Ban on incineration in Clean Air Act ill-conceived

By Dr. Emil Q. Javier

"There are those who look at things the way they are, and ask why… I dream of things that never were, and ask why not?" – Robert Kennedy

The previous column dwelt on the incoherence and contradiction of some of our laws on the environment, in particular the mess in the legislation and implementing rules and regulations on the cutting of trees.

The ill-conceived legislation for clean air with the complete ban of incineration of municipal solid wastes (MSW) in the Clean Air Act of 1999 (RA 8749) is another example.

The ban on incineration was premised on the need to reduce the release of greenhouse gases like carbon dioxide (CO2), methane, sulfur dioxide (SO2) and nitrous oxide (NO2) which bring about global warming and induce climate change. It was also meant to reduce the release of carcinogenic organic air pollutants, principally the highly toxic dioxins and furans.

Perversely the ban on incineration achieves the opposite result. After the municipal wastes are sorted and the non-biodegradable wastes like plastics, metals and glass recovered and recycled, the remaining organic biodegradable wastes are finally disposed properly in industrial scale in three ways:

sanitary landfills with or without methane gas recovery
incineration for steam and electricity generation, or
converted into some form of powdered solid fuel and also into gasoline and fuel-oil like products.

The first two are mature technologies while the third option is still under varying stages of technological development and commercialization.

Hence, the realistic choice for now for most countries/cities is between sanitary landfills versus incineration.

However, studies have shown that sanitary landfills with methane recovery systems produce 2–3 times more carbon dioxide equivalent, sulfur dioxide and nitrous oxide than incineration electricity systems per kilowatt hour of power generated.

The less capital-intensive, easier to manage landfills without methane capture are much worse because the escaping methane has 34 times more global warming potential compared with carbon dioxide.

Thus for the purposes of mitigating global warming and cleaner air, incineration is the far better technological option than sanitary landfill.

Additionally, both options can generate electricity. Sanitary landfills with methane recovery, generate power in the order of 44–84 kilowatt per hour per ton of waste. Modern incinerators on the other hand generate 450–930 kilowatt per hour per ton of waste, or an efficiency factor of 10, in favor of incineration.

Modern incinerators are miniscule contributors of dioxins and furans

One of the major issues raised against burning of wastes is the release into the atmosphere of the dreaded carcinogens dioxins and furans. The objection directed to incinerators is mis-informed because dioxins and furans are the products of incomplete burning of organic wastes at 400o–700oC. This problem is largely eliminated in incinerators because the burning temperatures in modern incinerators are above 1000oC.

The real culprits are the burning of agriculture and backyard wastes or the traditional “siga” which ironically are expressly allowed by the Clean Air Act. Worse the Clean Air Act is silent on the domestic burning of fuelwood for cooking which generate these carcinogens right in confined environments in homes.

Germany with 58 incinerators is next only to France with 123, as the countries in Europe with the most number of incinerators. In 2000, the German Ministry of Environment reported that the dioxin discharge from their many incineration plants was only less than one percent of the total dioxin generated. On the other hand “the chimneys and tiled stoves in private households discharge approximately 20 times more dioxin into the environment than incineration plants.”

Discrimination of incineration versus other industry stationary emission sources

Another glaring contradiction in the Clean Air Act is the artificial distinction and discrimination against incineration versus many other stationary sources of emissions such as coal and oil-fired power plants, petroleum refinery, primary copper smelter, steel plants, cement plants and geothermal plants.

All these industry stationary sources emit air pollutants to varying degrees. And yet, the law allows their operations provided the concentration of their pollutant discharges at the point of emission shall not exceed the limits set in the law.

Why can’t the same principle be applied on incinerators which are likewise stationary industrial sources of emissions?

For the same amount of produced energy, incineration plants emit fewer particulates, hydrocarbons and less sulfur dioxide, hydrochloric acid, carbon monoxide and nitrous oxide than coal-fired power plants (Delaware, USA Solid Waste Authority 1997). Thus if the twenty or so new coal-fired power plants in the pipeline prospectively are deemed compliant with the Clean Air Act, all the more with modern incinerators.

Better incineration than landfills

Our Clean Air Act got its priorities mixed up. Incineration, especially with the modern plants, are more benign to people and the environment than sanitary landfills.

Many progressive and environmentally conscious countries have adopted incineration as the preferred waste-to-energy option in handling municipal solid wastes. Denmark, Sweden Switzerland, The Netherlands, Germany, France and Italy are leading the way in Europe. Sweden even imports 700,000 tons of solid wastes each year to keep its incinerators running efficiently.

Japan which is land-poor like us in fact has the most number of incinerators, (1,243 plants constituting 70 percent of global total). Many of these incinerators are sited in high population density districts in Tokyo.

Closer to home, the tiny island city state of Singapore which generates close to 9,000 tons waste per day similar to Metro Manila has five operating incinerators.

Metro Manila is running out of dumpsites for the 9,000 tons of garbage it generates every day. The problem can only get worse. But suitable landfill sites are more and more difficult to find as the surrounding communities rise up in protest to the stench, sanitation and public order problems landfill sites bring with them.

The Clean Air Act RA (8749) shortsightedly closed the option to safely and neatly dispose municipal solid wastes by incineration which generate much needed electricity without unduly contributing to global warming and spoiling the air.

On the contrary, the residual biodegradable organic wastes burned in incinerators are really carbon-neutral and are treated by some countries as renewable sources, much like bioethanol and biodiesel, meriting tax incentives rather than being banned.

Dr. Emil Q. Javier is a Member of the National Academy of Science and Technology (NAST) and also Chair of the Coalition for Agriculture Modernization in the Philippines (CAMP). For any feedback, email eqjavier@yahoo.com.