February 15, 2025

The Honorable Lee Zeldin

Administrator of The Environmental Protection Agency

RE: Integrated Solid Waste Infrastructure

Dear Honorable AdministratorZeldin:

Congratulations on your selection as Secretary of the Interior!

I am in agreement with your positions on our energy policies, with one important addition. I believe we should adopt an integrated solid waste infrastructure that is based on the international waste management hierarchy. Currently, we landfill 52% of the over 300 million tons of the municipal solid waste that we produce every year in the U.S. Every pound of this waste contains 6,000- 7,000 BTUs of stored energy. We should harvest the stored energy that exists through proven, clean waste-to-energy technology and use it to produce electricity for the power grid and heat for buildings. We can accomplish this while reducing the volume of the trash by 90%. Burning and burying instead of just burying will greatly reduce the methane gas that is produced by rotting organics in our landfills. Employing this methodology can augment the “all of the above” energy policy that you promote.

I received my Ph.D. in May 2021 from UMBC’s School of Public Policy at the age of 71. My dissertation focused on municipal solid waste (MSW) in the U.S. I joined The Institute for Energy & Resource Management (IeRM) as a Senior Policy Advisor. IeRM is a team of leading experts and specialists from universities, institutes, authorities, and similar institutions. We bring our expertise and proven track record to educate, to correct false information, and to counter special interests, so that corrective actions protecting people, the environment, and the economy can be taken. More information is available at (https://www.ie-rm.org/).

I had an open letter to our national policymakers published on Real Clear Energy in December2021:(https://www.realclearenergy.org/articles/2021/12/09/solid_waste_management_an_open_letter_to_us_senators_and_representatives_807132.html).

I believe that we, as a nation, have an opportunity to change the direction of our policies that determine how wehandle our MSW. Currently, we employ a landfill-based infrastructure to dispose of the waste that remains after we compost and recycle. We bury reactive waste in landfills located all over the country. The reactive waste rots and produces methane gas, thus these landfills are a MAJOR source for methane emissions.

Recent studies by the EPA and the Environmental Integrity Project (EIP) show the extent of the problem (https://environmentalintegrity.org/reports/greenhouse-gas-emissions-from-marylands-landfills/). The levels of methane emissions have been under-reported for decades. There is a movement towards capturing the methane gas being released from the landfills, but the estimates for successfully capturing the gas are approximately 45-50%.

I believe that we should change paths and implement an integrated solid waste infrastructure based on the international waste management hierarchy by:

1- Avoid producing waste at all levels of production, packaging, and shipping This will take a cooperative effort from all sectors.

2- Reduce the organic waste by composting. Approximately 35% of the waste we produce is organic and can be separated in the home and taken to composting facilities and turned into reusable products. We currently capture 8.5% (EPA). There is much room for improvement.

3- Recycle all available products. We currently recycle 23.6% (EPA). In contrast, some European countries recycling rates are over 50%. Germany recycles 65%, Austria 57%, and Belgium recycles almost 54%. We can do much better if we try.

4- We should find the political will to change our landfill-based infrastructure to a WTE-based infrastructure. This will be very hard because of the aforementioned bias and outdated materials against WTE. The U.S. is lagging in our use of this method. Many countries around the world have embraced this choice because of the long-term positive environmental benefits.

5- An important part of changing our landfill- based infrastructure is to begin a robust “landfill-mining” program. This program includes mining the buried items from existing landfills. Every pound of buried municipal solid waste contains approximately 6,000 to 7,000 BTUs. Everything, including metal, aluminum, electronic parts with rare metals, and household items were buried. The EPA has a “Landfill ReclamationProgram” that should be expanded. There are reclaimable metals and combustible products that could offset the costs.

6- Employ waste-to-energy as the primary method to reduce the volume and recapture the energy released during the combustion process. This heat can be used to generate electricity for the power grid and a portion of it can be used as a heat source for district heating/ cooling systems in our cities. This method has faced decades of disparagement from many environmental groups. The information distributed by them is outdated. A recent peer-reviewed paper was written by Dr. Marco Castaldi, a professor at CCNY. This paper is a meta- analysis of recent papers that tell the scientific truth about WTE. (https://ccnyeec.org/wp-content/uploads/2021/05/WTE-REPORT7603.pdf). It is the most important paper written about our MSW in recent history. Dr. Castaldi is a Member of IeRM’s Board of Directors.

7- Most of the operatingWTE plants in the U.S. are decades old. That doesn’t mean that they have not been upgraded and kept in good operating order. The owners and the allowable emissions are zealously regulated by the EPA and state Departments of the Environment, as they must be. However, many need to have their air pollution control systems upgraded to the latest technologyin order to lower emissions further. A good example of how well WTE plants can operate is the West Palm Beach County, FL (WPB) facility. Unit #2 went into service in 2015. Its emissions history proves that we can successfully employ the WTE method. It operates far below the allowable limits set by the EPA. The technology currently exists and is available, but costly.I suggest that you visit this plant the next time that you are in Palm Beach visiting President Trump. Maybe even take him on a tour of this plant. Both of you will be very impressed at its positive environmentally-friendly operation.

Baltimore’s WinWasteWTE plant owners and Baltimore’s Mayor Young came to an agreement in 2020 to have new air pollution control systems installed on the plant. The cost for this upgrade is reported to be $45 million dollars. I met with the Plant Manager and Plant Engineer in 2021 and the project was underway in the construction phase. The upgrade is now complete and the plant is performing as expected. I would gladly arrange a tour of the plant for you the next time that you are in the Baltimore area. The plant’s emissions mimic the WPB facility’s low emissions, except for NOx. The WPB facility was specifically designed for lower NOx emissions.

I propose that you and your staff review Dr. Castaldi’s paper and forward it to theappropriate Senate and House Committeesso everyone can see the benefits to help upgrade the existing plants. Now is the time to allow WTE owners to expand the number of plants in the U.S. There is much room to increase the number of operating plants.The citizens who live near the existing WTE plants will benefit from the reduced emissions. Many of the people living near the plants are in the lower socio-economic strata. We will reduce the amount of greenhouse gases we produce.

As I stated in my dissertation- I believe that Waste-to-Energy is the best solution to our dirty Municipal Waste disposal problem until a better method is developed and implemented.

We at IeRM are ready to help address the growing waste and pollution problem. We would gladly meet with your National Energy Council and share our expertise. Please contact me to continue the conversation.

Very truly yours,

James P. Kruger, III, Ph.D.

Senior Policy Advisor- Institute for Energy & Resource Management

jameskruger@comcast.net

The Institute for Energy & Resource Management

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Newcastle, WA 98056

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