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36TH LEGISLATURE OF THE VIRGIN ISLANDS COMMITTEE ON GOVERNMENT OPERATIONS, VETERANS AFFAIRS, AND CONSUMER PROTECTION The Honorable Senator Avery L. Lewis Chair of Committee Testimony Presented By The Honorable Justa Encarnacion, RN, BSN, MBA/HCM Commissioner of Health on Bill No. 36-0232: An act amending Act No. 8018 to authorize the disposal of green waste using controlled incineration technologies, including air curtain incinerators, and for other purposes. 1 2 DOH Testimony on 3-0232 Good day, Honorable Senator Avery L. Lewis, Chairperson of the Committee on Government 1 Operations, Veterans Affairs and Consumer Protection; Honorable Senator Novelle E. Francis, 2 Vice Chair; members of the Committee, other Senators present, and to the viewing audience. 3 I am Reuben Molloy, Assistant Commissioner of the VI Department of Health testifying on 4 behalf of the Honorable Commissioner Justa Encarnacion. I am joined by Chief Legal Counsel 5 Mackiesh Taylor-Jones and Director of Environmental Health, Wanson Harris. 6 We are here to provide testimony on Bill No. 36-0232, which proposes the use of controlled 7 incineration technologies, including air curtain incinerators, for green waste disposal. 8 From a public health perspective, air curtain systems present conditional benefits and risks. 9 When properly operated — particularly for vegetative debris following disasters — they can 10 reduce waste accumulation, limit disease vectors, decrease fire risk, and improve sanitation. 11 However, these benefits must be balanced with potential air quality impacts, including 12 particulate matter exposure to nearby communities. 13 It is important to note that air curtain incineration is one of several potential waste management 14 approaches. Other methods may achieve similar public health benefits with less risk to air 15 quality, depending on how they are implemented. As such, the Department does not take a 16 position in favor of a single method but instead emphasizes the importance of selecting solutions 17 that minimize overall public health risk. 18 At the same time, maintaining the current system of grinding and stockpiling waste presents 19 clear and increasing public health concerns: 20 • Worker exposure to carcinogenic wood dust over prolonged periods 21 • Elevated community air pollution from fine particulate matter (PM2.5) 22 • Fire risk associated with large, unstable debris piles 23 • Increased vector activity, contributing to the spread of disease 24 Regardless of the method selected, these risks underscore the urgent need for timely and 25 effective waste reduction strategies. 26 3 DOH Testimony on 3-0232 The primary pollutant of concern across disposal methods is fine particulate matter (PM2.5), 1 which is associated with respiratory and cardiovascular health effects. Additional pollutants may 2 also be generated depending on the process and materials involved. Local weather patterns, 3 including low wind conditions, can further influence exposure levels for nearby communities. 4 For these reasons, the Department of Health strongly recommends that any selected approach 5 include: 6 • Strict operational controls and monitoring 7 • Clear limitations to vegetative waste only 8 • Worker protection measures 9 • Air quality monitoring and community safeguards 10 • Implementation of a process for immediately notifying the Department of Health’s 11 Division of Environmental Health upon changes in air quality that can adversely affect 12 surrounding communities. 13 In closing, the Department of Health’s role is to ensure that public health risks are clearly 14 identified, mitigated, and monitored. We remain committed to working with the Legislature and 15 our partners to support a solution that is effective, sustainable, and protective of both workers 16 and the broader community. 17 The Department of Health thanks Senator Clifford A. Joseph, Sr. for introducing this measure, 18 and Senator Lewis, Senator Kenneth Gittens, and Senator Franklin Johnson for their sponsorship. 19 We stand ready to answer any questions. 20