Why to attend the public hearing on the incinerator’s air permit violations
Wednesday, March 8, International House, 111 E. Kirby
6 pm information; 7 pm comment period
• The incinerator is located in a low-income community of color. 87% of residents within a mile
are persons of color; 60% live below the federal poverty line. The surrounding community has
a high rate of respiratory illness, particularly asthma, commonly triggered by emissions that
violate the Clean Air Act.
• Less than 20% of the garbage burned at I-94 & I-75 is Detroit garbage; 65% of the garbage
burned at I-94 & I-75 comes from Oakland County
• A low-income community of color bears the environmental and public health burden of burning
municipal solid waste coming mostly from the wealthiest county in the State of Michigan and
one of the wealthiest counties in the United States.
Health impacts of emissions:
• Average emissions from the DRP facility account for approximately 2% of premature deaths,
4% of the hospitalizations, and between 3 and 4% of asthma outcomes among children,
according to analysis of reported emissions data by Community Action to Promote Healthy
• The health impacts attributable to the DRP facility alone cost $2.6 million each year.
Gaps in addressing the violations and deficiencies of the penalty:
• The Violation Notice cites Detroit Renewable Power for 19 distinct air emission violation
incidents, yet the proposed Consent Order addresses only 6.
• The per-day cost of the particulate matter (PM) violations is extremely discounted. PM limits
were exceeded for 64 days and the fine proposed is $8,000, or $125/day. The daily fine for
other violations in the Consent Order is $5,000. 64 days of violation times $5,000 equals
$320,000 alone for PM.
• The incinerator has multiple violations of the Clean Air Act with failure to monitor sulfur dioxide,
carbon monoxide, and nitrous oxides. All of these pollutants are known to harm respiratory
function. These violations should be included in the penalty assessment.
• The draft Consent Order fails to discourage future violations: DRP’s negligence in failure to
perform continuous emissions monitoring, as well as failure to perform cylinder gas audits
should be deemed a History of Noncompliance and Willful Negligence, and a failure of
As drafted with a fine of only $149,000, the draft Consent Order is extremely deficient.
This is your opportunity to speak up:
• for Clean Air for Detroit residents
• for accountability by government agencies that are mandated to protect the public.