Comments Submitted on Behalf of Florida Rising on Draft Title V Permit No. 0250348- 013-AV, Proposed in Response to Application for Renewal of the Title V Permit for the Miami-Dade County Resources Recovery Facility

The document opposes the renewal of the Title V permit for the Miami-Dade County Resources Recovery Facility (Covanta Incinerator). It argues that the draft permit fails to include necessary emission limitations from previous State Implementation Plan (SIP) and Prevention of Significant Deterioration (PSD) permits, lacks adequate monitoring for pollutants and odors, and contains unlawful 'director discretion' provisions. The authors emphasize that the facility is located in an environmental justice community where 92% of the population are people of color and 36% live below the poverty line, exacerbating health risks from toxic emissions and greenhouse gases.

• The Covanta Incinerator is located in an environmental justice community where 92% of the population within three miles are people of color and 36% live below the poverty line.
• Waste incinerators are identified as the most emission-intensive form of electricity production in the U.S., emitting more greenhouse gases per unit of electricity than any other power source.
• The draft permit fails to include several emission limitations from SIP-approved PSD Permit No. PSD-FL-006A, specifically for volatile organic compounds (VOCs), fluoride, sulfuric acid mist, and arsenic.
• The draft permit contains unlawful 'director discretion' provisions that allow the DEP to authorize malfunction or startup/shutdown periods longer than the 3-hour or 2-hour limits established in the approved state plan.
• The facility has a history of severe odor issues, with over 3,500 complaints filed with the City of Doral's hotline between January 19, 2016, and September 8, 2021.
• The draft permit is criticized for lacking sufficient monitoring, relying on annual stack tests for pollutants like mercury, lead, and cadmium, which the authors argue cannot ensure continuous compliance.
• The authors argue the permit application is incomplete because it omits greenhouse gas (GHG) emissions reporting and fails to provide methods for determining current compliance with federally enforceable requirements.
• The draft permit allegedly creates an unlawful 'knowledge exemption' for the incineration of medical waste by using the term 'knowingly' in condition A.7.b, which contradicts the Clean Air Act's strict liability regime.

APA

Earthjustice (2021). Comments Submitted on Behalf of Florida Rising on Draft Title V Permit No. 0250348- 013-AV, Proposed in Response to Application for Renewal of the Title V Permit for the Miami-Dade County Resources Recovery Facility. https://earthjustice.org/wp-content/uploads/earthjustice_-_comment_letter_in_opposition_to_miami-dade_rrf_title_v_permit_renewal.pdf

Chicago

Earthjustice. Comments Submitted on Behalf of Florida Rising on Draft Title V Permit No. 0250348- 013-AV, Proposed in Response to Application for Renewal of the Title V Permit for the Miami-Dade County Resources Recovery Facility. 2021. https://earthjustice.org/wp-content/uploads/earthjustice_-_comment_letter_in_opposition_to_miami-dade_rrf_title_v_permit_renewal.pdf.

Wikipedia

{{cite report |author=Earthjustice |title=Comments Submitted on Behalf of Florida Rising on Draft Title V Permit No. 0250348- 013-AV, Proposed in Response to Application for Renewal of the Title V Permit for the Miami-Dade County Resources Recovery Facility |date=20 December 2021 |url=https://earthjustice.org/wp-content/uploads/earthjustice_-_comment_letter_in_opposition_to_miami-dade_rrf_title_v_permit_renewal.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{earthjustice2021comments, author = {{Earthjustice}}, title = {{Comments Submitted on Behalf of Florida Rising on Draft Title V Permit No. 0250348- 013-AV, Proposed in Response to Application for Renewal of the Title V Permit for the Miami-Dade County Resources Recovery Facility}}, institution = {Earthjustice}, year = {2021}, month = dec, url = {https://earthjustice.org/wp-content/uploads/earthjustice_-_comment_letter_in_opposition_to_miami-dade_rrf_title_v_permit_renewal.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }