350 Salem’s Comments to DEQ

August 18, 2021

Denise Miller, DEQ Permit Coordinator
165 E. 7th Ave, Suite 100
Eugene, OR 97401

Dear Ms. Miller:

On behalf of 350 Salem OR, I submit the following comments on the proposed renewal of a 10-year solid waste permit for Covanta Marion, Inc.

350 Salem OR requests that the DEQ not renew a permit for the continued operation of the Covanta Marion incinerator in Brooks, Oregon.

Our reason is simple. On March 10, 2020, Governor Kate Brown signed Executive Order 20-04 directing state agencies to take actions to reduce greenhouse gas emissions in the state in order to achieve the state’s goal of reducing emissions to 80 percent below 1990 levels by 2050 and 45% percent below 1990 emissions levels by 2035. The Executive Order directs the DEQ and other state agencies to “exercise any and all authority and discretion vested in them by law to help facilitate Oregon’s achievement of GHG emissions reduction goals …” In her Executive Order the Governor also notes that climate change “has had a disproportionate effect on the physical, mental, financial and cultural well-being of impacted communities, such as … communities of color.”

To comply with the Governor’s Executive Order, DEQ must not renew a 10-year permit that allows the continued operation of a facility that the DEQ’s own report for 2019 indicates emits over 162,000 metric tons of greenhouse gases every year, the equivalent of annual emissions from 35,000 automobiles. The Covanta Marion incinerator is the top emitter in Marion County and in the top 25 for the entire state.

The Covanta Marion incinerator needs to cease operations and Marion County should send all of its solid waste to the Coffin Butte landfill that emits far less greenhouse gases. Some of Marion County’s solid waste is already being sent there. If DEQ follows through on the Governor’s order to “take necessary actions to reduce methane gas emissions from landfills” by reducing or eliminating the amount of organic waste, the emissions at the landfill can be dramatically reduced in the coming years.

Besides the greenhouse gas emissions from the incinerator, 350 Salem OR is very concerned about the high levels of toxic emissions from the Covanta Marion incinerator that poses a severe environmental justice issue for impacted communities, including communities of color, and has for over three decades.

It is inconceivable to us that granting a 10-year permit to a facility that will emit 1.6 million metric tons of greenhouse gases in the next decade is compatible with the goal to reduce emissions by 45% over roughly that same time period. The DEQ needs to use “any and all authority and discretion vested in them” as the Governor directs. Granting another permit to Covanta Marion would be a clear and direct violation of EO 20-04 and we request that the permit be denied.

Sincerely,
Phil Carver, 350 Salem Co-Coordinator