Comments on “Arecibo Waste-to-Energy and Resource Recovery Project Draft Environmental Impact Statement”

The document argues that the Arecibo Waste-to-Energy and Resource Recovery Project is unnecessary, economically unviable, and environmentally hazardous. It claims the Draft Environmental Impact Statement (DEIS) fails to meet National Environmental Policy Act (NEPA) standards by ignoring reasonable alternatives, underestimating public health risks—particularly lead exposure in a non-attainment area—and omitting cumulative impacts on human health and biological resources. The authors contend that the project violates the Rural Electrification Act's mandate to serve rural areas and would cause irreversible damage to the Caño Tiburones Natural Reserve.

• The project's electricity generation is not needed because Puerto Rico currently has 50% more electricity-generating capacity than it requires.
• The incinerator is unlikely to receive sufficient municipal solid waste (MSW) to operate at capacity due to strong opposition from the Mayors Association of Puerto Rico and declining population and per capita waste trends.
• The project is likely unfeasible because the Department of Natural and Environmental Resources (DNER) denied the water franchise application for extracting two million gallons of water daily from the Caño Tiburones Natural Reserve.
• The project may violate the Rural Electrification Act of 1936 because its service area is predominantly urban, whereas the Act mandates funding for projects serving rural areas (populations under 20,000).
• The DEIS fails to consider reasonable alternatives to incineration, such as source reduction, reuse, recycling, and compost-to-energy facilities, which are prioritized under Puerto Rico's Waste Reduction and Recycling Act.
• The Human Health Risk Assessment (HHRA) used in the DEIS is flawed because it relies on proprietary software and underestimates cancer risks by using laboratory data instead of actual permit limits.
• The project is sited in a lead non-attainment area, yet the DEIS ignores the scientific consensus that there is no safe level of lead exposure, especially for children.
• The DEIS violates NEPA by omitting a cumulative impacts analysis for public health, ignoring the proximity of other polluting sources like the Battery Recycling Company and the Cambalache Power Plant.
• The project's ash management plan is inadequate, as it assumes ash can be made nonhazardous without specifying conditioning agents and ignores the fact that most Puerto Rican municipalities ban the landfilling of industrial ash.
• The DEIS incorrectly concludes the project will reduce greenhouse gas (GHG) emissions by assuming it will displace oil-fired power, despite declining electricity demand and the availability of cleaner renewables.
• The project is located in a floodplain and on wetlands, potentially violating Executive Orders 11988 and 11990, and is vulnerable to sea-level rise and storm events.
• The biological assessment is myopic, focusing only on the project footprint and ignoring indirect effects on the Caño Tiburones Natural Reserve, an Important Bird Area globally in danger.

APA

Earthjustice (2015). Comments on “Arecibo Waste-to-Energy and Resource Recovery Project Draft Environmental Impact Statement”. https://earthjustice.org/wp-content/uploads/final20comments20with20all20exhibits20-20reduced20size.pdf

Chicago

Earthjustice. Comments on “Arecibo Waste-to-Energy and Resource Recovery Project Draft Environmental Impact Statement”. 2015. https://earthjustice.org/wp-content/uploads/final20comments20with20all20exhibits20-20reduced20size.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Comments on “Arecibo Waste-to-Energy and Resource Recovery Project Draft Environmental Impact Statement” |date=12 November 2015 |url=https://earthjustice.org/wp-content/uploads/final20comments20with20all20exhibits20-20reduced20size.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2015comments, author = {{Earthjustice}}, title = {{Comments on “Arecibo Waste-to-Energy and Resource Recovery Project Draft Environmental Impact Statement”}}, publisher = {Earthjustice}, year = {2015}, month = nov, url = {https://earthjustice.org/wp-content/uploads/final20comments20with20all20exhibits20-20reduced20size.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }