Appendix 2A Consequence of No Action Final Technical Memorandum 2485 Natomas Park Drive, Ste. 600 Sacramento, CA 95833 United States T +1.916.920.3033 F +1.916.920.0212 www.jacobs.com Subject Consequence of No Action Project Name Renewable Placer: Waste Action Plan Attention Western Placer Waste Management Authority From Janet Goodrich/CH2M Lyndsey Lopez/CH2M Date February 6, 2019 Copies to Project File This technical memorandum summarizes the materials that were prepared to document the potential consequence of “No Action.” The majority of this information was developed in April 2018. As Western Placer Waste Management Authority (WPWMA) staff continued to engage key stakeholders, it became increasingly clear that ongoing dialog of the WPWMA’s master planning effort needed to include a discussion of the consequences of delaying or foregoing modifications to the WPWMA’s facilities. Staff and the CH2M Team identified several possible operating scenarios assuming the master planning and subsequent California Environmental Quality Act (CEQA) efforts were not successful and that future operations were limited to the currently permitted facilities. The table in Attachment 1 summarizes the various scenarios. These scenarios acknowledge that the WPWMA will not be able to fully meet the needs of the Member Agencies in the long term. Providing ongoing services constrained to only the existing site would necessitate either modifying and expanding materials recovery facility (MRF) and composting operations at the expense of landfill capacity or phasing out MRF and composting operations to maximize landfill capacity. In the former scenario, an alternative, existing, non-WPWMA disposal location would need to be identified that could accept the WPWMA’s waste in the future. In the latter scenario, the Member Agencies would likely need to arrange for their own waste diversion and processing operations to meet regulatory and legal mandates. After an initial discussion with the Member Agency Advisory Committee (MAAC), the general consensus was that, as long as future disposal capacity could be identified at a third-party landfill, it was preferred the WPWMA continue to provide waste processing and diversion services by maintaining a viable MRF and composting operation. WPWMA Staff and CH2M conducted preliminary research on possible alternative disposal locations for the purposes of estimating the budgetary-level cost impact of offsite disposal. The results of this preliminary research are shown in Attachment 2. Staff and CH2M looked at 10 alternative disposal sites with publicly available information. Out of these 10 sites, several existing facilities have capacity currently (can accept additional tonnage daily in permit and have capacity to accept a large amount of waste). WPWMA would need new infrastructure to enable use of these sites (either long-haul or rail-haul to transport waste). There is no guarantee that the capacity will be available when WPWMA needs it or that the owners of these facilities would be willing or able to accept the WPWMA’s materials. Based on this preliminary evaluation, it appears to be technically feasible, but we do not have a detailed economic evaluation nor commitments from receiving facilities. AX1114181225PDX 1 Attachment 1 No Action Potential Scenarios Attachment 1: No Action Potential Scenarios “No Project” Description Collection Transfer & Process Disposal Notes No Project 1a – Long Term No change for One Big Bin MRF becomes MRF/Transfer; upgrades for transfer required Western Regional Sanitary (WRS) • Keeping existing compost and C&D areas sacrifices permitted landfill capacity resulting in the landfill closing sooner MRF/Transfer/Limited Organics & Self Haul accepted for same Compost facility upgrades needed to meet current regulatory Landfill closes when existing capacity than permitted capacity dictates Construction and Demolition is filled materials as current; continue using requirements; does not include expansion and will not be • If not privatized, siting and developing facilities is a 5- to 10-year minimum, if feasible (note NEW facilities (C&D) existing area, may do small adequately sized to address all organics needs of jurisdictions to After closed, long-haul municipal solid infrequently sited in California in last 30 years) Phased closing of WPWMA Facility upgrades, no major changes comply with pending regulatory requirements. Some organics waste (MSW) to other existing disposal a • Lose at least partial control of rates for organics and C&D and ultimately disposal (Except for MRF and compost Some organics managed by will need to be managed separately, by jurisdictions facility under contract Puts partial burden on jurisdictions to achieve mandates and their own solid waste management plans. Must provide facility with NO compost or C&D jurisdictions C&D facility will not be sized to handle all C&D needs of • expansion) their own system, supply staffing to complete all activities, and hire their own contractors. Some C&D managed by jurisdictions; some C&D will need to be managed separately, by CEQA likely required for Transfer jurisdictions jurisdictions No Project 1b – Long Term No change for One Big Bin, MRF becomes MRF/Transfer; upgrades for transfer required. WRS Landfill capacity sacrificed to • Expanding existing compost and C&D areas sacrifices additional permitted landfill capacity resulting in the landfill MRF/Transfer/Organics & C&D organics, or C&D Also need to expand & upgrade to address regulatory provide capacity for recycling, closing sooner than permitted capacity dictates with Expansions requirements for organics and provide adequate organics organics, and C&D Self Haul accepted for same • Siting and developing facilities is a 5- to 10-year minimum, if feasible (note NEW facilities infrequently sited in capacity for all jurisdictions Phased closing of WPWMA Facility materials as current; continue using After landfill capacity filled, long-haul California in last 30 years) (Except for MRF, C&D and compost existing area, may do small C&D facility will be expanded to address needs of jurisdictions MSW to other existing facility under • CEQA needed for Compost and C&D facility with compost and C&D upgrades, no major changes contracta expansion) • Lose at least partial control of disposal rates disposal CEQA needed for C&D and • Puts partial burden on jurisdictions to achieve mandates and their own solid waste management plans. Must provide compost facility expansions. their own system, provide staffing to complete all activities, and hire their own contractors. No Project 2 – Long Term No change for One Big Bin MRF becomes MRF/Transfer; upgrades for transfer required WRS Landfill closes when existing • Removing organics and C&D operations and infrastructure allows for use of permitted disposal capacity MRF/Transfer/No Organics or capacity is filled Organics managed by jurisdictions Each jurisdiction will need to contract for organics and C&D • Siting and developing facilities is a 5- to 10-year minimum, if feasible (note NEW facilities infrequently sited in C&D C&D managed by jurisdictions processing After closed, long-haul MSW to other California in last 30 years) Phased closing of WPWMA Facility existing facility under contracta Self Haul accepted for MSW; C&D and organics operations must be removed from facility for • Lose control of rates for organics and C&D and ultimately disposal (Except for MRF/Transfer) availability of permitted landfill space continue using existing area, may Puts partial burden on jurisdictions to achieve mandates and their own solid waste management plans. Must provide CEQA likely required for Transfer • do small upgrades, no major their own system, provide staffing to complete all activities, and hire their own contractors. changes No Project 3a – Entire Site Each jurisdiction contracts on their Each jurisdiction will need to either site their own processing Cease disposal in the landfill • Clean closure is a major endeavor (both time and money) Closure and Waste Removal own; multiple contracts and transfer facility(ies) or contract for facilities/service immediately. Clean close landfill • Siting and developing facilities is a 5- to 10-year minimum, if feasible (note NEW facilities infrequently sited in (excavate and remove waste, fill hole) Services not provided by WPWMA. Changes in collection methods for Demolish MRF and other infrastructure at the facility California in last 30 years) Site is closed to operations, landfill MSW/recycling/organics/C&D Each jurisdiction will need to either site • Existing contracts would need to execute buy-out periods or be revised removed (clean closed), and site depending what facility they go to their own disposal facility or contract restored to “original” condition (i.e. move to 3 bins, private for facilities/service for MSW • Lose control of rates and enter a re-contracting period every 5 to 10 years; private company prices will be higher; no CEQA needed for landfill clean facilities) longer have local control over system closure and possibly for actions Self Haul facility closed at this site, • Economic impact by exporting jobs out of region implemented by each jurisdiction. must be addressed by jurisdictions. • Model flagship facility goes away • Puts full burden on jurisdictions to achieve mandates and their own solid waste management plans. Must provide their own system, provide staffing to complete all activities, and hire their own contractors. No Project 3b – Entire Site See #3a above See #3a above