscompiledbytheDavidSuzukiFoundation,SierraLegal(Ecojustice),PembinaInstitute,CanadianEnvironmentalLawAssociation,GreatLakesUnited,andtheTorontoEnvironmentalAlliance.Thesecovertheissuesoftheimpactofwastetoenergyincineratorsonglobalwarming,pollutionconcerns,thereasonablenessoftheseasanenergyoption,andunderstandingthecostsandfinancialrisksofbuildingincinerators.Thesefactsheetsareattached.

Incineration of Municipal Solid Waste Impact on Global Warming

Fact Sheet 1

Municipalities across North America are struggling with complex decisions around long term waste disposal planning. Decades of experience with various disposal options offers a sound set of data from which to measure their environmental impacts. Traditional landfilling for example, releases methane gas which has a significant impact on climate change. Recently, incineration of municipal solid waste has been receiving alot of attention, with new and improved technologies with claims of a significantly reduced pollution profile. This fact sheet aims to clarify questions relating to traditional and newer disposal methods for municipal solid waste and their impact on climate change in terms of the release of greenhouse gases (GHGs). How does incineration as an electricity producer rate against other sources of electricity in terms of their impact on climate change? When we compare energy producing technologies used in Ontario, incineration contributes the greatest amount of greenhouse gas emissions (see chart on right1). Compared to coal fired technology, combustion or “mass-burn” technology contributes about 33% more GHGs, and gasification emits 90% more GHG emissions per kwh of electricity produced. This is especially relevant in the context of Ontario’s energy policy. In 2005, the Provincial government announced an aggressive plan to replace coal-fired generation with cleaner sources of energy and conservation. The Minister of Energy at the time stated, “We are leading the way as the first jurisdiction in North America to put the environment and health of our citizens first by saying ‘no’ to coal…It's a prudent and responsible path that will ensure cleaner air for the province.” Doesn’t the electricity from incineration mean avoiding having to use electricity from another sources like coal, which results in an overall greater reduction in greenhouse gas emissions? This may be accurate in many countries, but in Ontario, very little of our electricity is generated using high greenhouse gas emission technologies like coal or oil fired generation. More specifically, today only 21% of our electricity production is dirty production in terms of GHGs.

Greenhouse Gas Emissions in grams per Kwh of electricity produced

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Gasification Coal Fired Natural Gas(Combined

Cycle)

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gram

s/Kw

h

By 2025, this amount will be reduced to 14%, and it is anticipated that even these remaining producers will be using cleaner burning technologies. Isn’t incineration the most climate friendly method of waste management? Reduction, reuse and recycling of materials have the smallest impact on climate change compared to any form of disposal. Recycling actually avoids the release of greenhouse gas emissions, because using recycled feedstock as a raw material to manufacturer new goods avoids the use of a lot of energy and related emissions associated with raw material extraction processes. (See chart at right2) Isn’t incineration the most climate friendly method of disposal? Comparisons3 of disposal options in terms of their contribution to climate change generally includes an “offset” which assumes that for every kwh of electricity generated from that option, a kwh of electricity from traditional sources (like coal or natural gas) is not required. The results show that traditional landfill with a 75% methane recovery rate has a similar impact to traditional incineration that produces electricity. In terms of energy efficiency, an electricity-only thermal plant is also about 60% less efficient than a thermal plant generating heat in terms of energy output. Newer, non-thermal technologies have a smaller impact on climate change, which include up-front material extraction, followed by a stabilized landfill. What is a ‘stabilized’ landfill? The stabilized landfill provides initial screening of waste to be landfilled to remove materials that should not be landfilled like recyclables, compostables, household special wastes, electronics etc. This significantly reduces quantity requiring landfill disposal. With a cleaner stream of waste going to landfill, vector problems like vermin and birds are reduced, along with methane gas and

Material

Avoided GHGs from recycling

(eCO2/tonne)

Net GHGs from

Incineration (eCO2/tonne)

Newsprint (0.30) (0.05) Fine Paper (0.36) (0.04) Cardboard (0.21) (0.04) Other Paper (0.25) (0.04)

HDPE (2.27) 2.85

PET (3.63) 2.13

Other Plastic (1.80) 2.63

Comparing GHG Emissions from Disposal Options

$-

$10.00

$20.00

$30.00

$40.00

$50.00

$60.00

$70.00

Combustion- Mass-burn

electricity

Landfill with75%

methanerecovery

Landfill with50%

methanerecovery

Landfill with25%

methanerecovery

Aerobicmechanicaltreatment,

stabilization

Aerobicmechanicaltreatment,RDF to

cement kiln

Dam

age

cost

s as

socia

ted

with

GH

G E

miss

ions

an

d of

fset

s in

$/t

onne

The latest scheme masquerading as a rational and responsible alternative to landfills is a nationwide – and worldwide – move to drastically increase the use of incineration… The principal consequence of incineration is thus the transporting of the community’s garbage – in gaseous form, through the air – to neighbouring communities, across state lines, and indeed, to the atmosphere of the entire globe, where it will linger for many years to come. In effect, we have discovered yet another group of powerless people upon whom we can dump the consequences of our own waste; those who live in the future and cannot hold us accountable. Then US Senator Al Gore, 1992

leachate. The waste is then composted through anaerobic digestion and its biogas is recovered and used for energy. In summary As we move forward and plan for the next 20 years, reducing our impact on climate change is the essential. Irrespective of how you analyze the data, we know that incineration technologies are bad for climate change. We must focus our efforts and spending on improving diversion and maximizing recycling of those materials that required significant amounts of energy to be produced in the first place. By recycling these materials instead of burning them, we can maximize our efforts to conserve energy and reduce our impact on climate change at the same time.

ENDNOTES 1Data sources: Coal: Ontario MOE – OnAIR Annual Report 2002; Natural Gas: US EPA – Fifth edition Compilation of Air Emission Factors Volume 1. Mass-burn and gasification data from Niagara Region/City of Hamilton’s EA — Wasteplan — Appendix C — Air Emissions from Thermal Technologies. 2 Determination of the Impact of Waste Management Activities on Greenhouse Gas Emissions: 2005 Update Final Report, ICF Consulting October 31, 2005, submitted to Environment Canada and Natural Resources Canada 3A Changing Climate for Energy from Waste?, Final report for Friends of the Earth, Eunomia 03/05/2006

Incineration of Municipal Solid Waste An Update on Pollution

Fact Sheet 2

Lately, the news media has been inundated with claims that incineration and other combustion-based waste treatment technologies are cleaner now than in the past and that they should be considered for both waste disposal and the generation of electricity. The objective of this fact sheet is to provide decision makers and the public with information about direct and indirect pollution releases from waste combustion technologies, including modern mass-burn incinerators as well as gasification and pyrolysis systems. Aren’t new technologies like “gasification”, “pyrolysis” and “plasma arc” much cleaner than traditional mass burn incineration technologies? Many who promote these technologies claim that they are less polluting than traditional mass burn technologies, but have not provided verifiable evidence to support these claims. As a consequence, proposals are often withdrawn1. Only a very few full-scale gasification, pyrolysis or plasma arc plants currently operating. Most proponent companies are promoting the concept or extrapolating from very small facilities to the large-scale plants that they are proposing to build. In this regard, the promise of gasification has not been matched by the reality of the operations of the technology. For example, Thermoselect’s MSW gasification plant in Karlsruhe, Germany, began trials in 1999 and full-scale operation in 2002. This plant was permanently closed at the end of 2004 due to technical and financial difficulties. By the time it closed in 2004 it had lost over US$500 million..2 What kind of pollution profile for these technologies? The US Environmental Protection Agency (USEPA) has collected data describing the concentrations of selected pollutants in the stack gas of gasification plants and traditional mass-burn facilities. These data indicate that gasification units emit more nitrogen oxides and dioxins than traditional incineration facilities, and equal amounts of mercury.3 Aren’t mass burn incineration technologies much cleaner than in the past? No doubt, municipal waste incineration has improved in facility design, construction and operation over the years. Nonetheless, even the most modern, state-of-the-art MSW incinerator releases toxic pollutants in its stack gases and residues. Some of the pollutants, such as dioxins and similar chemicals, are not only highly toxic but also persistent and bioaccumulative. Those released in stack gases are available for inhalation. They travel through the air and deposit on soils, surface waters and vegetation, entering the food web, where they bioaccumulate and biomagnify so that food, especially fish and animal products, become the primary route of human exposure. Dioxins and similar pollutants as well as volatile metals are concentrated in fly ash and residues of air pollution control residues while less volatile metals are concentrated in the bottom ash. Fly ash and bottom ash, which represent about 25 percent of the original weight of the waste combusted, are commonly sent to special landfills, hazardous waste landfills and/or conventional landfills. Scrubber water also requires treatment, and fugitive emissions will also find their way into the natural environment.4

In general, there are a handful of toxins including dioxin 2,3,7,8-TCDD – the most dangerous toxin know to man – that are widely known as the residual pollution from incinerating municipal solid waste. These include: dioxins, particulate matter, arsenic, beryllium, cadmium, chromium, lead, mercury, acidic gases, and polyaromatic hydrocarbons. 5 The most serious environmental and human health concern is from burning plastics such as vinyl (PVC - #3), which contain significant amounts of chlorine. This results in the production of hydrochloric acid and chlorinated chemicals such as chlorinated benzenes and polychlorinated dioxins and furans. 6 This is especially relevant in the Canadian context, because in 2001, our Federal government signed onto the Stockholm Convention on Persistent Organic Pollutants, which clearly states that authorities are obligated to give priority consideration to waste management methods that "avoid the formation and release" of dioxins.7 In addition to the six metals previously listed, 19 other metals have been identified in the wastes sent to incineration facilities or in their stack gas and/or ash.8 In addition, scientists have detected innumerable organic chemicals in incineration outputs. Among these so-called products of incomplete combustion (PICs) are hundreds of semi-volatile chemicals of which only 10-14 percent have been completely identified9. Semi-volatile PICs are likely to be persistent in the environment and lipophilic (fat-loving). More recently, fine and ultra fine particulate matter from combustion technologies, which are a known contributor to cardiovascular disease, pulmonary disease, and cancer have become the focus of research related to the incineration technologies.10 In general, how well is the pollution from incineration facilities monitored? Pollution monitoring varies depending how much money has been spent on the various monitoring technologies. Most incineration facilities continuous monitor for NOx, SOx, CO, HCL, PM, O2, opacity, temperature and amonia. Other pollutants are monitored through stack tests, usually done once annually (as per Ontario A-7 guidelines). Municipalities may request more frequent testing. Tests are always scheduled, so facility engineers can plan for tests to be run during optimum conditions. Technology to continuously monitor heavy metals and dioxin do exist, but can be prohibitively expensive. Have there ever been studies to measure the health impacts of people living near by, or working in these facilities? There have been many studies which show a correlation between the toxins released from incineration and their impact on people living near these facilities. For example, a newly published study of adolescent children who lived near two incinerators found: elevated blood levels of PCBs, dioxins and metabolites of volatile organic compounds were in the children’s blood; delayed sexual maturation; delayed breast development in girls was positively correlated with serum concentrations of dioxins; delayed genital development in boys was correlated with serum concentrations of PCBs; reduced testicular volume was found among the boys.11 Another study showed that mercury levels in the hair of people living near a waste incinerator increased by 44-56% over 10 years and with greater proximity to the facility.12 Clusters of two cancers associated with dioxin exposure -- soft-tissue sarcomas and non-Hodgkin’s lymphomas -- were found in one intricate study.13 Increased rates of deaths from childhood cancer, all cancers combined, cancer of the larynx, liver, stomach, rectum, and lung were found in a series of studies.14

In terms of the health impacts on workers, here too, many studies also exists, among them, several studies showed increased death rates from cancer of the stomach, lungs and oesophagus, 15 and increased death rates from ischemic heart disease.16 In Summary New incineration technologies are un-proven, and while traditional technologies have improved, they too are still very dangerous in terms of the known pollutants, as well as the unknown and unmonitored pollutants. As we plan for the next 20-years, we must make decisions about waste management which have the lowest possible impact on the environment and human health. This is especially relevant today, as we are learning more about how heavy metals and other toxics are compromising our health. Recently for example, Environmental Defense Canada released its findings of blood sample tests from random Canadian families. They tested 11 adults from across the country for 88 chemicals and in their latest study, they tested children, parents and grandparents from five families for 68 chemicals. The findings of both studies demonstrate that toxic chemicals contaminate people no matter where they live, how old they are or what they do for a living. Late in 2006, Dr. Philippe Grandjean, a leading health researcher and Professor of Environmental Health from the Harvard School of Public Health published a study which characterizes the loading of chemicals both known (201) and unknown (over 1,000) as “a silent pandemic that has caused impaired brain development in millions of children worldwide”. Grandjean urges governments worldwide to begin to strictly control these chemicals.

“Even if substantial documentation on their toxicity is available, most chemicals are not regulated to protect the developing brain…Only a few substances, such as lead and mercury, are controlled with the purpose of protecting children. The 200 other chemicals that are known to be toxic to the human brain are not regulated to prevent adverse effects on the

fetus or a small child.” – Dr. Phillipe Granjean, November, 2006

ENDNOTES 1 Examples of false claims include, but are not limited to:

1) North American Power Company’s Pyrolysis proposal claimed there would be no hazardous emissions. After the city of Chowchilla, CA requested proof of their claims, the company withdrew their proposal because they could not back-up heir claims. 2) Neoteric Environmental Technologies and International Environmental Solution built a plasma arc/pyrolisis facility in Romoland, CA. While company tests using MSW in 2005 were declared a success, the South Coat Air Quality Management District determined that the facility emits more dioxins, NOx, VOCs and particulate matter than two existing mass-burn facilities located in the LA area. 3) Plastic energy LLC received permits for catalytic cracking in Hanford, CA. They claimed that the technology would generate electricity without any emissions. In 2004 company officials admitted that their technology would have toxic emissions and temporarily stopped the project. 4) Global Energy Resources began to site a plasma arc facility in Sierra Vista, Arizona. The company claimed that the project would have no emissions. When challenged however, their consultants admitted that there would be emissions. The company has since dropped its proposal.

These and additional case studies can be found in the report: Incinerators in Disguise, Case Studies of Gasification, Pyrolysis and Plasma in Europe, Asia and the United States. GreenAction for Health and Environmental Justice, April 2006. 2 Incinerators in Disguise, Case Studies of Gasification, Pyrolysis, and Plasma in Europe, Asia, and the United States, Greenaction for Health and environmental Justice, April 2006. 3 Incineration And Gasification: A Toxic Comparison, April 12, 2002, Blue Ridge Environmental Defense League. Data from: US Environmental Protection Agency, Compilation of Air Pollutant Emission Factors, Volume 1, Fifth Edition, AP-42 4 Incineration & Health – power point presentation, GAIA Conference, Penang, Malaysia, 17-21 March 2002, Pat Costner, Senior Scientist, Greenpeace International 5 Ibid., 6 Linda. S. Birnbaum, PhD, DABT, US EPA's lead expert on dioxin effects. 7 Stockholm Convention On Persistent Organic Pollutants, Article 5 and Annex C of the treaty describe the obligations with respect to dioxins and other unintentionally produced POPs 8 Source: Pat Costner, Senior Scientist Greenpeace International 9 Ibid., 10 Origin And Health Impacts of Emissions Of Toxic By-Product And Fine Particles from Combustion and Incineration of Hazardous Wastes and Materials, Cormier, Lomnicki, Backed, Dellinger, Environmental Health Perspectives, Volume 114, Number 6, June 2006. 11 Staessen et al., 2001. Lancet 357:1660-1669 12 Kurttio et al. (1998) 13 Viel et al. (2000) 14 Elliot et al. (2000); Knox (2000); Knox and Gilman (1998); Michelozzi et al. (1998); Elliot et al. (1996); Biggeri et al. (1996); Babone et al. (1994); Elliot et al. (1992); Diggle et al. (1990) 15Rapiti et al. (1997); Gustavsson et al. (1993); Gustavsson et al. (1989) 16 Gustavsson (1989)

Incineration of Municipal Solid Waste A reasonable energy option?

Fact Sheet 3

Recently, a significant amount of attention has been paid to incineration of municipal solid waste (also know as energy-from-waste or thermal treatment) not only as a disposal option, but as an energy producer as well. As municipalities develop their waste management plans for the next 20-30 years, it is imperative that they be armed with accurate information to better inform their process. The following fact sheet is intended assist municipal decision makers better comprehend the issues related to municipal solid waste incineration facilities like the energy output; its relation to waste; the relationship to the sale of energy; and selling energy from waste in Ontario. How efficient is it to burn waste for energy? Materials that are found in our waste stream, like plastics, paper, tires, woods waste etc. contain carbon, which when combusted produce heat which can be used to create energy (electricity and/or heat). The amount of energy is dependent on a number of variables, including how much non-combustible material is in the stream, how much moisture is in the waste; how efficient the conversion technologies are; and finally if both electricity and heat are being generated. Recycling these same wastes results in a much greater energy gain, simply by not having to undergo all the energy intensive steps required to extract primary resources used to manufacture the same products. Recent extensive life cycle inventories for Canada compare the energy gained from recycling versus combustion (see chart at right1). The results show recycling paper materials saves 2.4 to 7 times the energy gained from combustion, and recycling plastics saves 10 to 26 times the energy gained from combustion alone.

When we look at thermally treating a tonne of mixed waste in a modern incineration electricity facility (in this case data is from the most efficient facilities currently operating in Europe), recycling that same waste would result in about 5.4, 1.6 and 2.6 times the energy savings than incinerating with electricity recovery; heat recovery; or combined electricity and heat recovery respectively. (See graph on left2).

Material Energy savings

from Recycling (GJ/tonne)

Energy output from Incineration (GJ/tonne)

Energy savings

from recycling versus

Incineration Newsprint (6.33) (2.62) 2.4

Fine Paper (15.87) (2.23) 7.1

Cardboard (8.56) (2.31) 3.7

Other Paper

(9.49) (2.25) 4.2

HDPE (64.27) (6.30) 10.2

PET (85.16) (3.22) 26.4

Other Plastic

(52.09) (4.76) 10.9

Energy gained (gigajoules per tonne)

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Recycling Thermaltreatment -

electricity only

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How does energy from waste compare with other energy sources in terms of their impact on global warming?

When we compare energy producing technology used in Ontario, incineration contributes the greatest amount of greenhouse gas emissions.3 Compared to coal fired technology, mass-burn incineration contributes about 33%, and gasification about 90% more GHG emissions per Kwh of electricity produced.4 This is especially relevant in the context of Ontario’s energy policy. In 2005, the Provincial government announced an aggressive plan to replace coal-fired generation with cleaner sources of energy and conservation. The Minister of Energy at the time stated, “We are leading the way as the first jurisdiction in North America to put the environment and health of our citizens first by saying ‘no’ to coal…It's a prudent and responsible path that will ensure cleaner air for the province.” How easy is it to sell energy from waste in Ontario? Today the Ontario Power Authority5 (OPA) has developed a short and long term plan for electricity which does include recovery of energy (methane) from landfills, but no energy from thermally treating municipal waste. Further, the OPA defines “renewable biomass” for energy production as organic matter that “is not municipal solid waste”6. Instead, OPA will monitor the feasibility of greater electricity generation from waste, as well as other emerging technologies, going forward and will update future integrated power system plan (IPSP) accordingly. OPA writes, “Incineration or other forms of thermal treatment can be controversial public issues, due to perceptions regarding air emissions, ash, odors..” “Some of these concerns could be alleviated through proactive municipal ordinances and waste diversion programs that remove packaging wastes, household hazardous wastes and other problematic components of municipal solid waste stream”. 7 Currently in Ontario, the diversion rate for:

• household packaging waste is only 44% with over 465,000 tonnes of highly recyclable packaging still going to waste8;

• household hazardous waste is only 36% with over 54,000 tonnes of waste paint, antifreeze, single cell batteries, and solvents going to waste9; and

• Information technology, telecom and audio visual equipment waste is only 1% with nearly 70,000 tonnes of obsolete electronics going to waste10.

Given the above statistics, it is highly improbable that the OPA would consider incineration of municipal solid waste which not only has recyclables, but more important, still contains many toxic substances suitable for combustion.

Greenhouse Gas Emissions in grams per Kwh of electricity produced

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Without OPA including energy from incineration facilities in the IPSP, municipalities or their operators will be required to initiate energy sales through the Independent Electricity System Operator (IESO) Administered System, which is subject to fluctuating prices (spot market pricing). Otherwise, facility owners must negotiate with the private sector to purchase Kwh and/or heat with short-term or long term contracts. Does maximizing recycling compromise energy production? While thermal facilities for waste disposal do exist around the world with varying levels of efficiency, in terms of energy outputs, one thing is certain; gaining efficiencies necessitates that incinerators operate continuously, which demands a steady stream of combustible waste. Disturbing the flow of waste will disrupt the system and its energy output. As Ontario residents continue to strive for diversion beyond 60%, our success will impact the economic viability and efficiency of the thermal facility. This irony is illustrated in a recent study which analyzed how recycling programs affect incineration. The study showed that increased recycling “leads to a decrease of energy recovery so that it is necessary to use additional boilers to meet the initial energy demand. The related impacts tend to offset the environmental benefits derived by the waste recycling itself.” “The main drawback of the selective collection {curbside recycling} of household waste is that it involves a decrease of the energy produced by waste incineration mainly caused by the recovery of paper/cardboard and plastics.”11

In summary As we move forward with waste management planning, our efforts and tax dollars should focus on the lowest risk option - improving diversion and maximizing recycling. Recycling instead of burning resources achieves the greatest efficiencies in terms of energy conservation, reduced overall pollution and promotion of renewable and sustainable energy planning in Ontario. ENDNOTES 1 Determination of the Impact of Waste Management Activities on Greenhouse Gas Emissions: 2005 Update Final Report, ICF Consulting October 31, 2005, submitted to Environment Canada and Natural Resources Canada 2 Energy savings from recycling; Source: Comparative LCAs for Curbside Recycling Versus Either Landfilling or Incineration with Energy Recovery, Morris, Jeff, Sound Resource Management Energy output from European Countries: CEWEP Energy Report (Status 2001 - 2004)Results of Specific Data for Energy, Efficiency Rates and Coefficients, Plant Efficiency factors and NCV of 97 European W-t-E Plants andDetermination of the Main Energy Results CEWEP: Confederation of European Waste-to-Energy Plants, http://www.cewep.com/ 3Data sources: Coal: Ontario MOE – OnAIR Annual Report 2002; Natural Gas: US EPA – Fifth edition Compilation of Air Emission Factors Volume 1; Mass-burn incineration: data provided for Niagara/Hamilton’s Environmental Assessment – Wasteplan. Final draft Report on Comparative Emissions Study, June 2005. The data was provided by 5 potential vendors of incineration technologies. 4 Ibid., 5Ontario Power Authority or “OPA’ has no commercial interest in any specific projects; its sole objective is to plan a system that delivers the best outcome for Ontario consumers based on the policy guidelines it has been given. The OPA’s mandate is to undertake a long-term planning function to develop an integrated power system plans to meet Ontario’s electricity requirements. 6Standard Offer Program – Renewable Energy Program Rules- page 30, www.powerauthority.on.ca/ 7 Discussion Paper 4- Supply Resources, www.powerauthority.on.ca/ 8 Based on data for 2004, Table 1: Generation and Recovery (full-year obligation), Stewardship Ontario. 9 Draft for Discussion - Handout #2 Municipal Hazardous or Special Waste Plan Development Workshop #2, Stewardship Ontario 10 Waste Electronic and Electrical Equipment Study, Waste Diversion Ontario, CSR, RIS International Ltd., MacViro Consultants Inc. & Jack Mintz & Associates Inc., 8 July, 2005 11 Wenisch, Rousseaux, Metivier-Pignon, Analysis of technical and environmental parameters for waste-to-energy and recycling: household waste case study, October 2003, International Journal of Thermal Sciences , ELSEVIER

Incineration of Municipal Solid Waste Understanding the Costs and Financial Risks

Fact Sheet 4 Across Canada municipalities are faced with the challenges associated with financing waste diversion and disposal. As we look to the future, municipalities should be cautious when entering into long-term commitments for their waste, especially if they require substantial investments. The following fact sheet is intended assist municipal decision makers better comprehend the costs, terms and risks associated with incineration for municipal solid waste. What does incineration of municipal solid waste actually cost? Incineration facilities for municipal solid waste come in many different sizes and varieties, from low-tech mass-burn plants, to newer technologies like gasification, plasma arc and pyrolysis, which are still unproven in terms of their success. Given the range of technologies, costs can vary dramatically. Variables such as capacity, the amount of up-front sorting required, emission testing and monitoring technologies, operator training, ash management, and the incineration process (technology) all impact the project costs. Today, most new projects will range in price from about $102 to over $168 per tonne (net costs) including ash management, amortized capital and energy revenue.1 The World Bank estimates that the cost of incineration is “an order of magnitude greater than” landfilling.2 Don’t energy revenues off-set the operating costs substantially? The revival of incineration as a disposal option in Canada is very much linked to the promise of substantial revenues from the sale of energy. In fact, budgeting for incineration facilities always incorporates revenues from the sale of electricity (kwh) or heat (GJ), or combined electricity of heat.3 These revenues usually off-set per tonne operating costs by as much as 30%-45%. In spite of these large revenue projections, the net costs range from about $102 - $168 per tonne. However, several very real changes can occur over a 20-year period4 which will impact the energy output and electricity revenue. For example, if the net calorific5 value of a tonne of waste is reduced, due to increased recycling, less energy will be produced. This may necessitate additional import of energy (usually natural gas) to maintain thermal heat within the combustion chamber, which will increase fuel costs. Finally, given the instability of electricity buyers for energy from incineration of municipal solid waste, there are no guarantees that energy revenues will continue to flow throughout the life of the facility.6 What are the financing options for municipalities? In general, there are two financing models for incineration facilities. Privately owned and operated projects require a guaranteed flow of waste and set tip fee. The owner is guaranteed revenue to cover capital and operating costs and profits, with a fixed amount of waste or a cash penalty. “Put or pay” contracts involve communities supplying waste or paying a penalty for the life of the thermal facility - about 20 years or more.

Public ownership is when a municipality or a group of municipalities raise the funds to finance the capital investment. Governments may issue bonds for low-cost financing, or can increase taxes to generate project financing. Public ownership does not involve put-or-pay commitments, but it still requires that the facility receive waste with reasonable energy content on a consistent basis for a 20-year term. The municipality is also accountable for financing on-going operations, imported natural gas for start-up and shut-downs, as well as annual capital costs and paying off debt on upfront capital costs. What are the risks to municipalities? For “optimal” operations, incineration facilities must combust waste around the clock to maintain consistent electricity output, and reduced pollution. In contrast to landfills, these facilities require a steady stream of mixed waste with the right composition of burnables like plastics and paper-based products for the entire life span of the facility. Put-or-pay provisions for incineration projects can be risky agreements for communities, as it requires the community to guess the amount of waste generation in their community for the next 5, 10, 15 and 20 years from now. Most forecasting factors in a degree of higher diversion, along with population growth and status quo waste generation. But this approach is short-cited, because it does not take into account the impact of new and less expensive diversion technologies, alternative cheaper disposal options, new regulatory requirements, changes in the composition of the waste, and the impact the state of the economy has on waste generation7. There are countless case studies8 of communities around the world whose incineration projects have landed them into significant debt, as a result of insufficient waste generation, insufficient calorific content in the waste, surpassing allowable emission limits, and unplanned mechanical failures, which required additional cost investments from the community. Are there other costs associated with incineration of municipal solid waste? As municipalities determine the costs associated with their disposal options, it is important that they consider the social costs associated with the pollution from incineration facilities. More specifically, these costs would include the cost of global warming, acidification, and eutrophication associated with emissions of certain pollutants to the atmosphere and to waterways. The increased likelihood of adverse impacts on human health associated with air pollution emissions and the release of toxic substances to the environment also carry a cost. Several studies9 have calculated the total social cost of incineration and landfill, and their findings show that most of the time incineration costs are much higher than landfill. One independent study writes10:

“The net private cost of WTE (waste-to-energy) plants is so much higher than for landfilling that it is hard to understand the rational behind the current hierarchical approach towards final waste disposal methods in the EU (European Union). Landfilling with energy recovery is much cheaper, even though its energy efficiency is considerable lower than that of a WTE plant.”

In Summary As we plan for the future – where energy conservation and environmental protection are crucial - we must be aware that this future is unsure about what new diversion technologies will emerge, the amount of waste available for disposal and the composition (i.e., calorific value) of waste. This is why plans for waste disposal require flexibility – the kind of flexibility that the economics of incineration will not bear. Instead, municipal finances should support the 3Rs and composting, with the remaining residual waste managed in a manner which has the lowest risk, lowest environmental impact, and allows for diminished quantities over time. ENDNOTES 1 This price range is based on several Canadian on-going and planned projects: Specifically, Algonquin Power in Peel Region, and the cost range provided in the Environmental Assessment done for Region of Niagara and City of Hamilton. In addition, similar price ranges were attained from John Chandler, A.J. Chandler and Associates presentation at AMRC Feb 2007 workshop. http://www.amrc.ca/proceedings/page9.html 2 Georgieva, 2000; and Cointreau-Levine, 1996. 3 Most facilities in North America produce and sell electricity only 4 20-years is usually the estimated life-span of a incineration facility. Capital costs are generally amortized over 20-years. 5 “Calorific” refers to the amount of heat released when all of the combustible material is burnt. Plastic and paper materials have the highest calorific content of the waste stream respectively. 6 Currently the Ontario Power Authority (OPA) will not procure biomass energy from municipal solid waste. As per Startdard Offer Program rules – page 30. However, a incineration project can negotiate with private company to purchase Kwh and/or heat over short-term or long term. Responsibility of the Incineration owner/operator, and may be subject to fluctuating prices/unstable revenues. 7 Generally, the state of the economy has a direct relationship to waste generation – the healthier the economy the greater the generation of waste per capita. 8 Case Studies can be found at:

1) Waste Incineration – A Dying Technology, July 2003, Global Anti-Incinerator Alliance; 2) Waste-to-energy and recycling: Tango or tangle?, Apotheker, Steve, Resource Recycling, September 1994, p72.; 3) Competition Between Recycling and Incineration, Jeffrey Morris, Ph.D. - Economics Sound Resource Management Sept 1996; 4) Incinerators in Disguise, Case Studies of Gasification, Pyrolysis, and Plasma in Europe, Asia and the United States., April 2006, Greenaction for Health and Environmental Justice

9 These studies include: 1) Eunomia, A Changing Climate for Energy from Waste?, Final report for Friends of the Earth, 03/05/2006. Page 24, table 4. 2) HM Customs & Excise (2004) Combining the Government’s Two Health and Environmental Studies to Calculate Estimates for the External Costs of Landfill and Incineration, December 2004. 3) Presentation of research findings, r. Jeffery Morris, Sound Resource Management – Recycling Council of Ontario, Energy from Waste Policy Forum, November 3, 2006.www.rco.on.ca

10 Burn or bury? A social cost comparison of final waste disposal methods, E. Dijkgraaf, H. Vollebergh, Feb 2003.