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Hennepin Energy Recovery Center [HERC]:

Reevaluating Waste Management in Minneapolis
A Minnesota Public Interest Research Group Report
Authors: Emma Wright Joshua Winters, MS Ryan Kennedy

Minnesota Public Interest Research Group

[HERC] Reevaluating Waste Management in Minneapolis

Foreword
A special thanks for this report goes to Emma Wright for her tireless work in doing the primary research and drafting this report. Additional thanks goes to Dakotah Johnson, Jamison Tessneer, Joshua Winters (MS Science, Technology, and Environmental Policy), and Ryan Kennedy for their thoughtful feedback and guidance in the development of this report.

[HERC] Reevaluating Waste Management in Minneapolis 3

Table of Contents

Executive Summary ................................................................................................................................................... 4 Introduction ................................................................................................................................................................. 6 History of the Hennepin Energy Recovery Center ........................................................................................ 7 Air Emissions ............................................................................................................................................................... 8 Public Health .............................................................................................................................................................. 11 Greenhouse Gas Emissions ................................................................................................................................... 16 Toxic Ash Disposal ................................................................................................................................................... 19 The Cost of Incineration ........................................................................................................................................ 20 Environmental Assessment Worksheet Inadequacies: ............................................................................. 22 A Path Forward ......................................................................................................................................................... 23 Conclusion ................................................................................................................................................................... 28 Recommendations ................................................................................................................................................... 28

[HERC] Reevaluating Waste Management in Minneapolis

Executive Summary
In 1989, Minneapolis became one of the few cities in the nation to approve and build a municipal waste incineration facility after the Clean Air Acts adoption. Covanta Energy, a multinational corporation that operates waste incineration facilities throughout the world, operates the Hennepin Energy Recovery Center (HERC). In the context of the Environmental Protection Agencys solid waste management hierarchy, only landfill disposal is less preferred than incineration. Covanta is seeking to expand the amount of waste burned by 212 tons a day, which would bring the facility to full capacity. This report seeks to outline the consequences and concerns related to garbage incineration at-large as well as those presented by the proposed 20% increase in waste burned. Further, this report outlines the very alternatives we should be pursuing as a better solution to our waste management challenges.

Key Findings:
The Hennepin Energy Recovery Center generates significant quantities of health damaging air pollutants. 1. When aggregating the health damaging air pollutants regulated by the Minnesota Pollution Control Agency, HERC is Minneapolis top polluter by pounds of emissions. 2. The amount of health damaging air pollutants emitted per megawatt generated is higher than any coal, oil or natural gas fired plant. 3. The pollutants monitored by HERC are self-reported, with permits issued based substantially off of estimates. The emissions monitoring system used by HERC uses estimates, not actual emissions, to determine permit compliance for most emissions. The toxins emitted are a public health concern and disproportionally effect lower income communities and children. 4. HERC is a significant source of many toxins in Minneapolis, including but not limited to mercury, NOx, SOx, dioxins, furans, and particulate matter. 5. The health damaging air pollutants emitted affect the lungs of children disproportionally, as they are still developing. There are eighteen elementary schools within two miles of the HERC stack. 6. Communities within a two-mile radius of the HERC stack have rates of asthma hospitalizations that are significantly higher than those of Minneapolis as a whole. The materials being incinerated have not been efficiently managed up the waste stream. 7. Over half (51.5%) of the materials burned at HERC are recyclables. 8. Nearly an additional third (32%) of the materials are organics. 9. Most of the other waste is comprised of materials with established disposal methods other than incineration.

[HERC] Reevaluating Waste Management in Minneapolis 5

Conclusions:
Based on these considerations and others found in the report, MPIRG would strongly recommend the following: 1. The Minneapolis City Council should deny Covanta the conditional use permit to increase waste incineration at HERC by 20%, or 212 tons of garbage per day, as the citys comprehensive plan dictates negative health effects to Minneapolitans should be avoided in zoning decisions. 2. The City of Minneapolis should move towards curbside composting as a waste reduction strategy to remove the 32% of incinerated materials that are organics. 3. The City of Minneapolis should continue its efforts to streamline recycling to increase participation rates and remove the 51.5% of incinerated materials that are recyclables. 4. Hennepin County and the City of Minneapolis need to seriously consider how HERC fits in the current waste management scheme. The key consideration being the rather perverse incentive that HERC creates by allowing for improperly sorted waste from across Hennepin County to be burned. By doing so, not only does Minneapolis bear the brunt of air pollution deposition, it also reduces the incentive that other cities have to reduce their waste through recycling and composting. 5. Failing these other policy recommendations, at the barest minimum a full EIS should be required to determine the extent of negative health effects.

[HERC] Reevaluating Waste Management in Minneapolis

Introduction
Waste brought to HERC is trucked in by waste haulers from the Minneapolis community and other areas within Hennepin County, where it is processed and burned. The Minneapolis waste incineration facility is what the industry considers a waste-to-energy facility because it generates electricity; as waste is burned the heat turns water into steam, which then powers a generator. But the waste also produces three main by-products: air emissions, toxic ash, and ferrous recycled metals. Because the exact content of each load of waste is unknown, it is nearly impossible to know the chemical composition of the ash and air emissions.1 The Environmental Protection Agency and the Minnesota Pollution Control Agency have adopted a waste hierarchy as follows for the order of the best waste management options possible:2 Waste reduction and reuse Recycling Composting Resource recovery, including waste-to-energy or waste composting Landfilling with methane recovery Landfilling without methane recovery Incineration is one of the bottom-tiered methods of waste management. Despite that, Covanta is seeking to expand the amount of waste burned by 212 tons a day, which would bring the facility to full capacity. Incineration may be above land filling on the waste hierarchy, but it doesnt follow that it should be the waste disposal method of choice. That waste could be reduced, reused, recycled or composted. These very alternatives were expected to be increased when the HERC facility was first built, as a temporary waste-management solution to supplement new recycling and waste reduction efforts. By focusing on burning and landfilling alone, there is a false choice. Better than a landfill is not good enough for the communities subjected to the pollution from HERC; responsible waste management plans for Minneapolis have always treated HERC as a temporary solution while recycling and composting capacity became more available. Nearly a quarter-century after HERCs boilers came online, it is more critical than ever to reevaluate our waste management strategies to divert recyclables and compostables from incineration. In the following report, the Minnesota Public Interest Research Group will examine the history of HERC, the air emissions produced, the cost to Minneapolis, and alternative means of waste disposal.

Combs, Susan. "Municipal Waste Combustion." Http://www.window.state.tx.us/. Web. 09 Nov. 2011. <http://www.window.state.tx.us/specialrpt/energy/renewable/municipal.php>. 2 Hennepin County Environmental Services. "The Hennepin Energy Recovery Center: A Waste-to-Energy Facility." Http://hennepin.us/. Hennepin County, Minnesota, 2009. Web. 15 Nov. 2011. <http://hennepin.us/herc>.

[HERC] Reevaluating Waste Management in Minneapolis 7

History of the Hennepin Energy Recovery Center

1985 An Environmental Impact Statement (EIS) completed for HERC 1989 HERC constructed, gains approval of needed air permits and begins operating3 2001 Covanta Energy fined $22,000 for excess hydrochloric acid emissions4 2002 Covanta Energy fined $15,000 for excessive mercury emissions from HERC5 2003 MPCA issues a Letter of Warning6 2003 HERCs Air Quality Permit Expires and has NOT been reissued7 2004 Covanta fined $4,200 because operators lack required certification 8 2009 Covanta verbally admits they would have to reduce dioxins to comply with new permit expectations9 2009 The Minneapolis Planning Commission rejects a Conditional Use Permit (CUP) application from Covanta and Hennepin County in June, in part because of insufficient environmental review. The Commission, in denying the CUP, states "increasing the capacity of the garbage burner, in all probability could be detrimental to public health, safety, community and general welfare.10 2009 Six state legislators send a seven-page letter to the members of the Minneapolis City Council opposing the expansion of HERC11 2011 The PCA cites 27 areas in which Covanta's documents "do not contain all of the information that is needed in order to continue to process the HERC Environmental Assessment Worksheet and air emission permit modification application."12 2013 Covanta continues to require extensions to complete the Environmental Assessment Worksheet

3 4

Hennepin County Environmental Services. MPCA Enforcement Files 5 "Citizen's Petitions for an EAW for HERC Expansion." Letter to Craig Affeldt, Supervisor Environmental Review Unit. 08 Sept. 2009. Pca.state.mn.us. Minnesota Pollution Control Agency, 11 Sept. 2009. Web. 20 Nov. 2011. 6 Ibid 7 Ibid 8 Ibid 9 Minneapolis Planning Commission Minutes. June 23, 2009. 10 Ibid. 11 State Representatives, Frank Hornstein, Jean Wagenius , Jim Davnie , Bobby Joe Champion , Diane Loeffler , Patricia Torres Ray , and D. Scott Dibble. "Hennepin County Recovery Center's Conditional Use Permit Proposal." Letter to Minneapolis City Council Members. 16 July 2009. MS. Minnesota House of Representatives, St. Paul, Minnesota. 12 Frank Hornstien, State Representative. "Request for an Environmental Impact Statement on the Hennepin Energy Recovery Center." Letter to Mike Opat, Chair, Hennepin County Board of Commissioners. 14 Apr. 2011. Minnesota House of Representatives, St. Paul, Minnesota.

[HERC] Reevaluating Waste Management in Minneapolis

Air Emissions
Despite requisite filters and precautions for a facility of its age and design, HERC produces a significant amount of pollution, ranking as one of the top point-source polluters in Minneapolis. These pollutants have significant health and environmental impacts on local communities, yet many go unregulated. In addition to direct health impacts on the community, the incinerator emits copious amounts of greenhouse gases, contributing to the larger problem of global climate change.

Point Source Pollution in Minneapolis

HERC is the number one known point-source producer of air toxin emissions in Minneapolis, and ranks as one of the top five point-source emitters for 5 of the 7 criteria pollutants identified by the Minnesota Pollution Control Agency.13 Covantas proposed 20% increase in burning at HERC does not come with a plan to keep pollutants emitted at current levels. This increase comes at a high cost compared to the amount of energy generated, especially when considering the known emissions.

HERCs Emission Track Record at a Glance

2002: Produced 51.89% of Dioxins emitted in Minnesota. 14 2005: Produced a total of 111,761 pounds of health damaging air pollutants; the next closest point source polluter was Xcel Energys (now retired) Riverside Generating Plant, which generated 96,327 lbs of emissions. Further, the health damaging air emissions are dramatically higher per unit of energy generated, with HERC producing 2,824 lb/megawatt generated versus 119 lb/megawatt generated at the Riverside Plant.15 See page 9 for table comparing emissions per megawatt generated to the Riverside Generating Plant. 2009: Top producer of nitrogen oxides (NOX), a criteria air pollutant, generating 553 tons.16 The 2nd highest emitter of Mercury in Minneapolis. The 4th highest emitter of carbon monoxide, lead, and particulate matter 10, all of which are criteria pollutants in Minneapolis. The 5th highest generator of sulfur dioxide in Minneapolis. The 8th highest producer of Particulate Matter, a criteria pollutant in Minneapolis.

13 14

Minnesota Pollution Control Agency. Point Source Air Emissions 2005 & 2009. Raw data. Minnesota, Minneapolis. "Citizen's Petitions for an EAW for HERC Expansion." 15 MPCA Point Source Air Emissions 2005. Raw data. 16 MPCA Point Source Air Emissions 2009. Raw data.

[HERC] Reevaluating Waste Management in Minneapolis 9 Table 1: Emissions Generated per Megawatt of Energy (Coal v. Incineration)17
Energy Generated (Megawatts) Total Pounds of Health Damaging Air Emissions/ Year Pounds of Health Damaging Air Emissions /Megawatt Generated 2,823.674 Pounds of Mercury Emitted/ Year Pounds of Mercury/ Megawatt Generated Tons of NOX / Year Tons of NOX/ Megawatt Generated

HERC (incineration) Riverside Generating Facility (Coal fired)

39.58

111,761.029

9.83101

.24838

552.888

13.960

511

96,327.206

118.507

105.7966

.20704

45.487

.089

As illustrated in Table 1, The HERC incinerator generates significantly more health damaging air pollutants and criteria pollutants per megawatt of energy than the former Riverside Generating Facility, which was coal powered in 2007, and retired in 2009.18 Table 2: Air Emissions from HERC by Pollutant19
Potential to Emit Tons Per Year 94.2 94.2 100 881.2 261.6 26.2 1 98.8 0.126 0.09 7.35 x 10-5 94.2 2007 Actual Emissions Tons Per Year 8.09 8.09 9.52 539.96 49.98 1.14 0.00684 65.01 0.00294 0.00101 1.33 x 10-6 8.09 2008 Actual Emissions Tons Per Year 25.7 25.7 13.05 525.99 48.31 0.87 0.00233 52.74 0.00358 0.000317 3.29 x 10-6 25.7 2009 Actual Emissions Tons Per Year 16.98 16.98 11.69 552.87 39.45 0.58 0.00114 52.77 0.00484 0.00115 5.23 x 10-6 16.98 Projected Actual Emissions Tons/Year 30.2 30.2 15.3 530 56.8 1.3 0.008 76.4 0.0057 0.0014 6.14 x 10-6 30.2

Pollutant Particulate Matter Particulate Matter 10 Sulfur Dioxide Nitrogen Oxide (NOX) Carbon Monoxide Volatile Organic Compounds Lead Hydrochloric Acid Mercury Cadmium MWC Dioxins/Furans MWC Metals

Table 2 shows the emissions of HERC, as self-reported, in comparison to the potential the facility has to emit. Though reported emissions often of allowed potential, each pollutant is significant in its environmental and public health impacts. See pages 11-12 for a list of health effects directly linked to each pollutant.
17 18

Minnesota Pollution Control Agency. Xcel Energy Inc. "Riverside Generating Station." Xcelenergy.com. 2012. Web. 28 Oct. 2011. <http://www.xcelenergy.com/About_Us/Our_Company/Power_Generation/Riverside_Generating_Station>. 19 Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency. Hennepin Energy Recovery Center Environmental Assessment Worksheet Draft. Draft V. Minneapolis, 04 Dec. 2009.

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[HERC] Reevaluating Waste Management in Minneapolis

Issues with Accuracy of Emission Data

Although four of the toxins emitted from HERC are tracked by continuous emission monitoring (CEM) systems, the other pollutant estimates are only based off four yearly measurements taken at Covantas discretion. All permits and data are based off calculations from these self-reported estimates, which attempt to predict annual emissions by extrapolating these four snapshot measurements. This practice fails to measure the actual impact HERC has on air quality in Minneapolis and surrounding communities. For example: when startup, shutdown, and malfunctions occur, emission changes are usually not reported. 20 A committee of the National Academy of Sciences observed in a report published in 2000: Such upset conditions usually occur during incinerator startup or shutdown when the composition of the waste being burned changes sharply. Upset conditions can also be caused by malfunctioning equipment, operator error, poor management of the incineration process, or inadequate maintenance.21 Following industry expert Alan Mullers review of HERC records, he shared that it: Revealed many upsets, many but not all resulting from failed boiler tubes. Boiler tubes fail due to some combination of inadequate maintenance and the burning of highly corrosive fuels such as garbage. A tube failure injects large amounts of steam/hot water into the combustion chamber, severely disturbing combustion conditions and causing very high emissions which can last for hours.22 The draft Environmental Assessment Worksheet (EAW) of HERC thus far does not provide enough information to determine how close these estimates are to the actual emissions. Even when the draft EAW is complete, it will lack these real emission measurements. It has been indicated that the final EAW will include dispersion and deposition data relating to HERC emissions. If so, this would be a major step forward assessing the true impacts that HERC has on Minneapolis and surrounding communities. Even so, given the magnitude of known health damaging air emissions from HERC and potential health impacts, only a comprehensive Environmental Impact Study (EIS) is capable of providing sufficient information to the public, and for assessing alternatives. With the information provided by the EIS, Hennepin County and the City of Minneapolis can more accurately assess the health impacts of an increase in waste incineration.

20 21

"Citizen's Petitions for an EAW for HERC Expansion." Waste Incineration and Public Health. National Academy of Sciences. http://books.nap.edu/catalog.php?record_id=5803 22 "Citizen's Petitions for an EAW for HERC Expansion."

[HERC] Reevaluating Waste Management in Minneapolis 11

Public Health
With an increase in materials burned, Minneapolis and surrounding communities can expect to see a proportionate increase in emissions. Although these increased emissions are not likely enough (in isolation) to push Minneapolis into nonattainment of federal air standards, these standards only reduce health concerns; they do not eliminate health issues. As shown in Table 3 below, emissions from HERC have significant health consequences when introduced to human lungs.

Table 3: Health effects of HERC Pollutants

Pollutant
Nitrogen oxides (NOx) Carbon monoxide (CO)

Health Effect
Low levels of nitrogen oxides in the air can irritate your eyes, nose, throat, and lungs, possibly causing you to cough and experience shortness of breath, tiredness, and nausea.23 CO can cause harmful health effects by reducing oxygen delivery to the body's organs (like the heart and brain) and tissues. At low concentrations, fatigue in healthy people and chest pain in people with heart disease. 24

Rate Monitored
CEM System (Greenhouse Gas & Criteria Pollutant) CEM System (Criteria Pollutant)

Sulfur dioxide (SO2)

Children who live in or near heavily industrialized areas where CEM System sulfur dioxide occurs may experience difficulty breathing, (Criteria changes in the ability to breathe deeply, and burning of the nose Pollutant) and throat. Children may be exposed to more sulfur dioxide than adults because they breathe more air for their body weight than adults do. Long-term studies surveying large numbers of children indicate that children who have breathed sulfur dioxide pollution may develop more breathing problems as they get older, may make more emergency room visits for treatment of wheezing fits, and may get more respiratory illnesses than other children. Children with asthma may be especially sensitive even to low concentrations of sulfur dioxide.25

Particulate
23

Exposure is linked to a variety of issues including: irritation of

Estimate

"ToxFAQs for Nitrogen Oxides." Agency for Toxic Substances and Disease Registry. CDC, 23 Mar. 2011. Web. 25 Oct. 2011. <http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=396&tid=69>. 24 "Basic Information on IAQ: Carbon Monoxide (CO)." EPA. Environmental Protection Agency, 12 Apr. 2011. Web. 25 Oct. 2011. <http://www.epa.gov/iaq/co.html>. 25 "ToxFAQs for Sulfur Dioxide." Agency for Toxic Substances and Disease Registry. CDC, 23 Mar. 2011. Web. 26 Oct. 2011. <http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=252&tid=46>.

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[HERC] Reevaluating Waste Management in Minneapolis the airways, coughing, and difficulty breathing, reduced lung function, aggravated asthma, chronic bronchitis, irregular heartbeat, nonfatal heart attacks, and some cancers.26 Eye, nose, and throat irritation; headaches, loss of coordination, nausea; damage to liver, kidney, and central nervous system. Some organics can cause cancer in animals; some are suspected or known to cause cancer in humans.27 Lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems and the cardiovascular system. Lead exposure also affects the oxygen carrying capacity of the blood.28 based on four days a year (Criteria Pollutant) Estimate based on four days a year

Matter (PM)

Volatile organic compounds (VOC) Lead (Pb)

Hydrochlori c Acid (HCI)

Mercury

Cadmium

MWC Dioxins & Furans

Estimate based on four days a year. Pb is a bioaccumulating substance (Criteria Pollutant) Chronic occupational exposure to hydrochloric acid has been EPA has not reported to cause gastritis, chronic bronchitis, dermatitis, and established a photosensitization in workers. Prolonged exposure to low Reference concentrations may also cause dental discoloration and Dose for 29 erosion. hydrochloric acid. Impaired neurological development for children. Mercury Estimate exposure at high levels can harm the brain, heart, kidneys, based on four lungs, and immune system of people of all ages.30 days a year Long-term exposure to lower levels of cadmium in air, food, or Estimate water leads to a buildup of cadmium in the kidneys and possible based on four kidney disease. Other long-term effects are lung damage and days a year fragile bones.31 Are persistent, bioaccumulated and likely to be human Estimate carcinogens and are anticipated to increase the risk of cancer at based on four background levels of exposure.32 days a year

26

"Particulate Matter (PM)." EPA. Environmental Protection Agency, 23 Mar. 2012. Web. 09 Apr. 2012. <http://www.epa.gov/pm/health.html>. 27 "Volatile Organic Compounds (VOCs)." EPA. Environmental Protection Agency. Web. 25 Oct. 2011. <http://www.epa.gov/iaq/voc.html>. 28 "Lead." EPA. Environmental Protection Agency, 29 Mar. 2012. Web. 09 Apr. 2012. <http://www.epa.gov/lead/>. 29 "Hydrochloric Acid (Hydrogen Chloride)." EPA. Environmental Protection Agency, Jan. 2000. Web. 25 Oct. 2011. <http://www.epa.gov/ttn/atw/hlthef/hydrochl.html>. 30 "Health Effects of Mercury." EPA. Environmental Protection Agency, 7 Feb. 2012. Web. 09 Apr. 2012. <http://www.epa.gov/mercury/effects.htm>. 31 "ToxFAQs for Cadmium." Agency for Toxic Substances and Disease Registry. CDC, 3 Mar. 2011. Web. 25 Oct. 2011. <http://www.atsdr.cdc.gov/toxfaqs/TF.asp?id=47&tid=15>. 32 "Dioxins and Furans." EPA. Environmental Protection Agency, 18 Apr. 2011. Web. 25 Oct. 2011. <http://www.epa.gov/pbt/pubs/dioxins.htm>.

[HERC] Reevaluating Waste Management in Minneapolis 13 Heath Concerns about Dioxins, Furans and Particulate Matter Two pollutants considerably harmful to human health, dioxins and furans, are among the toxins emitted during the incineration process. Incinerators cause significant emissions of dioxin and other chlorinated organic compounds that have well known toxic impacts on human health and the environment.33 Dioxins are known carcinogens at low doses and bioaccumulate over time, so communities in the vicinity of an incinerator continue to store these harmful pollutants each time they are introduced in their bodies. 34 Particulate matter (PM) is a criteria pollutant that is made up of very small particles that penetrate lungs and cause adverse health effects. These health problems include asthma, lung cancer, cardiovascular issues and premature death.35 The matter is categorized based on size. PM is the name of particulate matter emitted, and is labeled with a number that describes the size of the particle. PM 10 is one of the smaller particles. It is these respirable particles, and especially the ultrafine particles, which can reach the deepest regions of the lungs, and which are thought to be responsible for causing adverse impacts on human health.36 The majority of particulate matter from incinerators is ultrafine in size, and current air pollution control devices on incinerators only prevent 5 to 30% of the respirable (<2.5 m) sized particles from entering the atmosphere, and can do very little to prevent ultrafine (<0.1 m) particulates from escaping.37 The permits for PM 2.5 have changed since Covantas permit expired and Covanta has openly admitted that it has not made adequate changes to its control devices to meet current EPA permitting standards.38

Environmental Justice Issues

Many waste incineration facilities are built in vulnerable communities that are already subject to high levels of pollution from the numerous industrial facilities in the area. Therefore, studies seeking to examine the effects of incineration in these communities have difficulty distinguishing the point-sources of the health problems. Only a limited number of studies have been conducted on the human health impacts of incineration, and these have primarily focused on the impacts of dioxins and furans. [Waste incineration] Studies are restricted to investigations of exposure to dioxins and heavy metals. Results of these studies are mixed.

33

Platt, Brenda, David Ciplet, Kate M. Bailey, and Eric Lombardi. Stop Trashing The Climate. Rep. Institute for Local Self-Reliance, June 2008. Web. Nov. 2011. <www.stoptrashingtheclimate.org> pg. 43. 34 Dioxins and Furans." E.P.A. 35 "Particulate Matter (PM)." 36 Allsopp, Michelle, Pat Costner, and Paul Johnston. Incineration and Human Health: State of Knowledge of the Impacts of Waste Incinerators on Human Health. Issue brief. Green Peace Laboratories, University of Exeter, UK., Mar. 2001. Web. Dec. 2011. http://www.greenpeace.org/international/Global/international/planet2/report/2001/2/incineration-and-human-health.pdf 11. 37 Platt, Brenda, David Ciplet, Kate M. Bailey, and Eric Lombardi 43. 38 State Representatives, Frank Hornstein, Jean Wagenius , Jim Davnie , Bobby Joe Champion , Diane Loeffler , Patricia Torres Ray , and D. Scott Dibble.

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[HERC] Reevaluating Waste Management in Minneapolis

Some reported elevated exposure among nearby residents while others found no evidence of increased exposure.39 Map 1: Average per capita income in communities surrounding HERC

HERC

Tables 1 and 2 were created at the request of Representative Karen Clark (District 62A)

39

Allsopp, Michelle, Pat Costner, and Paul Johnston 25.

[HERC] Reevaluating Waste Management in Minneapolis 15 Map 2: Asthma hospitalizations per 10,000 people in communities surrounding HERC

HERC

As seen in Maps 1 and 2, the residential areas within a two-mile radius surrounding HERC is primarily low-income and has high levels of asthma hospitalizations. With an expanded permit, the negative health effects of air pollution can be expected to increase. Although many studies confound data about incineration in general, scientists have directly linked toxins like particulate matter and sulfur dioxide to diseases like asthma and other chronic health problems. The average rate of asthma hospitalizations for the United States is 17 per 10,000 people in the most recent data from 2004.40 As can be seen in Map 2, the majority of the communities around the HERC have over 41 asthma hospitalizations with some areas as high as 200+ hospitalizations due to asthma per 10,000 people. This data also indicates what scientists have known for some time; childhood exposure to pollutants increases with decreasing socioeconomic status.41

"Asthma Prevalence, Health Care Use and Mortality: United States, 2003-05." CDC. Centers for Disease Control and Prevention, 06 Apr. 2010. Web. 4 Nov. 2011. <http://www.cdc.gov/nchs/data/hestat/asthma03-05/asthma0305.htm>. 41 "The Biology of Disadvantage: Socioeconomic Status and Health." ANNALS OF THE NEW YORK ACADEMY OF SCIENCES 1186.1 (2010): 1-275. Web. <http://onlinelibrary.wiley.com/doi/10.1111/nyas.2010.1186.issue-1/issuetoc>.

40

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[HERC] Reevaluating Waste Management in Minneapolis

Children and Air Pollution

There are eighteen elementary schools operating within a two-mile radius of the Hennepin County incinerator. Children are disproportionately affected by air pollution due to their size, rate of breath, and type of breathing. Children typically breathe fast and through their mouth, which allows them to take in air quicker and without the nose as a filter for pollution.42 With significant, consistent exposure to the pollutants emitted, Minneapolis children are the population at highest risk to feel the negative health effects of the diminished air quality. Children tend to be especially vulnerable to criteria pollutants, including particulate matter. Studies have also shown that criteria pollutants can affect lung function and growth for exposed children. High levels of PM exposure can trigger an asthma attack faster in children due to irritation and inflammation in their small airways.43 This exposure can also cause damage in the long run. Irritants and toxicants present in air and water can result in cellular and molecular level damage that, when initiated during childhood or adolescence, could create vulnerabilities to future disease.44 It should also be noted that the impacts of HERC extend well past the City of Minneapolis and Hennepin County. Though these two governmental bodies have direct authority over the facility and the proposed expansion, they are not the only communities impacted. The diffuse nature of pollution from HERC warrants broader consideration about all the communities impacted by this proposal. Finally, HERC collects and burns garbage from all municipalities in Hennepin County, creating a perverse incentive that works counter to the preferences contained in the solid waste management hierarchy put forward by the MPCA. Even if cities like Minneapolis choose to adopt policies that encourage residential composting and other zero-waste initiatives, HERC will continue to work at full capacity. This means that if Minneapolis does a better job of managing and reducing waste, its citizens will still be subject to the air pollutions from HERC pollution that comes from surrounding cities.

"OEHHA Air: Air Pollution and Children's Health." Oehha.ca.gov/. Office of Environmental Health Hazard Assesment, 26 Nov. 2003. Web. 04 Dec. 2011. <http://oehha.ca.gov/public_info/facts/airkids.html>. 43 "OEHHA Air: Air Pollution and Children's Health." 44 "The Biology of Disadvantage: Socioeconomic Status and Health." ANNALS OF THE NEW YORK ACADEMY OF SCIENCES 1186.1 (2010): 1-275. Web. <http://onlinelibrary.wiley.com/doi/10.1111/nyas.2010.1186.issue-1/issuetoc>.

42

[HERC] Reevaluating Waste Management in Minneapolis 17

Greenhouse Gas Emissions

Greenhouse gasses are chemicals that trap heat inside the earths atmosphere and contribute to global climate change. The main greenhouse gas contributors produced from the incineration process are carbon dioxide (CO2), methane, nitrogen oxides (NOx), hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. They are reported as CO2 equivalent (CO2e) in Table 4 from the draft HERC EAW.45 Despite being considered an innovative energy solution in some states, waste-to-energy plants in the U.S. emit more carbon dioxide per megawatt-hour than coal- fired, natural-gas fired, or oil-fired power plants. 46 Table 4: Carbon Dioxide (CO2) Emissions Data from Draft HERC EAW

The analysis and modeling of greenhouse gas emissions from municipal solid waste combustion (MSW) in Table 4 only includes scope 1 & 2 emissions, which are the two types of emissions in direct control of the facility. Covantas draft EAW for HERC fails to report or model the scope 3 greenhouse gas emissions, which include the activities and shipment of waste before and after its time at the Center. 47 This is a major deficiency in that HERC receives waste not only from Minneapolis, but from its neighboring cities in Hennepin County. As a result, transportation of that waste and emissions related to the transportation must be measured to assess HERCs full impact.

45 46

Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency 31. Eureka Recycling. Recycling, Composting and Greenhouse Gas Reduction Minnesota. Eureka Recycling. Web. 5 Nov. 2011. http://www.eurekarecycling.org/pdfs/Composting_Recycling_GreenhouseGases.pdf 2. 47 Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency 31.

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[HERC] Reevaluating Waste Management in Minneapolis

In 2007, the Minnesota legislature passed the Next Generation Energy Act, with the goal of reducing greenhouse gas emissions among all sectors by 15% below 2005 levels by 2015, 30% by 2020, and 80% by 2050.48 Increasing the waste burned in the incinerator will significantly increase greenhouse gas emissions and is converse to the goals of this Act. The proposed expansion would increase the amount of CO2 emitted from the incinerator by 53,701 tons of CO2e, which is equivalent to consuming 113,295 barrels of oil, using 9,552 passenger vehicles for a year, or sequestered by 10,387 acres of fir-tree forest. 49

48 49

Minnesota Statutes 2008, section 216H,02, subdivision 1. http://www.epa.gov/cleanenergy/energy-resources/calculator.html#results

[HERC] Reevaluating Waste Management in Minneapolis 19

Toxic Ash Disposal

The first law of thermodynamics states that energy or matter can neither be created nor destroyed. Although the concept is simple, it is important to keep in mind that waste does not disappear when burned. When municipal solid waste is burned in an incinerator, about 20% or approximately 400lb/ton remains as ash. 50 Throughout that process, heat is generated and it releases matter and gases into the air. 51 The remaining waste is classified into two categories: fly ash and bottom ash, both of which are concentrated forms of the waste burned.52 The fly ash is concentrated debris from pollutant filters, typically containing toxic metals and organic matter. The majority of the ash remaining from the incineration process is called bottom ash, which makes up about 80-90% of incinerator weight. The main chemical components of bottom ash are silica (sand and quartz), calcium, iron oxide, and aluminum oxide.53 Both of these materials must be trucked to and disposed of in landfills in Minnesota at a significant cost to the incinerator. Ash from incinerators poses a greater risk to contaminating groundwater than other forms of waste because of the high concentration of metals and toxins. A study of incinerator ash landfilling demonstrated that, the ability of the wastewater extracts to cause genetic mutation was ten times as great in an incinerator capable of only incomplete combustion; 10% of these mutagens were reportedly disposed in the wastewater.54 The ash from HERC is currently disposed of in two landfills, the majority of which (~80%) is hauled to the landfill in Rosemount, Minnesota. The ash from HERC is stored in its own cell, where its leachate is tested for compliance with EPA and MPCA regulations and discharged to the Metropolitan Waste Water Treatment facility in St. Paul, Minnesota. The remaining 20% ash is hauled to the ash monofill at the Lake Area Disposal Landfill in Sarona, Wisconsin. Ash from the HERC is combined with ash from other waste combustor facilities and disposed in the ash monofill.55

50

State Representatives, Frank Hornstein, Jean Wagenius , Jim Davnie , Bobby Joe Champion , Diane Loeffler , Patricia Torres Ray , and D. Scott Dibble. 51 Combs, Susan. 52 Lam, Charles H. K.; Ip, Alvin W. M.;Barford, John Patrick;McKay, Gordon. 2010. "Use of Incineration MSW Ash: A Review." Sustainability 2, no. 7: 1943-1968. 53 "Municipal Solid Waste." EPA. Environmental Protection Agency, 19 Mar. 2012. Web. 9 Apr. 2012. <http://www.epa.gov/wastes/nonhaz/municipal/wte/basic.htm>. 54 Rowan, S. C. "Incinerator Toxic Emissions: a Brief Summary of Human Health Effects with a Note on Regulatory Control." Medical Hypotheses 52.5 (1999): 389-96. Pubmed.gov. Harcourt Brace & Co. Ltd, May 1999. Web. 20 Sept. 2011. http://www.ncbi.nlm.nih.gov/pubmed/10416945 pg. 5. 55 Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency 20.

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[HERC] Reevaluating Waste Management in Minneapolis

The Cost of Incineration

Although an incinerator may sound like an economically viable option for waste disposal and energy generation, the overall costs are incredibly high. Incineration is not an efficient way to generate electricity because it has to spend money to dispose of the waste ash, comply with pollution control standards, and upgrade the mechanical aspects of the plant. The U.S. Energy Information Administration compared the capital and operating costs of incineration with 26 other ways to generate electricity and found that it has the highest capital cost and highest fixed operating and maintenance costs.56 Minneapolis Solid Waste & Recycling specifically services approximately 105,000 households, with ~101,434 of those recycling. Service revenue has been estimated at $28 million for 2011, compared to $27.6 million for 2010. Table 5: Solid Waste Disposal Fees for Minneapolis 57 Base Fee $24.00 per month Disposal Fee + 5.00 for disposal of one large cart worth of garbage + 3.00 for disposal of one small cart worth of garbage Recycling Credit - 7.00 if you participate in the recycling program. Tax Total bill x 9.75% = State Waste Tax

As shown in Table 5, the 2011 base unit charge was set at $24 per dwelling unit with adjustments of $7 made for recycling credits. Monthly charges for large and small disposal carts are set at $5 and $3, respectively. Increase in service revenue is due to anticipated revenues from large cart to small cart conversions.58 The $3 $5 disposal fee paid by Minneapolis residents goes towards tipping fees paid by waste haulers to HERC. As a result Minneapolis taxpayers are paying upwards of $6,300,000 annually to pay for the cost of its operation (assuming all Minneapolis residents have a large cart). In essence, Minneapolis residents are paying for an industry to pollute themselves and their neighbors. When you contrast these economics with those of recycling, which are addressed later on, this is an incredibly difficult policy to justify and maintain.

56

Updated Capital Cost Estimates for Electricity Generation Plants, U.S. Energy Information Administration in November 2010 57 City of Minneapolis. "Billing." City of Minneapolis, Minnesota - Official Web Site. Web. 18 Oct. 2011. <http://www.ci.minneapolis.mn.us/solid-waste/billing.asp>. 58 "City of Minneapolis 2011 Budget Financial Plan." City of Minneapolis. Web. 8 Dec. 2011. <www.ci.minneapolis.mn.us/finance/docs/2011BudgetSolidWasteRecyclingFund.pdf>.

[HERC] Reevaluating Waste Management in Minneapolis 21

Costs and Benefits of Garbage Incineration Relative to Alternatives

One of the best ways to assess particular strategies in dealing with solid waste is to examine the costs and benefits of a particular approach. However, this is a very difficult calculation to make given the range of uncertainty regarding how much, and at what price waste is being managed in Hennepin County and Minneapolis in particular. The best data available comes from the Minnesota Pollution Control Agencys Metropolitan Solid Waste Policy Plan and their calculations on cost/ton and total cost of various waste management strategies. Table 6 extrapolates that data to determine total waste being managed and applies an estimate of how much waste was managed with that strategy. Table 6. Cost associated with waste management strategies in Metropolitan Area. Management Cost/ton Total Waste Total estimated % of Waste Method Managed (tons) cost Managed with Method Recycling $110 $143 1.1 1.3 million $121 138 38.53% million Organics $80 193 11,000 87,500 $880,000 $7 0.39% million Garbage $168 207 982,143 1.2 $165 203 34.40% Incineration million million Landfill $130 162 761,538 $99 -123 million 26.68% 946,154
Total waste managed tons were estimated using the least cost/ton estimate divided into the total estimated cost contained in the Metropolitan Solid Waste Policy Plan.

Though there is much variability in the data, it is evident on a simple cost per ton basis that garbage incineration is the most expensive way to address this issue. In contrast, source separated organics (or composting) and recycling offer far better rates of return per dollar spent. The operating costs of HERC are anticipated to be $21.5 million in 2011. When this cost is contrasted with the estimated $5.5 million spent on recycling programs by Hennepin County, it reflects a huge disparity in that per-ton garbage incineration expenses are nearly 4 times as great as recycling programs. While it should be noted that the costs stated here are total costs of these programs versus just the public costs incurred, they do reflect the price of these solid waste management strategies. Finally, this report doesnt include additional economic costs of an expansion to burning related to air pollution. The various health impacts, though often difficult to quantify in direct economic values, are nonetheless real and should be a serious consideration when pondering the costs and benefits of expanding garbage incineration. Further, this analysis does not address the costs and benefits of reducing waste altogether.

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[HERC] Reevaluating Waste Management in Minneapolis

Environmental Assessment Worksheet Inadequacies:

Why Minneapolis needs an Environmental Impact Statement
Covanta has proposed that the HERC incinerator increase to full capacity burning, meaning a 20% or 212 tons increase. This increase lies just under the 250 tons that would mandate an Environmental Impact Statement, and allows the use of a less extensive Environmental Assessment Worksheet to analyze the potential impact of expansion. 59 The initial Environmental Impact Statement (EIS) for HERC was compiled in 1986. Using these dated numbers means that the emission estimates, estimated health impacts, and impact of alternative means of disposal inadequately describe risks posed today. While the EIS from 1986 is inadequate, the proposed increase is an appropriate time to re-examine the real impact of the Center today. The latest financial data for Covanta Holdings from both Bloomberg and Morningstar make it readily apparent that the company is more than capable of financing the costs of an EIS. Given the impacts of the project on our environment, it is proper for them to do so.60 Michael Greenberg, an expert in environmental policy describes, One of the greatest drawbacks of the EIS process relates to administrative discretion () By allowing extensions of some permits, the EPA is allowing abuse of some of the most harmful environmental policies.61 Covanta has clearly sought a similar route with the incinerator, In November 2009 Covanta and Hennepin County attempted to circumvent environmental review altogether by applying to the Pollution Control Agency for a rarely used administrative permit. 62 Covanta sought this permit to avoid the process of completing an Environmental Assessment Worksheet (EAW), which it has now stalled by failing to provide the MPCA sufficient information to complete the EAW. 63 It is critical to understand the real impact of incineration on the city before the proposal moves forward.

59

State Representatives, Frank Hornstein, Jean Wagenius , Jim Davnie , Bobby Joe Champion , Diane Loeffler , Patricia Torres Ray , and D. Scott Dibble. 60 Frank Hornstien, State Representative. 61 Michael R. Greenberg, Environmental Policy Analysis and Practice, pg. 191 62 Frank Hornstien, State Representative. 63 State Representatives, Frank Hornstein, Jean Wagenius , Jim Davnie , Bobby Joe Champion , Diane Loeffler , Patricia Torres Ray , and D. Scott Dibble.

[HERC] Reevaluating Waste Management in Minneapolis 23

A Path Forward: The Benefits of Composting and Recycling

Current Waste Composition

As you can see from Graph 1, provided by the HERC draft EAW, less than half of the waste picked up from residential garbage carts is non-recyclable or recoverable material intended for incineration. Recoverable material comprises more than half of the material disposed of by residents. If even a portion of the material is diverted, citizens can dramatically reduce the resources destroyed in the incineration process. Graph 1: Composition of Garbage Carts in undisclosed community

According to SCORE data shown in Graph 2, the recycling rate of Hennepin County has remained flat since the plant began its operations in 1989.64 This rate looks at the proportion of total waste that is recycled, not the percentage of recyclables that are recycled. Despite stagnant performance for two decades, the Hennepin County waste management plan only seeks to increase the recycling rate by a small percentage. Extrapolating this plan, we have added what the recycling rates would be expected to look like over the next 8 years to the graph.

64

Hennepin County Environmental Services.

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[HERC] Reevaluating Waste Management in Minneapolis

Graph 2: Hennepin County Recycling Rates: Appendix A

Hennepin County SCORE Recycling Rates Lb. Recycled/ Total Waste Generated 60 50 40 30 20 10 0 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Year

Though garbage incineration was originally proposed as a transition solid waste management strategy, this data seems to indicate a stall in policies aimed at increasing recycling rate.

Energy Advantages of Recycling and Composting

The benefits of recycling and composting over incineration are significant. Overall, recycling produces a net reduction in energy 3.6 times larger than the amount of energy generated by incineration and 11 times larger than the energy generated by methane recovery at a landfill.65 Although incineration does generate some energy, it does not compare to the amount of energy saved from recycling and composting. Methane from landfills and the BTUs generated from incinerators are sometimes captured and converted into energy. However, energy from waste is inefficient and does not eliminate the pollution.66 When composting or recycling, you eliminate the need to extract, process and transport new raw materials for a product. At the same time, in the U.S., four primary materials industries paper, metals, plastics, and glass consume 30.2% of the energy used for all U.S. manufacturing. 67 In addition to outright energy savings, using compost for soil application allows for energy savings from reducing need of machinery, engineering, development, and maintenance for improving soil quality. Compost applications increase soil organic matter, thereby reducing soil erosion, water logging, nutrient loss, surface crusting, siltation of waterways, and more.68 When used for agricultural purposes, compost can reduce the need for chemical fertilizers as well. Synthetic fertilizers, for instance, are huge emitters of NOx emissions; in the U.S., these emissions represented 88.6 Teragram CO2E or 1.2% of all greenhouse gas emissions in 2005.69
65 66

Eureka Recycling 4. Eureka Recycling 2. 67 Platt, Brenda, David Ciplet, Kate M. Bailey, and Eric Lombardi 19. 68 Platt, Brenda, David Ciplet, Kate M. Bailey, and Eric Lombardi 55. 69 Platt, Brenda, David Ciplet, Kate M. Bailey, and Eric Lombardi 55.

[HERC] Reevaluating Waste Management in Minneapolis 25

Energy Saved by Recycling

Paper
44% energy savings v. raw materials

Glass Bottle
30% energy savings v. raw materials

Aluminum Can
90-97% energy savings v. raw materials

Economic Advantages of Recycling

Incineration and landfilling may be convenient options for waste disposal, but their convenience comes at a price for the economy. Tipping fees paid by trash haulers for waste disposal vary by state, but on average tipping fees are highest for incineration, whereas revenue is actually generated from some recycling programs.70 By developing the infrastructure for recycling and composting, a community is investing in local jobs. Incinerators and landfills sustain only 1 job for every 10 positions at a recycling facility.71 Recycling and composting initiatives create jobs that can serve toward bolstering the local Minneapolis economy not to mention its environment and the health of its citizens. More research is needed to determine exactly how much additional revenue, and how many additional jobs, could be expected with increased diversion of recoverable materials from the current waste stream.

Environmental Advantages of Recycling

When material is combusted in an incinerator, the material is permanently lost. This continues demand for extraction of new materials to create new products. For every ton of municipal waste discarded, about 71 tons of waste are produced during manufacturing, mining, oil and gas exploration, agriculture, and coal combustion. When material is recycled, it continues to provide material for new product and lessens the demand for extraction. For every ton of virgin aluminum recycled, 2.7 tons of solid waste related to mining, extraction, and virgin material manufacturing are avoided.72 Resource extraction, production and transport are all energy intensive processes that lead to the production of greenhouse gasses. Much of this energy used is from non-renewable
70

Ljupka Arsova, Rob Van Haaren, Nora Goldstein, Scott M. Kaufman, and Nickolas J. Themelis. "The State Of Garbage In America." BioCycle 49.12 (2008): 22. Web. 26 Oct. 2011. <http://www.jgpress.com/archives/_free/001782.html>. 71 The Institute for Local Self Reliance 62. 72 The Institute for Local Self Reliance 21.

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[HERC] Reevaluating Waste Management in Minneapolis

resources such as coal and oil. These non-renewable fuel sources have significant impacts on air pollution, land degradation and climate change. Many of the health damaging air pollutants also have a negative impact on the environmental surroundings and bioaccumulate in the soil and animals. These toxins include mercury; this chemical travels to bodies of water and has been found to increase the risk of cancer for people consuming fish with high mercury content. Particulate matter also contributes to a reduction of visibility in industrial facilities, acidifying lakes and rivers, and acid rain that degrades stone and other materials.73

Graph 3: HERCs Waste Isnt Garbage74

HERC Solid Waste Composition

Construction Debris 3% Textiles/Leather 3% Electronics/Appliance 3% Glass 2% Metals 4% Plastics 15% Paper 31% Organics 32% Furniture/Tires/Other 7%

Organics Metals Textiles/Leather

Paper Glass Construction Debris

Plastics Electronics/Appliances Furniture/Tires/Other

As Graph 3 shows, the most recent waste analysis required of Covanta under its permits show 32% of the materials entering HERC are organics and over 51% are recyclables.75 This means the majority of material can be captured and diverted to recycling and reuse efforts, leaving only 16.5% as other waste. Most of this other waste is comprised of items (like electronics, appliances, construction debris, and tires) that have specialized disposal requirements and cannot be incinerated. This leaves the remaining ~10% of waste, which is largely made up of furniture, mattresses, leather, clothing, carpets, and all the small materials that fall to the bottom throughout the sorting process. These items are the items that would remain if our waste stream was properly managed before materials reached the HERC. With such a small group of items to dispose of in an efficiently managed waste stream, focus can
73 74

"Particulate Matter (PM)." Covanta Hennepin Energy Resource Company, L.P. Solid Waste Composition Study Report of the Hennepin Energy Recovery Center. 14 Sept. 2007. Raw data. Minnesota, Minneapolis. 75 Covanta Hennepin Energy Resource Company, L.P. Solid Waste Composition Study Report of the Hennepin Energy Recovery Center. 12 Nov. 2012. Raw data. Minnesota, Minneapolis

[HERC] Reevaluating Waste Management in Minneapolis 27 shift to how to best reuse and recycle these remaining products. This is what San Francisco has done, beginning to create jobs by establishing markets for the reuse of goods that would be otherwise disposed. The alternatives before our community, along with the fact that the amount of recyclable and compostable materials is significantly greater than the amount of waste for which HERC is seeking to increase incineration, effectively eliminates the need for such an expansion. With over 90% of the materials currently being incinerated at HERC having already established disposal methods that are more efficient than incineration, the conversation must shift to better waste management systems. Graph 1 showed that residential carts are better sorted than the waste that arrives at the HERC, as seen in Graph 3. This leaves the impression that while residents are to blame for some of this errant disposal, there are huge holes in our system that we must explore before we can even consider burning more of our so-called garbage.

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[HERC] Reevaluating Waste Management in Minneapolis

Conclusion
When HERC was approved and built in the late 1980s, it was assumed to be a short-term alternative to direct landfilling while other programs and capacities were developed. Recycling and composting were assumed to eventually take away the need for the Center itself. Separate from the desires of Covanta, the HERC facility was intended not as a waste management solution, but rather a placeholder for technologies to come. Today, we have the technology and information to understand - more than those involved in the original construction of HERC ever could - just how deep the impacts of incineration are and just who poorly we are doing at recovering materials. Decision makers need to reevaluate whether HERC is a necessity for an era where nearly everything being incinerated could be diverted from the waste stream into already established processes for reclaiming materials.

Recommendations
As demonstrated in this report, waste incineration presents challenges in energy efficiency, economic efficiency, public health concerns, and more. MPIRG strongly contends that the preponderance of the evidence supports the following recommendations: 1. The Minneapolis City Council should deny Covanta the conditional use permit to increase waste incineration at HERC by 20%, or 212 tons of garbage per day, as the citys comprehensive plan dictates negative health effects to Minneapolitans should be avoided in zoning decisions. 2. The City of Minneapolis should move towards curbside composting as a waste reduction strategy to remove the 32% of incinerated materials that are organics. 3. The City of Minneapolis should continue its efforts to streamline recycling to increase participation rates and remove the 51.5% of incinerated materials that are recyclables. 4. Hennepin County and the City of Minneapolis need to seriously consider how HERC fits in the current waste management scheme. The key consideration being the rather perverse incentive that HERC creates by allowing for improperly sorted waste from across Hennepin County to be burned. By doing so, not only does Minneapolis bear the brunt of air pollution deposition, it also reduces the incentive that other cities have to reduce their waste through recycling and composting. 5. Failing these other policy recommendations, at the barest minimum a full EIS should be required to determine the extent of negative health effects.

[HERC] Reevaluating Waste Management in Minneapolis 29 Appendix A76 Table of recycling rates in Minneapolis by year
Recycling Rates Minneapolis Year Total Trash Total Recycling 1991 713,747 617,438 1992 700,762 659,256 1993 689,081 676,992 1994 729,326 686,982 1995 752,218 561,795 1996 791,457 577,621 1997 844,730 571,563 1998 885,288 577,914 1999 904,947 588,053 2000 939,831 594,111 2001 986,001 591,289 2002 959,509 593,274 2003 1,005,694 591,844 2004 947,994 603,722 2005 984,538 597,180 2006 982,230 598,219 2007 982,805 604,239 2008 854,215 596,972 2009 784,128 573,038 Total Waste 1,331,185 1,360,018 1,366,073 1,416,308 1,314,013 1,369,078 1,416,293 1,463,202 1,493,000 1,533,942 1,577,290 1,552,783 1,597,538 1,551,716 1,581,718 1,580,449 1,587,044 1,451,187 1,357,166 Recycling Rate 0.463825839 0.484740643 0.495575273 0.485051274 0.427541432 0.421905107 0.403562681 0.394965288 0.393873409 0.38730995 0.374876529 0.382071416 0.370472565 0.389067329 0.377551498 0.378512056 0.380732355 0.411368073 0.411368073 46.38258394 48.47406431 49.55752731 48.50512742 42.75414322 42.19051069 40.35626809 39.49652885 39.38734092 38.73099504 37.48765287 38.20714163 37.04725647 38.90673293 37.75514978 37.85120558 38.07323552 41.13680732 41.13680732

Appendix B Definition: Environmental Impact Statement (EIS) An EIS must contain a detailed statement of the following 5 factors77 1. The Environmental impact of the proposed action 2. Any adverse environmental effects that cannot be avoided if the proposed action is implemented 3. Alternatives to the proposed action 4. The relationship between local short-term uses of the human environment and the maintenance and enhancement of long-term productivity 5. Any irreversible and irretrievable commitments of resources that would be involved if the proposed action is implemented

76 77

MN SCORE Recycling Data Environmental Policy Analysis and Practice, Michael R. Greenberg (189)

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[HERC] Reevaluating Waste Management in Minneapolis WORKS CITED

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