Washington, DC’s History with Waste Incineration

1972 to 1994: DC’s old trash incin­er­a­tor oper­at­ed in Ben­ning Road neigh­bor­hood in Ward 7, a low-income Black com­mu­ni­ty where oth­er envi­ron­men­tal­ly harm­ful facil­i­ties have been con­cen­trat­ed, one of the city’s two trash trans­fer sta­tions (which had a fire in 2022 and is being rebuilt), an oil-fired pow­er plant (closed in 2012) that left behind a con­t­a­m­i­nat­ed site that is spread­ing under­ground into the neigh­bor­hood, and a Super­fund tox­ic waste site near pub­lic hous­ing where incin­er­a­tor ash and oth­er wastes were dumped years ago.

2004–2009: All 14 bids when land­fills were allowed to com­pete for DC’s trash came in cheap­er than using the Cov­an­ta Fair­fax incin­er­a­tor in Lor­ton, VA.

Cov­an­ta Fair­fax is the largest indus­tri­al air pol­luter with­in at least 25 miles of DC. How­ev­er, DPW kept sign­ing con­tracts to use Cov­an­ta. Read back­ground in our arti­cle on DC’s waste and envi­ron­men­tal racism. Designed to burn up to 3,000 tons of waste per day, this incin­er­a­tor was the 3rd largest in the nation. After being rebuilt in 2017 after a major fire, the incin­er­a­tor now burns over their capac­i­ty, aver­ag­ing 3,250 tons/day, more than the nation’s largest waste incin­er­a­tor. In April 2024, Cov­an­ta rebrand­ed itself as “Reworld.”

2013: DC DPW looks at build­ing a new trash incin­er­a­tor in the Dis­trict. Oppo­si­tion from Ener­gy Jus­tice Net­work, Sier­ra Club, and oth­ers kills that idea early.

Dur­ing that explo­ration, then DPW Direc­tor How­land (who used to work for Fair­fax Coun­ty), had expressed that DC should­n’t be giv­ing mon­ey to dis­pose of waste at Cov­an­ta Fair­fax if the city can own its own incin­er­a­tor with­in its bor­ders, and get mon­ey from import­ing waste from out­side of the Dis­trict. It became clear that the only fea­si­ble site being con­sid­ered was to reuse the Ben­ning Road site, which made it an envi­ron­men­tal jus­tice issue.

3/18/2013: Coun­cilmem­ber Mary Cheh chaired the Com­mit­tee on Trans­porta­tion and the Envi­ron­men­t’s Pub­lic Over­sight Hear­ing on the “Study of a Waste-to-Ener­gy Facil­i­ty in the Dis­trict.” See video.

In that hear­ing, the spokesper­son for the incin­er­a­tor indus­try’s trade asso­ci­a­tion admit­ted on the record that Mike Ewall from Ener­gy Jus­tice Net­work was cor­rect about incin­er­a­tion gen­er­al­ly being more expen­sive than land­fill­ing [at 1:44 in video] and incin­er­a­tion being dirt­i­er than coal pow­er plants [1:46]. Cheh remarked [2:04] “…there’s going to be a sub­stan­tial invest­ment… not to men­tion the polit­i­cal issue about where such a facil­i­ty would be locat­ed in the Dis­trict. I’ve already decid­ed it won’t be in Ward 3. Kid­ding.” While she claimed to be jok­ing, it’s clear that the city’s wealth­i­est and whitest ward would nev­er be cho­sen for a new incin­er­a­tor. In two years, on behalf of the admin­is­tra­tion, Cheh intro­duced the bill to enter into the con­tract to keep burn­ing DC’s trash in the com­mu­ni­ty of col­or in Lor­ton, VA for anoth­er 6–11 years, though she lat­er came to object to this con­tract (more below). 

2015: DC DPW put togeth­er a request for pro­pos­als (RFP) that did not allow land­fills to com­pete. The only facil­i­ties per­mit­ted to bid on tak­ing DC’s trash were waste incin­er­a­tors with­in 50 miles of DC’s two trans­fer sta­tions. There are four of them, and the only one in a white com­mu­ni­ty is in Mont­gomery Coun­ty and DPW knew well that they do not accept out-of-coun­ty waste. It was a vio­la­tion of Title VI of the Civ­il Rights Act to rig the RFP so that the only facil­i­ties eli­gi­ble to accept DC’s trash are incin­er­a­tors in com­mu­ni­ties of col­or. The incin­er­a­tors in Alexan­dria and Bal­ti­more did­n’t have the extra capac­i­ty, so Cov­an­ta Fair­fax was the only bid­der and got the con­tract, as the RFP was designed to do. It was a 5‑year con­tract with two 3‑year renew­al options. 21 groups opposed the con­tract, but it was approved, any­way. More on our oppo­si­tion at the time here: https://energyjustice.net/dc/wastecontract

Hal­lie Clemm served as DPW’s Sol­id Waste Man­age­ment Deputy Admin­is­tra­tor for over 30 years from July 1985 through Octo­ber 2015. She was in charge of design­ing the rigged con­tract and had the expe­ri­ence to know exact­ly what the result would be of the cri­te­ria she put in the RFP. Her role at DPW was high­ly con­tro­ver­sial among envi­ron­men­tal groups at the time, due to her pro-incin­er­a­tion views, and her hos­til­i­ty to zero waste efforts. She was cred­it­ed for the long his­to­ry of poor recy­cling rates in the Dis­trict. After retir­ing from DPW, she went to work as the Chief Oper­at­ing Offi­cer for the city’s largest pri­vate waste hauler, Ten­ley­town Trash. 

2017: Two months after a major waste pile fire at the Cov­an­ta-run incin­er­a­tor in Mont­gomery Coun­ty, MD which burned for near­ly two weeks, the same hap­pened at Cov­an­ta Fair­fax, caus­ing much more dam­age. Three sto­ries of trash burned uncon­trolled for near­ly two weeks and caused about $40 mil­lion in dam­age to the plant, shut­ting it down from 2/2/2017 until the very end of the year. Find some pic­tures of that here.

2017: We com­mis­sioned pub­lished econ­o­mist and life cycle assess­ment (LCA) expert, Dr. Jef­frey Mor­ris, to use his “MEB­Calc” mod­el to ana­lyze incin­er­a­tion vs. land­fill­ing for DC. The Mea­sur­ing Envi­ron­men­tal Ben­e­fits Cal­cu­la­tor (MEB­Calc) eval­u­ates nine dif­fer­ent health and envi­ron­men­tal impacts and is able to add them up using a mon­e­tized impact total to show all of the impacts on one chart. It’s the most com­pre­hen­sive LCA tool for eval­u­at­ing waste sys­tems. The mod­el showed incin­er­a­tion at Cov­an­ta to be far worse than land­fill­ing when look­ing at the nine health and envi­ron­men­tal cri­te­ria, includ­ing trans­porta­tion impacts. Mike Ewall pre­sent­ed this to DPW Direc­tor Short­er and the DPW’s Office of Waste Diver­sion staff that sum­mer. In gath­er­ing data for this, Mike spoke to land­fill man­agers at four south­east­ern VA land­fills to get land­fill gas cap­ture rate data, and asked them all if they thought they could beat Cov­an­ta’s price if they were offered a con­tract with the same 5–11 year term, despite the greater haul­ing dis­tance. All indi­cat­ed that they could. Here are the results of the life cycle assessment:

[Note: a more detailed 2021 report on the Cov­an­ta incin­er­a­tor in Mary­land, done for Coun­ty Exec­u­tive of Mont­gomery Coun­ty, using updat­ed method­ol­o­gy and more help­ful sum­ma­ry charts, found that incin­er­a­tion is twice as harm­ful for the cli­mate as land­fill­ing at more dis­tant land­fills in PA, and was 3.2 times as bad when fac­tor­ing in oth­er health and envi­ron­men­tal cri­te­ria. That can be found at https://energyjustice.net/md/moco]

2018: In the wake of the incin­er­a­tor clo­sure in 2017, and argu­ments between DC and Cov­an­ta on who will pay for the diver­sion of waste to South­east­ern VA land­fills dur­ing those 11 months, City Coun­cil Envi­ron­ment and Trans­porta­tion Com­mit­tee Chair, Mary Cheh, in DPW over­sight hear­ings, asked DPW to do an analy­sis of incin­er­a­tion vs. land­fill­ing (not real­iz­ing we had just done that). DPW promised to do so, and also com­mit­ted to issue a Request for Infor­ma­tion into the prices of going direct to land­fill. DPW nev­er did the lat­ter and took until 2021 to do the analy­sis.2020: With the 5‑year ini­tial term of the Cov­an­ta con­tract com­ing up soon, Coun­cilmem­ber Cheh writes this pow­er­ful let­ter to DPW object­ing to renew­ing it for more than one year while DPW does the two things they com­mit­ted to in 2018. 

2021: DPW reveals that they’re final­ly going to work on the land­fill vs. incin­er­a­tion analy­sis, would­n’t reveal who they con­sult­ed to design the scope of work, or the scope of work itself, and did­n’t com­mu­ni­cate the avail­abil­i­ty for the RFP so that experts like Dr. Mor­ris with Sound Resource Man­age­ment Group could even bid. They end­ed up putting togeth­er a scope of work that was biased in favor of incin­er­a­tion, using a biased mod­el (EPA’s WARM mod­el which looks only at cli­mate impacts of waste sys­tems) and hired a biased con­sul­tant, CDM Smith, which helps build incin­er­a­tors, but decom­mis­sion land­fills (and has a flame in their logo!). We reviewed the study design once it was revealed, and before the study was start­ed, we wrote up the con­cerned in this let­ter. EPA’s WARM mod­el was a cen­tral point in these con­cerns. Coun­cilmem­ber Cheh backed up these con­cerns in her own let­ter to DPW. The main bias­es in the WARM mod­el revolve around incor­rect assump­tions about dis­place­ment of elec­tric­i­ty, and out­dat­ed sci­ence that assumes that “bio­genic” car­bon (CO2) emis­sions do not count, which has long been dis­put­ed by cli­mate scientists.

In response, Mike Ewall met with DPW and six CDM Smith con­sul­tants. This meet­ing result­ed in no con­ces­sions on the ener­gy dis­place­ment assump­tion, even though Cov­an­ta Fair­fax sells into the only RPS mar­ket in the nation (Mary­land) where incin­er­a­tion is in a Tier 1 cat­e­go­ry, main­ly com­pet­ing with wind pow­er and not dis­plac­ing fos­sil fuels. They com­pro­mised par­tial­ly on the bio­genic car­bon point, but only in a small way, to not give dis­counts to more durable bio­genic car­bon like wood, but they still ignored the “short-term” bio­genic car­bon emis­sions from incin­er­a­tion, which is most of the bio­genic emis­sions, since food scraps and yard waste make up more of the waste stream than paper and wood.

2/23/2022: EPA admits to us that, despite hav­ing 15 ver­sions of their WARM mod­el out, it had nev­er been peer reviewed. A peer review has since been con­duct­ed in response to our request and a pub­lic com­ment peri­od waste opened in late 2023 / ear­ly 2024 where Ener­gy Jus­tice Net­work and our mem­bers and allies around the coun­try gave exten­sive com­ments on the three major flaws with the model.

2022: the CDM Smith study comes out and is far worse than we antic­i­pat­ed, even claim­ing that incin­er­a­tion is cheap­er (with no evi­dence and no RFP or RFI issued) and that land­fill­ing in a rur­al white com­mu­ni­ty is more of an envi­ron­men­tal jus­tice con­cern than incin­er­at­ing and land­fill­ing ash in a pop­u­lat­ed sub­ur­ban com­mu­ni­ty of col­or. They rigged this result by giv­ing equal weight to com­mu­ni­ties that trucks trav­el through, even though their own report shows what we’ve found in our 2017 and 2021 LCAs… that trans­porta­tion impacts are mar­gin­al com­pared to the land­fill or incin­er­a­tor impacts. CDM Smith found that trans­porta­tion impacts are 1–4% of the total, but weight­ed them with 50% of the eval­u­a­tion score in order to flip the obvi­ous envi­ron­men­tal jus­tice con­clu­sion on its head. (see Table 3–21 on page 3–28 [page 52 of the PDF]).

As overt­ly biased as this study was, it still proved our case (see Table 3–3 on page 3–3 [PDF page 27]) because in the sce­nario where the elec­tric­i­ty dis­placed by Cov­an­ta Fair­fax is 90% renew­able, the green­house gas impacts of incin­er­a­tion turn out to be worse than those from land­fill­ing, even with much greater truck­ing dis­tance, and even with CDM Smith’s oth­er bias­es still baked in. In fact, the ener­gy they dis­place is 100% renew­able because they sell into the Mary­land Renew­able Port­fo­lio Stan­dard pro­gram. If the study had used com­mon met­rics to com­pare oth­er emis­sions impacts affect­ing health and envi­ron­ment instead of a risk assess­ment mod­el, it would have shown a much more stark dif­fer­ence between incin­er­a­tion and land­fill­ing, as incin­er­a­tor emis­sions are far greater.

2022: We pre­sent­ed a DC Envi­ron­men­tal Net­work (DCEN) Brief­ing on the Biased DC DPW Incin­er­a­tion Report: “Sus­tain­abil­i­ty Assess­ment of Dis­pos­al Options,” debunk­ing its claims.

In the wake of this study, DPW has cho­sen not to ful­fill its promise to city coun­cil to get the pric­ing on direct land­fill­ing, using the CDM Smith report as an excuse to not even find out.

10/4/2022: 274 orga­ni­za­tions sup­port­ed a let­ter we wrote to the White House Coun­cil on Envi­ron­men­tal Qual­i­ty urg­ing them to lean on EPA to address numer­ous pro-incin­er­a­tion poli­cies includ­ing the bias­es in their WARM model.

11/7/2022 In a Trans­porta­tion & Envi­ron­ment Com­mit­tee hear­ing on Zero Waste, DPW states that they’re mov­ing away from incineration:

Coun­cilmem­ber Cheh: “I want to turn to prob­a­bly back to you, direc­tor, the incin­er­a­tor and recy­clables con­tract. We approved a one-year exten­sion for the waste to take us through the end of 2022, and I moved the leg­is­la­tion, I did it with some reser­va­tion as there’s a num­ber of com­pelling objec­tions to incin­er­a­tion, and to con­tin­ue our con­ver­sa­tion in par­tic­u­lar. So, I’d like to know, now that this con­tract exten­sion is com­ing to a close, what’s DPW’s plan to move forward?”

DPW Direc­tor Carter: “Our plan mov­ing for­ward is to work to take as much of that waste to local land­fills with incin­er­a­tion not being a viable alter­na­tive. I’m work­ing with my staff and with pro­cure­ment to see how we could expe­dite that process.”

See the video.

In a DPW stake­hold­er meet­ing short­ly after this, Blake Adams (head of DPW’s Office of Waste Diver­sion) denies that they are aim­ing to move away from incin­er­a­tion. Both Direc­tor Carter and Blake Adams left their posi­tions by ear­ly 2023 for dif­fer­ent reasons.

Since Cheh’s 2020 let­ter, DC City Coun­cil has refused to move for­ward 3‑year con­tract exten­sions with Cov­an­ta, and they’ve been on 1‑year exten­sions so far.