A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 April 3, 1991

National Energy Strategy: More incinerators

“The Administration has proposed a seven-fold increase in municipal waste incinerators by 2010 as part of the National Energy Strategy [NES], a move industry sources say will scuttle efforts to limit incineration in the upcoming Resource Conservation and Recovery Act [RCRA] reauthorization debate...In order to spur this growth, the NES proposed to increase research on waste incineration technologies and improve dissemination of information about the environmental benefits of WTE [waste-to-energy] plants...The energy strategy also suggests speeding siting procedures for all energy production facilities, singling out WTE plants as an example of the benefits of ‘stream-lining’ siting requirements...” Inside E.P.A. Weekly Report , 3-1-91.

National Environmental Groups: Uniting Against Garbage Incinerators.

On April 1, 1991, four national environmental groups (Environmental Defense Fund, Natural Resource Defense Council, Sierra Club, and Friends of the Earth) signed on to the grass-roots movement against municipal waste incineration, in a joint letter to the U.S. Senate Environment Committee with Greenpeace, Clean Water Action, Environmental Action, and the US PIRG, urging the Senate to incorporate into RCRA’s new municipal solid waste regulations:

* A moratorium in the permitting, construction or expansion of garbage incinerators until the year 2000;

* The classification of incinerator ash as a hazardous waste

The letter, signed by these eight national groups stated: “(Municipal waste incinerators) are necessary only to the extent that designers of consumer products and packaging ignore the disposal impacts of their marketing, passing these off to municipal tax budgets and saddling public officials with controversy. Currently, one of the greatest obstacles to effective recycling in the U.S. is the composition of consumer products...last year alone America consumed the equivalent of almost twice the amount of oil ever imported in a single year from Iraq and Kuwait combined just to produce packaging wastes.” The following are the group’s recommendations for RCRA’s reauthorization on municipal solid waste regulations:

* Permitting and use of municipal solid waste landfills, incinerators and composting units: Assure the use of the most environmentally benign management technologies for all materials found in the municipal waste stream. Provide the material specific information necessary to properly assess the correct technology, size, cost and labor requirements appropriate to any treatment or disposal facility under consideration, and; Assure that those most immediately affected by the siting of a facility approve its location.

* No locality, state government, authority or any other jurisdiction seeking to use, permit or renew a permit for a solid waste facility can do so unless it has met the following requirements:

* No permit shall be issued for any solid waste landfill, incinerator, or composting unit prior to issuance of a waste composition analysis. All permitting processes for the above mentioned facilities shall require that waste composition analyses be published and subject to public review

* Mandate materials diversion for recycling. Each municipality in the state, other jurisdiction, government or authority organized for the purpose of constructing, operating or using a municipal solid waste landfill or incinerator divert away from such landfill or incinerator: 65% of all glass; 65% of all papers; 80% of all plastics; 90% of all yard wastes; 10% of all food wastes. No permit shall be issued to any solid waste management system until: (a) localities planning to use such a facility have achieved the above diversion rates, and (b) it can be demonstrated that reliance on such a facility will not interfere with maintaining the diversion rates listed above;

* Mandate a public review and approval process for all waste management facilities. As part of the process, the applicant must provide a technical assistance grant of $100,000 to the local community group(s) reviewing the project proposal; Require that the local community must agree to host the facility. No facility can be sited in a community that does not want the facility.

* Mandate that the proposed facility will not harm public health or the environment, including a demonstration that the facility will not increase the levels of pollutants in the food chain.

* Mandate a demonstration that the full cost of the facility over its entire life (including, but not limited to capital costs, debt service, liability insurance, environmental remediation and lifetime operation and maintenance) will be less costly than alternative waste management strategies;

* Mandate a demonstration that it is not feasible to manage by waste reduction, re-use, recycling or composting any waste stream proposed to be sent to a landfill or incinerator.

* Mandate a moratorium in the permitting, construction or expansion of garbage incinerators until the year 2000.

* Prohibit the incineration of unsuitable materials. Ban the incineration of at least the following materials and products which contribute to the volume and toxicity of air emissions and ash residue: construction debris; household and lead acid batteries, PVC plastics and plastics containing metals used as a pigment, coloring agent or stabilizer; yard wastes, tires; specified household hazardous wastes; consumer electronics.

* Regulate ash from existing incinerators as a hazardous waste under RCRA Subtitle C. * Ash should be deposited in a monofill used only for incinerator ash. * Monofill must meet minimal technical requirements for hazardous waste landfills. * Prohibit any utilization of incinerator ash.

* No Federal overrides. Provisions for any override of local zoning ordinances to site solid waste

facilities must be avoided and would be unprecedented.


1. Establish packaging efficiency standards: “no consumer item shall be offered for sale...which includes less than 90% product or more than 10% packaging.”

2. Facilitate the recovery and re-use of bulky metallics, autos and beverage containers

3. Mandate a National “Take-it-Back” program for all vendors of large appliances and motorized vehicles of any sort (autos, lawnmowers, snowmobiles, etc).

4. Establish a national deposit on all beverage containers -- allow states to opt out of a national deposit program only if they are achieving an average 70% recovery rate for all their beverage containers.

5. Require that all beverage containers of a specific size be of a standardized color and form - this will allow any bottler to refill bottles produced by another manufacturer.

6. Promote a reduction in the use of toxic or potentially toxic chemicals in consumer products...Require reductions in the use of toxics materials in consumer goods. Adopt as Federal law the Coalition of Northeastern Governors model toxics reduction bill (now law in eight states) that bans the addition of lead, cadmium, mercury and hexavalent chromium to all consumer goods packaging...Ban the use of mercury in all household batteries and latex paints..phase out chlorine bleaching in the pulp and paper industry.

7. Nurture End Markets for Recycled Materials. Establish a recycled materials content standards mandate in RCRA, e.g., by 1997: Newsprint, 60%; boxboard, 80%; HDPE, 50%; glass containers, 50%; etc.

8. Establish a virgin materials tax .

9. Mandate aggressive federal and private sector procurement for commodities made from recyclables.

10. Regulate Environmental Claims to protect consumer from mis-leading or deceptive claims.

Clean Water Action, Greenpeace and the National Toxics Campaign are spearheading a War on Waste grass roots campaign with a series of coordinated events around the country to begin the first week of June. For more information on how to network your group to this campaign, contact Ken Brown at Clean Water Action, 1320 18th St, NW, Washington, DC 20036. Tel: 202-457-1286.

WASTE NOT # 145 A publication of Work on Waste USA, published 48 times a year. Annual rates are: Groups & Non-Profits $50; Students & Seniors $35; Individual $40; Consultants & For-Profits $125; Canadian $US45; Overseas $65. Editors: Ellen & Paul Connett, 82 Judson Street, Canton, NY 13617. Tel: 315-379-9200. Fax: 315-379-0448.