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Below is correspondance I wrote and sent to the California Integrated =
Waste Management Board and a number of legislaters (including Senetor =
Sher). No real responses whatsoever, even from Senetor Sher. Makes you =
wonder!
California Integrated Waste Management Board
8800 Cal Center Drive
Sacramento, CA
Subject: Year 2000 Goals Dear Board Members,
Your efforts regarding diversion of municipal solid waste and household =
hazardous waste are appreciated, and your achievements commendable! Year =
2000 is just around the corner. It is my understanding that the Waste =
Board is initiating procedures to contemplate goals and programs for the =
beginning of the next century.
Many jurisdictions have made tremendous headway towards achieving the =
required diversion goals of 25% and 50% by the year 2000. As we all are =
aware, the requirement in and of itself was aimed only at diversion for =
diversion sake. AB 939 passed because of impending landfill crisis and =
not the need to preserve our precious resources. Accordingly, some =
jurisdictions have unusual waste streams providing almost instant =
success based merely on the local processes already at hand. =
Universally, these programs are where a profit can be made by such =
diversion. Diversion requirements or not, these businesses would still =
perform as is because they are making a profit. Often, other diversion =
practices that are truly beneficial are ignored because the arbitrary =
number has been met.
Then there's the plethora of creative shuffling to show high diversion =
rates. Again, this is because the requirement is only for diversion =
numbers, with little regard to other impacts, natural resources or local =
economics. Law, perception, and in some cases, the need to maximize =
landfill space, appear to be the only motivating factors. For example, =
some counties with co-generation plants that use the massive tons of ash =
for local soil amendment have upwards of 70% diversion with very little =
effort.
The perception is most of us think that recycling a can or bottle is all =
that matters and that we have done our part for the environment. =
Recycling is popular, the "in thing to do". However, many people are =
becoming educated on the realities of special interest and how the =
manufacturing industry does not have to contribute to waste diversion. =
What will happen when perception goes from "doing my part for the =
environment" to "the politicians are making us pay for the wasteful ways =
of the manufacturing and business industry"?
We live in a monetary system. For the most part, impacts, economic and =
otherwise, are only analyzed from a present tense perspective. For =
instance, a farmer can make a lot more money for his immediate family by =
subdividing and constructing houses instead of growing food. The best =
agricultural land in the nation is disappearing under housing tracts. If =
we could put the long-term cost and impacts (100 years +) of losing the =
agricultural land, there would be little conversion. The same physics of =
time apply to waste reduction and recycling. Only short-term benefits =
appear to be considered with limited regard for future generations and =
impacts.
Cost versus benefit has been, and always will be, a hotly debated =
subject. Long term costs versus benefits must be part of the picture. =
Costs and benefits should not be restricted to mere monetary =
considerations; but social and environmental costs/benefits as well.
Please accept these suggestions to move into the 21st century and beyond =
as they are intended; as helpful considerations.
1.. Institute Advanced Disposal Fee (ADF). When European countries =
applied ADF, waste diversion reached 30% prior to involving the public. =
When a business knows it has to pay the cost of disposal based on what's =
being disposed, they will streamline their packaging, institute reuse =
and do whatever it takes to lessen the tax applied to the cost of =
disposal.
The CIWMB uses the term "source reduction" for reduction and =
programs at local levels. The "source" is not local, but at the =
manufacturing and packaging stage.
We (local jurisdictions) are like stream owners that are mandated to =
control the water level of our streams when we have no control of the =
water released from the dam above us (packaging and manufacturing =
industry).
We often hear that recycling is being subsidized. Recycling is not =
being subsidized, it is the taxpayers that are being required to =
subsidize the packaging and manufacturing industries.
No one disputes that the packaging and manufacturing industries are =
a major part of the problem. The fact that they do not participate in =
waste diversion while we are required to resolve their problem can only =
be seen as favors to special interests. And we wonder why there is such =
a growing lack of faith in our legislators.
When it comes to politics, for all practical purposes and intents, =
perception is reality.
2.. Remove government subsidies to virgin material =
exploration/cultivation that limits competitive pricing for recycled =
goods. For instance, the subsidies to logging, mining, and to a degree =
farming, often make virgin material cheaper than recycled material.
Our government often sells mineral rights, timber and electricity =
well below market value, and indeed, often even lower than taxpayer =
costs for building roads and producing power. This not only results in a =
loss of natural resources, but also a net reduction in jobs and economic =
stimulus.
There may very well be necessary economic/environmental reasons that =
are not apparent regarding subsidies. In addition, national changes can =
take considerable time to implement, regardless of need. Extending =
similar subsidies to the recycling market may be necessary to level the =
playing field.
Therefore, California must, and can, assure that the value of =
recyclable goods and materials are sufficient to promote competitive =
pricing.
3.. Include Life Cycle Assessment (LCA) as a major factor. LCA =
started in Europe and is now an international movement.
Life Cycle Assessment or LCA can be defined as a systematic =
inventory and analysis of the environmental effect that is caused by a =
product or process starting from the extraction of raw materials, =
production, use, etc. up to the waste treatment and beyond. For each of =
these steps there will be made an inventory of the use of material and =
energy and the emissions to the environment. With this inventory an =
environmental profile will be set up, which makes it possible to =
identify the weak points in the lifecycle of the system studied. These =
weak points are the focal points for improving the system from an =
environmental point of view.
LCA is a method of taking all aspects into consideration, not just =
diversion or landfill space or even costs. LCA looks at the cradle to =
grave and beyond regarding all associations and impacts. For instance, =
non-renewable resources versus renewable resources are weighted =
differently, with the loss of non-renewable resources having a greater =
long4erm impact.
Physics, short and long term environmental impacts, short and long =
term analysis, remediation, long term economics and mitigation are just =
a few of the elements needed to assess LCA. In its present stage =
scientists from around the world are attempting to develop a system of =
assigning points based on LCA. It is as important as it is technical. A =
usable point system is years away, but it is so obviously the right =
approach that we should incorporate whatever aspects may be possible.
California could, and should, move beyond mere diversion and =
incorporate a holistic approach similar to LCA. Does it really make =
sense to concentrate on closing small landfills without looking at the =
environmental impacts of trucking and energy consumption? Does it really =
make sense to truck glass 350 miles to be heated, melted and =
remanufactured when the energy consumption of trucking exceeds the =
environmental cost of virgin manufacturing? Does it really make sense to =
ignore water pollution/consumption in re-manufacturing versus reuse?
4.. Fund LCA studies in California related to waste diversion and =
the solid waste industry.
5.. The emphasis must be on reducing waste, not building industries =
that depend on waste to survive. Material recovery facilities and waste =
to energy plants are dependent on the production of waste to survive. =
Therefore, emphasis on these technologies to resolve our waste diversion =
mandates necessitates the need to continue producing waste instead of =
reducing waste by not creating it in the first place.
In addition, incineration, and to a degree massive large =
biodegraders, takes away the incentive, and ability, for reuse and wise =
use of our natural resources (see LCA).
Environmental damage and loss of natural resources is caused by the =
manufacturing and packaging industries, not by waste disposal. MRF's and =
waste to energy can be valuable tools in waste diversion. However, =
reduction and re-use prior to these steps must take precedence.
6.. Explore and remove impediments to businesses regarding reuse.
7.. Remove arbitrary percentages of diversion and move into =
diversion based on waste characterization and local economic viability.
Waste reduction should be based on what helps the environment and us =
the most instead of mere diversion of arbitrary percentages.
A variation of a theme might be to let those jurisdictions that want =
a reduction in diversion percent choose between diversion by percent or =
diversion by characterization. Diversion by characterization might =
include an analysis of what's in the waste stream and what has the =
greatest impact to divert, balanced by the economic ability to fund the =
elements of the program. Of course, this would not address the overall =
need to look at all diversion from a wise use perspective.
For instance, in California 19% of the waste stream is yard waste. =
Yard waste is an easy and practical item to remove from the waste =
stream. However, yard waste in many rural areas is less than 6%. Urban =
areas, by economics of volume, can afford curbside recycling. In rural =
areas, there aren't even curbs. In urban areas the cost to recycle water =
based paint is $2.25 per gallon. In rural areas the cost (trucking) is =
above $7.00 per gallon.
Back-hauling often cannot be used because union hauling rates do not =
permit reduced trucking rates even though the truckers and companies =
would love to participate.
Industrial waste in urban areas is generally between 25% and 35%. =
Industrial waste, by its nature, is conducive to recycling. Rural areas =
average around 5% industrial waste.
Promoting diversion based on characterization and economics and not =
mere arbitrary numbers would protect the environment better, create more =
jobs, greater protection of our natural resources and help alleviate =
local severe budget constraints. Perhaps most importantly, it would be =
doing the right thing for ourselves and environment - education in =
action.
8.. Work on national regulations. Waste diversion can be very =
difficult for businesses when different laws apply across state lines.
9.. International visitors generally come from countries with much =
better and friendlier recycling programs (funded through ADF). Our =
failure to institute good recycling programs is counter productive to =
the largest economic base in California: Tourism.
10.. Increase deposit fees. Glass and other items are still commonly =
discarded because the deposit fee isn't high enough to motivate =
collection. In addition, a higher deposit fee could create enough =
revenue so that service clubs and collection centers can benefit from =
collection programs. The result is better recycling, more incentive for =
businesses, and additional small funding sources for schools, girl/boy =
scouts, service clubs, churches etc.
11.. Consider requiring all sellers to take back and pay deposit =
fees (as was done in the 1950's). In areas without curbside pickup, the =
lack of convenience and small deposit fee inhibits collection. Add =
incentives and/or remove disincentives for sellers of beverages etc. to =
take back the same containers/packaging sold.
12.. Consider minimum payback fees to promote recycling. For some =
unknown reason, redemption centers vary considerably in payback to the =
public. This is very irritating to the public
13.. Consider creating tax exempt status for that portion of =
for-profit business (or other incentives) with proceeds funding local =
charities. We all like to help non-profit organizations (education, =
childcare, churches, service clubs, childrens'/seniors', recreation =
programs etc.). Proceeds used to help local charitable needs would go a =
long way to help promote recycling.
14.. Require, by law, a certain percent of post-consumer products =
sufficient to maintain healthy markets. This would help tremendously in =
stabilizing the market so that recycling would pay for itself. The fact =
that costs often exceed income to recycle severely limits program =
implementation and success.
As an example, over the last 10 years, car batteries had enough =
value where companies would pick them up for free and even pay a small =
fee to the recycler. However, the metal market is so low now that we =
have to pay 2 cents a pound ($40.00 per ton) and we have to deliver it =
to Bakersfield ourselves (270 miles away). The small income does not =
even come close to the cost of transportation.
Scrap metal has been around $22 per ton for several years. Current =
metal scrap value is now around $8.00 per ton. One location had to =
recently pay $1.00 per ton to have it picked up. Cardboard has suffered =
similar losses. Even if the low values were temporary, few companies can =
afford to stay in business for long when costs exceed revenue.
Accordingly, we are now seeing a large increase of batteries in the =
waste stream. You cannot recycle by collection only. The entire cycle =
has to be complete and healthy.
Clearly, economics rather than law or environmental concern dictates =
what gets landfilled or merely dumped on the ground.
15.. Promote one color of glass. Separating colors adds high costs =
to recycling glass. Regardless of what the manufacturers tell you, one =
color would work just fine for 99% of all glass products resulting in a =
higher percentage of recycled goods at a lower cost and safer working =
conditions. Again, perhaps ADF would help. If they want different =
colors, add the cost of separation at the manufacturing stage and just =
see how many different colors are really needed.
16.. Create heavy incentives for reuse. We are just now reaching the =
recycling percentages achieved in the 1950's, mainly because they reused =
so many items. The manufacturers tell us they can't reuse glass bottles =
because the consumers don't want scratched up bottles.
17.. Exporters of waste out of state should pay tonnage fees.
18.. Remove California's restrictive assurance requirement for =
governments regarding Reasonable Foreseeable Release Scenario. Sub Title =
D is more than sufficient in maintaining local responsibility for =
landfill water quality. If the California Water Quality Control Board =
District Regions applied the law as written, it could bankrupt 22 =
counties outright. If, as may be the only alternative, each jurisdiction =
pays for expensive insurance to pacify the unrealistic requirement, the =
annual premium could easily exceed $100,000.
19.. Safe disposal of household hazardous waste should be as easy as =
buying it in the first place. As was done in Washington State, place a =
very small tax on all oil and chemicals passing through the state in =
order to fund household hazardous waste collection and remediation. =
Variations on a theme could also obviously work. However, dealing with =
(funding) hazardous waste should be a priority.
Just as it is negligent to ignore the responsibility of the =
packaging and manufacturing industry in waste reduction, it is negligent =
to ignore the responsibility of the manufacturing industry of the =
hazardous waste they sell us to not fund collection of these toxic =
materials flowing into the environment.
The average cost of a one-day collection often exceeds $70,000. The =
irony is that officials in Sacramento think hazardous waste is actually =
being diverted from landfills. Other than the excellent =
used-oil-diversion program, this simply is not the case. The cost of =
dealing with hazardous waste is so expensive it's ignored. Those few =
items that are actually visible on the outside of open loads and are =
turned away at the load check just end up in someone's dumpster.
The cost-per-car for a hazardous waste collection day averages =
around $100.00. Obviously, the cost seems to exceed the benefit because =
the dollars are so short for grants to start with.
20.. There must be changes in law to lessen collection costs, and =
there must be revenue to collect the massive amounts of hazardous waste =
entering the environment. This is clearly much more important than =
trying to keep a few bottles out of the landfill.
We receive an average of three calls a week about what to do with =
certain household hazardous waste. I can only educate them on the =
impacts and implore the complete use and not to discard the substances. =
However, we, as well as 95% of California jurisdictions, cannot afford =
to collect hazardous waste. Sadly, much of it is illegally disposed.
The cost of insurance and other State/Federal mandates makes =
collection out of the question for all but the largest urban areas. A =
state-run program with a roving collection system would cost =
substantially less.
Even large urban areas like San Diego County are dropping their =
hazardous waste diversion programs because the cost is simply to high.
21.. California's used lubricating oil recycling program is very =
successful. Antifreeze made with ethylene glycol is also prevalent =
throughout our society and is very toxic. In 1991 (last available =
record), 3,000 pets and 8 children died from ingestion of antifreeze. =
Most other industrialized countries have banned ethylene glycol based =
antifreeze. Antifreeze made with propylene glycol is very safe. =
Propylene glycol is just as effective and has negligible harmful =
environmental impacts. California can, and should, take the lead in =
America and outlaw this very toxic, highly used, and completely =
unnecessary ethylene based antifreeze from our environment.
v.. Make storage and transportation of household hazardous waste =
more reasonable. You can truck a load of pesticide in cans down the road =
with no problem or special licensing, provided they're for sale. =
However, if you want to truck five gallons of discarded pesticide, you =
have to be a licensed hazardous waste hauler with other permits and =
costs that cannot be achieved locally. This same load of new cans of =
pesticide can sit on the store shelf for years without any required =
permits or special conditions. This same discarded five gallons cannot =
be stored for more than three days without being a licensed hazardous =
waste storage facility. Licensing, hauling and storage is so =
restrictive, there are only a handful of centers in the State.
These regulations are difficult to understand and seem to be =
unnecessarily burdensome from a health and safety perspective. The =
result is that a lot of household hazardous waste is being landfilled, =
dumped in backyards where children play, and down sidewalk drains. =
Lessening the requirements to make local storage and transportation =
actually work would help considerably in protecting the environment.
The net gain in environmental protection by preventing illegal =
disposal will well outweigh the associated risks of liberalizing =
storage, handling, and transportation constraints.
23.. Streamline education regarding impacts of hazardous waste, =
particularly for businesses and government. I recently received a call =
from someone who had inadvertently ended up with three 10-ounce =
containers of mercury. All I could do was to give him the phone number =
of the closest hazardous waste hauler (250 miles away). However, by =
being able to explain the severe hazards of the mercury, I am at least =
confident that the substance was kept away from people and not dumped in =
a shallow hole in his back yard as he originally had intended. =
Notwithstanding, the mercury was probably illegally disposed of with who =
knows what future consequence.
a.. Education should be paramount in dealing with hazardous =
material. The State has developed excellent K1 through K12 educational =
literature for recycling and dealing with used oil; however, there =
appears to be very little education regarding hazardous waste. A simple =
layman's desktop guide regarding the hazards of household hazardous =
waste that can be easily understood and referenced would also be =
beneficial.
b.. It is not lined landfills that are needed; it's locating them in =
first place where eventual leakage will have negligible impact. Lined =
landfills clearly help resolve ground water contamination - in the short =
term that is. Monitoring and maintenance continues for 30 years after =
closure. However, the liners will breakdown with time.
In a century, we will have left time bombs that will likely devastate =
ground water across the nation.
Our State's goal of landfill centralization not only depletes =
non-renewable resources and pollutes the air; it also creates time bombs =
of such size and magnitude that the inevitable releases will not be =
negligible and correction may not be possible.
Permitting of landfills should take into account:
=B7 Long term impacts (100 years plus).
=B7 Impacts of collection and delivering solid waste (cumulative and =
offsite).
=B7 Non-renewable resource use.
=B7 Energy use.
=B7 Placement where possible in arid areas.
=B7 Where future ground water usage will be unlikely (limited quality =
ground water to start with, no future growth within the area of =
potential impact etc.).
=B7 Assume a leaking plume and avoid areas where the plume could create =
a problem.
=B7 Sensitive environmental areas.
Thank you for the opportunity to provide input regarding this very =
important next phase of waste management. In addition, I would like to =
extend my appreciation for the quality of the staff members at the Waste =
Board, Water Board and Department of Conservation. I have found them to =
be caring and conscientious in their efforts to assist us.
Until the inevitable introduction of ADF and LCA, the Waste Board should =
make funding, market development and education primary goals.
Zero waste is achievable, providing economic incentive is the driving =
force. Use of arbitrary mandates and mere laws to force local =
jurisdictions into more blood letting is not the answer. Clearly, =
Advanced Disposal Fee and Life Cycle Analysis will need to be part of =
the picture to succeed.
Education is spreading fast. We must use the fruit of understanding from =
our education to change for a wiser and better waste-diversion world. =
Failure to follow the knowledge gained from education can only lead to =
apathy and failure.
Should you have any questions, or if I can be of any assistance, please =
contact me at any time.
Sincerely,
Greg Newbry
Environmental Services Manager, Mono County
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California Integrated Waste Management Board
8800 Cal Center Drive
Sacramento, CA
Subject: Year 2000 Goals Dear Board Members,
Your efforts regarding diversion of municipal solid waste and = household=20 hazardous waste are appreciated, and your achievements commendable! Year = 2000 is=20 just around the corner. It is my understanding that the Waste Board is=20 initiating procedures to contemplate goals and programs for the = beginning of the=20 next century.
Many jurisdictions have made tremendous headway towards achieving the = required diversion goals of 25% and 50%
by = the year=20 2000. As we all are aware, the requirement in and of itself was aimed = only at=20 diversion for diversion sake. AB 939 passed because of impending = landfill crisis=20 and not the need to preserve our precious resources. Accordingly, some=20 jurisdictions have unusual waste streams providing almost instant = success based=20 merely on the local processes already at hand. Universally, these = programs are=20 where a profit can be made by such diversion. Diversion requirements or = not,=20 these businesses would still perform as is because they are making a = profit.=20 Often, other diversion practices that are truly beneficial are ignored = because=20 the arbitrary number has been met.Then there's the plethora of creative shuffling to show high = diversion rates.=20 Again, this is because the requirement is only for diversion numbers, = with=20 little regard to other impacts, natural resources or local economics. = Law,=20 perception, and in some cases, the need to maximize landfill space, = appear to be=20 the only motivating factors. For example, some counties with = co-generation=20 plants that use the massive tons of ash for local soil amendment have = upwards of=20 70% diversion with very little effort.
The perception is most of us think that recycling a can or bottle is = all that=20 matters and that we have done our part for the environment. Recycling is = popular, the "in thing to do". However, many people are = becoming=20 educated on the realities of special interest and how the manufacturing = industry=20 does not have to contribute to waste diversion. What will happen when = perception=20 goes from "doing my part for the environment" to = "the=20 politicians are making us pay for the wasteful ways of the manufacturing = and=20 business industry"?
We live in a monetary system. For the most part, impacts, economic = and=20 otherwise, are only analyzed from a present tense perspective. For = instance, a=20 farmer can make a lot more money for his immediate family by subdividing = and=20 constructing houses instead of growing food. The best agricultural land = in the=20 nation is disappearing under housing tracts. If we could put the = long-term cost=20 and impacts (100 years +) of losing the agricultural land, there would = be little=20 conversion. The same physics of time apply to waste reduction and = recycling.=20 Only short-term benefits appear to be considered with limited regard for = future=20 generations and impacts.
Cost versus benefit has been, and always will be, a hotly debated = subject.=20 Long term costs versus benefits must be part of the picture. Costs and = benefits=20 should not be restricted to mere monetary considerations; but social and = environmental costs/benefits as well.
Please accept these suggestions to move into the 21st = century and=20 beyond as they are intended; as helpful considerations.
The CIWMB uses the term "source reduction" for = reduction and=20 programs at local levels. The "source" is not local, but = at the=20 manufacturing and packaging stage.
We (local jurisdictions) are like stream owners that are mandated = to=20 control the water level of our streams when we have no control of = the water=20 released from the dam above us (packaging and manufacturing=20 industry).
We often hear that recycling is being subsidized. Recycling is = not=20 being subsidized, it is the taxpayers that are being required to = subsidize=20 the packaging and manufacturing industries.
No one disputes that the packaging and manufacturing industries = are a=20 major part of the problem. The fact that they do not participate in = waste=20 diversion while we are required to resolve their problem can only be = seen as=20 favors to special interests. And we wonder why there is such a = growing lack=20 of faith in our legislators.
When it comes to politics, for all practical purposes and = intents,=20 perception is reality.
Our government often sells mineral rights, timber and electricity = well=20 below market value, and indeed, often even lower than taxpayer costs = for=20 building roads and producing power. This not only results in a loss = of=20 natural resources, but also a net reduction in jobs and economic=20 stimulus.
There may very well be necessary economic/environmental reasons = that are=20 not apparent regarding subsidies. In addition, national changes can = take=20 considerable time to implement, regardless of need. Extending = similar=20 subsidies to the recycling market may be necessary to level the = playing=20 field.
Therefore, California must, and can, assure that the value of = recyclable=20 goods and materials are sufficient to promote competitive=20 pricing.
Life Cycle Assessment or LCA can be defined as a systematic = inventory and=20 analysis of the environmental effect that is caused by a product or = process=20 starting from the extraction of raw materials, production, use, etc. = up to=20 the waste treatment and beyond. For each of these steps there will = be made=20 an inventory of the use of material and energy and the emissions to = the=20 environment. With this inventory an environmental profile will be = set up,=20 which makes it possible to identify the weak points in the lifecycle = of the=20 system studied. These weak points are the focal points for improving = the=20 system from an environmental point of view.
LCA is a method of taking all aspects into consideration, not = just=20 diversion or landfill space or even costs. LCA looks at the cradle = to grave=20 and beyond regarding all associations and impacts. For instance,=20 non-renewable resources versus renewable resources are weighted = differently,=20 with the loss of non-renewable resources having a greater long4erm=20 impact.
Physics, short and long term environmental impacts, short and = long term=20 analysis, remediation, long term economics and mitigation are just a = few of=20 the elements needed to assess LCA. In its present stage scientists = from=20 around the world are attempting to develop a system of assigning = points=20 based on LCA. It is as important as it is technical. A usable point = system=20 is years away, but it is so obviously the right approach that we = should=20 incorporate whatever aspects may be possible.
California could, and should, move beyond mere diversion and = incorporate=20 a holistic approach similar to LCA. Does it really make sense to = concentrate=20 on closing small landfills without looking at the environmental = impacts of=20 trucking and energy consumption? Does it really make sense to truck = glass=20 350 miles to be heated, melted and remanufactured when the energy=20 consumption of trucking exceeds the environmental cost of virgin=20 manufacturing? Does it really make sense to ignore water=20 pollution/consumption in re-manufacturing versus reuse?
In addition, incineration, and to a degree massive large = biodegraders,=20 takes away the incentive, and ability, for reuse and wise use of our = natural=20 resources (see LCA).
Environmental damage and loss of natural resources is caused by = the=20 manufacturing and packaging industries, not by waste disposal. MRF's = and=20 waste to energy can be valuable tools in waste diversion. However, = reduction=20 and re-use prior to these steps must take precedence.
Waste reduction should be based on what helps the environment and = us the=20 most instead of mere diversion of arbitrary = percentages.
A variation of a theme might be to let those jurisdictions that = want a=20 reduction in diversion percent choose between diversion by percent = or=20 diversion by characterization. Diversion by characterization might = include=20 an analysis of what's in the waste stream and what has the greatest = impact=20 to divert, balanced by the economic ability to fund the elements of = the=20 program. Of course, this would not address the overall need to look = at all=20 diversion from a wise use perspective.
For instance, in California 19% of the waste stream is yard = waste. Yard=20 waste is an easy and practical item to remove from the waste stream. = However, yard waste in many rural areas is less than 6%. Urban = areas, by=20 economics of volume, can afford curbside recycling. In rural areas, = there=20 aren't even curbs. In urban areas the cost to recycle water based = paint is=20 $2.25 per gallon. In rural areas the cost (trucking) is above $7.00 = per=20 gallon.
Back-hauling often cannot be used because union hauling rates do = not=20 permit reduced trucking rates even though the truckers and companies = would=20 love to participate.
Industrial waste in urban areas is generally between 25% and 35%. = Industrial waste, by its nature, is conducive to recycling. Rural = areas=20 average around 5% industrial waste.
Promoting diversion based on characterization and economics and = not mere=20 arbitrary numbers would protect the environment better, create more = jobs,=20 greater protection of our natural resources and help alleviate local = severe=20 budget constraints. Perhaps most importantly, it would be doing the = right=20 thing for ourselves and environment - education in = action.
As an example, over the last 10 years, car batteries had enough = value=20 where companies would pick them up for free and even pay a small fee = to the=20 recycler. However, the metal market is so low now that we have to = pay=20 2 cents a pound ($40.00 per ton) and we have to deliver it to = Bakersfield=20 ourselves (270 miles away). The small income does not even come = close to the=20 cost of transportation.
Scrap metal has been around $22 per ton for several years. = Current metal=20 scrap value is now around $8.00 per ton. One location had to = recently pay=20 $1.00 per ton to have it picked up. Cardboard has suffered similar = losses.=20 Even if the low values were temporary, few companies can afford to = stay in=20 business for long when costs exceed revenue.
Accordingly, we are now seeing a large increase of batteries in = the waste=20 stream. You cannot recycle by collection only. The entire cycle has = to be=20 complete and healthy.
Clearly, economics rather than law or environmental concern = dictates what=20 gets landfilled or merely dumped on the ground.
Just as it is negligent to ignore the responsibility of the = packaging and=20 manufacturing industry in waste reduction, it is negligent to ignore = the=20 responsibility of the manufacturing industry of the hazardous waste = they=20 sell us to not fund collection of these toxic materials flowing into = the=20 environment.
The average cost of a one-day collection often exceeds $70,000. = The irony=20 is that officials in Sacramento think hazardous waste is actually = being=20 diverted from landfills. Other than the excellent used-oil-diversion = program, this simply is not the case. The cost of dealing with = hazardous=20 waste is so expensive it's ignored. Those few items that are = actually=20 visible on the outside of open loads and are turned away at the load = check=20 just end up in someone's dumpster.
The cost-per-car for a hazardous waste collection day averages = around=20 $100.00. Obviously, the cost seems to exceed the benefit because the = dollars=20 are so short for grants to start with.
We receive an average of three calls a week about what to do with = certain=20 household hazardous waste. I can only educate them on the impacts = and=20 implore the complete use and not to discard the substances. However, = we, as=20 well as 95% of California jurisdictions, cannot afford to collect = hazardous=20 waste. Sadly, much of it is illegally disposed.
The cost of insurance and other State/Federal mandates makes = collection=20 out of the question for all but the largest urban areas. A state-run = program=20 with a roving collection system would cost substantially less.
Even large urban areas like San Diego County are dropping their = hazardous=20 waste diversion programs because the cost is simply to high.
These regulations are difficult to understand and seem to be=20 unnecessarily burdensome from a health and safety perspective. The = result is=20 that a lot of household hazardous waste is being landfilled, dumped = in=20 backyards where children play, and down sidewalk drains. Lessening = the=20 requirements to make local storage and transportation actually work = would=20 help considerably in protecting the environment.
The net gain in environmental protection by preventing illegal = disposal=20 will well outweigh the associated risks of liberalizing storage, = handling,=20 and transportation constraints.
In a century, we will have left time bombs that will likely devastate = ground=20 water across the nation.
Our State's goal of landfill centralization not only depletes = non-renewable=20 resources and pollutes the air; it also creates time bombs of such size = and=20 magnitude that the inevitable releases will not be negligible and = correction may=20 not be possible.
Permitting of landfills should take into account:
·
Long term impacts (100 years plus).·
Impacts of collection and delivering solid waste = (cumulative=20 and offsite).·
Non-renewable resource use.·
Energy use.·
Placement where possible in arid areas.·
Where future ground water usage will be unlikely = (limited=20 quality ground water to start with, no future growth within the area of=20 potential impact etc.).·
Assume a leaking plume and avoid areas where the = plume could=20 create a problem.·
Sensitive environmental areas.Thank you for the opportunity to provide input regarding this very = important=20 next phase of waste management. In addition, I would like to extend my=20 appreciation for the quality of the staff members at the Waste Board, = Water=20 Board and Department of Conservation. I have found them to be caring and = conscientious in their efforts to assist us.
Until the inevitable introduction of ADF and LCA, the Waste Board = should make=20 funding, market development and education primary goals.
Zero waste is achievable, providing economic incentive is the = driving=20 force. Use of arbitrary mandates and mere laws to force local = jurisdictions into=20 more blood letting is not the answer. Clearly, Advanced Disposal Fee and = Life=20 Cycle Analysis will need to be part of the picture to succeed.
Education is spreading fast. We must use the fruit of understanding = from our=20 education to change for a wiser and better waste-diversion world. = Failure to=20 follow the knowledge gained from education can only lead to apathy and=20 failure.
Should you have any questions, or if I can be of any assistance, = please=20 contact me at any time.
Sincerely,
Greg Newbry
Environmental Services Manager, Mono = County