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Solid Waste Facilities

**[Incinerator]{.underline} [Landfill]{.underline}**

Fosston Industrial Park Gentilly, Minnesota

708 8^th^ Street NW P.O. Box 605

P.O. Box 605 Fosston, Minnesota 56542

Fosston, Minnesota 56542 (218) 281-5419

\(218\) 435-6501 Telephone Facilities Manager: <county@gvtel.com>

\(218\) 435-6619 Fax Accounting:<jbaumann@gvtel.com>

February 11, 2004

U.S. Department of Energy

Via Internet

Dear Sir or Madam:

RE: Revised General Guidelines for the Reporting of Greenhouse Gas
Emissions and Emission Reductions Under Section 1605(b) of the National
Energy Policy Act.

On behalf of Polk County and the Polk County Resource Recovery Plant
located in Fosston, MN, we wish to offer the following comments in
response to the above-referenced U.S. Department of Energy General
Guidelines for Reporting of Greenhouse Gas Emissions.

Polk County owns and operates a waste-to-energy facility that serves a
five county region in Northwest Minnesota. A Materials Recovery Facility
is included in front of the WTE plant to remove problem/objectionable
and recyclable items prior to incineration. The five county group is
proud of their accomplishments in developing a complete integrated solid
waste management program that includes recycling, household hazardous
waste, composting and, lastly landfill services that, collectively,
protect the environment and save natural resources. Polk has recently
completed a \$1.8 million Air Pollution Control (APC) retrofit project
by installing dry sorbent injection, carbon injection, and upgrading
electrostatic precipitators in order to meet revised EPA emission
guidelines. We are also one of nine waste-to-energy facilities in
Minnesota that are operating successfully to manage municipal solid
waste in an environmentally sound manner.

We are troubled by the proposed Guidelines issued by the U.S. Department
of Energy that appear to disavow any method that would account for the
significant, quantifiable avoided emissions resulting from the
technologies selected by Polk County and many of our nation's cities and
counties to manage its municipal solid waste. Specifically, we urge DOE
to account for the benefits of waste-to-energy technology. Our decision
to use waste-to-energy as a solid waste management tool has resulted in
tangible savings in greenhouse gas emissions that otherwise would be
emitted into our atmosphere. The failure by the U.S. DOE to account for
waste-to-energy ignores reality, and the significant advancements
attributable to decisions made by Polk County towards halting global
climate change.

Waste-to-energy offers two important benefits to America's cities and
counties -- environmentally safe solid waste management and disposal, as
well as the generation of clean electric/steam power. Waste-to-energy
facilities produce energy through the combustion of municipal solid
waste in specially designed power plants equipped with the most modern
air pollution control equipment to clean stack emissions.

The growing use of waste-to-energy as a method to dispose of trash and
generate power has greatly reduced environmental impacts of municipal
solid waste management, including emissions of greenhouse gases. For
example, an analysis prepared for the U.S. Conference of Mayors by the
U.S. Environmental Protection Agency, entitled *The Impact of Municipal
Solid Waste Management on Greenhouse Gas Emissions in the United
States,"* documents that significant contribution made by
waste-to-energy in reducing the amount of greenhouse gases that
otherwise would be released into our atmosphere in the absence of the
technology. Waste-to-energy technology reduces more than forty million
metric tons of greenhouse gases in the form of carbon dioxide
equivalents that otherwise would be released into the atmosphere on an
annual basis, according to this analysis developed by the U.S.
Environmental Protection Agency and the Integrated Waste Services
Association (IWSA) using EPA's Decision Support Tool program.

America's waste-to-energy facilities dispose of trash, and are an
alternative to land disposal that releases methane -- a potent
greenhouse gas -- as trash decomposes. Waste-to-energy also produces
electricity/steam, lessening reliance on fossil fuel power plants that
release carbon dioxide, another greenhouse gas, into the atmosphere when
coal is burned. Operation of waste-to-energy plants avoid the release of
methane that otherwise would be emitted when trash decomposes, and the
release of CO~2~ that would be emitted from generating electricity from
fossil fuels.

Waste-to-energy's benefits are quantifiable. A recent study of the
Saugus, Massachusetts facility included site specific and verifiable
information regarding alternative landfill disposal, plant emissions,
trash composition and other plant-specific data. This information that
was analyzed using the EPA Decision Support Tool computer modeling to
determine that about 73,000 metric tons of carbon dioxide equivalent
emissions are avoided annually because of one plant's operations. An
accounting for the Polk County Facility would also result in a
contribution to solving the climate change problem.

It is essential that DOE address the importance of technologies such as
waste-to-energy, and the facilities' contribution to reducing greenhouse
gas emissions that otherwise would result from the unavoidable need to
dispose of trash. If cities and counties close their waste-to-energy
facilities tomorrow, millions of tons of greenhouse gases would be
released into the atmosphere that otherwise would be safely avoided.

The proposed DOE 1605(b) approach is incorrect because it refuses to
admit that greenhouse gas reductions from waste-to-energy operations may
be realized within the context of overall solid waste management
practices. If not waste-to-energy, then increased greenhouse gas
emissions. It is as simple as that.

The nation's cities and counties urge DOE to take credit for
waste-to-energy reductions, and further urge DOE's acceptance of the EPA
life-cycle approach and the underlying computer model used to calculate
reductions. For more information, we would suggest contacting Susan
Thorneloe at U.S. EPA Air Pollution Prevention and Control Division,
Office of Research and Development in Research Triangle Park, North
Carolina, (919) 541- 2709. Also contact Art Dunn, Director, Minnesota
Office of Environmental Assistance (MOEA), 520 Lafayette Road N.,
St.Paul, Minnesota, 55155-4100, (651) 215-0283. The MOEA has completed a
research study regarding the GHG benefits of waste-to-energy. Another
Minnesota contact is Trudy Richter, Executive Director, Minnesota
Resource Recovery Association (MRRA), 477 Selby Avenue, St.Paul,
Minnesota, 55102, (651) 222-7227.

Finally, Polk County believes that credits should be owned by the entity
owning a waste-to-energy facility. We urge DOE to accept this
recommendation. Municipalities own more than half of America's
waste-to-energy facilities. Local public officials have made difficult
political decisions in the selection of preferred solid waste management
technologies. The resulting benefits -- including greenhouse gas credits
-- should accrue to the communities that own a facility. Similarly,
private operators developed waste-to-energy plants taking on significant
risk and should be offered the reward of operating clean, efficient
plants. We oppose assignment of greenhouse gas credits to either the
supplier of trash or the purchaser of electricity.

Thank you for consideration of our views. We look forward to working
with the U.S. DOE on this very important issue.

Sincerely,

# Willard Wilson

Willard Wilson

Facilities Manager

Polk County Solid Waste

Cc: William Montague, Polk County Board Chair

John P Schmalenberg, Polk County Administrator

Art Dunn, Director, Minnesota Office of Environmental Assistance

Trudy Richter, Executive Director, Minnesota Resource Recovery
Association

Maria Zannes, President, Integrated Waste Services Association