Comments on DEP’s Preliminary Recommendations for Achieving the 75% Recycling
Goal
Sierra Club Florida, Dwight Adams
Several of DEP’s recommendations should substantially increase Florida’s recycling rate
including: materials recovery facilities for C&D debris, required recycling in the
commercial sector, pay-as-you-throw collection rates, landfill disposal surcharge,
beverage container deposit legislation, creation of a Recycling Business Assistance
Center, and increased emphasis on organics recycling. Sierra Club Florida (SCF)
supports almost all of these recommendations. However, these measures alone will not
allow the 75% goal to be reached even when the rate is increased artificially by
including the amount incinerated. Since the recommendations are preliminary,
hopefully, additional recommendations prior to reporting to the legislature in January
2010 will strengthen the report. Sierra Club’s comments and suggestions for
improvement follow.
1. Require three-stream source separation by all waste generators of MSW into drystream recyclables, wet-stream biodegradables, and residuals. Ban disposal of
recyclables and biodegradables in landfills or incinerators to be phased in for
various sectors over four years (including small counties and cities).
2. Provide grants on a competitive basis to counties to construct Materials Recycling
Facilities (MRF) and either composting facilities or anaerobic digesters for
organics.
3. Require counties and municipalities to base collection rates on quantities of
residual waste collected (PAYT) and use an aggressive rate schedule.
4. Impose a surcharge on disposal at landfills and incinerators of at least $2/ton to be
increased if need to achieve the 75% goal by 2010. Use proceeds to fund
recycling programs or return a portion to high-recycling counties.
5. Enact beverage container deposit legislation with a 10 cent deposit on all drink
containers. Use unredeemed deposits to fund recycling programs.
6. Use economic development approach to promote waste-based industries to locate
near Materials Recovery Facilities (MRF) to use recycled materials as feed-stock
for new products.
7. Require all government agencies including counties, cities, schools and prisons to
purchase products and supplies with maximum available post-consumer recycled
content.
8. Enact Extended Producer Responsibility enabling legislation that requires retailers
to implement take-back programs for all types of problem waste including (but
not limited to): electronic waste, batteries, compact fluorescent lamps, other
products containing hazardous metals, paint, carpets, mattresses, pharmaceuticals,
household and garden chemicals, and excess packaging, etc.
1.
Collection
Require “three-stream” source separation of municipal solid waste (MSW) by all
waste generators into dry-stream recyclables, wet-stream biodegradables, and
residuals. Ban disposal of recyclables and biodegradables in landfills or incinerators,
to be phased in for various sectors over five years (including small counties and
cities). Three-stream source separation of MSW is the common feature of highrecycling communities, including San Francisco, Seattle, Toronto, and all of Nova
Scotia that has only 1/6th the density of Florida. This is the single most important
step to be taken; it is highly unlikely that anything like 75% recycling can be
achieved without it.
DEP’s recommended required recycling in the commercial sector is a good first step.
SCF recommends that mandatory recycling, including source separated organics, be
phased in to include multi-family residential units within two years and then all
generators, including all governmental agencies, within five years. Based on the
situation in Gainesville and Alachua County, which have mandatory commercial
recycling ordinances that are not well enforced, a state enforcement mechanism will
be required such as denying significant funds to local governments that do not
effectively enforce mandatory recycling ordinances.
SCF recommends that materials to be recycled, both wet- and dry streams, be
extended beyond those currently identified that includes cardboard, paper, magazines,
junk mail, plastics (all seven types), glass jars and bottles, and cans to include
anything that is being recycled anywhere in the US or Canada.
Organics recycling—The DEP report correctly recognizes the importance of
organics recycling and the connection to greenhouse gas emissions from methane
generation in landfills. Nationally, methane emissions from landfills constitute 3.8%
of greenhouse gases. The DEP recommendation to require capture of landfill gas by
2020 is a backend solution that should be replaced by one that keeps the organics out
of landfilled waste.
The percentage of organic MSW suitable for biodegradation, food, food-soiled paper,
and other items, is likely 15 to 25%. This material is too valuable as a source of
methane for energy and compost for soil amendment to bury it in a landfill. The
suggested modification of statutes to include anaerobic digestion (AD) of organics as
well as composting is needed since AD recovers both the energy content and the
fertilizer value of the waste. For the entire state anaerobic digestion of organic MSW
would produce about 500 MW of power, enough for 400,000 homes. The compost
solid fraction would be valuable for landscaping, mulching, and as a planting medium
in environmental horticulture, Florida’s number one agricultural industry. The
recommendations should include a ban on disposal (landfill or incinerate) of organics
beginning in 2015 to give jurisdictions time to establish biological treatment facilities
for organics. A ban on landfilling organics would eliminate the problem of methane
generation in landfills. Generation of methane from the organic waste would occur in
enclosed anaerobic digesters for use as fuel and recovery of the nutrients for soil
amendments.
For either AD or composting, clean feed stock is required in order to produce a
marketable compost product. Legislation banning disposal of organics should include
required source separation by all generators, households, businesses and institutions
of the entire waste stream into three categories: wet-stream organics, dry-stream
recyclables, and residuals.
The Canadian province of Nova Scotia has pioneered source separation of organics,
with the small town of Lunenberg being the first city in North America to offer
curbside collection of separated organics in 1994. Now organics disposal in landfills
is banned in the entire province that is largely rural except for Halifax where the
population density is comparable to Florida’s rural counties. This resulted in a
dramatic increase in Nova Scotia’s diversion rate to over 50%.
Pay-as-you-throw (PAYT) collection rates—As the DEP report notes, PAYT can
be effective in discouraging waste and encouraging recycling. Experience in
Gainesville and Alachua County has shown that there is little problem in setting up
and implementing these systems. Purported problems with dumping of waste as a
result of PAYT rates have not materialized.
SCF recommends that PAYT collection rate structures be made mandatory
throughout Florida within three years, as Minnesota has done.
For greatest
effectiveness, rates should be steeply progressive, at least proportional to the volume
of the carts, e.g. the rate for a 96-gal cart should be at least three times that for a 32gal cart. An ultra-small 20-gal-cart should be included for really serious recyclers.
Enforcement of the use of purchased “overflow bags” is necessary.
The rate structures of Loveland, CO (population of 60,000) and of Gainesville
(110,000) are indicative of their effectiveness. Loveland attributes its very successful
recycling (over 50%) to an aggressive PAYT rate structure of just $2.75/mo for the
smallest 17-gal cart, increasing to $16.50 for a 96-gal cart. In contrast, Gainesville’s
smallest 20-gal cart rate is $13.21, exactly half that for the largest 96-gal cart.
Gainesville’s recycling rate is 30%. As an incentive to source separate, collection
fees should apply only to waste being disposed, not to recyclables and
biodegradables.
Another feature of collection in Loveland and numerous other locations is use of
dual-collection vehicles, with recyclables and trash collected in different
compartment of the truck at the same time by the same vehicle. For three-stream
collection (see above), all three waste streams may be collected by the same vehicle
with organics collected every week in one compartment, recyclables and residuals
collected in the other compartment in alternate weeks. This lowers the cost of
collecting recyclables and removes the impediment for recycling in small cities,
counties, schools, and other entities that claim that recycling is too expensive.
Except for specialized waste such as C&D, collection vehicles should have two
compartments to allow for collection of the three steams (recyclables and residuals in
alternate trips) at the same time. This would solve the problem of extra hauling cost
for recyclables that is cited by some entities (e.g. schools, small counties and cities)
as reason to not recycle.
Beverage container deposit legislation—DEP’s recommended bottle bill or
beverage container deposit legislation (BCDL) is an excellent provision that will
significantly improve recycling of beverage containers. Unredeemed deposits should
be used by the State to fund recycling infrastructure and programs.
SCF recommendations that BCDL apply to all types of drink containers and sizes
(including 2-liter), including soft drinks, water, juice, and milk, and should be 10
cents per bottle. Unredeemed deposits should be used by the state to fund and
improve recycling programs.
Extended Producer Responsibility (Product Stewardship)—For some problem
wastes that are not readily recyclable, take-back programs are needed. DEP’s
recommendation for enabling legislation that would require retailers to implement
take-back programs for all types of problem waste should include (but not be limited
to): electronic waste, batteries, compact fluorescent lamps, other products containing
hazardous metals, paint, carpets, mattresses, pharmaceuticals, household and garden
chemicals, plastic bags, Styrofoam, and other excess packaging, etc.
2.
Processing facilities
DEP’s recommended Materials Recovery Facilities for processing C&D debris prior
to disposal should increase recycling in this sector. However, not all C&D material
needs to be processed at MRF’s, e.g. in situations where it is source separated such as
by Building Deconstructors.
For much of the dry-stream recyclables, processing at MRF’s would improve the
marketability of the materials and is essential for many materials. SCF recommends
that the State provide competitive grants to counties that have adopted credible plans
for achieving 75% recycling for the construction of MRF’s for dry-stream
recyclables.
Since there are no facilities in Florida for anaerobic digestion of MSW organics and
few composting facilities, it would be useful for the State to provide grants to several
counties with credible plans for achieving 75% recycling for demonstration programs
and for construction of biological degradation facilities. The ban on landfilling of
organics should be effective starting in 2015 to give jurisdictions time to build
appropriate biological degradation facilities.
3.
Recycling-based industries
The DEP recognizes that little has been done in Florida to make use of materials
collected in recycling programs and that most markets for recycled materials are out
of state. A golden opportunity for recycling-based economic development is being
largely missed. Based on EPA data, 75% recycling in Florida should be able to
support 100,000 jobs with an annual payroll of up to $6 billion. Materials recovered
would have a value of $600 million. The average pay in recycling-based jobs of over
$30,000 exceeds the average of all paid jobs.
In contrast to the huge potential for economic development through recycling, when
waste is used as a fuel only a few jobs are provided, similarly for landfilling. Studies
show that recycling provides ten times the number of jobs as landfills and
incinerators.
Sierra Club Florida recommends that local governments, the State, chambers of
commerce and other economic development agencies devote much more of their
effort towards establishing recycling-based businesses throughout Florida.
The DEP recommendation of Recycling Business Assistance Centers (RBAC) is
similar to Recycling Materials Development Zones (RMDZ) that are in use in
California. Sierra Club Florida recommends full use of incentives that are commonly
used in other sectors to attract and develop businesses that use recycled materials as
feed stock. These can be located in Eco-parks near MRF’s to use the materials
without the need for shipping long distances.
4.
Markets development
DEP realizes that development of markets for recycled materials is essential.
Governmental agencies are responsible for about 30% of the gross domestic product
and could greatly affect use of recycled materials in goods and services that they
purchase.
Sierra Club Florida recommends that all state and local governmental agencies
including colleges, schools and prisons be required to purchase materials with the
maximum amount of post-consumer content that is consistent with other requirements
for the performance of material. The State should provide grants for the development
of methods or procedures for using various recycled materials, e.g. rubber in paving
or crushed glass for road beds.
5. Funding through a landfill disposal surcharge
DEP recommends that a landfill disposal surcharge of at least $1/ton be imposed on
waste disposed in landfills. SCF recommends that the surcharge on disposal be at
least $2/ton and increased if it becomes apparent that 75% recycling will not be
achieved by 2020, and that it apply to incinerators also. At $2/ton, the annual costs of
the surcharge for a family of four would be equal to the cost of only a couple of
Happy Meals.
A total of 31 states have landfill disposal surcharges, the highest being $8.75/ton in
West Virginia. Also, several states impose disposal surcharges on waste disposed in
incinerators (waste-to-energy). The 75% legislation indicates the goal of diversion
from disposal in landfills or incineration facilities.
Incinerators are primarily
disposal technologies with less than 20% efficiency in recovering the energy content
of materials consumed that are, in fact, about 50% non-renewable fossil-based plastic,
and 40% (by weight) of material is left as ash that requires landfilling (even if it is
used as daily cover).
In order to reduce objections to the surcharge by local governments that lose tipping
fees for materials being recycled, a portion of the fees proportional to their recycling
rate should remain with the local government.
5. Recycling education and training of recycling coordinators
.
With three-stream source-separation of waste, education could be much more focused
on what materials are appropriate for each of the three streams, with posters similar to
those used in areas such as Seattle and Toronto. Then, once three-stream collection
has been established as the way waste is managed in Florida, recycling becomes just a
matter of which one of three containers is correct for the item in hand. Recycling
education in schools is a good idea that would work best if the schools are actually
recycling, i.e. they are the laboratories where recycling is demonstrated. Few schools
in Alachua County are recycling, with hauling costs cited as the reason. Requiring
dual-compartment waste-collection vehicles and three-stream separation would solve
this problem since all the materials would be hauled in the same vehicle.