Tell the US Treasury: No Subsidies for Waste Incinerators

Not ? Click here.

First name*

Last name*

Email address*

ZIP Code*

Postal code*

Would you like to keep your comment anonymous? No, please include my name Yes, please submit my comment anonymously

You can customize this letter! Share why this is important to you, how the issue impacts you and more.

Thank you for the opportunity to provide feedback on the development of the IRS and Treasury Department’s determination of the scope of new energy tax credits (45Y) under the Inflation Reduction Act (IRA). This issue is really important to me.

I am writing to strongly urge you to ensure that so-called “waste to energy” (WTE) or waste incinerators are not considered eligible for federal subsidies in the Inflation Reduction Act.

The Inflation Reduction Act is at its core, a tax bill designed to accelerate the transition to clean energy and catalyze climate action. Subsidizing the renewal of waste incinerators would both fail to achieve the stated goal and would mark a backward step in President Biden’s Justice 40 initiative centering environmental justice communities in energy policy and climate action.

1. We cannot build a clean energy future on the back of environmental justice communities

Waste incinerators release a cocktail of harmful pollutants: fine particulate matter, heavy metals, dioxins, NOx, VOC and other known human carcinogens all with serious implications for surrounding communities. Some 80% of waste incinerators are located in low-income and/or communities of color, a result of historic red-lining policies. These communities are oftentimes already overburdened with exposure to industrial pollutants.

There is a reason that no waste incinerators were built in the 21st century; attempts have been deemed untenable with respect to the needs of communities. Continuing to offer tax credits for the continued operation of these facilities would be an insult to environmental justice communities and would be in contravention to the White Houses’ Justice 40 initiative.
 
2. Waste Incinerators emit heavy amounts of greenhouse gasses

Emissions include carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). Electricity generation from WTE is marginal and does not significantly contribute to the electricity grid. In fact incinerators emit 68% more CO2 per unit of electricity than coal-fired power plants. According to the U.S. EPA, WTE and landfills contribute far higher levels of greenhouse gas emissions and overall energy throughout their lifecycles than source reduction, reuse and recycling of the same materials. Denmark (renowned for its embrace of incineration) recently discovered that its incinerators were releasing double the quantity of CO2 than originally estimated.

3. Waste incinerators entrench waste, and are incompatible with a low-carbon circular material

Contracts between municipalities and waste incinerators are structured to ensure a steady supply of waste feedstock. Communities with incinerators often have lower recycling and composting rates since there is no incentive to create such programs under the existing economic paradigm. The emergence of a suite of policies to decarbonize our waste sector from composting, recycling, EPR and plastic reduction laws are all likely to delay or negatively impact the adoption of such policies due to existing waste contracts. Moreover, tax credits are a zero sum game, any efforts to provide funding to incinerators would remove tax credits from other worthy efforts to reduce GHG emissions.

Thank you for your consideration and I hope that the US Treasury will ensure incinerators are not further subsidized by federal tax credits under the IRA’s 45Y program.

You are filing a document into an official docket. Any personal information included in your comment text may be publicly viewable on the web.

Please review the Regulations.gov privacy notice and user notice.

Burning Trash is Not a Climate Solution

Burning trash emits toxic air pollution, subjects local communities to adverse health impacts and perpetuates an unsustainable take-make-waste material economy. Now, with millions of dollars in federal funding available for real climate solutions, we can’t let dirty waste incinerators greenwash their way into getting a cut.

Tell the US Treasury: don't provide climate subsidies or bailouts for polluting waste incinerators!

This form allows you to easily submit a message to the federal public comment portal.

The Inflation Reduction Act has been touted as a huge “climate bill”, but millions of dollars of taxpayer funds could be spent on corporations running dirty incinerators that prop up a system of consumption and waste.

Right now, the US Treasury is deliberating on what industries can apply for a “zero-emissions” tax credit under the Inflation Reduction Act, potentially opening up millions of dollars in subsidies to incinerators to renew their operations.

In order to appeal to federal subsidies, waste incinerators have rebranded as “waste-to-energy” facilities. This is greenwashing. Parent corporations are claiming incineration is sustainable, as they ignore the toxic air pollution that burning trash creates and the communities that are forced to grapple with the consequences.

In reality, incinerators consume more energy than they produce, as waste material is a poor feedstock for burning. Incinerators emit a striking 68% more greenhouse gasses per unit of energy than coal plants.

Our latest mini documentary, Burning Injustice, is a testament to the lived experience of communities who live near incinerators. 80% of the waste incinerators in the US are located in low-income and/or communities of color – a product of historic redlining. These communities are oftentimes already overburdened with industrial chemicals and are further exposed to incinerators that produce fine particulate matter, heavy metals, dioxins, NOx, VOC and other known carcinogens.

A generation of aging waste incinerators are reaching their end-of-life, providing an opportunity to move towards better “zero-waste” policies that generate less waste. Waste incinerators are an enormous impediment to change: once established, they create powerful incentive structures to ‘feed the beast’. Contracts between municipalities and incinerators often establish financial penalties for failing to produce sufficient waste, thereby ‘locking in’ a wasteful system.

Waste incineration is a relic of the 20th century. No new waste incinerator has been built this century.

This Administration must not hand out a financial lifeline to dirty incinerators. Take action now and tell the US Treasury – no subsidies for waste incinerators!

What does it feel like to live near an incinerator that burns trash?

Burning Injustice is a powerful short documentary that follows the inspiring journey of Latino activists, John Mataka and Bianca Lopez, as they expose the toxic pollution and devastating health consequences of one of the last trash incinerators in California in an effort to close the facility once and for all. Through their unwavering determination, they call for environmental justice and a safer future for their community and loved ones.

No Bailouts for Dirty Waste Incinerators!