American Environmental Health Studies Project * Biomass Accountability

Project * Citizens' Environmental Coalition * Clean NY * Global Alliance

for Incinerator Alternatives* Grassroots Recycling Network * Greenwich
Citizens Committee * Hopewell Junction Citizens for Clean Water *
Institute for Local Self-Reliance * New York Public Interest Research
Group * Real Majority Project of the Hudson Valley

August 2, 2010

Tara Stickles
Office of the Town Clerk
Town of Montgomery
110 Bracken Road
Montgomery, New York 12549
tomtownclerk@frontiernet.net

Charles T. Bazydlo, Esq.

Attorney to Town Board of Town of Montgomery
Law Office of Charles T. Bazydlo
5 Howard Seely Road
Thompson Ridge, NY 10985
cbazydlo@hvc.rr.com

Re: Taylor Biomass Gasification Draft Environmental Impact Statement

Dear Ms. Stickles and Mr. Bazydlo,

We are writing to express our serious concern about this ill-advised, polluting
project. We believe the Town Board should not allow this DEIS to move forward in the
absence of the complete permit review by the DEC. It is our understanding that the DEC
requested additional information from the applicant for these permits in December 2009,
which has not yet been received by DEC Region 3. The DEIS contains an air permit
application and a solid waste permit application that are obviously incomplete if the DEC
is seeking more information. As a result any public or Town Board review of this
application will be missing adequate technical detail to reach any reasoned conclusion
about this project. Under SEQRA, the town should not act in the absence of necessary
supporting technical information, and for that they must wait for DEC to act.

Given the late date that we learned about this DEIS, we are listing for the Town
Board’s review the numerous serious problems with this proposal and provide supporting
documents that discuss some of the history of these newer versions of solid waste
incinerators-- gasification, pyrolysis and plasma arc. A large number of these facilities
have been defeated across the country once public officials have been confronted with the
facts instead of the representations of the vendor.

• There are currently no commercially operated facilities in the US using

gasification technology for solid waste. These facilities have not
succeeded in the free market on their own, and it is doubtful that they are
commercially viable without substantial government subsidies.

• The Taylor proposal is completely experimental. No one has done this

before at this scale and Taylor has no experience at all with this kind of
combustion facility. Taylor’s DEIS states that “the purpose of this project
is to demonstrate that the Taylor MSW gasification can be commercially
viable at a scale of 500 TPD MSW and approximately 24 MW of
electricity.” P.1-29 It should be in the interest of the Town of
Montgomery and the public to expect and require much more –- proven
technology with good emissions data and demonstrated experience for the
operator.

• The proposal is being advanced as renewable energy. However the

majority of the waste to be burned is municipal solid waste (MSW) and
construction and demolition debris, neither of which are considered
renewable energy in NY State.

• In terms of waste more energy is obtained from zero waste strategies

including waste reduction, reuse, recycling and composting/anaerobic
digestion. Incineration is not a solution to global warming; recycling alone
saves 3-5 times the energy incineration recovers. Per unit of electric
energy incineration puts out 30% more CO2 than a coal plant.

• The DEIS claims implausibly low air emissions for hazardous air
pollutants and particulate emissions. This is largely because the DEIS uses
emissions data from natural gas combustion. This is not a natural gas
plant; it is going to be burning large quantities of mixed solid waste and
potentially contaminated C&D materials. Regulators have in general
determined that gasification facilities have an emissions profile similar to
MSW incinerators.

• The input to the gasifier shows that only 100 TPD of relatively clean wood
waste will be going into this process – less than 10% of the waste input
(500 TPD MSW, 450 TPD C & D, construction and demolition debris,
and 100 TPD unadulterated wood waste). Both MSW and C&D debris are
heterogeneous mixtures containing toxic constituents and plastics. Dioxin
is one of the most toxic substances emitted, and is formed when PVC
plastics and wood products are burned together. Treated and painted wood
can be contaminated with arsenic, chromium, pentachlorophenol and other
toxic substances.

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 • There are very good markets for most C&D debris and for clean wood
waste. The real problem lies with contaminated wood and other materials
for which there are no markets. As a result there will be a financial
incentive to burn increasing amounts of contaminated materials.

It should be noted that following a Tellus Institute review of these newer types of
incinerator technologies—gasification, pyrolysis and plasma arc—that the Massachusetts
DEP decided to extend their moratorium on incinerators. We wish to leave you with a
brief history of a gasification facility that was operated in Germany. A major German
energy company contracted for two gasification facilities from Thermoselect. Its
operation was so plagued by problems that the town and press referred to it as the
Thermo Defect facility. It operated commercially from 2002-2004. Finally it had a major
release of toxic emissions from an emission point that had never been disclosed to
regulators. The German energy company cancelled further dealings with Thermoselect
after losing $500 million. The facility was only able to process 1/5 of the waste it
contracted for and despite using additional natural gas for one year produced no
electricity to the grid. The facility had excessive dioxin and other hazardous emissions.

As you are probably aware the state budget situation is dire. You may be less aware of
how seriously budget cuts have impacted the Department of Environmental Conservation
and its already limited staffing from years of cuts during the Pataki administration. The
Town may have the idea that it can rely on DEC to monitor and oversee problems at any
difficult facility. We caution the Town against reliance on DEC for this kind of truly
experimental facility.

We have attached a full 2009 report, An Industry Blowing Smoke, that discusses the
problems with these newer incinerators. An earlier report, Incinerators in Disguise,
clarified the similarities between these newer thermal treatments and incinerators. In
addition we include the New Yorkers for Zero Waste Platform, which calls for a
moratorium on incineration, like that in Massachusetts. Please note the large numbers of
national, statewide and local groups that are supporting that platform.
A factsheet from another report, Stop Trashing the Climate, is also included.

Sincerely,

Barbara Warren, Executive Director

Citizens’ Environmental Coalition
www.cectoxic.org
845-754-7951 H

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Paul Connett PhD, Director
Ellen Connett, Former Waste Not editor
American Environmental Health Studies Project
www.Americanhealthstudies.org

Margaret Sheehan, Attorney at Law

Biomass Accountability Project
www.nobiomassburning.org

Sam Tesh, President

Citizens' Alliance for a Clean,Healthy Economy

Kathy A. Curtis, Policy Director

Clean NY

Ananda Tan, Coordinator US & Canada

Global Alliance for Incinerator Alternatives
www.no-burn.org

Gretchen Brewer, Director

Grassroots Recycling Network
www.grrn.org

Tracy Frisch, President

Greenwich Citizens Committee

Debra Hall, Founder

Hopewell Junction Citizens for Clean Water

Neil Seldman, President

Institute for Local Self-Reliance
www.ilsr.org

Laura Haight
Senior Environmental Associate
New York Public Interest Research Group

Joel Tyner, Founder

Real Majority Project of the Hudson Valley

Attachments:
An Industry Blowing Smoke, Report
New Yorkers for Zero Waste Platform

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Stop Trashing the Climate Factsheet