City Council's Clean Air Bill will have regional impacts

City Council Bill 18-0306, Clean Air Regulation will impose stricter emissions standards on commercial solid waste incinerators in Baltimore City. The bill is up for a final vote today. The stakes are high, not only for the BRESCO incinerator and its operator Wheelabrator, but for the entire region since the incinerator may have to shut down as early as 2021 if the new clean air standards go into effect. (This is the year when the current City contract with Wheelabrator expires). The battles lines are typical for environmental legislation: industry versus environmentalists, economic arguments against those that address social justice, equity and health and, of course, legal questions whether the City has the authority to legislate clean air standards.

BRESCO incinerator: Baltimore's largest point polluter

Wheelabrator floods the City with propaganda in the form of mailers and newspaper ads, Councilman Zeke Cohen alleges a violation of the Transparency in Lobbying Act. Late Friday, the Council got a document they had long requested: The Fiscal Analysis of Possible Impacts of
City Council Bill 18-0306. (The document can be found here). The impact analysis is limited, though, it is prepared by the Department of Public Works (DPW) and not by an independent agency and it does not include any specific recommendations about how the City can achieve further waste reduction. The "fiscal note is limited to assessing the impact of several BRESCO scenarios on the scope of our current waste stream and disposal means" DPW admits. Several scenarios were developed costing the city money for lost income from BRESCO (a loss totaling $9.8 million per year should it shut down), and lost tipping fees from commercial haulers at the City landfill who would have to find disposal outside the city. If the City would dispose all its solid waste in its own landfill, the cost would be about $12.8 million per year or $98.6 million over seven years. The landfill would reach capacity in 2024 instead of 2026, not assuming the planned capacity expansion expected to be completed by 2026 or later.

Protest against counting incineration  as a renewable energy

If the City would dispose its waste gradually outside the city limits via an additional transfer station (cost about $10 million) to be constructed, the annual cost is given with $15.8 million, a number with lots of uncertainty, since no negotiations have been had which landfills in the region would accept all the City's trash.

The municipal landfills in Baltimore County, Anne Arundel County, and Harford County are the nearest options for alternative disposal sites if BRESCO were to close. However, this would significantly impact the effective lifetime of those landfills so it is unknown whether those counties would be amenable to accepting large quantities of waste and at what cost. BRESCO is utilized by Baltimore County and a number of private haulers, so if it were to close, those entities would also need to find alternative disposal sites. Therefore, it is likely that landfills would increase their tipping fees in the face of high demand and low supply. (DPW analysis)

The Baltimore trash equation includes a number of variables:

• The amount of trash that is produced (it could sink considerably due to waste avoidance legislation such as the styrofoam ban, a better recycling rate, more composting etc.)
• the cost and construction of a trash transfer station should trash have to be hauled beyond the city limits
• the expansion of the City's own Quarantine road landfill estimated to cost about $100, million
• the actions of Baltimore County and commercial trash haulers who currently deliver waste at the BRESCO plant
• the district heating customers and the Trident facility which use steam from the incinerator to heat downtown properties (they can also use natural gas supplied by BGE but at a different cost).
• the cost of poor air quality caused by the incinerators which produce toxins such as mercury, dioxins, SO2 and NOx 

One of the less reported aspects of the incinerator is that it received in 2018 more solid waste from Baltimore County than from Baltimore City.  The split was 159,000 tons (City) and 215,000 tons (County), according to Mira Green, a Senior Budget Management Analyst at City of Baltimore. This makes the question of the incinerator a truly regional matter. No comment was available from the new Baltimore Executive Johnny Olszewski who has stressed regional collaboration and partnership with the City.

Destiny Watford, clean air activist

Commercial haulers who service businesses and larger rental and condo complexes in the City and the County deliver also solid waste to the BRESCO plant, creating tipping fees for the City.

Also not much reported is the fact that only 51% of DPW collected waste goes to the incinerator, in spite of the City's dismal 15% recycling rate. There is no immediate explanation why currently a large portion of waste would be directly landfilled. 

Wheelabrator's arguments aim at the emissions from additional trucking and landfilling, notably diesel fumes (NOx) and methane and the fact that landfilling isn't a green method of waste disposal either. However, these additional emissions the clean air bill may cause, though bad for greenhouse gases, are not in the same league as the highly toxic emissions from the smokestack of the incinerator and from the ash disposed in the landfill. Proponents of the Clean Air bill count as costs of incineration the poor health outcomes from bad air, such as asthma. Such "external costs" are not part of the cost evaluation prepared by DPW.

The DPW study ends with this conclusion:

Currently, the majority of waste collected within Baltimore City is sent to BRESCO for disposal. If this facility were no longer an option, then the City would need to find an alternative waste disposal method due to the limited capacity available at the City-owned landfill. The landfill is currently projected to have capacity until 2026, but the closure of BRESCO will increase landfill usage by possibly 100% a year.
The City would lose approximately $10 million a year in payments from BRESCO and $4.5-5 million in tipping fee revenue. There would be necessary expenditures of at least $10 million for a new transfer station, operating expenses of approximately $2.2 million a year for the transfer station, increased operating costs at the landfill, and transportation and tipping fees to an outside landfill, which could range from $10-22 million depending on which landfill is willing and able to accept the waste and how much they would charge. 

Most City Council members have made up their mind and will vote for the bill. Mary Pat Clarke, a long serving Council member put it this way:

“We’ve been working up to this gradually in this entire term of office. We’ve got to do this, and this is one step that takes us a leap into the future we need to create.” (Clarke, Baltimore SUN)

The Baltimore metropolitan area has been a non attainment area under the Clean Air Act for decades.

 Klaus Philipsen, FAIA

This article is an adjunct to Friday's article about the same topic.