Comments posted on behalf of Jody Smith Williams, submitted to
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Dear DEP Secretary Sole, DEP staff, and all interested parties:

Please enter the following as my comment for the public meeting tomorrow. They are identical to comments entered by Tina Henize, as I cannot improve on her clear and informed remarks. I respectfully request that you give your full consideration and exclude Waste-to-Energy from any recycling goals.

We want to see a true 75% recycling rate in Florida. This is a lofty goal and may not be possible with true recycling. But, using waste-to-energy and burning landfill gasses to fulfill this goal is not the honest way to reach the rate.

The definition of renewable fuel must exclude Municipal Solid Waste(MSW). It stretches truth to use MSW burned for waste-to-energy (WTE) or the biomass in landfills producing combustible gas as part of a recycling rate; it is simply not recycled, and much of it is not recyclable. Ever. Doing so is a subterfuge, injects more toxic chemicals into our environment, undermines 'green' industry and jobs, and ultimately is an insult to us, the Florida public.

The only advantage of using WTE and landfill gas burning as part of the recycling rate is for the bottom line of the big waste handlers. Recycling, true recycling, is a lot of work, involves much coordination, and provides a lot of jobs directly and down the line within associated industry. For waste handling companies, however, it is simpler and cheaper to burn, burn, burn.

In 2008, the Florida legislature adopted a goal of 75% recycling of MSW by 2020. Unfortunately, the law stated that waste used for producing renewable energy would count towards the goal. The State already had legislation that claimed MSW was a renewable fuel, although a significant part of the energy in MSW comes from non-renewable plastics made primarily from fossil natural gas or petroleum.

The US Energy Information Administration has calculated the fraction of the energy in MSW from renewable and non-renewable sources. Since the non-renewable part comes mostly from plastics that constitute up to 15% of MSW and have about three times as much energy as other components, the non-renewable fraction of MSW energy is now at about 50% of the total. In Florida, it's over 50% because many tourists consume large quantities of drinks bottled in plastics.

Florida now incinerates 12% of MSW, so with the stroke of a pen, state authorities have recently added 12% to the current recycling rate. Counting all that is burned as recycling adds injury to insult since "waste-to-energy" plants recover only 19% of the energy. The remaining 81% is lost in burning the valuable resources, with 40% (by weight) left to be landfilled. And now we see that landfill gasses are to be burned for energy and also thus used to bump up the recycling rate.

The best way to recover the energy from waste material is to recycle it. Most of the energy in MSW is supplied by three materials: paper, cardboard, and plastics. According to EPA data, recycling these saves three to five times as much as the energy obtained using them as fuel.

It is a fact that for every material in MSW, recycling saves more energy than can be generated by using it as fuel. Waste-to-energy is wasted energy! Imagine the absurdity of a campaign to increase recycling by burning more waste.

"Wet-stream" organic waste that constitutes 25-30% of MSW is a very poor fuel because of its very low heating value. In contrast, anaerobic digestion (AD) is an efficient, natural process for handling organic wastes that produces methane fuel and captures the nutrients in the digestate as well. For the State, AD of the wet-stream waste would produce over 500 MW, enough to power 400,000 homes.

Some components of MSW, particularly glass and metals that do not "burn", produce no energy in WTE plants. The aluminum and glass are destroyed and must be replaced from virgin materials. Aluminum requires so much energy to process from bauxite that recycling a ton would save over ten times as much energy as is provided from burning a ton of waste.

Industries using recycled materials employ ten times as many workers as WTE plants. For the entire State, recycling at 75% would support over 100,000 high-paying jobs with an annual payroll of up to $6 billion. These are permanent jobs that can not be outsourced, and would help reduce Florida's high unemployment rate.

Incineration and landfill gas burning is disposal technology, not recycling, and should not be labeled as such. Florida cannot change this fact by passing a law claiming that it is. Whatever fraudulent claim Florida makes for its recycling rate will not be accepted by real recyclers; Florida will be denounced nationally as a recycling fraud.

Thank you for accepting my comments.

Jody Smith Williams
1211 Watson St.
Key West, FL 33040
Green Living & Energy Education (GLEE)
Last Stand