Category: News

The Baker Institute’s ‘The Energy Forum’ podcast dives deep into a promising response to plastic waste: advanced recycling (also known as chemical or molecular recycling). This two-part series, hosted by Rachel A. Meidl, LP.D., CHMM, explores both the science and policy landscape shaping the future of plastic waste management.

In Part 1 of the podcast series, Meidl is joined by Marco J. Castaldi, director of EEC|CCNY. This episode describes how advanced recycling differs from traditional mechanical processes, and why it is becoming a focal point in circularity. Continuing the conversation in Part 2, the dialogue delves into the various categories of advanced recycling, tackling the misunderstandings and mischaracterizations surrounding them. More importantly, Meidl and Castaldi discuss what it will take to scale up these technologies in a responsible, science-based way manner.

On May 30, 2025, the U.S. Environmental Protection Agency (EPA) closed the public comment period for its proposed rule titled “Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources: Large Municipal Waste Combustors Voluntary Remand Response and 5-Year Review; Reopening of Comment Period”. The proposed amendments include a comprehensive revision of emissions limits and regulatory requirements for large municipal waste combustors (MWCs), including both new and existing waste-to-energy (WTE) facilities.

These changes reflect EPA’s reevaluation of the maximum achievable control technology (MACT) floor levels following a voluntary remand and a petition for reconsideration, as well as the agency’s 5-year review obligation under the Clean Air Act. The rule also proposes the elimination of startup, shutdown, and malfunction (SSM) exemptions, updates to electronic reporting requirements, corrections to technical and typographical errors, and clarification of provisions related to air curtain incinerators and applicability dates.

As part of the public record, the Earth Engineering Center at The City College of New York (CUNY) submitted a technical analysis during the initial comment period, which closed in March 2024. This study, titled “Technical Assessment of Current APC Performance to Theoretical Emissions Reductions”, was commissioned by the American Society of Mechanical Engineers (ASME) Material and Energy Recovery (MER) Division. It evaluates the performance of air pollution control (APC) systems currently employed at WTE facilities in the U.S. and Canada. The assessment is accompanied by a preliminary health risk analysis to contextualize measured emissions in terms of potential community exposure and health impacts. The findings in the technical assessment are consistent with the objective of EPA to ensure facilities achieve emission levels below Federal and State permit limits.

Earlier Engagement on Transparency and Cost Methodology (2023)

The 2024 submission builds on earlier engagement by the EEC. In May 2023, EEC submitted a comment to the EPA’s non-rulemaking docket, Reviewing Emission Standards for Clean Air Act section 129 pollutants from the Large Municipal Waste Combustor source category, opened to solicit stakeholder input ahead of formal rulemaking. In that comment, EEC requested that the Agency make public the data and modeling assumptions used to develop its preliminary cost projections for emissions control technologies, which were referenced in presentations shared with stakeholders. This submission was spearheaded by EEC researcher Erica Razook.

The comment noted that the EPA’s initial materials outlining potential cost implications for municipal facilities lacked sufficient detail for meaningful technical evaluation. EEC emphasized that transparency in cost methodology is critical to ensuring that any future regulatory requirements are grounded in feasibility and informed by the most up-to-date research in emissions control.

A recent article¹ explored the ongoing debate surrounding the Baltimore WIN Waste waste-to-energy (WtE) facility, revealing a city divided on how best to manage its waste. As part of its “Less Waste, Better Baltimore” Master Plan report from July 2020² , the city has set ambitious goals to improve solid waste and recycling. One of the most relevant targets to the WIN Waste WtE facility is diversion of 80% of residential food and organic waste away from landfills and incineration.

Public opinion on the WIN Waste facility is anything but uniform. The article featured perspectives from various stakeholders, including environmental advocate Mr. Dipnarine, who supports the facility, and members of the Chesapeake Bay Foundation and the South Baltimore Land Trust, who oppose it. This division mirrors broader community sentiment, as reflected in Baltimore’s Task 1 Survey Report. With over 2,000 responses, the survey found that 41% of residents supported a pay-as-you-throw trash system, while an equal percentage opposed it.

The article also touched on the importance of benchmarking waste management strategies. Internationally, Sweden and Denmark are often cited as models for waste-to-energy success, but Baltimore has opted to compare itself to domestic cities like Austin, Boston, Charleston, Charlotte, and Portland. Which of these cities provides the best roadmap for Baltimore remains an open question.

From a regulatory standpoint, Baltimore’s facility meets or exceeds federal, state, and city emission standards. However, public trust and perceptions of fairness in waste management policies will likely play a significant role in shaping the future of waste-to-energy in the region.

The city’s approach—benchmarking against comparable U.S. cities and adhering to strict emissions regulations—suggests a methodical path forward. But for any waste policy to be successful in practice, it must be based on sound assumptions. Professor Marco J. Castaldi from EEC casts doubts on the ambitious reductions and diversions targets, and he acknowledges that recycling doesn’t always go as planned. Whether Baltimore can navigate these challenges effectively remains to be seen, and hopefully, local journalists will continue to shed light on this important issue.

1. https://www.thebaltimorebanner.com/community/climate-environment/christopher-dipnarine-baltimore-incinerator-CKMQ5ZUAZZAKRHZX5YGN2VRIXU/ ↩︎
2. https://publicworks.baltimorecity.gov/lesswaste ↩︎

WtERT® has received accreditation from the United Nations Environment Programme (UNEP). This milestone further strengthens our commitment to advancing sustainable WtE solutions globally. WtERT-USA, officially recognized as EEC|CCNY, celebrates this important milestone in the global push for sustainable waste management solutions. We look forward to continuing our efforts in advancing the global adoption of waste-to-energy solutions and working alongside international partners to achieve a more sustainable future.

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