Plainfield Trash Facts

Precedents worth knowing

How Communities Elsewhere Defeated Plants Like This

Comparable incinerators and gas pipelines have been stopped elsewhere by state permit denials, expired permits, and developers missing their own deadlines. In the documented cases below, none was defeated by a non-binding town referendum, and two projects ended after the developer already held a federal certificate.

Plainfield is not the first community to face a large waste-to-energy plant. The proposed SMART Technology Systems gasification facility remains a proposal under active review by state agencies; no final permit decision has been issued.67 Residents reasonably ask whether a project of this kind has ever actually been turned back. It has, more than once. What follows are six documented cases from four states, each tied where possible to the governing regulatory decision or court ruling and corroborated by an independent report. Each is a comparable precedent, not a prediction. Facility types and locations differ; what transfers is the legal and administrative mechanism, not a promised outcome.

6documented cases, in four states12
0stopped by a binding town referendum
2021a developer won at the U.S. Supreme Court, then ended the project for lack of a state water permit114
18 moconstruction gap that voided a Baltimore incinerator permit by law58

Case one · New York

Constitution Pipeline: a state water-quality denial the courts upheld

The Constitution Pipeline was a proposed 124-mile interstate natural gas pipeline designed to move roughly 650,000 dekatherms per day from northeastern Pennsylvania into New York. The Federal Energy Regulatory Commission issued its certificate of public convenience and necessity in December 2014.16

The project still required a Clean Water Act Section 401 water-quality certification from the state. On April 22, 2016, the New York State Department of Environmental Conservation denied that certification, finding the company had not supplied an adequate stream-by-stream analysis of pipeline burial depth for the roughly 250 New York streams the route would cross, submitting a site-specific analysis for only 21 of them.2 The developer challenged the denial. In August 2017 the U.S. Court of Appeals for the Second Circuit upheld the state, and on April 30, 2018 the U.S. Supreme Court declined to hear the appeal.2

Unable to obtain the state permit, the developers ended the project on February 24, 2020, after an eight-year effort.16 A federal certificate did not override a state’s authority over its own waters.

The transferable mechanism: a state can deny the Clean Water Act Section 401 water-quality certification on the record, and that denial can be upheld in court even against a federally certificated project.2

Case two · New Jersey

PennEast: a Supreme Court win that a state permit outlasted

PennEast was a proposed interstate natural gas pipeline from Pennsylvania into New Jersey. It held a FERC certificate, but New Jersey withheld the state approvals it needed, including the Section 401 water-quality certification and freshwater wetlands permits, which the New Jersey Department of Environmental Protection declined to issue.1415

On June 29, 2021, in PennEast Pipeline Co. v. New Jersey, the U.S. Supreme Court ruled 5–4 for the developer on the separate question of eminent domain, holding that a FERC certificate holder could condemn state-owned land.1 The company won that case. It did not matter. Less than three months later, in September 2021, PennEast ended the project, stating that it had not obtained the New Jersey water-quality certification and wetlands permits the project required.1415

The transferable mechanism: the state water and wetlands permits are a distinct barrier. A developer can prevail on federal questions, and even at the Supreme Court, and still be unable to build without the state’s Clean Water Act approvals.114

Case three · Massachusetts and New Hampshire

Northeast Energy Direct: sustained opposition, then a withdrawal at FERC

The Northeast Energy Direct project, proposed by Kinder Morgan subsidiary Tennessee Gas Pipeline, would have run several hundred miles across New York, Massachusetts and New Hampshire, with a market segment costed around $5 billion. The company filed its FERC application in November 2015 (Docket No. CP16-21).18

The route drew sustained, organized opposition across dozens of towns, including the No Fracked Gas in Mass coalition, which contested the application, the eminent-domain surveys, and the claimed regional need.11 On April 22, 2016 the company suspended work and asked FERC to take no further action, and it withdrew the application the following month, stating it had not secured sufficient contractual commitments from New England customers to proceed.1118

The transferable mechanism: multi-town, multi-year opposition that contests need at every step raises a project’s cost and uncertainty. A developer that cannot demonstrate committed demand may withdraw before any permit is ever decided.11

Case four · Maryland

Frederick County: permits issued, project ended anyway

Frederick and Carroll Counties jointly proposed a roughly 1,500-ton-per-day waste-to-energy incinerator in Frederick County, budgeted near $471 million, to be operated by Wheelabrator. The Maryland Department of the Environment issued its final permit determinations on February 21, 2014, for a plant designed to produce about 55 megawatts gross and 45 megawatts net.4

Holding the permits did not save the project. Carroll County withdrew from the partnership in April 2014, undermining the plant’s economics. On November 20, 2014, after roughly a decade of local opposition, the Frederick Board of County Commissioners voted 3–2 to cancel the contract and exit the permits.1213

The transferable mechanism: an issued permit is not the end of the fight. A project can still collapse when a financial partner leaves and elected officials decline to proceed.1213

Case five · Baltimore, Maryland

Curtis Bay: a permit that expired because construction stalled

Energy Answers proposed the Fairfield Renewable Energy incinerator in the Curtis Bay neighborhood of South Baltimore, less than a mile from schools. At 4,000 tons of waste per day it would have been the largest municipal-waste incinerator in the United States, permitted to emit up to 1,000 pounds of lead per year. The Maryland Public Service Commission issued its Certificate of Public Convenience and Necessity on August 6, 2010.8

Under the federal Prevention of Significant Deterioration rule, an air permit becomes invalid if construction is discontinued for 18 months or more.5 Construction at Fairfield stopped in November 2013 and did not resume; the air-quality authorization lapsed on May 1, 2015. After a seven-year community campaign, residents and the Environmental Integrity Project filed a Clean Air Act notice of intent to sue on February 10, 2016.89 On March 17, 2016 the Maryland Department of the Environment determined that, by operation of law, the certificate’s air-quality provisions had expired, ending the project.917

The transferable mechanism: permits carry construction deadlines. Sustained pressure that delays a developer past those deadlines can void the permit by operation of law, without any new vote.58

Case six · Chester, Pennsylvania

Chester: the environmental-justice legal tool residents established

Chester is included for precision, not as a clean win. It is important to state plainly what was and was not achieved. Chester Residents Concerned for Quality Living, led by Zulene Mayfield, challenged a Pennsylvania Department of Environmental Protection permit for a Soil Remediation Services facility in Chester, a predominantly Black community that already hosted a cluster of waste facilities.310

On December 30, 1997, in Chester Residents Concerned for Quality Living v. Seif, the U.S. Court of Appeals for the Third Circuit held for the first time that private residents may sue under the Environmental Protection Agency’s Title VI disparate-impact regulations over a state pollution permit, without having to prove intentional discrimination.3 The U.S. Supreme Court granted review but then vacated the case as moot in 1998, after the specific Soil Remediation Services facility at issue did not go forward.10

The honest caveat: Chester’s largest waste facility, the incinerator now operated as Reworld (formerly Covanta), remains in operation. Chester residents did not shut that plant down. What the case produced was a durable legal tool, the recognition that communities can raise disparate-impact civil-rights claims against pollution permits, and the defeat of the particular facility that prompted the suit.310

At a glance

Six cases, and what actually decided each

These were not identical facilities to the Plainfield proposal. They ranged from interstate gas pipelines to mass-burn incinerators to a soil-treatment facility. The mechanisms that decided them, however, travel across facility types.

Comparable projects turned back, and the decisive legal or administrative mechanism in each.
Project State Type Outcome Decisive mechanism
Constitution Pipeline NY Gas pipeline Ended 202016 State Section 401 water-quality denial, upheld in court2
PennEast NJ / PA Gas pipeline Ended 202114 State water and wetlands permits denied; survived even a Supreme Court win1
Northeast Energy Direct MA / NH / NY Gas pipeline Withdrawn 201618 No committed demand; developer withdrew amid sustained opposition11
Frederick County WTE MD Trash incinerator Ended 201412 Partner withdrew; commissioners voted to exit the permits13
Fairfield / Curtis Bay MD Trash incinerator Permit voided 20169 Missed 18-month construction deadline; permit expired by law5
Chester (Soil Remediation Services) PA Waste facility Facility not opened; civil-rights precedent set3 Title VI disparate-impact suit; permit did not proceed10

What this means for Plainfield

What Plainfield can honestly take from this

  • These were different facility types than the proposed Plainfield gasification plant. The lessons are about legal process and pressure points, not a promise of the same result.
  • None of these projects was stopped by a town referendum. In each case the decision rested with a state agency, a court, or the developer’s own board.
  • A state permit denial can defeat a federally certificated project. Both Constitution and PennEast held FERC certificates and were ended after states withheld Clean Water Act approvals.214
  • Deadlines are leverage. The Baltimore incinerator’s permit expired by operation of law after an 18-month construction gap.58
  • An issued permit is not the last word. Frederick County held its permits and the project still ended when a partner left and officials declined to proceed.412
  • Sustained public participation matters. Organized, multi-town opposition contributed to a withdrawal at FERC and established a lasting civil-rights tool in Chester.311

Questions and answers

Common questions

If not by town votes, how were these projects stopped?

By state permit denials, expired permits, lost financial partners, and developers withdrawing for lack of committed demand. State agencies, courts, and company boards, not local referendums, decided each outcome.214

Can a state permit denial really stop a project that already has federal approval?

Yes. Both the Constitution and PennEast pipelines held Federal Energy Regulatory Commission certificates and were ended after states withheld their Clean Water Act Section 401 water-quality certifications. PennEast even won at the U.S. Supreme Court in June 2021 and still ended that September.12

What is the “18-month rule” that ended the Baltimore incinerator?

Under the federal Prevention of Significant Deterioration rule (40 C.F.R. 52.21(r)(2)), an air permit becomes invalid if construction is discontinued for 18 months or more. The Fairfield incinerator’s authorization lapsed on May 1, 2015, and Maryland declared it expired in March 2016.59

Did any of these communities win by referendum?

No. None of these outcomes came from a binding town vote. That is the central lesson: the leverage lay in state permits, deadlines, financing, and organized public participation.

Is the Plainfield plant the same as the projects on this page?

No. The facility types and locations differ, and each case is a precedent, not a prediction. What transfers is the legal and administrative mechanism, not a guaranteed result.

See how to be heard →  ·  How Connecticut towns turned back plants →

Sources

Where These Facts Come From

Official & regulatory sources

  1. U.S. Supreme Court, PennEast Pipeline Co. v. New Jersey, No. 19-1039, decided June 29, 2021 (5–4; a FERC certificate holder may condemn state-owned land). Establishes that PennEast prevailed on the federal eminent-domain question. supremecourt.gov (PDF)
  2. U.S. Court of Appeals for the Second Circuit, Constitution Pipeline Co. v. New York State Dept. of Environmental Conservation (2017), upholding New York’s denial of the Clean Water Act Section 401 water-quality certification; U.S. Supreme Court certiorari denied April 30, 2018. Establishes the state denial and its judicial affirmance. scotusblog.com (case record)
  3. U.S. Court of Appeals for the Third Circuit, Chester Residents Concerned for Quality Living v. Seif, decided December 30, 1997 (private plaintiffs may bring Title VI disparate-impact claims against a state pollution permit). Establishes the environmental-justice legal precedent. caselaw.findlaw.com (opinion)
  4. Maryland Department of the Environment, “Waste-to-Energy Facility in Frederick County” (final permit determinations effective February 21, 2014; approximately 55 MW gross / 45 MW net; operator Wheelabrator). Establishes that permits were issued. mde.maryland.gov
  5. U.S. Code of Federal Regulations, 40 C.F.R. § 52.21(r)(2) (a Prevention of Significant Deterioration permit becomes invalid if construction is discontinued for 18 months or more). Establishes the legal basis for the Curtis Bay permit expiration. ecfr.gov
  6. Connecticut Department of Energy and Environmental Protection, “Environmental Justice Public Participation Plan — SMART Technology Systems, LLC, Norwich Road / Black Hill Road, Plainfield” (official DEEP-hosted filing on the state regulatory record). Establishes that the SMART facility is a proposal in the state environmental-justice and permitting review process, not a permitted or a cancelled project. portal.ct.gov (DEEP EJ plan, PDF)
  7. Connecticut Department of Energy and Environmental Protection, Materials Management Infrastructure Request for Information — response filed by SMART Technology Systems (official DEEP-hosted PDF; the developer’s own project description on the state regulatory record). Corroborates that the proposal is under state review and that its project figures are the developer’s stated figures. portal.ct.gov (DEEP RFI response, PDF)

Technical, legal, and expert-organization sources

  1. Environmental Integrity Project, “Baltimore Residents File Notice of Intent to Sue Over Nation’s Largest Trash Incinerator” (Fairfield permit issued August 6, 2010; construction halted November 2013; permit expired May 1, 2015 under the 18-month rule; 4,000 tons/day; up to 1,000 lbs of lead per year; notice filed February 10, 2016). environmentalintegrity.org
  2. Sierra Club (Maryland), “Victory: MDE Pulls Incinerator Permit” (Maryland Department of the Environment determined the Energy Answers Fairfield / Curtis Bay permit had expired, March 2016). sierraclub.org
  3. Public Interest Law Center, “Taking on environmental racism: Chester Residents for Quality Living v. Seif” (litigation history; the Supreme Court vacated the case as moot in 1998 after the Soil Remediation Services facility did not proceed). pubintlaw.org
  4. Global Nonviolent Action Database, Swarthmore College, “Massachusetts residents block construction of Kinder Morgan Northeast Energy Direct pipeline, 2014–2016” (organized regional opposition; Tennessee Gas Pipeline suspended work April 22, 2016 and withdrew the FERC application the following month for insufficient contractual commitments). nvdatabase.swarthmore.edu
  5. Maryland Association of Counties, Conduit Street, “Frederick County Commissioners Vote Down Waste-to-Energy Plant” (November 2014; 3–2 vote to cancel the contract and permits). conduitstreet.mdcounties.org
  6. Energy Justice Network, “Incinerator in Frederick, MD Canceled After Decade-Long Fight” (cancelled November 20, 2014 after a roughly 10-year campaign; approximately 1,500 tons/day; about $471 million; Carroll County withdrew from the partnership in April 2014). energyjustice.net

News coverage

  1. StateImpact Pennsylvania (NPR), “PennEast cancels pipeline project — months after winning its case at the U.S. Supreme Court” (September 27, 2021; company cited the missing New Jersey Section 401 water-quality certification and wetlands permits). stateimpact.npr.org
  2. NJ Spotlight News, “How the PennEast pipeline was defeated” (October 2021; New Jersey Department of Environmental Protection permit denials cited as decisive). njspotlightnews.org
  3. Natural Gas Intelligence, “A ‘Sunk Cost,’ Constitution Pipeline Canceled After Eight-Year Battle” (cancelled February 24, 2020; FERC certificate issued December 2014; stalled by the New York water permit). naturalgasintel.com
  4. Baltimore Brew, “Maryland declares Energy Answers’ Fairfield incinerator permit expired” (March 17, 2016; Maryland Department of the Environment declared the air-quality provisions of the 2010 certificate expired by operation of law; 4,000 tons/day). baltimorebrew.com
  5. Utility Dive, “Kinder Morgan pulls plans for Northeast pipeline” (2016 withdrawal of the Northeast Energy Direct project, FERC Docket No. CP16-21, for insufficient contractual commitments; market segment costed around $5 billion). utilitydive.com

See the full evidence library →