Sierra Club
Pennsylvania Chapter - Lehigh Valley Group
P.O. Box 1901
Allentown, PA 18105-1901
email: l vs i er r a clu b@g ma il .c om
Allentown City Council
City Hall
435 Hamilton Street
Allentown, PA 18101
February 15, 2012
re: Waste-to-Energy project proposed by Delta Thermo Energy, Inc.
Members of City Council:
The Sierra Club is America's oldest (1892) and largest (1.5 million members) environmental
organization, with over 24,000 members in Pennsylvania. The Lehigh Valley Group of the
Pennsylvania Sierra Club urges Allentown City Council to reject the DTE Waste-toEnergy Project as an extraordinarily expensive and risky way to address long-term waste
management needs.
Committing to this large-scale, costly project would lock the city into an outmoded 20th century
waste management system (burning trash and combustion-based electricity generation) with an
unproven, unconventional and inflexible technology. The list of reasons NOT to invest in this
plan in the 21st century overwhelms any alleged benefits that it might deliver.
The problems with the project range from the direct negative impacts of the facility on the city to
a number of broader environmental and economic concerns. These include:
• Importing trash The latest and perhaps most disturbing revelation in the news is the
suggestion that the facility will IMPORT waste from other areas INTO the city as the project is
scaled larger than the city's current waste processing needs.
• Location The facility will be located a few blocks from the prime redevelopment efforts
along the river and in the heart of downtown.
• Promoting waste; inhibiting recycling The plan commits the city to 35 years of businessas-usual in waste generation, with 3% or larger annual growth in waste--effectively planning
against future efficiency, recycling and waste reduction. The proposed facility NEEDS waste
generation and wastefulness in order to operate. (Compare San Francisco where 77% of waste is
diverted from disposal.) http://www5.sfgov.org/sf_news/2010/08/san-francisco-achieves-77landfill-diversion-rate-the-highest-of-any-us-city.html
• Bringing waste home; not sending it away This plan to bring waste into the city from
surrounding regions is already occurring in the wastewater treatment facility operations, but
under the currently operations the sludge residue, like the solid waste now collected in the city, is
TRANSPORTED AWAY for disposal. The new DTE facility reverses the timeless logic of
resources IN and waste OUT. It's model is bringing WASTE IN and discharging some of it into
the air IN THE HEART OF THE CITY.
• Impacting our own citizens- the defenseless The neighborhoods directly downwind from
the site are primarily working class areas. Other incinerators in the state have been criticized as
examples of environmental racism, inflicting disproportionate environmental and health risk onto
minority and politically powerless sectors of the population.
• Bad neighbor policy Downwind Bethlehem will also be affected by the
project. (Prevailing West SW & WSW winds point toward Bethlehem.) When Bethlehem flirted
with an incinerator some years ago, at least it planned to build it downwind from the city.
• A bad deal - no competition The facility contract will financially lock in a major increase
in disposal fees along with a 2.21% annual increase. This predetermined price for the life of the
contract could be a serious overcharge if waste handling alternatives (increased recycling and
lower landfill disposal prices) provide cheaper options.
• Destruction of resources and revenues Items from the waste stream with highest fuel
value are most likely to be recoverable either as revenue producers (recycled paper and
cardboard and plastic) or as more easily processed with inexpensive low technology (composting
and diversion--e.g., yard waste and firewood).
• Pollution risks in the heart of town Waste is not fuel. The mix of materials input is
released in the output. Where will all the inputs from the waste mixture of municipal solid waste
(everything we throw away) and sewage sludge (with all its contaminants--toxic heavy metals,
radioactive isotopes, chemical wastes, etc.) end up? In the air, the water, or the ash? Everything
has to go somewhere; elements can't be broken down.
• Greenhouse gas impact The carbon will end up in the air; combustion at the waste-toenergy facility will add to the greenhouse gas burden already overwhelming climate stability.
Energy planning should be moving beyond combustion based energy sources, not adding
additional burning.
• Trash truck traffic Trucks hauling waste into the heart of town, from around the city and
from wherever? New York?.
• Where are the venture capitalists? if this process really produces cheap energy and less
waste disposal and saves money, where are the private investors? Successful competitive
technology and business should attract private capital.and paying customers, not need 35-year
city contracts.
• Opportunity cost and alternatives and jobs The same investment in recycling and waste
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reduction programs would lower waste disposal costs and create more permanent jobs in waste
recycling and recovery, rather than a couple of dozen in resource destruction.
• Image of city Would this add to or harm economic development? Does a waste-attracting
facility encourage other investment in the community? Will it enhance city property values?
• Bankruptcy or technological failure If the unproven process doesn't work, the facility
will have only salvage value. What will be the source of funds for alternate waste disposal
operations?
Needless to say, the Mainline Philadelphia suburbs will not be battling Allentown for such a
facility designed to import other people's waste.
City Council should avoid this already outmoded, risky technology at all costs, but if councilors
don't share that view, they should at least move slowly and look before they leap. Thirty-five
years ago Bethlehem Steel was an important economic force; today it is a relic of a bygone
era. Investing a city's future in a technological "fix" based on burning trash in a world moving to
renewable energy ignores both environmental and economic reality. It would be like an
investment in a typewriter company 35 years ago. Allentown could and should do better.
To protect the city and its citizens and environment, The Sierra Club urges the City Council to
reject this plan.
Very truly yours,
Sierra Club
Pennsylvania Chapter - Lehigh Valley Group
by: ______________________________
Donald W. Miles, chairman
xc:
Hon. Ed Pawlowski, Mayor
Allentown Environmental Advisory Council
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Sierra Club national policies on solid waste:
The Sierra Club’s policy for reducing waste is based on Zero Waste: it aims to prevent waste by design rather than
manage it after the fact. Zero Waste addresses not only the quantity of waste we generate, but also its toxicity, its
contribution to climate change, and the important links between waste reduction and corporate responsibility.
Environmental management of materials and energy should first, reduce the use of materials and energy and the use
of toxic substances to a minimum (through design for the environment); second, repair and reuse, extending the
service life of materials and products; and third, recycle, conserving as much as possible of embodied value.
Elimination or reduction of wastes should have the highest priority in a waste management program. Process
substitution, waste reduction, reuse, and conversion to nonhazardous substances should be encouraged. Closed
systems of manufacture, use, and disposal should be developed. Industrial processes producing wastes that cannot be
reused, converted to nonhazardous substances, or safely incinerated should be phased out. If materials and energy
recovery are not possible, the best technologies should be used to reduce the level of hazard as much as possible.
Waste exchanges should be encouraged .
Incineration should only be considered after all other acceptable options have been evaluated and found to be
impracticable for managing a particular waste. Regulations must be in place to require the lowest levels of emissions
and effluents that are technically feasible. Incinerator design, permitting, and operation must include sufficient
safeguards to protect human health and the environment. If the lowest feasible levels of emissions do not fully
protect human health and the environment, the facility should not be allowed to operate unless incineration is the
least hazardous option for management of an existing problem waste. Because much is still not known about the
health and environmental effects of emissions, including the products of incomplete combustion, research should be
pursued to further characterize and reduce emissions.
(a) The permitting, sighting, and operation of hazardous waste incinerators, including mobile units, must include a
public education and participation process that makes all data associated with design, waste streams, transportation,
storage, and emissions conveniently available to the public.
(b) All permits should be written to provide for changes or revocation at any time, and should be re-evaluated at
least every two years. A mobile incinerator must have a permit that is specific for each site where it operates.
(c) Incinerator sighting should minimize risks to the public from emissions and transportation, at the same time
avoiding such environmentally sensitive areas as critical wildlife habitat, parks, and wilderness areas. A facility
should include a buffer zone and operate inside a containment building where fugitive emissions are controlled.
(d) Trial burns must be conducted on each individual incinerator using waste streams as close as possible in
character to those to be burned in normal operations.
(e) All hazardous waste incinerators should be equipped with emission control systems for acid gas, toxics, and
particulates. Monitoring should address all potentially toxic emissions, including organics and metals. Monitoring
should be based on frequent or continuous sampling whenever technically feasible. Continuous emissions
monitoring should be employed that will fully characterize the operating conditions of the incinerator and should be
connected to automatic interlock systems that will not allow continued operation of the incinerator if design values
cannot be attained. Ashes, slag, and aqueous wastes should be presumed hazardous and managed appropriately.
Management of incinerator residues should be provided for in the design and permitting process.
(f) Monitoring programs should include the collection of on-site and off-site baseline data prior to facility operation
so that contamination from the facility can be distinguished from ambient or background pollution levels when
operation begins. Established quality control procedures should be used. All monitoring data should be conveniently
available to the public and the press from facility operators and regulatory authorities.
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(g) Regulatory controls should require operator certification and an operations and maintenance plan. Inspection to
determine that the plan is being followed should be both announced and unannounced and should cover all shifts at
facilities. Regulations should provide for the establishment of a citizens' over-sight committee which can designate
and supervise its own inspector. This person shall be trained and employed at state or facility owner expense and
should inspect the facility on a least a weekly basis, independently of state inspections.
(h) Research on other thermal technologies, using nonhazardous chemicals for initial testing, should be encouraged.
(i) Part of the facility's cost of doing business should include the preparation of environmental and public health risk
assessments, permit fees, monitoring, closure, insurance, and post-closure contingency funds. A special tax, such as
a gross receipts tax, should be imposed on the facility to compensate the host community that bears the health risks.
This compensation should be available for improving community emergency response capabilities, additional
monitoring, health testing, health care, transportation safety, and other costs attributable to facility impacts. Marine
incineration is not acceptable because human or mechanical error or natural disaster could cause a release of toxics
that could not be contained or cleaned up. Compliance with strict safety or emissions requirements would be
difficult to assure and safer disposal options exist.
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