In recent developments, the Environmental Protection Agency (EPA) has proposed stringent pollution restrictions on large trash incinerators, a move welcomed by advocates but met with skepticism regarding its impact on environmental justice. This blog delves into the intricacies of the EPA’s proposal, shedding light on the potential consequences and lingering concerns about the public health risks associated with waste-to-energy facilities.

Understanding the Proposal:

The EPA’s Jan. 11 proposal targets 57 facilities across the nation capable of burning over 250 tons of trash daily. While environmental groups applaud the effort to reduce harmful pollution and improve air quality, concerns linger over the persistent release of toxic pollutants like lead, mercury, and dioxin, known for their adverse health effects.

Environmental Justice and Community Impact:

The proposed standards aim to address the disproportionate placement of these facilities in low-income communities and communities of color. Advocates argue that despite the improvements, trash incinerators, even with advanced emission upgrades, continue to endanger the health of overburdened communities. Senay Emmanuel, a climate policy analyst, highlights the concerning asthma rates in Baltimore City, which are three times higher than the rest of Maryland.

Toxic Emissions and Health Impacts:

Trash incinerators, in addition to emitting substantial amounts of CO2, release toxic pollutants like lead, mercury, nitrogen oxides (NOx), sulfur dioxide, and PM2.5. These pollutants trigger and worsen asthma symptoms, contributing to the health crisis in affected communities. The case of Baltimore City, heavily invested in trash-to-energy incineration, serves as a stark example of the repercussions, with asthma hotspots and high hospitalization rates.

Industry Response and Regulation:

The Waste-to-Energy Association (WTEA) is cautiously reviewing the proposal, emphasizing the importance of achievable emissions limits. Thomas Hogan, WTEA’s president, defends the facilities as safe and effective waste management tools, citing their role in reducing greenhouse gas emissions and providing essential services to millions of Americans. On the other hand, critics like Mike Ewall argue that incineration is the most expensive and polluting waste management method, advocating for the closure of existing incinerators.

Analyzing the Proposed Standards:

Environmental groups, including the Energy Justice Network and the Environmental Integrity Project, express both support and disappointment regarding the proposed standards. While Leah Kelly acknowledges the overall strength of the standards, she emphasizes the need for continuous monitoring, a feature lacking in the current proposal. The EPA estimates substantial health benefits from the proposed limits, but critics argue that the standards fall short of addressing the full extent of the problem.

Environmental Justice Movement and Legislative Initiatives:

The environmental justice movement gains momentum as nonprofits, community advocates, and lawmakers push for legislative changes. The movement calls for the removal of trash incineration from Maryland’s renewable portfolio standard, diverting public funds towards alternative waste management strategies like composting.

Looking Ahead:

As the EPA opens the proposal for public comments, the debate on trash incineration continues. The proposed rule’s compliance is not required until three years after the effective date, allowing room for further discussions on the path forward. The blog concludes by emphasizing the need for a comprehensive approach that addresses the environmental and health concerns associated with trash incineration, steering towards sustainable waste management practices.

The Dangers of Trash Incineration:

To comprehend the gravity of the issue, it’s essential to delve into the specific dangers posed by trash incineration. Beyond the substantial carbon dioxide emissions, these facilities release a cocktail of toxic pollutants, including lead, mercury, nitrogen oxides (NOx), sulfur dioxide, and fine particulate matter (PM2.5). These pollutants are not only detrimental to the environment but also pose severe health risks, especially to communities residing in close proximity to these incinerators.

The Case of Baltimore City:

Baltimore City stands as a poignant example of the challenges posed by trash incineration. Despite the advanced emission upgrades, the city reports asthma rates three times higher than the rest of Maryland, directly linking the prevalence of respiratory issues to the incineration activities. The Wheelabrator Incinerator in Baltimore, in particular, has come under scrutiny, emitting significant amounts of toxic substances into the air.
In 2017, a Chesapeake Bay Foundation report estimated that the Wheelabrator facility in Baltimore caused $55 million in health damages annually. These damages are felt most acutely by communities living adjacent to the facility, struggling to cope with escalating healthcare costs. The detrimental impact on public health underscores the urgency of addressing the issue at its core.

Industry Perspectives and Regulation:

Amidst the environmental concerns, industry representatives, such as Thomas Hogan of the Waste-to-Energy Association, advocate for a balanced view. While acknowledging the need for emissions limits, Hogan asserts that waste-to-energy (WTE) facilities play a crucial role in managing waste, reducing greenhouse gas emissions, and providing essential services to millions of Americans.
Hogan contends that WTE facilities are highly regulated and have been deemed safe by multiple third-party studies. The industry’s stance revolves around the argument that incineration is a necessary component in reducing the environmental impact of waste, recycling metals lost to landfills, and offering reliable waste management services.

Contrary Perspectives and Advocacy:

On the opposing side, critics, including Mike Ewall, Executive Director of the Energy Justice Network, challenge the viability and sustainability of trash incineration. Ewall asserts that burning trash and landfilling toxic ash constitute the most expensive and polluting methods of waste management. He contends that these methods are even dirtier than burning coal, emphasizing the urgent need to close existing incinerators.
Ewall draws attention to the proposed standards’ impact on 57 of the 66 commercial trash incinerators operating in the U.S. While some facilities may need to adjust their technology, others may only require additional chemical spraying into the exhaust using existing technology. The perceived inadequacy of the proposed controls for nitrogen oxides, a major trigger for asthma attacks, raises concerns about the efficacy of the standards in addressing the full spectrum of pollutants emitted by these facilities.

Environmental Justice Movement and Legislative Initiatives:

The growing momentum of the environmental justice movement ahead of Maryland’s legislative session reflects a broader shift in public opinion. Nonprofit groups, community advocates, and some lawmakers are rallying behind legislative initiatives aimed at redefining waste management strategies. Specifically, there is a push to remove trash incineration from Maryland’s renewable portfolio standard (RPS), which currently categorizes it alongside solar and wind energy sources.
Advocates of this legislative change argue that the state has wasted $51 million over the last three years subsidizing trash incineration. The proposed Reclaim Renewable Energy bill seeks to redirect public funds toward alternative waste management approaches like composting. This legislative initiative aligns with the broader goal of steering away from environmentally harmful practices and towards sustainable alternatives.

Analyzing the Proposed Standards in Detail:

While environmental groups express support for the proposed standards, they also highlight certain areas of concern. Leah Kelly, a senior attorney with the Environmental Integrity Project, acknowledges the significant strength of the standards but expresses disappointment over the lack of new requirements for continuous monitoring.
Continuous monitoring is crucial for ensuring that emissions limits are consistently met. Kelly emphasizes that, currently, companies typically opt for stack testing only once a year, providing a limited and potentially inadequate snapshot of their emissions. The absence of continuous monitoring requirements for some of the most toxic pollutants raises questions about the efficacy of enforcement and the ability to ensure the sustained reduction of harmful emissions.
Additionally, Kelly points out that the EPA last updated these standards in 2006, and the Clean Air Act mandates a review every five years to determine if updates are warranted. The prolonged gap between updates raises concerns about whether the standards are keeping pace with advancements in technology and understanding of environmental risks.

The EPA’s Cost-Benefit Analysis:

The EPA estimates substantial health benefits from the proposed limits, particularly in terms of reductions in particulate matter and ozone. The projected benefits over 20 years amount to up to $14 billion. Furthermore, reductions in mercury, lead, and other hazardous air pollutants are anticipated to yield additional, albeit unquantified, economic and public health benefits.
While these estimates highlight the potential positive impact of the proposed standards, critics argue that they fall short of addressing the full spectrum of pollutants emitted by trash incinerators. Mike Ewall contends that, while progress is welcomed, it should not be mistaken for satisfaction when standards fail to go far enough. The call for more comprehensive measures remains central to the ongoing discourse on trash incineration and its environmental and health implications.

Public Participation and Future Implications:

As the EPA opens the proposal for public comments, it invites diverse perspectives to shape the final rule. Public participation is a crucial aspect of democratic governance, allowing stakeholders, including affected communities, industry representatives, and environmental advocates, to contribute to the decision-making process.
The proposed compliance timeline, not requiring adherence until three years after the effective date of the final rule (anticipated by the end of 2024), provides an opportunity for continued dialogue. This extended timeline allows for thorough consideration of the implications, potential adjustments, and the development of strategies to meet the proposed standards effectively.


In conclusion, the EPA’s proposed pollution restrictions on trash incinerators mark a significant step towards addressing the environmental and health concerns associated with these facilities. The ongoing dialogue between advocates, industry representatives, and regulatory bodies is crucial in shaping a future where communities can breathe cleaner air and live without the looming threats of toxic emissions from trash incineration.
While the proposed standards have garnered both support and criticism, they highlight the complex nature of waste management and the need for comprehensive solutions. The environmental justice movement’s push for legislative changes aligns with the broader goal of transitioning towards sustainable waste management practices.
As the public comment period unfolds, it becomes paramount for stakeholders to engage actively in shaping the final rule. The debate on trash incineration extends beyond regulatory compliance to encompass broader discussions on waste reduction, alternative waste management strategies, and the pursuit of a more sustainable and equitable future. The journey towards environmental justice and sustainable waste management is intricate, requiring collaborative efforts from all stakeholders to navigate the complexities of the smokestacks and foster a healthier, cleaner environment for future generations.