Points of Caution in Enacting New Fuel Rules
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The DEP's proposed rules controlling alternative fuels such as CDD debris will have impacts well beyond the immediate boilers burning CDD debris fuel. We urge caution in establishing new rules on waste-derived fuels.

1. Be cautious about opening the door to huge flows of CDD waste from out of state that will arrive for final disposal in Maine.

The fuel supply being considered in this bill must come from outside Maine. Maine itself only creates 1/10 of the raw CDD debris per year as will be required to produce this fuel (about 320,000 tons per year waste from Maine, vs. 3-5 million tons raw waste required to produce needed 1 million tons of fuel). Will this arrive from out of state in the form of processed fuel or raw debris to sort in Maine and then burn or landfill here? Optimists say it will come in clean. The economics of the waste industry, however, point toward incentives to haul it here in raw, unsorted form. Rules are not in place to limit this flow.

2. Use caution when thinking about the hidden costs of the new waste that will be brought here or created here.

At most, 25% of CDD debris waste can be burned. At least 25% of CDD raw debris must be landfilled. In addition, thousands of tons of incinerator ash containing toxins will be landfilled in Maine. The huge increase in total amounts of CDD debris fuel burned here means millions of pounds per year of pollutants inevitably released into Maine's air. These involve costs that Maine's citizens must bear.

3. Be cautious in the false assumption that Maine leads the nation in regulating debris derived fuels.

Neither the science nor the policy implications of the DEP's new fuel rules have passed thorough review. Though local test results support some of the proposed regulations, others seem to take no account of rules and practices now in place elsewhere. For instance, today, there is zero tolerance (0.00%) in California for burning arsenic treated wood, while Maine's rules would permit this at 1.5%. In addition, Massachusetts has enacted a ban on landfilling most components of CDD debris, and New Hampshire has a moratorium on burning it, pending further study. These conditions have direct impact on the situation in Maine.

We urge the Committee to be cautious about disrupting established regulatory processes. Respect for existing formal rules will affirm the public's need for fair involvement in the public process. In addition to rulemaking underway, at least two study groups are in place that will report to the Committee on waste policy. CDD debris component is an important component of the waste stream, and policy decisions should be informed by the deliberations of those study groups.

We suggest that the Committee on Natural Resources should recommend a moratorium on licensing new facilities to process or burn CDD debris fuel, outlined in Amendment B to LD141.

Note. Waste and fuel figures from SPO and DEP; other sources: Calif. Integrated Waste Management Board; Pacific Ultra-Power; Office of NH Gov. Lynch; MassDEP

We The People is an advocacy group founded in Alton and Old Town, Maine against the imposition of Maine's largest landfill in their communities. We The People recognizes the interrelated nature of waste infrastructure, and seeks solutions beneficial to all.