This CIR is an appeal to the ruling of our original CIR dated 5-25-08. Our project is inquiring on the use of a local "Energy from Waste" facility to assist in diverting waste from landfills. We are fortunate enough to have an "Energy from Waste" facility here in Onondaga County who uses the waste as fuel to power an alternative energy plant to produce energy for the local community. We intend on performing a fully executed waste management plan and only use this facility for the waste that we are unable to find a recycling source for per the US EPA hierarchy of solid waste management. While the intent states we are not to incinerate it also states that we should redirect recovered resources back to a manufacturing process. In our case, we think redirecting our non-recyclable waste to an energy manufacturing plant is the way this should be viewed. "Energy from Waste" facilities avoid the production of methane and hydrogen sulfide while eliminating the potential of leaking toxins into the groundwater, all of which are potentials of landfill usage. "Energy from Waste" facilities not only offset the dependence on fossil fuels but also prevent the production of greenhouse gases from the degrading materials in landfills. For every ton of waste used in "Energy from Waste" facilities, one ton of CO2 is prevented from entering the atmosphere compounded by the fact the fossil fuels used to manage the waste at the landfills are also avoided. This process also meets or exceeds the strictest federal standards set forth by the US EPA for their air quality emissions control systems. This is a pretreatment process which takes municipal solid waste and transfers it to combustion chambers where the heat is used to generate steam that runs a turbine to create continuous energy. Upon completion of this process all metals are recovered, totaling approx. 773,000 tons annually from all "Energy from Waste" facilities. This non-recyclable waste is reduced to 10% of its original volume during this process. The byproduct of this process is then sold to municipalities as a low grade cementitious product for use as a stabilization material. Therefore, none of this material is treated as waste and is 100% reused to better other needs of the community. This process will save on emissions based on the fact that our local landfills are further away than the "Energy from Waste" facility. The landfill is 45 miles from the project site after passing through a transfer station while the "Energy from Waste" facility is only 5 miles from our project site. This shorter distance will save on fossil fuel usage along with emissions reduction due to the shorter distance while providing a renewable source of energy for the community. This "Energy from Waste" facility would take our non-recyclable waste through a thermal conversion process to generate energy, gain access to recyclable metals and provide a beneficial reuse material for the communities surrounding the plant. This process as a whole is less destructive to the environment based on its production of three benefits versus the use of valuable landfill space and all the associated problems that come with landfills. From waste management to energy generation through renewable resources, our team feels that the benefits of "Energy from Waste" is keeping with the spirit of LEED. Our question: Can the "Energy from Waste" facility be used to assist the CWMP with waste diversion from the local landfills while contributing to earning MRC2.2?
The applicant has requested the acceptance of "energy from waste" as a means of construction waste management contributing to credit achievement. Based on the information provided, it does not appear that this practice meets the intent of the credit. While the noted benefits of energy production, reduced transportation distance and landfill emission reduction are important, there are other factors that must be considered. First, much of the methane emissions from landfills results from waste sources other than construction (residential and commercial food, and landscaping waste), so diverting construction debris from a landfill may have little effect on these emissions. Secondly, promoting "energy from waste" removes the incentive for communities to develop infrastructure and resources for the recycling and salvage of materials. Many communities have developed active recycling industries that currently support construction projects achieving 90 - 98% construction waste diversion rates while providing recycled feed stock to regional manufacturing businesses. "Energy from waste" facilities may have virtues compared to landfills, but they are not equivalent to salvage and recycling with regards to the intent and requirements of this credit. Applicable Internationally.