If we burn it, we breathe it!

Outdated wastewater treatment infrastructure is failing to meet today’s demands — let alone tomorrow’s. The City of Bellingham has an opportunity to set an example for the region and beyond by building climate-resilient, safe and environmentally responsible wastewater infrastructure for the future.

Sign the petition!

Bellingham deserves a cleaner, cheaper way to manage toxic sewage.

We’re urging the City to stop a $60 million plan to upgrade 33- and 53-year-old sewage incinerators at Post Point and pursue a safer, smarter alternative. Continuing to invest in outdated equipment means more pollution, higher costs, and missed climate goals. Sign the petition below to add your voice!

In the City of Bellingham, the wastewater produced by more than 90,000 people is treated at the Post Point Wastewater Treatment plant located in Fairhaven, only a few hundred feet from the coastline of Bellingham Bay and the Salish Sea. This sewage water contains human waste, along with everything else we flush down our drains, including soaps, cleaners, pharmaceuticals, and more—a cocktail of nutrients and toxic chemicals.

Post Point, which first began operations in 1974, currently uses incinerators to burn sewage sludge derived when water is separated from solids in the treatment process. These incinerators are at risk of failure due to their age and years of deferred maintenance. They also spew climate-warming pollution into the air as a byproduct. It’s clear that action is needed to ensure effective, continued wastewater treatment for a growing population while also addressing three core community concerns: cost, climate and contaminants.

An uncertain future

Currently, the City is taking serious steps toward spending $60 million on upgrading the 33- and 53-year-old multihearth incinerators to comply with clean air regulations. This is a necessary step if the incinerators are to continue operating, due to a 2024 Notice of Violation for noncompliance of air emissions from the Northwest Clean Air Agency, as well as for not applying and obtaining the necessary permits.

These ancient incinerators, nestled between Marine park and the Fairhaven and Edgemoor neighborhoods, continuously emit toxic air and water pollution. Permitted and regulated pollutants such as carbon monoxide, nitrogen oxides, sulfur oxides, dioxins/furans, mercury and other metals are present in the emissions, as well as non-regulated pollutants such as PFAS. PFAS (per- and polyfluoroalkyl substances) or “forever chemicals” are found in wastewater, are hard to break down, and are harmful in very small amounts. Most troubling is that much of this pollution is small particulate matter (PM 2.5) — so small that they can be inhaled deeply into the lungs and can lead to respiratory illness, heart disease, and lung cancer.

Spending that much money on antiquated technology that will continue to pollute and consume methane gas doesn’t make sense—especially since the price tag will likely only go up. It’s analogous to dumping money into an ancient, 50-year-old gas-guzzling car that is not nearly as efficient, safe, clean, or capable as a modern car.

As the City sits on the precipice of investing tens of millions of dollars into Post Point, RE Sources is urging the City to look at short-term, temporary solutions to minimize pollution and reduce the use of fossil fuels as it takes more time to make a decision that will impact the City, its residents, and our environment for decades to come.

We believe landfilling or lagooning our waste—at a cost of $4 million per year—for an interim period will enable the city to explore proven, alternative options for wastewater treatment infrastructure that will balance considerations of cost, contaminants, and climate. This is a decision that affects everyone, and therefore should be made with input from our entire community.

How’d we get here and what could be next? Read our blog post to learn more about interim options and future solutions.

FAQs

Waste comes to Post Point from our houses, industries, and our streets. Anything that gets flushed down the toilet, put down a sink drain, or washed off our downtown streets gets piped to the treatment plant. Pharmaceuticals, cleaning products, industrial waste, fossil fuels, pesticides, and other chemicals travel to our wastewater treatment plant every second of every day. The treatment plant is located next to Marine Park in Fairhaven.

The first treatment step removes all the solid stuff that is not poop or pee—“flushable” wipes, diapers, toys, and other unmentionables (I think you know what we mean). The second step is to separate the organic solids (the poop) from the liquid (pee and water). The liquid is further treated before being discharged into Bellingham Bay via a pipe that is hundreds of feet long. The organic solids are put in a centrifuge where extra water is taken off; the solids are then burned in an incinerator. The waste is converted to heat, toxic gasses, and smoke that is discharged into the air and what is left behind as ash is taken to a landfill.

We are currently most concerned about what is happening during the incineration process, though we do have concerns about the liquid stream too! Bellingham has two incinerators, one built in 1973 and the other in 1993. By no fault of their own, wastewater treatment plants have become a reservoir of toxic material and these antiquated incinerators are no longer adequate for treating this sludge. Incinerating this sludge has environmental consequences such as air, water, and land pollution as well as a large carbon footprint.

In sum, the two multi-hearth incinerators were constructed in 1973 and 1993, they are 53 and 33 years old, respectively, and use old and out-of-date technology that leads to incomplete combustion of harmful pollutants both regulated and unregulated. They use an enormous amount of energy and pollute our air and our water.

The incinerators struggle to meet air quality standards regulated by the Northwest Clean Air Agency (NWCAA). Because of their age, they are only required to meet the less stringent LLL air quality standards which allows them to release larger amounts of contaminants such as carbon monoxide, dioxins and furans, mercury, small particulate matter, and nitrogen oxides. Fragments of unregulated pollutants such as PFAS, microplastics, and pharmaceuticals are also being released. The hazardous exhaust is released 24/7 right next to Marine Park, Fairhaven, and Edgemore where people live, work, and play. Even if the incinerators were to someday meet the more stringent LLLL, quad L, air quality standards there would still be chronic and considerable air pollution. See below for a comparison of LLL and LLLL standards.

The EPA does not like these types of incinerators because they take an enormous amount of energy and emit toxic and climate warming gasses. In fact, the EPA no longer permits these incinerators and the only reason they can still operate is that they are grandfathered in. The EPA shut down the incinerator at the wastewater treatment plant in Lynwood, WA which was a few years older than the one at Post Point because it could not meet air quality standards. This could happen to our incinerators too, despite efforts to fix them.

These Incinerators are way past their life expectancy and parts necessary to maintain them are bought off of eBay (per Public Works employees comments). They need a lot of maintenance and repairs and are very expensive to maintain. There are only two other incinerators of this era in Washington State and less than twenty of them left in the entire US. We are flushing money down the toilet trying to fix and maintain these ancient machines.

The incinerators run primarily on natural gas and diesel. They consume 465 therms of natural gas per day which is well over 100x more than a 4 bedroom house. Sewer utilities make up 40% of the City’s emissions and the incinerators are responsible for most of that. They are also the main reason that the City is not able to meet its greenhouse gas reduction goals. Lastly, the incinerators are running at or above capacity. The City is planning on building extra storage containers to hold the solid waste but the amount of waste keeps increasing with population growth and the incinerators will have to burn more and more each year, adding stress to an already strained system.

Reliability comes from redundancy, not familiarity. The Post Point incinerators are 30-50 years old and the building in which they are housed is also old and in disrepair. The incinerators are at or above capacity and population growth will add additional strain. The City relies on hauling and landfiling as an emergency backup, yet does not have this infrastructure in place to do this.

On March 27, 2024, Northwest Clean Air Agency (NWCAA) sent a Notice of Violation (NOV) to the City of Bellingham for violating emission standards at Post Point for carbon monoxide and dioxins and furans as well as not having necessary permits.

Specifically, the violation stated that a notice was sent to the City of Bellingham for High Priority Violations in regards to the Post Point WWTP. Three violations were listed:

Compliance with 60 Subpart LLLL standards.
Failure to apply for and obtain NSR permit prior to burner replacements in 2021, 2022, and 2024.
Failure to submit the major source permit application addressing the major status of the facility with respect to carbon monoxide.

In regards to the first violation: A comprehensive compliance testing of the incinerators was performed in 2023 and revealed that the carbon monoxide readings were 27 times and 72 times higher than the standards for incinerator 1 and 2, respectively. Gross exceedances were also recorded in 2021. The City of Bellingham indicated that as early as 2014 the facility was not meeting Title V thresholds (2024 NWCAA Enforcement Report). Carbon monoxide is a greenhouse gas that contributes to global warming and is a hazardous gas that is harmful to human health when inhaled. Detecting high amounts of carbon monoxide also signals incomplete combustion and the likely presence of a lot of other contaminants. Carbon monoxide emissions are highly sporadic which is why a continuous monitoring system is necessary, this also makes it impossible to understand the full extent of the carbon monoxide pollution emitted from Post Point but it has likely been going on for over 10 years! We don’t understand why the Post Point facility has been allowed to knowingly violate the carbon monoxide threshold for so long without penalty or mitigation.

To address these violations, the NWCAA sent the City of Bellingham a Regulator Order 52 to establish a limit on the emission of carbon monoxide from the two incinerators. In response, the City has built a continuous monitoring system to measure the amount of carbon monoxide pollutant that is emitted. While this is helpful, this action alone does not adequately ensure that these incinerators are preventing air pollution from being emitted to the surrounding community. In addition to carbon monoxide standards, air quality standards also require meeting the emission limits for: Particulate matter, hydrogen chloride, dioxins/furans, mercury, oxides of nitrogen, sulfur dioxide, cadmium, lead, and fugitive emissions from ash handling (Table 2 to Subpart LLLL of Part 60).

In addition to carbon monoxide exceedances, compliance testing from 2023 found that dioxins/furans emissions were 2 times higher (incinerator 1) and 5 times higher (incinerator 2) than the regulations. Dioxins and furans are persistent organic pollutants that are highly toxic to humans and the environment. It has been over a year since this compliance testing was done with no known efforts to curb the pollution. Studies show that carbon monoxide is not the only pollution problem and legally, all of these pollutants need to be monitored at the incinerators at Post Point.

Emission controls reduce some pollutants but do not eliminate PFAS, other unregulated pollutants, or cumulative exposure risks. Meeting regulator limits is not the same as eliminating harm – especially when exposure is involuntary and long-term. The clean air permit is a permission slip to pollute.

The City needs an air operating permit from the Northwest Clean Air Agency (NWCAA). Because of the age of the incinerators, they are grandfathered into the permitting system. This means that these types of incinerators could not be permitted today. The EPA and NWCAA do not like these incinerators because of how much they pollute and how inefficient they are. As described above, the City has not met the requirements of the permit and was issued a notice of violation (NOV). The EPA shut down the incinerator in Lynnwood, WA because it could not meet emission standards. The City is planning on spending more than $60 million to fix the incinerators and upgrade the solids handling to help make them compliant.

It appears that the City also needs a Solid Waste Handling Permit (WAC 173-350). The sewage sludge is considered a solid waste because it is not treated, there is no energy capture from the incinerators and the ash can not be beneficially used (it is landfilled). The City is currently in negotiation with the County Health Department about this permit.

For more than 10 years. The exact time is unclear, but at a City Council meeting (March 24, 2025) the Public Works department made it clear that these incinerator fixes are not temporary repairs but rather they are intending to keep the incinerators running for 10, 20, 50, and even 100 years.

The City is expected to complete an emissions upgrade project that will be completed by 2030. These upgrades should make them compliant with LLL air quality standards. Because of their age and condition, it is unclear if they can meet and continue to meet LLLL (quad L) standards over the long term. In the meantime, the incinerators will continue to pollute. See below for a comparison of LLL and LLLL air quality standards.

As a part of their emissions upgrade the City is planning to build storage tanks that will hold the raw sewage to provide extra space for the increasing amounts of sewage coming to the plant. This will help create some redundancy in the system. Note – storing raw sewage will have similar odor challenges as hauling raw sewage.

The City’s plan B is to haul the sewage to a landfill. This is problematic because they do not have a haul out system in place right now. Sewage would pile up fast if the incinerators broke down or could not get fuel. Fuel lines could be compromised by a variety of factors including a natural disaster such as an earthquake.

No. The petition does not propose shutting down the treatment plant at Post Point or interrupting wastewater service. It asks the CIty to stop further investment in fixing the antiquated incinerators and use a safe, permitted temporary disposal method (landfilling) for sewage solids while long-term solutions are evaluated.

Sewage sludge can be diverted to permitted landfills using an existing, widely used practice. Many cities such as Lynnwood and Edmonds already use landfiling either permanently or as an interim measure. Like Post Point, both of these WWTPs are nestled in neighborhoods by the Salish Sea. The sewage sludge would be transported to a permitted landfill that is lined so that no contaminants can seep into the groundwater. The leachate (the wastewater that comes from the sewage sludge and other garbage) is treated before being discharged. Methane that is emitted from composting sewage is captured and used as natural gas. In a nut shell, landfilling contains contaminants instead of dispersing them into the air and water.

Kind of, however, landfilling contains the toxics better and uses less fossil fuels. Landfilling is not a long term solution but it is the better short term solution. Landfills are engineered containment systems designed to manage contaminants. Multihearth incineration does not destroy PFAS and other persistent chemicals – it redistributes them into air emissions and ash. Containment is safer than dispersion; it is the lesser of two evils.

Long-term cost projections depend heavily on assumptions. Incineration requires ongoing fuel, maintenance, compliance testing, and future upgrades – costs that escalate over time. Landfilling uses less fossil fuels and less large capital reinvestments while preserving flexibility.

Once we stop incineration, we can no longer use these incinerators because the EPA will no longer permit them. Choosing an interim solution does not eliminate future options, it actually frees us up to look at more long-term sustainable options. Spending tens of millions of dollars on upgrades and maintenance will commit the City to continued incineration for decades.

No, the Department of Ecology will give a temporary waiver to landfill if there is an intention to replace the incinerators. They have done this for Lynnwood and Edmonds and this option is clearly stated in WAC 173-308.

Any solids-handling method requires transport. Landfilling plans include enclosed loading facilities and odor control, similar to existing operations. These impacts are localized and manageable, unlike air emissions, which disperse involuntarily across neighborhoods. The City’s plan to build raw sewage storage containers will have the same odor issues as building a load out bay for the sludge.

WSDOT conducted a traffic survey of Old Fairhaven Parkway and determined that it is not at capacity and that adding an additional few trucks every day would not materially impact traffic. Traffic could be mitigated by imposing a condition limiting “rush” hour transfers.

Currently, the City’s backup plan for if the incinerators are not operable is to haul the sludge to a landfill. However, there is no infrastructure in place to haul sewage offsite. We want the City to build a haul out facility within the next year, so that there is legitimate plan B and so that landfilling can be a part of the solution. This is relatively low cost and creates actual (not theoretical) redundancy in the process.

In this case, an alternative analysis is a method to evaluate and rate a range of different sewage sludge management technologies. The analysis is a common method carried out by an independent, and presumably unbiased consultant to strategically analyze different technology options. A rubric is created to evaluate the technologies based on such things as cost, proven technology, reliability, greenhouse gas and toxic emissions, and other factors such as odor. While an alternative analysis was completed in 2019, it failed to account for toxic contamination in any media – air, water, or soil. To date, a credible and independent alternative analysis has not been conducted.

The alternative analysis that was conducted compared eleven different technologies: Anaerobic Digestion, Thermal Hydrolysis, Aerobic Digestion, Alkaline Stabilization, Lagoon, Raw Solids Composting, Incineration, Gasification, Pyrolysis, Hydrothermal Liquefaction, and Supercritical Water Oxidation. Anaerobic Digestion was chosen as the best fit for the criteria chosen. The main problem, however, was the evaluation metric they used – known as the Triple Bottom Line Plus – did not evaluate toxic contamination or nutrient discharge.

About the same time, the world became more aware of the dangerous chemical PFAS (per- and polyfluoroalkyl substances or “forever chemicals”) and other contaminants that are commonly found in sewage sludge. Anaerobic digestion contains PFAS and a whole slew of other chemicals (see below for the list of contaminants that were found when Post Point sludge was tested). Anaerobic digestion also increases the amount of nutrients, most notably nitrogen, that is sent to wastewater (effluent) treatment. Bellingham Bay and the entire Salish Sea are seeing impacts to increased nitrogen loads coming from WWTPs -there are more algal blooms and low dissolved oxygen areas. Because of these concerns, and mounting expenses, Mayor Fleetwood ordered that the City pause its plans to implement anaerobic digestion construction.

In 2024, the City conducted another alternative analysis but restricted its evaluation to only look at three different incineration options. Alternative one being an update to the existing multiple hearth incinerators. Solids hauling and landfilling were assessed briefly (but not thoroughly) in an attachment of the analysis. The analysis states, “…because Post Point dewaters its solids to between 20-25 percent solids prior to incineration, hauling solids may be feasible, particularly as a short-term solution while emissions compliance issues with the incinerators are addressed.” It is not clearly understood why this option was not more thoroughly investigated and why the City discounted it without more information.

Most recently, the city responded to community concerns about their choice to upgrade the antiquated incinerators by publishing a comparison of Incineration vs Landfilling (see Related News Tab for a link to this assessment). This report was an in-house analysis and not done by an independent analysis that is the norm and again, lacked details and information about the risks to human health and the environment. For example, the following nuances were not made clear: hauling sewage takes less fossil fuels than incineration, landfills capture methane while incineration does not, and contaminants are contained in a landfill but emitted as exhaust with the incinerators. We also question some of the budget details because it does not corroborate with the research we have done.

The following contaminants have ALL been detected in Bellingham’s sewage sludge:

Heavy Metals
- arsenic
- barium
- cadmium
- chromium
- lead
- mercury
- selenium
- silver
Contaminants of Emerging Concern
- plastics
- fire retardants
- PFAS (Per- and PolyFluoroAlkyl substances)
- PCB’s (PolyChlorinated Biphenyls)
- dioxins furans
Hydrocarbons and petrochemicals
Pharmaceuticals
Steroids and hormones

We don’t know. We would like the City to invest in a proper, non biased analysis of the different sewage sludge treatment options currently available both in the short term and the long term. This analysis would bring clarity to the true costs, health effects, and environmental impacts of the different available technologies. It would be a transparent process that the rate payers deserve to be a part of because they are the ones paying the bill.

There are other technologies that could reduce the cost of temporary landfilling such as lime stabilization, drying, biodrying, pressing, or digesting. These intermediate solutions, if planned correctly, could help ease the financial burden in the short term and set up for longer term solutions.

This petition does not ask the City to wait for unproven technologies. It asks the City to stop locking in decades of additional incineration while those technologies are evaluated. Landfilling is available now and does not prevent future adoption of better solutions. Running the incinerators until these technologies become available means decades of continued pollution.

Thermochemical processes such as gasification (with limited O2) or pyrolysis (w/o O2) degrade large molecules such as PFAS and PCBs with high temperatures and high pressure into their non harmful elemental forms. Anaerobic digestion only breaks down food like particles, not forever chemicals, and leaves a lot of material (energy) behind. Gasification and pyrolysis produce more energy from breaking down sludge than anaerobic digestion and, unlike incineration, they create syngas that can be used to power themselves while minimizing the emissions of greenhouse and other toxic gasses. The end product biochar is largely free from chemical contaminants and can be used as a soil amendment, filtration media, or for carbon storage in cement or other products. Thermochemical processes are considered carbon neutral (syngas is used to power the gasification or pyrolysis unit) and if you consider that you no longer have to truck sewage solids anywhere they can even be considered carbon negative.

Benefits of using thermal technologies: gas on site for energy, being more self-sufficient than biosolid digesters, and not huge amounts of natural gas and diesel like the incinerators does. Federal funding is available for projects that curb climate emissions in the way that thermal processing does, and we can curb emissions even more than biosolids or landfilling would.

Technology leaders in the field:

US Thermal Operations (and there are more around the world)

Fully Operational:

Linden, NJ [Aries Linden Biosolids Gasification Facility] (2022-present) Regional facility that processes 430 tons/day biosolids. Produces 22 tons of beneficial biochar/day. A closed-loop system requires no fossil fuels during operations.
Bethel, PA [Earthcare Gasification Dual Module Plant] (2024-present) Each unit can process 40 dry tons/day. One unit processes Ag waste the other biosolids, both digested and undigested. .
Epharata, PA [Bioforcetech Epharata Borough Wastewater Pyrolysis] (2024-present) Four biodryers, 1 pyrolysis. Processes 4000 tons of undigested biosolids.
Lebanon, TN [Aries Lebanon Waste-to-Energy Gasification] (2016-present) Processes 1000 wet tons/year, mixed biosolids and tires/wood chips— but phasing into just going with biosolids.
Covington, TN [Aries gasification] (2014 -present) Processes 1000 wet tons/year, mixed biosolids and wood wastes.
Redwood City, CA [Bioforcetech Silicon Valley Clean Water Pyrolysis] (2017 -present) Three biodryers, 1 pyrolysis. Precesses 3000 tons of digested biosolids.
Redding, CA [BioforcetechClear Creek WWTP Pyrolysis] (2024-present) Six biodryers and 1 pyrolysis, processes 6000 tons of digested biosolids. .
Los Angeles, CA [Kore SoCalGas pyrolysis] (2021-present) Processing 24 tons/day including biosolids.
San Bernardino CA [Anaergia’s Rialto Bioenergy Pyrolysis Facility] (2022-present). Processes up to 1,000 tons per day of a combination of food waste and biosolids. Produces over 1,000,000 MMBtu natural gas per year.
Schenectady, NY [Biowaste Pyrolysis Solutions and Technotherm] (2022-present) Processing 40,000 tons/year of dewatered sludge.
Moreau, NY [Saratoga Biochar Solutions] – The facility is designed to process up to 15% of the biosolids generated in NY and produces a revolutionary new bio-fertilizer; Carbon Fertilizer™.

Coming Soon:

Edmonds, WA [Ecoremedy Edmonds WWTP gasification]; Pilot tested in November, 2024. Expected to be fully operational soon.
Brentwood, CA [Bioforcetech WWTP Pyrylosis] (under construction) Eight biodryers and 2 pyrolysis. Processes 7,500 tons undigested biosolids.
Sanford, ME [Aires Regional Gasification facility] (Under construction – expected to be operational in 2027).

2026, February: RE Sources launches a petition to Stop Incineration at Post Point Wastewater Treatment Plant

2025, November: Public Work Director publishes an incomplete analysis done by the City that compares Post Point incineration vs landfiling.

2025, October: RE Sources and members from the Sludge Coalition meet with the Mayor, Public Works, and Brown & Caldwell to talk about their decision to fix the incinerators.

2025, June: RE Sources and Sludge Coalition write a letter to the Mayor and City Council Members recommending that the City decommission the incinerators in lieu of spending millions of dollars fixing them.

2025, March: The Emission Control Upgrades Alternative Analysis that was conducted by Brown and Caldwell is completed and presented to the City. Soon after, the City announces its plan to spend over $50 million to fix the incinerators to bring them into compliance.

2024, March: Northwest Clean Air Agency sends a Notice of Violation to the City of Bellingham for violating emission standards at Post Point for carbon monoxide, dioxins, and furans as well as not having necessary permits.

2022, September: Mayor Fleetwood recommends a pause on plans to implement anaerobic digestion upgrades at Post Point, citing ballooning cost estimates from $220 million to potentially $1 billion.

2022, August: California has added PFAS to the list of chemicals that require consumer warnings

2022, August: Public Works announces that it will spend $700,000 to evaluate post digestion technologies and to carry out an education and outreach program both conducted by Brown & Caldwell Consultants.

2022, June: EPA issued drinking water recommendations that warn that PFOA and PFOS in trace quantities (parts per trillion) undetectable quantities of PFOA and PFOS pose significant human health risks.

2022, April: Bellingham City Council voted unanimously to spend $220 million on the Post Point Wastewater Treatment upgrades including the construction of 4 anaerobic digesters but to also fund a study that evaluates the best option for disposing of the biosolids and to include a public engagement component. Note: estimated cost has gone up potentially doubling

2022, April: Maine becomes the first state to ban the practice of spreading PFAS-contaminated sewage sludge as fertilizer.

2021, November: Post Point Sewage Solids test results are made public in a 3,000+ page document. Results show that Post Point Sewage Solids are contaminated but because contaminants are not regulated, the City continues to pursue the making and land spreading of toxic biosolids.

2021, July: RE Sources presents to City Council and requests that Sewage Solids be tested for contaminants. The City Council approves the request unanimously.

2019: RE Sources and Mt Baker Sierra Club began expressing concerns about the safety of land spreading biosolids

2018: EPA publishes alarming report that identifies 352 pollutants in biosolids including pharmaceuticals, steroids, and flame retardants and admits it does not have enough information to regulate these pollutants.

2016-19: Used the Triple Bottom Line Plus (TBL+) criteria to decide on Anaerobic Digestion to make Class A biosolids cakes and to capture methane gas. Biosolids would be sold to a third party to be blended into a solid amendment that would then be spread in Whatcom and Skagit counties.

2017: City of Bellingham publishes an updated Climate Action Plan and highlights the inefficiencies and the greenhouse gas emissions by the incinerators at Post Point.

2012: City of Bellingham Public Works and Consultants decide to pursue Anaerobic Digestion to replace aging incinerators. Technologies were not evaluated on how well they treated contaminants such as PFAS, PCBs, pharmaceuticals, flame retardants, or microplastics.

Solid waste is the umbrella term to describe any type of waste product such as trash and sewage sludge. The legal definition is: “Solid waste,” “waste materials,” or “wastes” means all putrescible and nonputrescible solid and semisolid wastes including, but not limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, demolition and construction wastes, abandoned vehicles or parts thereof, contaminated soils and contaminated dredged material, and recyclable materials. (WAC 173-350)

Sewage sludge is the raw material that comes to wastewater treatment plants – all the stuff that goes down sink drains, toilettes, industrial waste, and stormwater. Sewage sludge is a type of solid waste. (WAC 173-308-080)

Biosolids is sewage sludge that has been treated and can be beneficially recycled and meets specific requirements. Biosolids are not a solid waste. People often mistakenly call sewage sludge biosolids.

No, in Washington State there is a law that we have to beneficially use biosolids. As defined above, sewage sludge is a solid waste, not biosolids, because it has not been treated.

Environmental Protection Agency (EPA) standards for Sewage Sludge Incineration (SSI) units.

While they target the same nine pollutants, they apply to different generations of facilities: Subpart LLL (40 CFR Part 62) is the Federal Plan for existing units, while Subpart LLLL (40 CFR Part 60) sets the “New Source Performance Standards” (NSPS) for new units.

Comparison Table: LLL vs. LLLL Standards

Feature	Subpart LLL	Subpart LLLL
Applies To	Existing SSI units (constructed on or before October 14, 2010).	New SSI units (constructed after October 14, 2010, or modified after September 21, 2011).
Legal Basis	CAA Section 111(d)/129 (Emission Guidelines).	CAA Section 129 (New Source Performance Standards).
Regulated Pollutants	9 pollutants: Cadmium, Carbon Monoxide, Hydrogen Chloride, Lead, Mercury, Nitrogen Oxides, Particulate Matter, Dioxins/Furans, and Sulfur Dioxide.	Same 9 pollutants, but generally with stricter numerical limits.
Compliance Focus	Bringing older facilities up to a “floor” of emission control.	Ensuring modern facilities use the “Best System of Emission Reduction” (BSER).
Siting Analysis	Not typically required for existing units.	Required (must consider air pollution alternatives and minimize environmental impacts).
Waste Type	Domestic sewage sludge at a wastewater treatment facility.	Domestic sewage sludge at a wastewater treatment facility.

Anticipated costs for wastewater treatment upgrades have been a topic of discussion in our community, and for good reason. The short answer is that if anything, gasification would likely be cheaper than the anaerobic digester approach, all other infrastructure and maintenance costs being equal.

Here’s a more nuanced and much longer answer: When deciding how to proceed, it’s important to take a holistic view of which options best meet all three priorities of cost, climate AND contaminants. It’s also important to consider upfront costs associated with purchasing and/or repairing equipment and bringing it online, as well as the ongoing potential costs (or potential revenues) associated with the byproducts of wastewater sewage sludge treatment.

Unfortunately, any of our three options – repairing aging incinerators, installing anaerobic digesters, or gasification units – will bring substantial costs. Ratepayers will likely see rate increases regardless of the path chosen because of years of deferred maintenance and investment that kept sewage utility bills artificially low. What remains to be seen is the degree to which federal funding via the Bipartisan Infrastructure Bill and state funding could be leveraged to cover substantial portions of the cost and reduce the financial burden on individual ratepayers. RE Sources is exploring these opportunities and is encouraging the City of Bellingham to do the same.

Anaerobic Digestion
Capital investment costs will be substantial for any upgrades, but in addition to likely costing the most to purchase and bring online, anaerobic digestion also creates a substantial recurring cost if state or federal regulators move to restrict or prohibit the land-spreading of biosolids known to contain PFAS or other forever chemicals (as has already happened in Maine). Biosolids are a heavy, wet byproduct that would likely need to be trucked long distances and landfilled on an ongoing basis, adding to the operation’s costs as well as its carbon footprint. The estimated costs for upgrades including anaerobic digesters quoted by Mayor Fleetwood in Cascadia Daily News approached $1 billion, and that does not account for potential recurring biosolids disposal costs. The estimated costs of the anaerobic digestion system alone (with loan interest) would be roughly $430 million of that $1 billion price tag. According to the City, using anaerobic digesters would also increase nutrient removal costs by $200 million.

Gasification (a type of thermal treatment)
Gasification units would likely be cheaper than anaerobic digesters to acquire and bring online, and would create a lighter, non-toxic soil amendment that could actually be sold (revenue generating) rather than trucked away and landfilled. Two gasification units would cost an estimated $100 million.

It’s worth noting that gasification units could be used either as a replacement for all of Post Point’s incinerators or as a compliment to some of them. These technologies are not mutually exclusive.

Repair and Maintenance of Existing Incinerators
Repairs to the existing incinerators are likely necessary at this point, given the amount of time it would take to plan and implement other types of sewage sludge treatment. Estimates solely for repairing existing incinerators currently sit at around $100 million.

It’s also estimated that another $21 million is needed for plant wide generators, $200 million for nutrient removal (see more on this below), $30 million for operations and maintenance related to nutrient removal, and $50 million for inflation, contributing to an all-told price tab of $541 million. See the Department of Public Works’ recent (September 2022) presentation to the City’s Natural Resources Committee for a cost comparison between the anaerobic digester (resource recovery) plan and the incinerator repair and maintenance plan (p.14).

Pursuing the incinerator maintenance approach alone raises additional questions: how much time will the repairs buy us? What happens when parts for these decades-old systems are no longer in circulation? What will it cost to bring the emissions from the incinerators in line with air pollution regulations, and what about the greenhouse gas emissions and local air pollution impacts?

A note about costs for removing nutrients from wastewater
Because of strengthened Department of Ecology permit requirements, we’ll need to invest at least roughly $200 million to ensure we remove enough nutrients from the Post Point’s wastewater before the treated water is released into the Salish Sea as effluent. With the anaerobic digestion plan, the price tag for nutrient removal potentially doubles to $400 million.

Strengthening the nutrient general permits for the 58 wastewater treatment plants that empty into the Salish Sea was a crucial step toward recovering the health of the region’s iconic Salish Sea ecosystems and marine life. We’ll need to make this investment regardless of how sewage sludge is processed. State-level grant funds may also be available for these investments.

That’s a lot of information, and all prices quoted are subject to changes due to inflation, loan terms, and numerous other factors. The bottom line is we face substantial costs just to keep Post Point in operation and in compliance with state regulations. It’s RE Sources’ view that gasification is the best available option for sewage sludge processing when you consider climate, contaminants and cost.

Coalition Members

Atul Deshmane, Whatcom PUD Commissioner, engineer background, biofuels
Rick Eggerth, Whatcom Environmental Council, Sierra Club, retired attorney
Sean Hopps, Institute for Washington’s Future, C2C
Larry Bateman, former plant operator at Post Point WWTP
Stan Snapp, former City Council
Ken Bell, former POB commissioner, Iron Creek Group
Mike Montazeri, PhD, engineer with Windsor Engineers
Rodd Pemble, Whatcom Environmental Council president, retired SSC recycling manager
Liz Darrow, Community to Community Development (C2C)
Jane Bright, public health activist, co-founder HealthLink MA
Heather Witzel Lakin, RE Sources volunteer, climate education
John Matzinger, retired WWTP consultant
Bob Lanphear, creative strategist (visual & video)
Jordan Ballou, concerned community member
Enoch J Ledet, retired environmental quality assurance chemist
Brooks Anderson, former president of Fairhaven Neighbors, community activist
Kirsten McDade, North Sound Waterkeeper at RE Sources

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It’s Time to Dump the Incinerators (Part 1)

Is “Upgrading” Bellingham’s Post Point Incinerators the Answer?

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Nationwide Analysis Shows Shocking Contamination from PFAS “Forever Chemicals”

Bellingham May Process Sewage Into Fertilizer (Updated August 2022)

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