by Dylan Voorhees, NRCM Clean Energy Project Director
Senator Thibodeau and Representative Fitts,
Thank you for the opportunity to provide testimony on this legislation. NRCM strongly supports the use of our Renewable Energy Portfolio standard to spur investment in renewable resources that help reduce our dependence on fossil fuels, improve our environment, provide long-term stability and sustainable for our energy system. We oppose the addition of waste incineration to Maine’s RPS for several reasons.
First, a ratepayer subsidy for waste incineration provides a perverse incentive that is inconsistent with Maine’s solid waste management hierarchy. Waste incineration is 6th out of 7 in that hierarchy. It is hard to dispute that providing a subsidy for it reduces the incentive to pursue the more preferred waste management strategies of reduction, reuse and recycling. It is true that landfill gas is in the existing RPS, which may create an incentive for #7. We are uncomfortable with that policy and it certainly does not make it good policy to throw more money toward the bottom of the list. Proponents may suggest that recycling rates are higher in WTE communities. It reflects poor analytics to suggest that WTE causes higher recycling rates, and furthermore, the evidence does not suggest even this correlation exists in Maine.
Second, waste incineration should not be considered a renewable resource, and has clear environmental impacts. Waste incineration is generally not included in most RPS’s (and no “Class I” standards), and only under very narrow circumstances when it is, such as with required recycling activities, strict emission standards, and capped REC amounts. Waste incineration may indeed be cleaner and have fewer toxic emissions than in past years. This does not make the incineration of our trash so desirable as to deserve a public subsidy. Instead we should continue to focus our efforts on the strategies that reduce costs (for energy and waste) and improve our environment: recycling, energy efficiency and renewable generation such as wind, solar and tidal.
Finally, and perhaps most important to this committee, this bill would provide a significant ratepayer subsidy at little or no clear public or ratepayer benefit. Unlike Maine’s modern (i.e. Class I) RPS and those of the rest of the region, the proposed Waste-to-Energy RPS would provide a subsidy to existing plants, indeed plants that have been running on their own for some time. These plants presumably already receive capacity payments from ISO-NE to help ensure that their capacity will be available when most needed. The purpose of our Class I RPS is to incentivize investments in new generation that help diversify our generation mix beyond its current situation. It would be astonishing contradiction of the typical concern for ratepayer interests to see this new category of RPS added when the benefits to ratepayers and the public interest seems so questionable.