Comments and Testimonies

Testimony Before The Harrisburg City Council Bond Authorization Hearing for the Harrisburg Incinerator

October 31, 2000

Good evening. I am Michael Fiorentino, Harrisburg Director of Clean Air Council. The Council is a non-profit membership environmental organization dedicated to protecting everyone's right to breathe clean air. Founded in 1967, the Council works through education, advocacy and oversight to advance this goal.

City Council has an extraordinary opportunity tonight, an opportunity to say "no more" to a financial liability that is infamous for its lamentable environmental performance. Shouldn't Harrisburg be nationally and internationally known as something other than the home of the largest incinerator dioxin source in the nation?

Before deciding to authorize this $25 million bond issue, Council should pause and carefully consider a number of issues.

Is there any reason to believe this is the last time this incinerator will come to you for a handout? Tonight's bond issue is the smaller of two near term requests-the next is likely to be $60 million for the full retrofit to meet federal standards for such facilities. But the fact of the matter is that you cannot receive adequate assurance of clear sailing with this facility even after that amount of money is spent. Simply look at its history--repeated substantial expenditures beyond simple operation and maintenance as well as penalty payments to the DEP and EPA. These costs add up. Furthermore, this plant's effort to meet new standards is no guarantee of future compliance with the standards. Pollution control technology is only as good as those who operate and maintain it. Waste combustion remains an industrial process that creates huge amounts of pollution. If the controls are not engaged or functioning optimally, then the dangerous chemicals are released to the air. If the controls work as intended, then the city is left with even more potent incinerator ash to dispose of.

In addition, the $60 million retrofit is no guarantee to unfettered operation for the life of the plant. Though EPA sometimes allows facilities to do the best they can with the technology that prevailed in the era in which construction took place, there is no regulatory certainty that EPA won't require a major upgrade 10 or 15 years down the road. What would happen if, with substantial remaining debt, the incinerator revenue stops due to a future federal or state standard?

Incineration is a flawed and dangerous means of handling municipal waste. This city must embrace the future, and the future is waste reduction, reuse and recycling. It is extremely counter-productive environmentally to burn materials which can be recycled. Recycling avoids the pollution and degradation caused by the extraction and processing of virgin materials. It also avoids the pollution caused by the act of incineration itself. Organics, like dioxins that resulted in the evacuation of Times Beach, heavy metal poisons like mercury and lead, and acid gases like hydrogen chloride-all of these pollutants take an unacceptable toll on human health.

Another consideration worthy of pause is the fact that there is no certainty that this plant will be given the green light to operate after December 19 short of a full retrofit. The city is attempting to work out a suitable plan to "de-rate" the plant and keep it running. But if DEP and EPA do not appear to have great enthusiasm for the city's proposal, it's no small wonder. Acceptance of the city's plan requires a questionable interpretation of the federal regulations, one vulnerable to challenge.

The city wants to draw waste from other municipalities and even other states to burn. It's outrageous. This proposed 720-ton incinerator far exceeds Harrisburg's disposal needs. Even though Dauphin Meadows landfill may no longer be an option, Pennsylvania has a tremendous surplus in permitted daily capacity at its landfills. It is better to improve the recycling programs here, encourage waste reduction and fully utilize the new transfer station. Economists should identify the advantages this option would hold over the huge new investment in the incinerator, and all the operations and maintenance costs and increased ash disposal costs concomitant with continued burning.

The incinerator repeatedly violates its permit and spews poisons into the air. Why should the good working class and low-income residents of the city be exposed to these toxins? Why should anyone? When in society, an individual repeatedly violates the law, that person is taken off the streets-sometimes for good. Why shouldn't the same standard apply to a recalcitrant polluter? Throwing more money at this plant is not the answer.

Clean Air Council urges this deliberative body to close an unfortunate financial and environmental chapter in the city's history by refusing additional funding for this obsolete facility. Thank you for the opportunity to comment on this matter.