Could EPA’s preference for ‘energy recovery’ change as it evaluates waste hierarchy, other tools?

The US EPA is currently evaluating two well-known materials management policy tools – the Waste Management Hierarchy and the Waste Reduction Model (known as WARM) – with the potential for changes in how it evaluates certain disposal technologies.

According to an Oct. 4 letter from the anti-incinerator network Energy Justice, co-signed by more than 270 other advocacy groups, the EPA’s Office of Lands and Emergency Management has been reviewing both items in recent months. A note on the EPA’s Hierarchy page, which outlines the well-known list of materials management options, from source reduction to disposal, now says the agency is reviewing it “to determine whether potential changes should be made based on the latest available data and information.”

These EPA tools are advisory, with no specific regulatory role, but both have been commonly cited elements of waste policy for decades. Changes to either would be a notable agency move that could have ripple effects in national and local policy discussions.

The agency said it was all part of a larger research work, but did not answer specific questions about what prompted it to release the note, the nature of the data it referred to, or what aspects of the hierarchy might change.

“The waste hierarchy was created decades ago and served as a general guide for materials management. EPA’s next research plan includes work that will help us determine if potential hierarchy changes are needed,” an agency spokesperson said in a statement. “We want to deliver better resource conservation and reduced environmental impact through more informed materials management decisions, including community decisions.”

These research plans, which outline the work the agency’s Office of Research and Development will conduct throughout FY26, contain brief mentions of upcoming waste initiatives.

An “Air, Climate and Energy” plan mentions that “improved data is needed on waste management in the United States”, including “landfills and waste incineration and other sectors in the GHG inventory “. A “Sustainable and Healthy Communities” plan mentions how upcoming changes to a broader sustainability calculation model could affect several tools, such as WARM. This plan also mentions a series of upcoming research on materials management, including a focus on climate change and environmental justice.

According to Mike Ewall, executive director of the Energy Justice Network, advocates have met with the EPA’s Carlton Waterhouse several times since last year. Waterhouse – deputy deputy administrator of OLEM – emphasized environmental justice during his time at the agency.

The EPA “admitted to us in March that it had no citations to support placing incineration above landfill in the hierarchy,” Ewall said.

The groups also believe that WARM has a “bias in favor of incineration”. Their recent letter is addressed to the Council on Environmental Quality because a recent report by that group reaffirmed the EPA’s waste hierarchy after the agency added its disclaimer this summer. In addition, their letter calls for updated emission standards for these facilities and tougher bottom ash regulation, among other measures to regulate an industry they describe as an environmental justice issue that has “ past its peak.

Energy Justice Network and related groups would prefer to see the EPA use a hierarchy adopted by the Zero Waste International Alliance, which calls for biological treatment before landfilling waste materials and calls any form of incineration “unacceptable.”

While the number of mass combustion facilities has declined in the United States in recent years, as landfill development continues to expand, dozens of these facilities remain active and are central elements of waste infrastructure in some regions. Beyond the advocacy of companies or local governments that operate these facilities, the presence of the sector in the debate on national waste policy is less strong than in previous years.

A newer US group, the Institute for Energy and Resource Management, is working to promote the technology as part of an integrated system where recycling is maximized and residual waste is treated by thermal treatment. The group’s team of advisers, including a range of European waste professionals, expressed alarm that the EPA could change the hierarchy and reiterated calls for landfills to be phased out.

“Much of the energy in the waste is also buried with it, even with landfill gas extraction. Therefore, advanced heat treatment based on mass combustion technology for energy and material recovery is also an essential part of a circular economy,” said the Founder and CEO. Philipp Schmidt-Pathmann in a statement. “Humanity can only exist in the long term with a circular economy. landfill means the collapse of our long-term economic system.

Waste policy experts could not point to a specific origin for the agency’s current hierarchy, but multiple sources said it dates back to at least the 1970s, when disposal policy was politically focused. national.

According to a Recycling Archives Project interview with longtime zero-waste advocate Gary Liss, the agency was actively training solid waste professionals to prefer various forms of thermal treatment systems as early as 1975. Others recalled that the subject had attracted attention during the 1978 monitoring hearings for resource conservation. and Recovery Act.

The book “War on Waste” notes that the agency “…adopted a position in the late 1980s in favor of incinerators as ‘a viable waste management alternative for many communities.’ it does not explicitly establish the current hierarchy.One former staff member from this era recalls that the policy was formalized around this time, with another saying the concept was fully in place by the early 2000s at the latest.

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