Section 9.0 – Off-Reservation Disposal Waste Economics...... 43 9.1 Contracted Residential Waste Collections Costs...... 45 9.2 Medical Facilities Contracted Waste Costs ...... 46 9.3 Schools Contracted Waste Costs ...... 46 9.4 Official/Governmental Facilities Waste Cost Estimates...... 47 9.5 Commercial Facilities Waste Costs ...... 48

Section 10.0 – Waste Transportation Analysis...... 49

Section 11.0 – Transportation Network...... 50 11.1 Primary Transportation Routes...... 51 11.2 Secondary Transportation Routes...... 52 11.3 Tertiary Transportation Routes...... 53 11.4 Chapter Route Summary...... 53 11.5 Climatic Impacts on Transportation...... 54

Section 12.0 – Solid Waste Vehicle Transportation Costs ...... 55

Section 13.0 – Waste Haulage Cost Models...... 57 13.1 Existing Collection System...... 58 13.2 Central Transfer Station to Off-Reservation Landfill Model ...... 59 13.3 Central Transfer Station to Navajo Nation Landfill Model...... 61 13.4 Chapter Waste Directly to Navajo Nation Landfills...... 62 13.5 Summary of Transportation Cost Model Analysis ...... 63

Section 14.0 – Facility Organization ...... 65

Section 15.0 – Solid Waste Infrastructure Costs Background...... 67

Section 16.0 – Infrastructure Cost Analysis ...... 71

Section 17.0 – Central Transfer Station Construction and Operational Costs...... 72

Section 18.0 – Navajo Nation Landfills Construction and Operational Costs ...... 74 18.1 Pre-Development ...... 75 18.2 Initial Landfill Construction ...... 75 18.3 Equipment...... 77 18.4 Personnel...... 78 18.5 Landfill Expansion...... 78 18.6 Closure and Post-Closure...... 78 18.7 Landfill Cost Summary...... 79

Section 19.0 – Navajo Nation Solid Waste Authority (NNSWA) Administration Costs..81

Section 20.0 – Waste Model Comparisons...... 83

Section 21.0 – Alternative Waste Systems Costs ...... 86 21.1 Western Agency Alternative Waste Models...... 87 21.2 Shiprock Agency Alternative Waste Model ...... 88 21.3 Western and Chinle Agency Combined Waste System...... 88

Section 22.0 – Infrastructure Costs Analysis Summary and Recommendations...... 90 22.1 Western Agency...... 91 22.2 Chinle Agency...... 92 22.3 Fort Defiance Agency...... 92 22.4 Shiprock Agency...... 93 22.5 Eastern Agency...... 94 Section 23.0 – Waste Authority Personnel and Equipment Requirements...... 94

Section 24.0 – Project Costs ...... 95

Section 25.0 – Navajo Nation Solid Waste Authority ...... 99

Section 26.0 – Land Scheduling ...... 100

Section 27.0 – Waste Transportation Equipment Scheduling ...... 103

Section 28.0 – Authority Administration Building Scheduling...... 104

Section 29.0 – Central Transfer Station Scheduling...... 105

Section 30.0 – Waste Collection Scheduling...... 106

Section 31.0 – Critical Scheduling Milestones...... 108

Section 32.0 – Community Participation Overview ...... 109

Section 33.0 – Solid Waste Authority Community Relations Program...... 110

Section 34.0 – Community Solid Waste Education...... 111

Section 35.0 – Recycling – Reduce –Reuse Programs ...... 114

Section 36.0 – Household Hazardous Waste ...... 118

Section 37.0 – Community Participation Summary ...... 119

Section 38.0 – Summary and Recommendations ...... 119 38.1 Summary...... 120 38.2 Recommendations...... 122

Exhibit A – Maps and Figures

Exhibit B – Models

Exhibit C – Database Tables

Exhibit D – 2000 Census Data NAVAJO NATION ENVIRONMENTAL PROTECTION AGENCY NAVAJO NATION DIVISION OF COMMUNITY DEVELOPMENT NORTHWEST NEW MEXICO REGIONAL SOLID WASTE AUTHORITY LONG RANGE COMPREHENSIVE SOLID WASTE MANAGEMENT PLAN FINAL REPORT

1.0 Background

The Navajo Nation covers 17.6 million acres of land in the Southwest, covering lands in Arizona, Utah, and New Mexico. Taking into account the 2000 Navajo Nation census, the total population within Navajo Nation is 180,443. Of the 110 Navajo Chapters, population range from a low of 60 tribal and non-tribal members (Whiterock, New Mexico) to a high of 8,229 tribal and non-tribal members (Shiprock, New Mexico). Population densities range from 50 individuals per square mile for some Chapters to less than one person per square mile in some of the remote Chapter areas. Municipal solid waste on the Navajo Nation is generated from a number of sources: Individual residences, commercial establishments, schools, hospitals, industrial, tourist areas and administrative and support facilities. Six Chapters - Chinle, AZ; Crownpoint, NM; Kayenta, AZ; Shiprock, NM; St. Michaels [Window Rock], AZ; and Tuba City, AZ have more expanded sources than other Chapters. The listed Chapters have solid waste volumes comparable to similar sized municipalities outside of Navajo Nation. Waste disposal across the Navajo Nation ranges from weekly residential and commercial pickup in the more populous area to the continued use of burn barrels and depositing solid waste in illegal dumpsites. Many problems of compliance for solid waste disposal are apparent within the Navajo Nation. Remote locations, lack of dense populations, inadequate road systems, multi- jurisdictional problems and limited local funding, have hampered the development of solid waste collection and disposal systems across Navajo Nation.

Disposal of solid waste generated on the Navajo Nation has been problematic. There are no permitted solid waste facilities or landfills for the final disposal of solid waste on the Navajo Nation. A progressive growth of population within the Navajo Nation shows that in 1996, the amount of solid waste moving off the Navajo Nation was approximated at 108,423 tons per year. In comparison to the 2000 census, approximating 378,930 to 451,108 tons of solid waste is generated for all entities, of which 242,405 tons of solid waste was commercially transported off the Navajo Nation from residences and transfer stations alone. Illegal open dumpsites expanded to many areas (i.e., mesa tops, forested areas, open pastures, etc.) largely due to new technology solid waste (i.e., plastics), introduced into the living lifestyle of all Navajo Nation families, and is considered between 15,000 and 30,000 tons per year. In accordance with Title 40, Code of Federal Regulations, Part 258, Navajo Nation is in the process of closing 465 large open dumpsites scattered throughout the 110 Navajo Chapters that comprise Navajo Nation. Approximately 370 dumpsites remain to be closed as of 2002. Of the remaining dumpsites, individuals continue to illegally open dump, sometimes burning the remains of solid waste at the dumpsites that includes 50% to 70% recyclable products. A significant volume of solid waste continues to be burned and/or illegally dumped on the Navajo Nation based on site assessments of the remaining open dumps. The Navajo Nation Environmental Protection Agency has identified an additional 639 small pockets of illegal open dumpsites since 1998 to date, that usually consist of approximately 2 pounds of solid waste to as much as 500 pounds per site (i.e., household refuse, appliances, furniture, and automobile parts). These dumpsites are in addition to the 1995 inventory of 465 large illegal dumpsites. 1,960 notices of violation were given out to those individuals who contributed to the 639 open dumpsites. This Plan provides an insight into all waste stream factors affecting Navajo Nation.

Start up cost for a compliance landfill within Navajo Nation would average $9.8 million dollars to facilitate a compliance landfill operation, $3.9 million for startup cost, and $6.4 million for closing cost, with $1.5 million for the financial bond alone. The operation would include insurance, personnel, office equipment (i.e., software, computers, and security system), weigh scale, heavy equipment, maintenance, and transporters. The tonnage volume leaving Navajo Nation (i.e., residences, schools, businesses, governmental entities, and industries) is transported to one of nine (9) state regional and permitted landfills, with the exception of the Hopi Landfill, Second Mesa, Arizona which is not permitted as a RCRA Subtitle D landfill but is permitted by the United States Environmental Protection Agency for a Small Solid Waste Facility and regulated by the Hopi Environmental Protection Office which receives not more than 2,400 tons of waste per day. The inception of this landfill has had lined waste cells following RCRA Subtitle D technical guidelines for construction. Currently, residential, school, businesses, and some governmental offices have pickup service done by the Hopi Landfill, and include the following areas: Teesto, Jeddito, Low Mountain, Skunk Springs area, Whitecone, Pinon, Hardrock, and some of Coalmine Mesa. Outside of Navajo Nation the following states have permitted RCRA Subtitle D landfills: Arizona (i.e., Blue Hills Regional landfill, St. Johns; Cinder Lake landfill, Flagstaff; and Painted Desert landfill, Joseph City but for businesses only because Painted Desert is not open to the general public); Montezuma County Landfill, Cortez, Colorado; New Mexico (i.e., Crouch Mesa Landfill, Aztec; Red Rocks Regional Landfill, Thoreau; Sandoval County Landfill, Cerro Colorado which is not open to the general public; and Socorro County Landfill, Socorro); and White Mesa Landfill, Bluff, Utah (see Appendix I). The Hopi landfill has a USEPA permit for a small municipal solid waste landfill. Based on the average tipping fee dollar amount of tons ($29.55 – Table Four and other cost components) for landfills utilizing cost per ton, Navajo Nation is estimated to be losing approximately $71,630,068.00 per year for all the estimated solid waste taken to a permitted landfill. This cost includes tipping fees, transportation costs, rental fees, taxes; and the added RCRA Subtitle D bulky solid waste such as construction solid waste from a number of construction companies conducting business within Navajo Nation and alone contributes an estimated $50 million.

Subtitle D of the Resource Conservation Recovery Act (RCRA), as passed by the U. S. Congress, mandates the proper disposal of solid waste in the United States. RCRA does not allow the United States Environmental Protection Agency (USEPA) to approve tribal solid waste management plans and permitting programs but permits can be gained for small municipal landfills following all federal requirements of the Resource Conservation and Recovery Act. However, Tribes retain inherent sovereign authority to regulate solid waste in Indian Country. The tribes can develop environmental statutes and regulations that govern the management of solid waste and permit solid waste facilities. As previously stated, the Hopi Tribe Landfill is an example of a Tribe’s own initiative in which they pursued a USEPA permit for a small municipal landfill for their single landfill facility.

The Navajo Nation Environmental Protection Agency (NNEPA) was established in 1995 as a separate entity within the executive branch of the Navajo Nation Government. NNEPA is responsible for implementing and enforcing laws for the protection of human health and the welfare of the Navajo Nation’s environment. In 1997, the Navajo Nation Council passed into law, the Navajo Nation Solid Waste Act followed by adoption of the Navajo Nation Solid Waste Regulations in 1998 and amended in 2001. In order to facilitate civil enforcement for open illegal dumping, the Resource Conservation & Recovery Program (RCR Program) was developed in 1998 under NNEPA, and in 2001, the Enforcement Section was formally developed to facilitate criminal enforcement for littering, since open dumping and littering are defined separately for judicial due process. The RCR Program has the responsibility of developing and enforcing the solid waste civil laws and regulations, increasing public awareness, and to provide an effective and integrated approach to oversight of open dumps of solid waste closures on the Navajo Nation. Both the Navajo Nation Solid Waste Act and Regulations provide the guidance for all residents of Navajo Nation their individual responsibility for solid waste compliance, and addresses the prohibited types of solid waste disposal, inspections and enforcement, standards for solid waste landfill facilities, facility permitting requirements, financial responsibility, transfer stations, composting waste collection and transport and recycling.

Separately, in 1998, the Navajo Nation Division of Community Development initiated the Solid Waste Management Program (DCD/SWMP) to facilitate the closures of all open dumpsites within Navajo Nation, and provide responsibility for infrastructure to Navajo Chapters for cost-shared solid waste disposal convenience centers. The Program has provided convenience collection points for 28 Navajo Chapters as of 2002, with a loss of 14 Navajo Chapters at one time having waste disposal, totaling 42 Chapters, and having another 10 Chapters requesting assistance. Separately, 26 Navajo Chapters have transfer stations, with a current number of compliance disposal facilities as 54 for Navajo Nation. Larger compliance disposal points began with transfer stations, beginning in 1995, utilizing funding provided by the Navajo Area Indian Health Service.

In 1994, the Navajo Nation, the Navajo Area Indian Health Service and the Bureau of Indian Affairs developed a Memorandum of Understanding Team (MOU team). The MOU Team’s purpose is to promote activities related to the closure of illegal dump sites within the Navajo Nation, development of alternative solid waste management systems and has jointly assisted in the development of a long-term operation and maintenance plan to implement the alternative solid waste management systems. All team members contributed to this Plan with review of all segments with the contractor and subcontractor.

The Navajo Nation entered into a Joint Powers Agreement (JPA) on June 14, 2000 with the Northwest New Mexico Regional Solid Waste Authority to utilize its solid waste experience to develop a long-range solid waste management comprehensive plan (Plan). The NWNMRSWA would also assist the NNEPA and the DCD/SWMP in developing a Reservation-wide solid waste strategy for the next 10 to 20 years. Jacobson Helgoth Consultants were subcontracted by NWNMRSWA to provide engineering and environmental consulting services to the Authority and assist them with the collection of information for the development of the Plan. The subcontractors utilized the 1996 “Chapter Images” for reference to define the demographics of Navajo Nation, and did not incorporate the 2000 census, of which NNEPA provide for this Plan and other current reference information.

Solid waste transporters for Navajo Nation include two primary businesses that provide individual household pickup or commercial contracts with schools, government entities, or industries within Navajo Nation. The businesses include Navajo Sanitation and Waste Management (New Mexico and Arizona), of which, Navajo Sanitation does contract with Waste Management for some areas of Navajo Nation. These businesses have various cost contracts to include the tipping fee, transportation costs, rental fees for bins, and taxes as applicable to each State with a compliance landfill. The Navajo Nation does have smaller solid waste trucks under the Navajo Facility Maintenance but they are limited to servicing Navajo Nation employee housing, and still have to dispose of waste into bins provided by Navajo Sanitation.

The Plan was prepared to consider the municipal waste in terms of waste generated, transportation components, cost obligations, waste reduction, and future infrastructure in order for the Navajo Nation to consider short- and long-term solid waste feasible management planning to accommodate the sources of solid waste (i.e., compliance landfills within Navajo Nation, expanded business services in solid waste transportation, highway networking, etc.). The Northwest New Mexico Regional Solid Waste Authority (NWNMRSWA) was contracted by Navajo Nation to develop this Plan. The Plan involved aspects of various materials already prepared from the Navajo Nation Environmental Protection Agency (NNEPA) and Division of Community Development, Solid Waste Management Program (DCD/SWMP), Navajo Area Indian Health Service (IHS), and Bureau of Indian Affairs (BIA), and by working on other unknown aspects to compile an appropriate Plan. This Plan identifies the possibilities of Navajo Nation determining the economics of solid waste infrastructure development, and included eight (8) objectives: 1) The identification of solid waste disposal facilities on/adjacent to the perimeter of the Navajo Nation; 2) The identification of collection facilities such as transfer and convenience stations; 3) To review the status of the existing waste disposal facilities outside the Navajo Nation; 4) To review the status of the major waste collection facilities and transfer stations that are currently in operation with the Navajo Nation; 5) Identify the various waste components on the Navajo Nation and a quantification of the waste stream on the Reservation; 6) To provide a waste stream transportation analysis to determine the current cost of waste disposal on the Navajo Nation; 7) To determine the centralization of the waste stream and possible development of solid waste infrastructure facilities on the Navajo Nation; and 8) To develop the costs for permitting, design, construction, and operation of solid waste facilities on the Navajo Nation for determining the economics of future solid waste infrastructure development.

2.0 Inventory of Solid Waste Landfill Disposal Facilities Outside the Navajo Nation

Jacobson Helgoth Consultants contacted all the solid waste disposal facilities outside the Navajo Nation to determine their location, ownership, contact individual, facility size, tipping fees, permit status, average daily capacity, types of solid wastes accepted and landfill methodology. The summaries of the telephone survey for each waste disposal facility are included in Appendix I. Figure One shows the Four Corners region, the boundaries of the Navajo Nation and the locations of the solid waste disposal facilities that are discussed in this report. Table One lists the landfills by state and shows the relative size and average daily capacity of each of these facilities. The larger capacity landfills, for example, Cerro Colorado and Rio Rancho are located near larger urban populations in Bernalillo and Albuquerque, New Mexico respectively.

Table One Perimeter Solid Waste Facilities – Size/Capacity State Landfill Facility Size Average Daily (Acres) Waste (Tons) AZ Cinder Lakes 353 430 AZ Painted Desert*** Businesses Only Not Open to the Public AZ Blue Hills 161 20 to 25 AZ Hopi (**) 100 40 to 50 CO Montezuma County 340 70 to 80 CO Transit Waste 47 140 NM Red Rocks Regional 600 350 NM Crouch Mesa 160 800 NM Rio Rancho NA* 1,200 to 1,300 NM Sandoval 165 550 NM Cerro Colorado*** 860 1,600 to 1,700 NM Socorro 60 400 UT White Mesa 260 20 *NA – Information Not Available ** USEPA Permit for SMLF (has lined cells). *** Not Open to the Public, only Commercial Haulers.

The following paragraphs describe each solid waste facility in the four state areas surrounding the Navajo Nation.

2.1 Arizona

There are four (4) landfills located outside the Navajo Nation in the State of Arizona. All of the Arizona landfills, with the exception of the Hopi landfill, are RCRA Subtitle D permitted facilities. In Coconino County, the City of Flagstaff operates the Cinder Lake landfill on the northeastern side of the City. A considerable volume of solid waste from the Western Agency Chapters is hauled to the Cinder Lake landfill from the transfer station systems operated by Coconino County. Seven (7) transfer stations operated by Coconino County would be included in this waste stream.

Waste Management of Arizona, Inc. operates the Painted Desert landfill that is located immediately north of Joseph City, Arizona in Navajo County. The Painted Desert landfill is the primary destination for solid waste generated in the Western and Fort Defiance Agencies for businesses only, and is not open to the general public. This information is important because it eliminates the public usage availability of this particular landfill.

The Blue Hills Environmental Association operates the Blue Hills Regional landfill east of St. Johns, Arizona on behalf of Apache County and local municipalities. Some of the solid waste generated in the Sanders, Arizona area is currently being hauled to the Blue Hills landfill.

NNEPA does advise Navajo Nation residents to utilize the Hopi landfill based on the Navajo Nation Solid Waste Act that defines a compliance landfill. The Hopi landfill is a defined as a small municipal solid waste landfill, and they do have a U. S. Environmental Protection Agency permit for this type of facility of which Navajo Nation may pursue independently or allow to be pursued in one or several locations as defined under the siting criteria of the Navajo Nation Solid Waste Regulations.

2.2 Colorado

Two (2) permitted solid waste landfills operate within the State of Colorado, and are approximately 50 miles northeast of the Navajo Nation. Both landfills possess RCRA Subtitle D Permits issued by the State of Colorado Public Health and Environment. Montezuma County, Colorado operates the Montezuma County landfill, which is located three miles south of Cortez. This landfill is taking waste from the Navajo Nation in Utah, Arizona, and New Mexico and has sufficient capacity to accept additional solid waste from the Navajo Nation.

Transit Waste, LLC, a private solid waste collection and disposal firm, operates the privately owned Transit Waste landfill that is located south of Durango in LaPlata County. This landfill is located five miles north of the Colorado-New Mexico State line on US Highway 550. This landfill has excess capacity and is willing to accept solid waste from the Navajo Nation.

2.3 New Mexico

Six (6) solid waste landfills operate in northwestern New Mexico, and all landfills have RCRA Subtitle D permits issued by the New Mexico State Environment Department. The Northwest New Mexico Regional Solid Waste Authority owns and operates the Red Rocks Regional landfill located six miles northeast of Thoreau. This landfill was permitted under RCRA Subtitle D in 1995 by the State of New Mexico. The Authority operates under a JPA agreement between the Cities of Gallup and Grants, the village of Milan, and McKinley and Cibola Counties. The current permitted facility covers 29 acres and has the potential to be expanded to over 160 acres of waste cells. Four 800 feet by 200 feet lined cells have been constructed to date. Solid waste generated in a number of Chapters in the Chinle, Eastern, and Fort Defiance Agencies have solid waste hauled to this landfill for compliance disposal. Navajo Sanitation and Waste Management of New Mexico, Inc. provide the transportation and disposal.

The Crouch Mesa landfill near Aztec (Flora Vista), is owned by San Juan County, New Mexico and operated by Waste Management of New Mexico, Inc. The Crouch Mesa landfill occupies a 160-acre tract. The older waste cells at this landfill were unlined. Cells constructed since 1993 are lined. San Juan County operates a number of transfer stations across the County and these stations feed the Crouch Mesa landfill. The Crouch Mesa landfill is the primary depository of solid waste generated in the Farmington, Bloomfield, and Aztec areas. Solid waste generated in the Shiprock and northernmost Eastern Agencies is hauled to the Crouch Mesa facility.

The Albuquerque area has three (3) permitted landfills. The Cerro Colorado landfill, located 20 miles west of downtown Albuquerque, is owned and operated by the City of Albuquerque. Cerro Colorado accepts most of the solid waste generated within the Albuquerque City limits. The Sandoval County landfill and the Rio Rancho landfill are both located adjacent to teach other between Rio Rancho and Bernalillo. The Sandoval County landfill is owned and operated by Sandoval County, New Mexico. The Rio Rancho landfill is owned and operated by Waste Management of New Mexico. Some of the solid waste generated in the Torreon, Counselor, Ojo Encino, Pueblo Pintado areas are hauled to the Sandoval County landfill. Solid waste has been hauled from the Tohajiilee (formerly Canoncito) Chapter to both the Cerro Colorado and Rio Rancho landfills. All three (3) landfills in the Albuquerque area are high capacity solid waste facilities that can easily handle the volumes of solid waste generated in the eastern portion of the Navajo Nation.

Socorro County has operated a landfill near Socorro, taking primarily municipal solid waste. The County is in the process of permitting and constructing a new landfill south of the City of Socorro. This landfill is the closest solid waste disposal facility to the Alamo Chapter, and is currently transporting solid waste from this Chapter to its landfill.

2.4 Utah

The State of Utah has two (2) solid waste landfills in southernmost Utah with RCRA Subtitle D permits issued by the Utah Department of Environmental Quality of which one (1) serves Navajo Nation. San Juan County, Utah owns and operates the White Mesa landfill, which is located 10 miles north of Bluff, Utah on State Highway 191. The White Mesa landfill is located on a 260-acre site and currently averages 20 tons of solid waste per day. The Landfill has a State of Utah Class I Permit that allows them to take over 20 tons of solid waste per day. Currently, some of the waste from the Kayenta Township, Oljato and Aneth Chapters is being hauled to this landfill as well as waste from the County owned transfer stations, including Bluff and Mexican Hat. This landfill has additional capacity and actively seeks additional solid waste from the Navajo Nation. The Kanab landfill located within Kane County, Utah currently does not service Navajo Nation.

2.5 Landfill Summary

The two key factors that influence the cost of solid waste disposal at solid waste facilities outside the Navajo Nation are transportation costs (delivery fee and bin rental hauling fee) directly related to the distance the solid waste must travel and the tipping cost (per ton for one sized-bin) for disposal of solid waste at the landfill. Table Two, as follows, lists all of the landfills that were contacted as part of this Plan and the distances to the nearest Chapter House. The distances range from as little as six miles from the Red Rocks Regional landfill to the Thoreau Chapter House to over 50 miles for a number of Chapters. The average distance from a Chapter House to a solid waste landfill is 40 miles. Some of the locations provide a cost analysis from Waste Management of New Mexico and Arizona in 2002. Navajo Sanitation provides a unit contract cost for residential household pickup ranging on the average of $18.00 per household, and they do contract with Waste Management for some areas.

NNEPA has included the single cost for a 40-cubic yard bin from information received from Waste Management. A single pull for this size of bin varies in cost considerably from location to location. The disposal point is important to show that the transportation cost to the nearest facility costs less and is more economically feasible. If a landfill is to be located within Navajo Nation, the gain economically would be the distance traveled from location to location, as shown in Table Two. Expenditure could range from $20,178.60 on a bi-weekly pull for one bin to $40,3357.20 on a weekly basis for Cameron, Arizona to Flagstaff, Arizona for example.

Table Two Landfill Distance to Nearest Chapter House and Cost State Landfill Distance Waste Management Cost (Miles) AZ Cinder Lakes 40 $776.10 per bin (40-cubic yard, ~10 tons*) from Cameron vs. & $1,132.10 from Tuba City at same 68 tons AZ Painted Desert 47 $817.10 per bin (40-cubic yard, ~10 tons*) from Dilkon AZ Blue Hills 54 N/A AZ Hopi 28 USEPA Permit for SMSWLF CO Montezuma County 55 N/A CO Transit Waste 44 N/A NM Red Rocks 6 N/A NM Crouch Mesa 28 $595.00 per bin (40-cubic yard, ~10 tons*) from Hogback NM Rio Rancho 38 N/A NM Sandoval 38 N/A NM Cerro Colorado 26 N/A NM Socorro 60 N/A UT White Mesa 33 N/A

Navajo Nation is just over 300 miles long (east to west), and 170 miles wide (north to south) which allows the Navajo Nation to consider future infrastructure with improved roadways for passage to the nearest compliance solid waste landfill, that includes transportation routes necessary for appropriate solid waste vehicle transports to move solid waste in all directions. In consideration for developing a compliance landfill within Navajo Nation, Table Three provides an insight to the distances current solid waste transports are utilizing in order to take Navajo Nation solid waste to a compliance landfill. The Table also provides a more significant way of looking at the distance factor from collection point at the larger population centers within the Navajo Nation and the distances to the nearest landfills. Table Three provides this information, listing landfill(s) near the major population centers and distances to the nearest landfills.

Table Three Distance to Landfills from Large Population Centers Population Center Landfills/Distance Tuba City Cinder Lakes, AZ/68 miles Kayenta San Juan County, UT/76 miles Montezuma County, CO/114 miles Shiprock Crouch Mesa, NM/38 miles Montezuma County, CO/42 miles Chinle Red Rocks, NM/146 miles Painted Desert, AZ/135 miles Blue Hills, AZ/138 miles Fort Defiance/St. Michaels Red Rocks, NM/64 miles Blue Hills, AZ/100 miles Painted Desert, AZ/109 miles Crownpoint Red Rocks, NM/20 miles Crouch Mesa, NM/86 miles

With the exception of the Shiprock and Crownpoint areas, the distances to the nearest solid waste facility from the larger population centers on the Navajo Nation, are in excess of the 40 mile average distance to the nearest Chapter House. In the case of the Chinle community, the nearest landfills are in excess of 100 miles.

All of the landfills contacted in the survey were asked about their tipping fees. The cost information is based on rated in effect for September 2000, and the increased for August 2002. The costs to deposit solid waste at the perimeter landfills show considerable variations. Many of the larger landfills charge a tipping fee based on tonnage. The common practice is, vehicles containing waste are weighed prior to depositing the waste in the landfill and then the vehicles are weighed again when leaving the facility.

A number of landfills do not have scales to weigh the vehicles containing solid waste. The facilities without scales usually charge by the cubic capacity of the waste container. The non-scale landfills tend to have lower rates when the waste volumes are recalculated on a tonnage basis. The non-scale waste facilities make up the difference in fees by charging the entire volume of the container, no matter how full it is.

Table Four lists the tipping fees for the landfills that weigh incoming waste. The Blue Hills Regional landfill at St. Johns, Arizona has the highest tipping fee while the White Mesa landfill, Bluff, Utah has the lowest fee as shown in Table Four.

Table Four Scale-Equipped Landfill Tipping Fee State Landfill Tipping Fee/Ton Tipping Fee/Ton August 2002 September 2000 AZ Cinder Lake $30.85 $32.20 AZ Blue Hills Regional $50.00 $50.00 AZ Painted Desert* $8.15 per cubic yard $26.00 ($20.38) CO Montezuma County $24.00 $25.25 NM Red Rocks Regional $24.00 $25.00 NM Cerro Colorado* $28.00 $26.40 UT White Mesa $22.00 $22.00 Mean Average Tipping Fee: $28.46 $29.55 Note: CPI may change rates to +/- 5% per year. * Not Open to the General Public, Commercial Haulers Only.

Table Five lists the tipping fee charges for those solid waste facilities that charge on a volume/cubic yard basis. The highest volumetric rate was for the Transit Waste in Colorado for incoming solid waste. The lowest volumetric rate is Sandoval County landfill at Rio Rancho, New Mexico as shown in Table Five.

Table Five Non-Scale Landfill Tipping Fees State Landfill Uncompacted Compacted Uncompacted Compacted $/cubic yard $/cubic yard $/cubic yard $/cubic yard Sept. 2000 Sept. 2000 Aug. 2002 Aug. 2002 AZ Hopi $8.33 $8.33 $8.50 $8.50 CO Transit Waste $7.00 $7.00 $10.00 $10.00 NM Crouch Mesa $3.41 & $4.20 & $3.57 & $4.68 & - Outside Cty. $4.50 $5.29 $4.21 $5.21 NM Sandoval Cty. $3.00 $3.50 $3.50 $4.00 NM Socorro $3.00 $3.00 $3.00 $3.00 NM Rio Rancho $4.10 $5.13 $4.24 $5.30 Note: CPI may change rate to +/- 5% per year.

In order to compare the two different methods of charging for waste, Jacobsen Helgoth used the volumetric landfill tipping fees, and recalculated the fees using the conversion rate of 350 pounds per cubic yard for uncompacted, loose waste and the conversion rate of 1,000 pounds for compacted waste in September 2000. NNEPA-RCRP has reevaluated this assessment using the same volumes with current 2002 information provided in Table Six.

Table Six Perimeter Landfill Tipping Fees State Landfill Uncompact Compacted Uncompacted Compacted $/350 lbs. $/1000 lbs $/ton (2000 lbs.) $/ton (2000 lbs.) (August‘02) (August ‘02) (Aug. ’02) (Aug. ’02) AZ Cinder Lake $5.45 $16.10 $31.10 $32.20 AZ Painted $4.55 $13.00 $26.00 $26.00 Desert* AZ Blue Hills $17.48 $25.00 $50.00 $50.00 CO Montezuma $7.00^ $12.63 $22.00 $25.25 County CO Transit Waste $10.00^ $20.00 $40.00 $40.00 NM Red Rocks $4.50^ $12.50 $25.00 $25.00 NM Crouch Mesa $3.57^ $8.42 $14.28 $16.84 ($4.21)^ ($10.42) ($18.72) ($20.84) NM Rio Rancho $4.24^ $10.60 $16.96 $21.20 NM Sandoval $3.50^ $8.00 $14.00 $16.00 NM Cerro $6.60^ $13.20^ $26.40 $26.40 Colorado* NM Socorro $3.00^ $12.00 $24.00 $24.00 UT White Mesa $5.00^ $11.00 $22.00 $22.00 Average $6.09 $13.30 $25.42 $26.60 *Not Open to the General Public. **NOTE: CPI may change rate to +/- 5%.

Based on Chapter and community input, the information in Table Six, a permitted compliance landfill within Navajo Nation could provide the same type of cost measures currently imposed at the 12 compliance landfills on the perimeter of Navajo Nation. Cost trends would be equal or less to the highest current dollar rate shown in the Table. The customs on Navajo Nation show the tendency for households far from a nearby convenience disposal facility is to make one trip bi-weekly or monthly to a compliance disposal location, or border community outside Navajo Nation in connection with local shopping and/or laundry mostly for cost incentives that are higher within Navajo Nation.

3.0 Inventory of Solid Waste Transfer Stations and Collection Points Within Navajo Nation

Solid waste disposal for most residents of the Navajo Nation requires taking the waste to a transfer station or collection point (i.e., open-top bin). Individual household pickup by either Navajo Sanitation or Waste Management is provided for residents within a housing development area, businesses, industry, or governmental entity, and it is estimated approximately 55% of Navajo Nation has household pickup services. Of the 110 Navajo Chapters throughout Navajo Nation, 54 Navajo Chapters have either a transfer station or collection point. The transfer stations are facilities that involve the dumping of solid waste into one or more open top container bins that, when full, are transported to compliance landfills with the use of roll-off trucks. Bins range in size from five (5) cubic yards, eight (8) cubic yards, 12 cubic yards, 30 cubic yards to 40 cubic yards. Larger populated areas (i.e., Shiprock, New Mexico and Tuba City, Arizona) have transfer stations with one or more 40-cubic yard bins to hold up to 10 tons of compacted solid waste, and eight (8) tons of uncompacted solid waste. Table Seven and Eight below shows the current operating solid waste systems under Navajo Nation: 26 Navajo Chapters have a transfer station, and 28 Chapters have a convenience collection point. In addition, 15 Navajo Chapters previously had a collection point and one transfer station, with open-top bins but ceased operation mostly due to a lack of funding and local participation.

Table Seven Chapter Solid Waste Transfer Stations State Chapters with Transfer Stations Operator Bodaway/Gap JPA w/ Coconino County Cameron JPA w/ Coconino County Chinle NWNMRSWA w/ Chapter Fort Defiance Waste Mgmt. w/ DCD-SWMP Ganado Navajo Sanitation ARIZONA Kaibeto JPA w/ Coconino County Kayenta Kayenta Township Leupp JPA w/ Coconino County Pinon Chapter/DCD-SWMP/NWNMRSWA

Tonalea JPA Coconino County

Tuba City JPA Coconino County

Alamo Socorro County Breadsprings NWNMRSWA Coyote Canyon NWNMRSWA Crownpoint NWNMRSWA Huerfano San Juan County Lake Valley San Juan County Nenahnezad San Juan County NEW MEXICO Pinedale NWNMRSWA/Chapter Ramah San Juan County Sand Springs (Burnham) San Juan County Shiprock NWNMRSWA Tohatchi Bernalillo County/IGA Upper Fruitland San Juan County Whiterock San Juan County

NOTE: The Red Rock, New Mexico transfer station was removed in its entirety in 2000.

Table Eight Chapter Solid Waste Convenience Centers (Collection Points) State Chapters with Transfer Stations Operator Beclabito San Juan Cty/ Waste Mgmt. Birdsprings JPA w/ Coconino Cty Coalmine Mesa JPA w/ Coconino Cty Coppermine DCDSWMP/ PSI Cornfields Navajo Sanitation Dennehotso Navajo Sanitation Dilkon Navajo Sanitation Greasewood Sps. Navajo Sanitation Houck NDES ARIZONA Indian Wells Navajo Sanitation

Kinlichee Navajo Sanitation

Lukachukai NWNMRSWA

Lupton Navajo Sanitation

Nahata Dzill NDES

Red Valley Chapter w/ Waste Management Shonto Chapter w/ I.H.S. Steamboat Navajo Sanitation Tolani Lake JPA w/ Coconino County/Navajo Sanitation Teesto Hopi Sanitation Wheatfields/Tsaile Chapter w/ Waste Management

Baca/Prewitt NWNMRSWA Crystal Navajo Sanitation Little Water NWNMRSWA NEW MEXICO Manuelito NWNMRSWA Ojo Encino Sandoval Cty / W.M. Rock Springs NWNMRSWA Twin Lakes Waste Management Whitehorse Lake NWNMRSWA NOTE: 14 Navajo Chapters have had previous bins, and include: Arizona: Black Mesa, Chilchinbeto, Cove, Navajo Mountain, Oaksprings, Red Lake, Red Mesa, St. Michaels, Sawmill, TeecNosPos; and New Mexico: Iyanbito, Mexican Water, and Pinedale, and; Utah: Aneth.

Six (6) transfer stations operate and are available for nearby Navajo Chapters and include: Page (LeChee), Arizona; Gallup (McKinley County), and Waterflow (San Juan County), New Mexico; Bluff and Blanding (Aneth and Montezuma Creek), and Mexican Hat (Oljato), Utah.

Of the larger populated Navajo Chapters, solid waste is considerable, and warrants use of a compactor bin to maximize the volume of solid waste to be hauled as with Chinle Chapter Transfer Station, Chinle, Arizona. All Transfer Stations and convenience collection points have various operating hours, mostly with a manned attendant who collects a tipping fee where applicable, with the exception of a few. Some Navajo Chapters provide a punch ticket at various cost or no cost, if the resident is a voting member of a particular Chapter. Figure Two is a map of Navajo Nation that shows the locations of each transfer station, and Figure Three shows the locations of the collection point solid waste facilities. Table Nine provides information for all 110 Chapters on current and past infrastructure for waste disposal.

Table Nine Chapter Solid Waste Facility Data Agency Chapter Transfer Station Bins Operator Remarks Black Mesa NO NO NONE Bins in past. Forest Lake NO NO NONE Hard Rock NO NO NONE Pinon YES NO Pinon Chapter SWMP/NWNMRSWA Tachee/Blue Gap NO NO NONE Facility Closed CHINLE Whippoorwill NO NO NONE Facility Closed AGENCY Chinle YES NO NWNMRSWA/Chinle Chapter Many Famrs (Chinle) NO NWNMRSWA Nazlini (Chinle) NO NWNMRSWA Rough Rock NO NO NONE Tselani/Cottonwood NO NO NONE Lukachukai NO YES NWNMRSWA Round Rock NO NO NONE Tsaile/Wheatfields NO YES Wheatfields Chapter Arizona Waste Management Becenti (Crownpoint) NO NONE Crownpoint YES NO NWNMRSWA Lake Valley YES NO San Juan NM Little Water (Crownpoint) YES NWNMRSWA Nahosdishgish (Crownpoint) NO NWNMRSWA Pueblo Pintado (Crownpoint) NO NWNMRSWA Standing Rock (Crownpoint) NO NWNMRSWA Bins are pending Torreon/Star Lake NO YES Sandoval County JPA expired, weekly service from County White Horse Lake (Crownpoint) YES NWNMRSWA

White Rock (Lake Valley) NO San Juan NM

Baca NO YES NWNMRSWA

Bread Springs YES NO NWNMRSWA Casamero Lake (RRR Landfill) NO NWNMRSWA Waste can be taken to Red Rocks Landfill Chichiltah (Breadsprings) NO NONE Church Rock (Gallup TS) NO NONE Iyanbito (Gallup TS) YES NWNMRSWA Inactive EASTERN Manuelito (Gallup TS) YES NWNMRSWA NAVAJO Mariano lake YES NO NONE AGENCY Pinedale NO NO NONE Former station removed Red Rock (BS/Gallup) NO NWNMRSWA Former station closed Rock Springs (Gallup TS) NO NWNMRSWA Smith Lake (RRR Landfill) NO NWNMRSWA Thoreau (RRR Landfill) NO NWNMRSWA Tsayatoh (Gallup TS) NO NWNMRSWA Counselor NO YES Sandoval County Waste Management Huerfano YES NO San Juan NM Nageezi (Huerfano) NO San Juan NM

Ojo Encino NO YES Sandoval County Waste Management

Tohajiilee YES NO Bernalillo County IGA

Alamo YES NO Socorro County Socorro County Ramah YES NO NWNMRSWA/Ramah Tow stations serve Chapter Chapter Dilkon NO YES Navajo Sanitation Planning Transfer Station FORT Indian Wells NO YES Navajo Sanitation DEFIANCE Jeddito NO NO NONE AGENCY Low Mountain NO NO NONE Teestoh NO YES Hopi Sanitation White Cone NO NO NONE Waste Management bins in past Coyote Canyon YES NO NWNMRSWA Mexican Springs (Tohatchi) NO NONE Naschitti (Tohatchi) NO NONE (Sand Springs TS is also available) Tohatchi YES NO NWNMRSWA (McKinley County TS also available) Twin Lakes NO YES Waste Management Cornfields NO YES Navajo Sanitation Ganado YES NO Navajo Sanitation Tipping fee Greasewood Springs NO YES Navajo Sanitation FORT Kinlichee NO YES Navajo Sanitation DEFIANCE Klagetoh NO NO NONE AGENCY Steamboat NO YES Navajo Sanitation Wide Ruins NO NO NONE Bins are pending Crystal (Tohatchi) YES Navajo Sanitation (Sand Springs TS is also available) Fort Defiance YES NO SWMP/Waste Management Houck NO YES NDES Bins are pending Lupton NO YES Navajo Sanitation Nahata Dzill Curbside YES NDES Oak/Pine Springs NO YES NONE Bins in Past Red Lake NO NO NONE Bins in past St. Michaels NO NO NONE Bins in past Sawmill NO NO NONE Bins in past Mexican Water (Bluff) NO San Juan County, UT Chapter bins previously Red Mesa (Bluff) NO San Juan County, UT Chapter bins previously Rock Point NO NO NONE Bins are pending Sweetwater NO NO NONE Teec Nos Pos NO NO NONE Bins in past Aneth NO NO NONE Bins in past Beclabito (Shiprock) YES San Juan, NM Waste Management Cove NO NO NONE Bins in past

Cudeii (Shiprock) NO NONE SHIPROCK Hogback (Shiprock) NO NONE JPA AGENCY Newcomb (Sand Springs) NO NONE JPA Red Valley NO YES Red Valley Chapter Waste Management Sanostee (Newcomb) NO San Juan, NM JPA Sheep Springs (Sand Springs) NO San Juan, NM JPA Shiprock YES NO San Juan, NM JPA Two Grey Hills (Sand Springs) NO San Juan, NM JPA Burnham (Sand Springs) NO San Juan, NM JPA Upper Fruitland YES NO San Juan, NM JPA Nenahnezad (Upper NO San Juan, NM JPA Fruitland) San Juan (Upper NO San Juan, NM JPA Fruitland) Coppermine (Bodaway/Gap) YES SWMP/PSI SWMP/PSI/Waste Management Cost Share Kaibeto YES NO Coconino County JPA Lechee (Page) NO Coconino County JPA Tonalea YES NO Coconino County JPA Inscription House (Kaibeto) NO Coconino County JPA Navajo Mountain NO NO NONE Bins in past – trying to WESTERN reopen NAVAJO Shonto NO YES Shonto Chapter AGENCY Bodaway/Gap YES NO Coconino County JPA Cameron YES NO Coconino County JPA Coalmine Mesa (Tuba City) YES Coconino County JPA, Bins are pending Tuba City YES NO Coconino County JPA Birdsprings (Leupp) YES Coconino County JPA, Bins are pending Leupp YES NO Coconino County JPA Tolani Lake (Leupp) YES Coconino County JPA/Navajo Sanitation Chilchinbeto NO NO Kayenta Bins in past Dennehotso NO YES Navajo Sanitation Kayenta YES NO Kayenta Township Oljato NO NO San Juan County, UT Transfer station at Mexican Hat NOTE: Transfer Station in parenthesis is nearby available facility.

The remaining 56 Navajo Chapter residents, approximately 80,000 residents, have to take their solid waste to either a transfer station or convenience collection point at another location and may have solid waste pick up by either Navajo Sanitation or Waste Management.

Ownership and operation of transfer and convenience collection stations on the Navajo Nation vary considerably on a site-by-site basis. In four of the five Tribal Agencies, the transfer stations are located on Navajo Nation property; however they are operated by local County Solid Waste Agencies. Table Seven through Table Ten list all of the waste collection stations by Agency and Chapter. Chapters that only have unsupervised waste bins are also shown on the facility lists. The tables also provide information regarding the Agency or firm that is operating the facility and is responsible for disposing of the waste. Information on these charts was derived from Indian Health Service compilations and telephone contacts with operators of the transfer stations.

The following paragraphs describe the status of transfer and convenience stations for each of the five Agencies of the Navajo Nation.

3.1 Western Navajo Agency

Coconino County operates the bulk of the eight (8) transfer stations located in the Western Navajo Agency. With the exception of the Page Transfer Station, the solid waste collected at the Coconino County waste facilities is transported to the Cinder Lake Landfill operated by the City of Flagstaff. Allied Waste contracts the operation of the Page transfer station, and the waste from this facility is hauled to the Painted Desert Landfill near Joseph City, Arizona. Residents of the LeChee Chapter can use the Page facility as part of the JPA with Coconino County. Currently, seven (7) transfer stations within Navajo Nation are owned and operated by the County as shown in Table Ten. Operation is made possible under a JPA between the Navajo Nation and Coconino County. The original agreement with Coconino County charged the Navajo Nation with 30 percent of the operating costs of the stations. In 2002, Coconino County would like to contribute only 40% of its funds to operate the seven (7) transfer stations, and have Navajo Nation provide 60% of the cost. Currently, ½ of 1% of the Arizona Sales Tax funds the solid waste for Coconino County. All household solid waste taken to any of the seven (7) transfer stations is currently at no charge to the consumer. It is the intension to have these transfer stations operate on their own, such as other non-Coconino transfer stations in which a set tipping fee is imposed, and Navajo Nation contributes the remaining cost.

Table Ten Coconino County Transfer Stations Transfer Station Waste Tonnage (Tons/Year) Leupp T. S., Leupp, Arizona 160 tons Cameron T. S., Cameron, Arizona 200 tons Tuba City T. S., Tuba City, Arizona 2,400 to 2,600 tons Bodaway/Gap T. S., The Gap, Arizona 130 tons Kaibeto T. S., Kaibeto, Arizona 700 tons Tonalea (Red Valley) T. S., Tonalea, AZ 530 tons Page (LeChee) T. S., Page, Arizona* 135 (750*) tons Subtotal Tonnage Per Year 4,455 tons *LeChee has a population of 3,734 residents according to the 2000 Census of which the City of Page has a population of 9,500 residents, so 18% of the 750 tons is actually contributed by Navajo Nation at ~135 tons. The Navajo Generating Station employs 530 employees, and local businesses have their own contract with the same Page Transfer Station.

The Tuba City transfer station, Tuba City, Arizona is one of the largest solid waste acceptance facilities on the Navajo Nation, and it has two open-top 40-cubic yard bins and one 40-cubic yard compactor bin. The Tuba City station has containers available for recycling newspapers and cardboard, and is open and manned seven days per week. The Kaibeto transfer station is representative of the smaller manned stations operated by Coconino County. The Kaibeto facility has a single 40-cubic yard container. The Kaibeto station is open seven days per week but is only manned five days per week. Unmanned transfer stations include Cameron and Bodaway/Gap that consist of a single 30-cubic yard bin at each station. Illegal dumping and vandalism are problems at unmanned stations. In 2001, NNEPA provided the Gap/Bodaway Chapter with civil enforcement for those who did illegally dump at the transfer station even though this facility is open seven days a week with no manned attendant.

The Kayenta Township has purchased waste collection and roll-off equipment, has constructed and is operating a transfer station in the Kayenta Township. The Kayenta transfer station has a 40-cubic yard compactor bin and a 40-cubic yard open top bin and is open only five days per week. The former Kayenta open dump is no longer used and it is located east of the transfer station, and it is estimated it will cost $445,000.00 to properly close the site. The Kayenta School District also operates a transfer station for school-related waste collections. Navajo Sanitation, a private firm, previously hauled waste from bins at the Dennehotso Chapter. San Juan County, Utah is accepting waste from the Oljato Chapter via the County-operated transfer station in Mexican Hat, Utah.

3.2 Chinle Agency

The Chinle Agency has the fewest transfer and convenience stations of any of the five Agencies of the Navajo Nation. Apache and Navajo Counties do not participate in the regional transfer station process because there is no public works program, and the Counties priority is road maintenance. The NWNMRSWA has been collecting waste from the Chinle transfer station for the past three years and a bin at the Lukachukai Chapter for the last year. There are no long-term contracts in place with regards to operation of formal transfer stations in this Agency. The Authority is currently charging the local chapter houses for hauling the waste to the Red Rocks Landfill on a per pull basis.

The Chinle Chapter transfer station is operated by the Chinle Chapter and consists of a 30-cubic yard compactor bin and a 30-cubic yard open-top bin. The 30-cubic yard compactor bin, on average, takes two weeks to fill. The open-top bin, depending on waste activity, takes from one to two weeks to fill. The Chinle facility is only open five days per week. In 1999 and 2000, the NWNMRSWA hauled an average of 17 tons of waste per month from the bins at Chinle and during the past eight months, an average of one ton of waste per month from Lukachukai. The transfer station at Pinon, which includes a ramp and fenced enclosure, was re- opened as of September 2001.

3.3 Fort Defiance Agency

There are four transfer stations in the Fort Defiance Agency. The two stations located at Fort Defiance and Ganado, Arizona are operated by Waste Management of Arizona, Inc., by contracts with the Chapters. The NWNMRSWA haul bins from the Tohatchi and Coyote Canyon Transfer Stations. Authority records indicate that the waste hauled from the Tohatchi station averages 6.8 tons per month. Beside the local residents of Tohatchi, some of the surrounding communities of Sheepsprings, Mexican Springs, and Twin Lakes, New Mexico utilize this station as well. Many of the chapters in this Agency have waste bins at the chapter houses and have temporary contracts with waste haulers to have the waste transported to landfills.

The Fort Defiance transfer station consists of a 40-cubic yard compactor bin and a 40-cubic yard open-top bin. The facility is located on the south side of the former Fort Defiance Chapter House location. Currently, it takes from two to two and a half weeks to fill both bins. The manned facility is free to residents of the Chapter, and non-residents pay by the size of trash bag, or truckload. Cost for a truckload range from $22.00 to $27.00. This facility also takes appliances, with the exception of refrigerators, at a cost of $10.00 per white good. Other communities utilizing the Fort Defiance transfer station include Sawmill, St. Michaels, Window Rock, and Oaksprings, Arizona. The former Watchman landfill has been officially closed but is still utilized as an illegal dumpsite by the local communities of Fort Defiance and the surrounding area. The Greasewood Springs (Lower Greasewood) collection point is an unmanned 40-cubic yard open-top bin. The former open dump at Lower Greasewood was closed by DCD-SWMP in 1999. The Ganado transfer station currently consists of a single 30-cubic yard bin, which takes about three weeks to fill. The station is located across from the Apache County facilities on the south side of State Highway 264 within Ganado. Other communities utilizing the transfer station include Klagetoh, Cornfields, Kinlichee, and Nazlini, Arizona. The Chapter currently charges $5.00 per truckload to deposit waste at the Ganado station. The Ganado facility is currently being upgraded with a 30-cubic yard compactor bin. The Coyote Canyon transfer station consists of a single, unmanned 30-cubic yard bin and it averages 8.2 tons per month. Communities utilizing this transfer station would be Standing Rock and Twin Lakes, New Mexico. NWNMRSWA transports the waste from the Coyote Canyon facility.

3.4 Shiprock Agency

San Juan County, New Mexico, under a JPA, operates three transfer stations that serve Chapters in the Shiprock Agency. Transfer stations are located at Shiprock, Sand Springs (Burnham), and Upper Fruitland. The Shiprock facility is located on the east side of State Highway 666 across from the Shiprock Indian Health Hospital. The Sand Springs transfer station is also on the east side of State Highway 666, at the junction of Toadlena and Burnham turnoffs. And, the Upper Fruitland Transfer station is located along Navajo Route 36 on the south side of the highway at Upper Fruitland. Residents of San Juan County do not have to pay to use the transfer stations but other residents outside the County do pay a tipping fee. Another San Juan County transfer station, not under the JPA is located at Waterflow and is available to local Chapter members. The Shiprock and Upper Fruitland facilities have bins for loose waste and compactor bins. San Juan County tracks waste volumes from the transfer station in both the Shiprock and Eastern Navajo Agency and the average monthly and yearly waste information is shown in Table Twelve.

Table Eleven San Juan County, NM Average Monthly Transfer Station Waste Transfer Station Average Monthly Estimated Monthly Estimated Yearly Waste Volume Waste Tonnage Waste Tonnage (cubic Yards) (Tons) (Tons) Shiprock 3,770 1,460 17,520 Sand Springs 605 166 1,992 Upper Fruitland 1,286 397 4,764 Waterflow 765 210 2,520 Lake Valley 82 22.6 271.2 Huerfano 291 80 960 Total: 6,799 2,335.6 28,027.2

The Lake Valley and Huerfano waste facilities are in the Eastern Navajo Agency. The transfer station at Bluff, Utah, operated by San Juan County, Utah, is available to the Aneth, Mexican Water, and Red Mesa Chapters.

The large Shiprock transfer facility averages 6,000 vehicles visits per month. This transfer station has one 40-cubic yard compactor bin for general waste and one 40-cubic yard open-top bin for construction and demolition wastes. The station also has facilities for the collection of ashes and scrap metal. This facility is open seven days a week. The communities within San Juan County take advantage of this transfer station since the businesses in Shiprock attract commerce for consumers, and include from communities at Teec Nos Pos and Beclabito, Arizona; Cudeii, Hogback, Newcomb, Waterflow, and Upper Fruitland, New Mexico.

3.5 Eastern Navajo Agency

The Eastern Navajo Agency has transfer station facilities that are operated by the NWNMRSWA and San Juan County, New Mexico. The San Juan County facilities at Huerfano and Lake Valley are operated by the County and free to San Juan County residents. Both San Juan County-operated solid waste facilities are not located on Navajo Nation land. The NWNMRSWA contracts with individual Chapters to have manned or unmanned transfer stations available to Chapter residents. The manned, Authority-operated facilities, on average, are open only one or two days per week.

The Authority-operated transfer station, at Breadsprings, averages 4.7 tons of waste per month, and is located along State Highway 602 in Vanderwagon, New Mexico. The station is west of the highway, approximately one mile south of the Bean Farm Road. The Crownpoint transfer station averages 7.9 tons of waste per month. The facility is located north of Crownpoint along State Highway 371 near the Junction of Route 9 near Whitehorse. The NWNMRSWA also collects waste from the Pine Hill and Ramah transfer stations. The Authority also operates the McKinley County Transfer Station, which is located on Hasler Road, northeast of Gallup, New Mexico. This facility is available to the Chapters in the Gallup vicinity, the cost of dumping waste at the transfer station is currently $29.00 per ton, and $4.50 per level truckload. Recycling of newspaper, cardboard, glass, and plastics is available at no cost. Chapter residents in Mariano Lake, Casamero Lake, Thoreau, and Smith Lake can take their waste to the Red Rocks Regional landfill where the cost is $25.00 per ton to deposit waste.

Sandoval County does not operate a public works program, and funds are mainly targeted for highway maintenance. The County does provide a trash truck to collect waste from Torreon/Star Lake, Counselor, and Ojo Encino Chapters. The waste is transported to the Sandoval County Landfill in Rio Rancho, New Mexico. The County had a JPA with Navajo Nation but has terminated the agreement.

Solid waste from the Tohajiilee Chapter is transported to the Cerro Colorado Landfill, operated by the City of Albuquerque. The Alamo Chapter has a transfer station constructed and operated by Socorro County.

4.0 Waste Stream Characterization

The delineation of the solid waste stream, generated by the Navajo communities and a determination of the amount of waste and dollars leaving the Navajo Nation, is an important step in the development of a solid waste management plan. The following paragraphs identify the sources of waste generated on the Navajo Nation, describe the sources of waste generated on the Navajo Nation, describe the methodology used to model the volumes of waste generated on each of the Navajo Chapters, provides estimates of waste volumes leaving the Navajo Nation and the dollar value of that waste. The 2000 Census was included with new information received directly from available sources, such as, I.H.S., B.I.A., and Navajo Nation. Jacobson Helgoth Consultants originally used the Division of Community Development publication “Chapter Images: 1996” as a reference but did not incorporate the facts of the 2000 Census which was used to recalculate the original numbers from the 1996 information, with the exception of newer data from 2001. All information set forth in this Plan is the most current for population trends. On-site visits were made to communities with more complex waste generation to further characterize the waste stream collection methods. Information was gathered directly from the landfills for cost analysis.

5.0 Waste Stream Methodology The characterization of the entire volume of waste generated on the Navajo Nation is unknown in its entirety due to the number of small pockets of illegal dumpsites, the large industries within Navajo Nation that contract a commercial waste hauler or independently dispose of waste within a lease area with available company dump trucks. Many schools and businesses also do a similar waste hauling contract as applicable. Others have contracts with Navajo Sanitation or Waste Management of New Mexico or Arizona.

The solid waste disposal at landfills via transfer stations and collection points was characterized by indirect methods identifying the major contributing components of the waste stream and to estimate the weight of waste produced by each of the components. Based on the 2000 Census of Navajo Chapter populations, information was combined with solid waste generation factor data to estimate the waste stream tonnage.

Each of the five agencies, their respective Chapter community, their usage of transfer stations or collection points, and the volume of waste generated at these receiving locations ranges from 2.1 to 7.3 pounds per individual. The waste factor originated from key generation sources, on-site counts of waste receptacles at selected communities that took into accounts, schools, businesses, governmental facilities, and medical institutions. On-site visits were made to transfer stations to confirm waste collection rates. The average waste factor for Chapters ranges from 2.1 to 2.5 pounds per individual per day.

6.0 Solid Waste Sources

The initial step in defining the Municipal solid waste stream on the Navajo Nation is to determine the sources and nature of the solid waste, itself. Municipal solid waste is generated on the Navajo Nation from five primary sources: Residential, Commercial, Medical/Hospital, School, and Governmental/Organizational solid waste.

Industrial waste consist of solid waste generated from facilities like Navajo Generating Station and Four Corners Power Plant; the coal mining industry (Peabody Western, Inc., P&M Coal Mining Co., and BHP Billiton – New Mexico Coal); and U. S. Park Service (Canyon de Chelly and Navajo Monument, Arizona; and Chaco Canyon, New Mexico), provide their own contracts with Navajo Sanitation or Waste Management. The waste generated from these sites includes solid and/or hazardous wastes. All hazardous waste is handled by a licensed transporter who delivers the waste to a facility under the RCRA Subtitle C facility, different than a RCRA Subtitle D landfill or facility.

The following paragraph describes the key elements of the solid waste stream and some of the factors utilized in quantifying the tonnages of each of these waste sources.

6.1 Residential Waste

Residential waste is generated at individual homes and primarily includes: Paper, glass, plastics, ashes, food waste, cardboard, wood, and metal. Yard waste is a minor component of this category of solid waste and generally consists of weeds, tree clippings, and brush removal wastes. For the majority of homes on the Navajo Nation, solid waste disposal is the responsibility of the residents of that household. Some residences have curbside waste pickup. Currently, the method of disposal for most residential waste is for the resident to take the waste to the nearest transfer station or collection point. For many years, the most common disposal method was the use of a 55-gallon burn barrel or a shallow burn pit to burn paper, wood, and plastics. The ashes and remains of non-combustible wastes, such as glass and tin cans, still required disposal, most often into a nearby arroyo. The Navajo Nation has discouraged the use of burn barrels and pits, but their use is still common at isolated residences in the more remote Chapters on the Navajo Nation. Many urban-type housing units still have burn barrels, and most residents under the Navajo Housing Authority (NHA) provide commercial solid waste disposal utilizing a 96-gallon wheeled container. These containers can normally hold 30 to 50 pounds of solid waste per week, and provides the common use waste factors of 2.1 and 2.5 used in this Plan for many communities. Separately, N.H.A. does contractual home renovations on a 10-year basis, when the homes provided are still leased, and not purchased through their owner-lease contract. When renovations take place, construction debris is generated and must be properly disposed of, and each home would originally take approximately a 30-cubic yard bin that holds up to eight (8) tons of waste. Each of the 110 Chapters has a number of homes fitting the criteria for renovation at one point or another in time. If concrete is involved or sheetrock, the weigh of a small ½-cubic yard averages about 100 pounds alone, and the weigh and not volume is the basis for removal in a bin. Other construction debris can come from Chapter House’s undergoing renovation, and other buildings within a Chapter. The construction debris cost was not considered under the Plan but a general estimated cost is listed as a separate item since the waste is also transported to any of the compliance landfills nearby.

Residential housing on the Navajo Nation is subdivided in this study as to those housing units that have residential waste pickup and those units that do not. Within Navajo Nation, approximately 33 percent have curbside pickup or nearby waste bins. The majority of the housing units, administered by the NHA, Navajo Nation Employee Housing, the Bureau of Indian Affairs (BIA), and the Indian Health Service (IHS), residential waste pickup is available. Residents are supplied with individual waste can or bins. In some areas, groups of houses are supplied with five or eight cubic yard bins that are located within individual neighborhoods. Collection is normally bi-weekly. Waste disposal, for residents that are not served by residential pickup, involves the transport of solid waste to a local transfer station. In some cases, the transport of waste requires someone to travel many miles to reach a regional transfer station. Significant amounts of waste from residences continue to be deposited in commercial and institutional receptacles on the Navajo Nation and border town sites. Table Twelve shows the total population in the five Agencies. Table Thirteen summarizes the number of residential units in each of the five Agencies that are managed by various Tribal authorities, most of which have solid waste pickup or neighborhood waste bins available.

Table Twelve Total Population by Agency Agency Total Population from 2000 Census Chinle 28,491 Eastern Navajo 35,517 Fort Defiance 47,213 Shiprock 30,962 Western Navajo 38,260 Totals: 180,443

Table Thirteen Managed Residential Housing Units Agency Navajo NHA IHS BIA Totals Nation Chinle 1,661 124 450 2,235 2,235 Eastern 0 999 234 570 1,803 Fort Defiance 550 2,093 131 485 3,229 Shiprock 0 1,088 104 304 1,496 Western 0 1,462 343 650 2,455 Totals: 550 7,273 936 2,459 11,218

Table Fourteen Estimated Waste for Managed Residential Housing Units Agency Total Units Waste Tons/Day Tons/Week Tons/Year Factor* Chinle 2,235 3.1 3.5 24.2 1,261 Eastern 1,803 2.9 2.6 18.3 952 Fort Defiance 3,229 3.6 5.8 40.7 2,116 Shiprock 1,496 2.7 2.0 14.1 735 Western 2,455 2.7 3.3 23.2 1,206 Totals: 11,218 3.0 Avg. 17.2 T/Dy 120.5 T/Wk 6,270 T/Yr • The averages for each Agency had a mean solid waste generation factor.

Each of the residential units have the 96-gallon wheeled container to utilize for daily solid waste disposal, and taking into account the amount of bagged solid waste at 30 to 50 pounds per week or bi-weekly, the estimated waste factor per agency was defined and averaged as shown in Table Fourteen. The 6,270 tons per year is estimated to demonstrate the mean tipping fee of $29.55 (Table Four) could show that approximately $185,278.50 is leaving Navajo Nation. Waste generation by a single person would be lower than an average family unit of three to four individuals, so utilizing the waste factor of 2.1 is standard, and with the surveys, the usage at transfer stations increased the waste factor to a high of 7.3. Population densities do factor into the amount of solid waste generated for a given community. The I.H.S. had calculated an average usage of 2.15 pounds per person for an average community, and this number can be lower if the community is more remote or higher if in a larger populated community. 2.1 is standard for the smaller families in comparison to larger families or a family residing in a communal setting of relatives living side by side, as in many cases throughout Navajo Nation.

6.2 Commercial Waste

Within the Navajo Nation, a total of 375 (i.e., Chinle Agency at 60; Eastern Navajo Agency at 29; Fort Defiance Agency at 88; Shiprock Agency at 94; and Western Navajo Agency at 104) businesses are registered with the Navajo Division of Economic Development, with employees ranging from 1 to 600 employees, and include: Fast food establishments, restaurants/cafes, curio shops/trading posts, hair styling salons, clothing and fabric outlets, grocery/convenience stores, animal feed stores, beverage suppliers, gasoline and diesel stations, laundromats and/or dry cleaners, lodging, tire shops, movie rentals and theaters, electrical stores and companies, automobile parts stores and automobile sales, carwashes, tool stores, septic services, propane vendors, banks, medical support and supply stores, recreational services, optical stores, trucking businesses, construction companies, attorney offices, dental services, tax services, and industries (coal-fired power plants, coal mines, and oil extractive operations). Most of these commercial establishments within Navajo Nation are contracted with private waste haulers that supply the establishments with five-, eight-, or 12-cubic yard metal bins with covers. A few establishments have 30-cubic yard compactor bins. Collection is most commonly scheduled for a once a week pickup. Waste composition ranges from cardboard and paper to food wastes, styrofoam, paper, glass, plastics, wood, and metal. Most food preparation establishments also have grease collection bins that are collected by specialty waste collectors. All of these establishments have their own solid waste contract, and depending on the amount of debris leaving an establishment, the 375 businesses could generate more or less than 140,000 tons of waste per year. It is possible Navajo Nation looses a mean dollar amount of more than $4,000,000.00 based on the mean tipping fee amount of $29.55 per ton at the regional landfills. Other Subtitle D waste, such as construction debris is not considered, and only the main waste of household debris as described.

Most transfer station are set up for household waste only, and require business establishments to have a direct contact with a separate waste haulers but some areas have a temporary fast food set up, such as a flea market setup, and the solid waste from these establishments do go to a nearby transfer station. In some Chapters, such as Tuba City, the Chapter Local Governance requires all vendors with fast food located at a flea market empty the majority of their solid waste into a large bin provided specifically for their use as well as flea market consumers.

Other waste is fly and bottom ash generated from the coal-fired power plants, and is recycled at a nearby coal mine for reclamation as with the Four Corners Power Plant that takes ash back to the Navajo Mine, and the ash is used as an artificial soil base for reclamation re-establishment. Both the Four Corners Power Plant and the Navajo Generating Station utilize an in-house cement business to utilize some of the fly ash produced by each plant, and must possess the necessary constitutes of ash content to be able to use as a binder in the cement process. Ash is also stockpiled at the Navajo Generating Station, and does not leave the lease area. No ash is taken to any landfill, so no cost is associated with this by-product of coal. Also, due to their individual permits with the U. S. Office of Surface Mining, an unknown amount of solid waste has been buried within mining pit areas for the three (3) surface coal mining companies located within Navajo Nation without consideration of the Navajo Nation Solid Waste Act.

Due to past yearly business practices within Navajo Nation involving construction debris, such as with buildings and highways, several businesses not identified as part of the 375 Navajo Nation Economic Development listing are located and operating from large municipalities as Phoenix, Arizona or Albuquerque, New Mexico. Several major projects with all State highway departments and local governmental institutes have taken place on a yearly basis with the outside vendors. It has been estimated approximately 30,000 to 1 million tons being taken off Navajo Nation. A bag of cement covers approximately 0.5 cubic feet and weighs approximately 80 pounds and heavier with water added. Given the projects within Navajo Nation for demolition, many buildings cover more than 5,000 square feet, and have a cement foundation. In utilizing the mean disposal fee of $29.55, an estimated range total of $886,500.00 to $30 million dollars is spent each year for disposal fees alone. This does not consider the cost amounts for rental fees for the bins, tax, and transportation.

6.3 Hospital Waste

Six (6) major hospitals, seven (7) health centers, and 15 health stations are located within or border Navajo Nation to generate both municipal solid waste and medical waste, separately. In 2002, less than 4,000 employees work at these facilities. All facilities contract with specialized waste handlers to collect the medical wastes, which are taken to specific, permitted, medical waste facilities outside of the Navajo Nation for disposal. The hospital municipal wastes, which include paper, metal, cardboard, glass, plastics and food wastes are placed in covered bins for collection and disposal by commercial solid waste haulers. The waste is collected weekly and range from 30- (6 to 8 tons) to 40- (8 to 10 tons) cubic yards of solid waste from employees, patients, and visitors; approximately total tonnage per year at ~5,807 tons for an estimated patrons and employees at 2.1 pounds of waste twice per day leaving Navajo Nation to a compliance landfill from all facilities. Due to the I.H.S. contracts, Navajo Nation loses $171,600.00 (mean $29.55 tipping fee) for the yearly tons of regular solid waste, not including medical waste at any regional landfill as shown in Table Fifteen.

Table Fifteen Indian Health Service Health Facilities Facility Hospital No. Health Health Stations Total Estimated of Centers No. of Tons Per Beds Staff Week* Chinle Chinle, AZ 60 Tsaile, AZ Pinon, AZ ~500 ~16 Rock Point, AZ Crownpoint Crownpoint, 25 Pueblo Pintado, ~380 ~11 NM NM Thoreau, NM Fort Defiance Fort Defiance, 56 Sanders, AZ ~400 ~`1 AZ Gallup Gallup, NM 98 Tohatchi, NM Fort Wingate, ~880 ~20 NM (School) Kayenta Kayenta, AZ Chilchinbeto, ~300 ~10 AZ Inscription House, AZ Dennehotso, AZ Navajo Mtn., AZ Shiprock Shiprock, NM 59 Dzilth-Na-O- Sanostee, NM ~650 ~17 Dith-Hle, NM Shiprock, NM & TeecNosPos, (Teen Life Ctr.) AZ Toadlena, NM Tuba City-638 Tuba City, AZ 73 Dennebito, AZ ~500 ~16 Winslow-638 Winslow, AZ Dilkon, AZ ~200 ~10 Leupp, AZ Totals 6 371 7 15 <4,000 ~112 * Estimated tonnage determined on size of bin pulled on a weekly basis. The I.H.S. contracts with one private hauler on an annual basis to pickup waste bi-weekly at all of the medical facilities under its jurisdiction. Waste, from some of the medical facilities, is picked up more than twice a week. There are also some privately operated hospitals, such as the Sage Memorial Hospital in Ganado, Arizona, who contract to have their waste removed by commercial haulers. The Tuba City Hospital and Winslow Indian Health Service Units are considered contract health facilities under P. L. 638, as of September 2002. There are also a number of smaller medical clinics that are not open every day, located in some of the smaller Chapters. These small clinics generate smaller volumes of municipal waste. The wastes generated at the medical facilities are normally deposited in eight- to 30-cubic yard containers supplied by the contracted commercial hauler.

All facilities encourage patients to bring back bio-hazardous materials such as syringes and lancets used for diabetics for proper disposal. Illegal dumping of these types of medical waste are a smaller part of illegal open dumping but do occur frequently.

6.4 School Waste

Municipal solid waste generated at the schools on the Navajo Nation represents a significant portion of the total solid waste stream. Table Sixteen below provides the necessary information on schools. Table Sixteen Schools Within Navajo Nation Public School - No. of Schools Students Staff/Faculty Est. Tons/Wk 2002 Headstart 141 2,820 423 24 Elementary 96 Middle 65 48,246 23,520 528 High School 35 Subtotal 337 51,066 23,943 552 B.I.A. School- No. of Schools Students Staff/Facility Est. Tons/Wk 2002 Elementary 40 Middle 30 11,704 2,461 104 High School 4 Subtotal 74 11,704 2,461 104 Private School- No. of Schools Students Staff/Facility Est. Tons/Wk 2002 Elementary to H. 3 448 77 4 S. Dine College - No. of Schools Students Staff/Facility Est. Tons/Wk 2002 Secondary – Colleges 2 1,955 322 18 Subtotal 2 1,955 322 18 TOTALS 416 65,173 26,803 676

• Estimated tonnage was based on each individual generating 2.1 pounds per day. Each of the populations of students and staff can contribute approximately 2.1 pounds of solid waste per week to include their lunch and snack breaks, and disposal of schoolwork not necessary, and estimating 676 tons of solid waste per week. An estimate per year would be 35,152 tons of solid waste transported off of Navajo Nation to a regional landfill. An estimate of dollars, based on this amount of tonnage, would be $1,038,742.00 lost to Navajo Nation each year.

Waste generated at schools is primarily paper and cardboard, and can also contain, glass, plastics, metal, and wood. School food service programs can also generate significant volumes of food waste. Many school cafeterias collect grease in special containers for special disposal similar to restaurants. Schools range considerably in size and serve preschool, elementary, middle, and high school-aged students. There are also post-secondary facilities located on the Reservation. Operational control of the schools ranges from public to private and religious institutions. There are also Community Schools funded through the B.I.A. A significant number of schools have boarding facilities that generate additional solid and food waste. The bulk of the school waste on the Navajo Nation is contracted to private haulers for removal. The B.I.A. contracts with waste haulage firms, to collect waste at the schools and associated housing under its jurisdiction on the Reservation. School waste is normally collected on a twice-weekly basis. Depending on the size of the school, waste containers can vary in size from five-cubic yards to 30-cubic yards. In 2000, the amount of solid waste coming from the schools was estimated at 22,412 tons per year in comparison with 2002 estimate at 35,152 tons per year.

6.5 Governmental Waste

Municipal solid waste is also generated by the Navajo Nation Government and supporting agencies. Included in this category are: Chapter Houses, Navajo Nation offices, Navajo Housing Authority, Navajo Tribal Utility Authority, B.I.A. offices and support facilities, U. S. Government Agencies, such as the Indian Health Service, Forest Service, Department of Agriculture, County and State Agencies that have facilities on the Navajo Nation, such as the Arizona Department of Transportation. Governmental waste can range from paper, plastics, glass, metals, wood, food-waste to a separate consideration of construction and demolition wastes. Municipal solid waste is also derived from the various governmental agencies and services that are located on the Navajo Nation. Most of the governmental facilities have waste containers that range in size from 55-gallon waste containers to 30-cubic yard roll-off boxes. This study assumes that commercial haulers collect all office wastes on a weekly basis but no considering the bulky debris, such as, construction debris and other bulky office items not normally disposed of on a weekly basis.

7.0 Community Solid Waste Survey

In order to better quantify the tonnage of waste generated by commercial, hospitals, schools, and governmental agencies on the Navajo Nation, representatives of Jacobson Helgoth Consultants and the NNEPA visited 12 different Navajo communities in 1998. The primary focus of the on-site visits was to estimate the volumes of waste that were being collected by contacted commercial waste haulers. The purpose of this survey was to determine the number and volume of waste disposal containers at schools, hospitals, commercial businesses and governmental agencies. Communities on the Navajo Nation, with the larger populations and complex waste streams, were primarily selected for this survey. Smaller communities, such as Coyote Canyon, NM and Kaibeto, AZ that have smaller waste streams, were also surveyed.

The community survey involved the enumeration of the commercial waste containers at each business, school, hospital or government agency. The sizes of the containers at each facility were also recorded. Waste tonnages for containers were estimated using a conversion factor of 550-pounds per cubic yard for uncompacted waste and 1,000-pounds per cubic yard for compactor container waste. To average winter versus summer waste generation cycles, the open-top waste containers were considered to be 50 percent full and compactor containers were considered to be 75 percent full on an annual basis. The waste bins for the commercial businesses and governmental agencies were assumed to be collected on a weekly basis. School and hospital waste containers were assumed to be collected on a twice-weekly basis. School waste was also calculated for a nine-month school year even though some schools operate during the summer months and have food service available. The waste tonnages were expressed in tons per week as most waste is collected at a minimum of once per week. The Solid Waste Survey data sheets for each of the 12 communities included in the study are included in Appendix II of this report. Table Seventeen summarizes the results of the Solid Waste Survey and shows the variability of the waste stream for each of the surveyed communities. The size and number of schools and businesses seems to have the most impact on the waste streams in these communities.

Table Seventeen Solid Waste Survey Estimated Commercial Pickup Solid Waste (Tons/Week) Community Commercial Hospitals Schools Official Total Cameron 14.1 0 0 0 14.1 Chinle 34.7 15.4 37.8 7.9 95.8 Coyote Canyon 1.4 0 0 0.7 2.1 Crownpoint 8.4 2.8 14.2 3.2 34.7 Fort Defiance 4.8 6.6 23.3 24.8 46.6 Ganado 5.0 15.4 20.9 4.4 45.7 Kaibeto 1.1 0 4.2 0 5.3 Kayenta 33.2 5.3 16.8 3.7 59.0 Pinon 15.9 0 27.4 1.1 44.4 Shiprock 28.1 22.5 26.3 1.1 78.0 St. Michaels/ Window 29.2 0 13.7 13.1 48.2 Rock Tuba City 14.4 15.0 58.0 20.6 100.5

For the communities surveyed, there are a significant number of managed residential housing units operated by the NHA, B.I.A. and I.H.S. Waste pickup from these residences is contracted by the agencies managing these housing units. Table Eighteen summarizes the estimates for the total solid waste stream for the surveyed communities. This estimate includes all of the contracted pickup from businesses, schools, hospitals, and governmental sources. The waste tonnages for the managed residential units are included along with the estimated tonnages of waste generated weekly at residences that do not have commercial pickup.

Table Eighteen Solid Waste Survey Estimated Total Solid Waste Stream (Tons/Week) Community Commercial Residential Residential Total Waste Pickup Pickup without Pickup Cameron 14.1 0.6 5.8 20.5 Chinle 95.8 18.3 28.8 142.9 Coyote Canyon 2.1 2.8 5.5 10.4 Crownpoint 34.7 13.0 4.4 52.1 Fort Defiance 46.6 25.4 16.2 88.2 Ganado 45.7 3.1 14.1 62.9 Kaibeto 5.3 4.6 5.4 15.3 Kayenta 59.0 8.7 27.9 95.6 Pinon 44.4 3.0 10.7 58.1 Shiprock 78.0 13.8 11.6 103.4 Tuba City 48.2 8.2 29.8 86.2 Totals 100.5 13.8 39.0 153.3

8.0 Solid Waste Stream Models

In most cases, it is nearly impossible to weigh every scrap of waste that is generated within large study areas. Additionally, seasonal variations in travel, shopping habits, and the nine-month long school year produce non-uniform waste flows. Municipal solid waste stream characterization commonly utilizes estimate on methods to quantify the waste volumes generated within the area of interest. Indirect estimation methods have proven to provide reasonable estimates of waste stream volumes for solid waste facility planning. Most commonly, waste stream volumetrics are based upon average individual waste generation. The Solid Waste Generation Factor is defined as the weight of waste generated by one individual per day.

In the United States, the USEPA currently estimates the Solid Waste Generation Factor for an average American, to be 4.5 pounds of waste per person per day (single or a combination of paper, food waste, plastics, glass, textiles, metal, wood, etc.). Because of the differences in the standards of living and lifestyles of members of the Navajo Nation, the Solid Waste Generation is estimated to be 2.1 to 2.5 pounds of waste per person per day, and can increase depending on population, and the availability of commercial enterprises, schools, hospitals, governmental offices nearby. Both factors were acceptable to the MOU Team of Navajo Nation, B.I.A. and I.H.S. These factors are considered primarily because the minimal volumes of cubic yard waste generated on the Reservation are lower due to the median incomes of tribal members. The I.H.S. previously conducted limited studies into residential solid waste generation rates for a Chapter on the Navajo Nation. The I.H.S. research computed a Solid Waste Generation Factor of 2.15 pounds per person per day for residential waste only. In factoring the waste stream for Navajo Nation has 2.1 plus 0.75 pounds per person, equaling 2.85 pounds per person approximated for each individual.

In 1992, the Northwest New Mexico Regional Council of Governments, commissioned a Solid Waste Management Study for Cibola, McKinley and San Juan Counties, New Mexico. The study, prepared by R. W. Beck and Associates, utilized a Solid Waste Generation Factor of 2.5 pounds per person per day for estimating waste generated on the Navajo Nation. This factor remains true for some of the communities located within Navajo Nation.

The Community Solid Waste Survey data collected by Jacobson Helgoth Consultants found, that when the total waste tonnages estimated by the field surveys were compared against community populations, there are significant differences in the estimated Solid Waste Generation Factors for different communities. Table Nineteen shows the Solid Waste Generation Factors calculated for the field survey communities.

Table Nineteen Estimated Solid Waste Generation Factors Community 2000 Chapter Waste Factor Total Estimated Population (Pounds per Person Waste Tonnage Per per Day) Week Cameron 1,231 5.0 21.5 Chinle 8,756 5.0 153.2 Coyote Canyon 957 2.1 7.0 Crownpoint 2,906 5.5 55.9 Fort Defiance 5,754 4.0 80.6 Ganado 3,030 6.3 66.8 Kaibeto 1,970 2.5 17.2 Kayenta 6,315 5.0 110.5 Pinon 3,066 7.3 78.3 Shiprock/Cudeii 9,279 5.0 162.4 St. Michaels/Window Rock 6,147 4.0 86.1 Tuba City 8,736 5.0 152.9 [NOTE: 4.7 is the average waste factor for these communities – Calculation = CPxWF/2000=Nx7=tonnage per week.]

With the exception of Coyote Canyon, which has a Solid Waste Generation Factor of 2.1 pounds per person per day, all of the other communities have much higher waste generation rates, primarily due to the inclusion of schools, hospitals, business and official solid wastes. The waste tonnage are especially increased significantly in communities that have large boarding school populations or have large numbers of commercial enterprises that draw residents from the surround Chapters. The 2000 Census was incorporated by NNEPA in place of the data Jacobson Helgoth Consultants ran for previous 1996 data. Student populations, at boarding schools, can increase the effective community population by as much as one-third. The larger communities generally have larger, central-located schools, in which students are bused in from outlying Chapters. Both of these factors increase the expected volumes of school-generated wastes, when only the official Chapter populations are considered.

The 12 Navajo Chapters listed in Table Nineteen are all directly off of major state and local highways and have neighboring commercial enterprises associated with the community, thereby, increasing the waste factor as shown in the table. The numbers were compared to the localized disposal system and found to be in relation with the tonnage leaving the facilities on a weekly to bi-weekly basis.

Two approaches were taken to estimate the tonnage of waste being generated on the Navajo Nation. The first approach, called the Population Model, was to estimate the waste stream for each of the Chapters by applying a Solid Waste Generation Factor to the 2000 Census data and the 1996 Census data. This provides a comparison on the growth of Navajo Nation, thereby, producing more solid waste. The magnitude of the Solid Waste Generation Factor was adjusted by increasing the value to allow for those communities that have large school populations or significant numbers of commercial establishments. A Solid Waste Generation Factor of 2.1 pounds per person per day was utilized for the rural Chapters with very small schools and limited commercial enterprises. Factors of up to 5 pounds per person per day were used for communities with larger school populations and/or larger numbers of commercial enterprises. A factor of 7.3 was the highest number used for the community of Pinon, Arizona due to the transition of the transfer station, the surrounding communities within close range of this community, and the influence of those surrounding communities. The larger Solid Waste Generation Factors were based upon the results of the community solid waste survey calculations. The factors are utilized in many of the tables developed in this Plan. The second approach to estimating the waste stream was to utilize the field survey data in combination with the census data, school data, residence data, business data and hospitals or clinics to estimate the waste tonnages from each of the sources for each Chapter. NNEPA staff updated the original information provided by Jacobson Helgoth Consultants to provide current statistics. The data was obtained directly from the school districts, and information provided by I.H.S., B.I.A., N.H.A., Navajo Employee Housing, and Navajo Economic Development. Information received from Waste Management and Navajo Sanitation indirectly, demonstrates these commercial solid waste haulers provide service to Navajo Nation at approximately 55% residential, 80% businesses, and 95% for schools. Some businesses are small time operators or vendors and do not have an established waste service, as well as some Headstart schools which do not have contracts.

The Population Model and Chapter Model are included in Appendix II. When the two models are compared for individual communities, the communities that were field surveyed have nearly identical waste flow tonnage because the Solid Waste Generation Factor values were generated by the same mechanism. Table Twenty below compares some communities that have a significant difference in waste generation rates, as estimated by the two different models.

Table Twenty Solid Waste Models – Chapter Comparisons Chapter Population Model Chapter Model (tons/week) (tons/week) Hard Rock, AZ 1,256 9.9 14.2 Leupp, AZ 1,605 14.0 19.0 Nahata Dzill, AZ 1,452 25.4 48.7 Oljato, AZ 2,292 20.1 28.6 Round Rock, AZ 1,292 9.5 14.5 Naschitti, NM 1,695 12.5 16.3 Newcomb/Two Grey Hills, NM 1,838 32.2 11.1 Pueblo Pintado, NM 464 5.7 11.1

In most cases, the Chapter Model waste generation rates are higher than the generation rates developed by the Population Model. All of the Chapters in the above table have sufficient numbers of businesses or large numbers of bussed-in students to result in more waste generated than would be expected by the population data alone. Table Twenty-One compares the total expected weekly solid waste generation for each of the five Agencies of the Navajo Nation. The tonnages of waste indicated by the model calculations shows that the waste generation rates follow Agency population variations with the largest waste tonnages generated in the Fort Defiance/St. Michaels area. For the other Agencies, the estimated waste tonnages mirror population differences. Waste Generation Factors were averaged from all Chapters located within each Agency.

Table Twenty-One Solid Waste Models – Agency Comparison Agency Population Solid Waste – Solid Waste – Population Model Chapter Data Model (tons/week) (tons/week) Chinle 28,491 401 430 Eastern Navajo 35,517 382 403 Fort Defiance 47,213 560 623 Shiprock 30,962 413 408 Western Navajo 38,260 465 486 Totals 180,443 2,221 2,350

Table Twenty-Two shows the distribution of waste types from the Chapter Model for each of the Agencies. Residential waste, which contributes 2221 tons per week is the largest single source of solid waste on the Navajo Nation in the waste stream. Commercial business waste makes up 410 tons per week, and schools contribute 551 tons per week. Hospital and governmental wastes make up the remaining 7,000 tons of waste per week within the waste stream for Navajo Nation.

Table Twenty-Two Agency Waste Stream By Waste Categories (tons/week) Agency School Business Hospital Governmental Residential Chinle 163 91 18 16 159 Eastern 111 402 10 9 216 Ft. Defiance 138 157 19 50 282 Shiprock 102 107 26 6 153 Western 162 90 20 20 223 Totals 676 547* 112 101 1,033 % 27% 22% 5% 4% 42% [*Construction debris is excluded from this total and percentage, and based on the information calculated from construction projects within Navajo Nation in 2001 and 2002, the number of locations, and volume of disposed of debris calculated the tonnage at more than 1 million tons of debris was removed to various landfills for disposal or recycled.]

Table Twenty-One lists the estimated total annual tonnages of individual waste generated in each of the five Agencies, as estimated by the Chapter Data Model. This table also shows the tonnages of waste collected by contracted commercial haulers and the waste collected at various transfer stations on the Navajo Nation and the unaccounted for waste tonnages. Currently, all of the waste collected by the commercial haulers and at the transfer stations, is taken off the Navajo Nation for compliance disposal. The known total tonnage of waste leaving the Navajo Nation is 242,405 tons per year as shown in Table Twenty-Three (residential and transfer station only), in comparison to the estimated population tonnage of 115,493.

Table Twenty-Three Estimated Agency Annual Waste Streams Agency Total Est. Waste Commercial Transfer Unaccounted for Stream /Pop. Pickup Stations Waste (tons/year)* (tons/year)* (tons/year)* (tons/year)* Chinle 20,852 23,712 16,496 15,268 Eastern Navajo 19,859 28,071 17,358 21,545 Ft. Defiance 29,126 39,094 20,126 29,128 Shiprock 21,469 24,514 28,027 26,266 Western 24,187 29,368 15,342 19,004 Subtotal 115,493 145,056 97,349 84,081 Total 115,493 242,405 Tons/Year 84,081 * All amounts are estimated figures based on the 1998 cost factors generated by JH, Inc.

The difference between the total waste stream tonnage and the tonnages of waste collected by commercial haulers and the transfer stations represents the tonnage of waste that is not being collected or brought to the transfer stations. It is assumed that the unaccounted for waste tonnage is either being burned, illegally dumped and/or taken off of the Navajo Nation for disposal. For most Agencies, this unaccounted for waste ranges from 15,000 to 30,000 tons of waste per year per Agency that is shown in the statement above on known and estimated tonnage.

The Shiprock Agency is anomalous because there is more waste deposited at the transfer stations operated by San Juan County, NM than the expected tonnage of waste generated by the waste models. The Shiprock Transfer Station alone receives approximately 17,520 tons of waste per year (Table 11). In comparison, the maximum expected annual tonnage for the entire chapter to the Shiprock Transfer Station, is compared at 8,445 tons per year (Shiprock/Cudeii is estimated at 162.4 tons of waste per week for the populations of both Chapters). The Shiprock Transfer Station is currently free to residents of San Juan County for residential-municipal solid waste. The transfer station will accept commercial waste of less than four (4)- cubic yards per day, without charge. San Juan County, the operator of the facility, does not have a system to screen the identity of individuals bringing waste to the facility. It is unknown how much waste received at the Shiprock Transfer Station is derived from sources outside of San Juan County or is commercial waste disguised as residential waste. It is, however, gratifying to note the willingness of Navajo Tribal members to bring solid waste long distances for proper disposal, if there is not cost for disposal.

Table Twenty-Four compares the annual solid waste tonnages estimated by the four different waste models discussed in this Plan. All four methods are estimates of solid waste generation. The I.H.S. Residential Waste Model results in the smallest predicted tonnage of waste being generated on the Navajo Nation. The Chapter Data Model predicts the largest tonnage of the four estimates and results in a 100 percent increase in predicted waste over the I.H.S. estimate for waste generation. The I.H.S. and New Mexico Council of Government’s Model (Beck) provide a minimum base estimate for solid waste generation on the Navajo Nation, and no current information has been formulated for these two models.

Table Twenty-Four Waste Model Comparison – Annual Waste Tonnage Estimates Agency I.H.S. Model Beck Model Population Chapter Data Model (tons/year) (tons/year) Model (tons/year) (tons/year) Chinle 9,950 11,840 28,491 22,360 Eastern 13,060 15,550 35,517 20,956 Navajo Ft. Defiance 17,595 20,950 47,213 32,396 Shiprock 11,320 13,475 30,962 21,216 Western 14,150 16,847 38,260 25,272 Navajo Totals 66,075 78,662 180,443 122,200

Chapter Data Models are more representative of the solid waste stream on the Navajo Nation because they take into account the extra waste tonnages generated at businesses and schools. The Chapter Data Model tonnages will provide an excellent base for the sizing of facilities necessary to handle the waste stream of the Navajo Nation in the future.

9.0 Off-Reservation Disposal Waste Economics

One of the key concerns of the Navajo Nation that resulted in the initiation of the development of this Plan, is the question of how much solid waste is currently leaving the Navajo Nation and the dollar value of that waste. The establishment of the volume of waste leaving the Navajo Nation is an important factor in planning for future solid waste facilities, to concentrating the waste for continued off-Reservation disposal, or for designing permitted waste disposal sites on the Navajo Nation itself. The dollar value of the waste that is leaving the Navajo Nation is also important in making economic decisions as to what type of facilities/solid waste systems are appropriate for the entire Navajo Nation or only a part of it.

To determine the dollar value of the solid waste leaving the Navajo Nation, the Chapter Data Model commercial hauler and transfer station waste stream tonnages were combined with the landfill tipping charges that were previously identified in the Draft Perimeter Solid Waste Facility Inventory Report. For many of the Agencies, the waste stream is divided between several Off-Reservation landfills. Commercial haulers may take their waste to a different landfill rather than deposit the waste at the transfer stations. For the landfills that do not have scales, the tipping rates were recalculated to put all of the facilities on a dollar per ton basis. Table Twenty-Three summarizes the tipping fee cost estimate for disposal of waste from commercial pickup and transfer stations for the five Agencies of the Navajo Nation. This analysis does not include the cost of pickup and haulage of waste on the Navajo Nation, only the cost of disposing of the waste at its final repository. The estimated landfill disposal costs for solid waste leaving the Navajo Nation is estimated at $7.1 million per year as defined in Table Twenty-Five (Note: It is estimated the Navajo Nation looses approximately $71 million if taking into account construction debris, and the cost associated with rental, taxes, and transportation costs.)

Table Twenty-Five Annual Waste Volume Value Expressed As Landfill Tipping Charges Agency Commercial Transfer Station Total Pickup Chinle $700,690.00 $487,457.00 $1,188,147.00 Eastern $829,498.00 $512,929.00 $1,342,427.00 Fort Defiance $1,155,228.00 $594,723.00 $1,749,951.00 Shiprock $724,389.00 $828,198.00 $1,552,587.00 Western $867,824.00 $453,356.00 $1,321,180.00 Totals $4,277,629.00 $2,876,663.00 $7,154,292.00

The average disposal cost per ton of the plus 100,000 total estimated tons of solid waste generated on the Navajo Nation would be $29.55 per ton.

Quantification of the current costs to pickup and dispose of municipal waste by governmental agencies and commercial facilities is difficult due to the large number of contracts involved. Requests were made to various governmental agencies on the Navajo Nation that contract for municipal waste collection to determine how many dollars are currently being spent for solid waste collection and disposal. Information from the B.I.A., I.H.S., N.H.A., and the Navajo Nation identified $2,981,800.00 in annual waste cost for commercial facilities, governmental agencies and public and private schools were estimated based on the contracts supplied by the various agencies and waste cost information from the collecting entities. The current waste contracting process involves some Reservation-wide contracts, but for many agencies, this process involves contracting on an Agency basis often involving multiple contacts and different collection rates depending on the distance to the final disposal and the number of weekly pickups. The following paragraphs and tables summarize the estimated contacted waste costs for the 2001/2002 for the Navajo Nation.

9.1 Contracted Residential Waste Collection Costs

Of the 42,000 residences on the Navajo Nation, almost 7,400 residences are estimated to have contracted municipal waste pickup. The NHA provides residential waste collection covering 3,573 residential units across the Reservation. The BIA manages over 2,400 residential units. Waste contract cost information was obtained for 70 percent of the contracted residential units. The BIA residential pickup rates were based on typical rates for housing associated with the BIA School contracting process that involves 689 residences. The Navajo Nation Administration (NNA) residential waste costs were based upon one contract in the Window Rock area covering 149 residences. There may be additional residential units that have individual contracts for waste pickup or individual residents units that have individual contracts that is not contracted through a Tribal or Federal Agency. Table Twenty-Six shows the residential waste costs for the primary governmental agencies for all five Agencies on the Reservation.

Table Twenty-Six Annual Contracted Waste Costs For Residential Unit Pickup Agency NHA I.H.S. BIA Navajo Total Nation Western $135,000.00 $67,000.00 $225,000.00 0 $457,000.00 Chinle $118,000.00 $57,000.00 $275,000.00 0 $450,000.00 Fort Defiance $205,000.00 $24,000.00 $125,000.00 $105,000.00 $459,000.00 Shiprock $221,000.00 $12,000.00 $115,000.00 0 $348,000.00 Eastern $113,000.00 $19,000.00 $122,000.00 0 $254,000.00 Totals $792,000.00 $179,000.00 $892,000.00 $105,000.00 $1,968,000.00

9.2 Medical Facilities Contracted Waste Costs

The I.H.S. operates the majority of the medical facilities on the Navajo Nation. The I.H.S. contracts for pickup of municipal waste at each of its hospitals, clinics and residential units associated with those medical facilities. The waste collection costs, for the privately operated hospital Ganado, were estimated, based on the I.H.S. contracts. The medical facilities waste costs are for municipal waste only. Special medical waste costs are not included as they require more rigorous disposal requirements than are allowed for municipal waste and this waste is contracted to specialized disposal firms. Table Twenty-Seven shows the estimated annual costs for the medical facilities waste collection.

Table Twenty-Seven Annual Contracted Medical Facilities Waste Costs

Agency Indian Health Other Medical Total Service Facilities Facilities* Western $71,000.00 0 $71,000.00 Chinle $23,500.00 $12,000.00 $35,500.00 Fort Defiance $19,500.00 0 $19,500.00 Shiprock $35,600.00 $3,000.00 $38,600.00 Eastern $7,000.00 0 $7,000.00 Totals $156,600.00 $15,000.00 $171,600.00

9.3 Schools Contracted Waste Costs

Municipal waste, associated with educational facilities, is a significant volume of the waste stream on the Navajo Nation. As previously indicated, schools are operated by a number of different public and private organizations. The BIA provided contract waste disposal costs for the facilities under its management. BIA contracts are on an Agency basis and includes schools, residences and support facilities. The costs for the school facility waste is clearly identified and this information was used to single out school waste cost the BIA schools. Public and private school waste costs were based on Chapter Images estimates of student enrollment for those 56,000 students attending facilities located on the Navajo Reservation. Students attending public schools in communities, such as Page, Arizona and Gallup, New Mexico, were excluded from this analysis. BIA student enrollment represents 16 percent of the total school enrollment on the Navajo Reservation. BIA school waste costs an average of $51 per student per year. Because many of the BIA schools are boarding facilities and generate higher volumes of waste, it was assumed that the other schools, which also include Headstart schools, would best be represented by a smaller, annual per student cost. Because of the uncertainty about the nature of the other school waste contracts, a conservative average waste cost of $30 per student per year was used to estimate the waste costs for other schools on the Reservation. Table Twenty-Eight shows the estimated waste costs for the BIA and other schools on an Agency basis.

Table Twenty-Eight Annual Contracted School Facilities Waste Costs

Agency BIA Schools Public & Private Total Schools Western $68,000.00 $270,000.00 $338,000.00 Chinle $39,000.00 $267,000.00 $306,000.00 Fort Defiance $111,000.00 $423,000.00 $534,000.00 Shiprock $78,000.00 $194,000.00 $272,000.00 Eastern $175,000.00 $256,000.00 $431,000.00 Totals $471,000.00 $1,410,000.00 $1,881,000.00

9.4 Official/Governmental Facilities Waste Cost Estimates

The costs for collection and disposal at governmental offices and facilities on the Navajo Nation was based on some limited facility waste cost data provided by the BIA and the Navajo Nation. Again, the costs for facility waste disposal are distance and waste frequency dependent. Waste cost analysis indicates that a conservative estimate of $50.00 per ton of waste collected should be used to estimate the costs for this portion of the waste stream. Table Twenty-Nine shows the governmental facilities waste tonnages and costs for each of the five Agencies developed by the Chapter Waste Model.

Table Twenty-Nine Annual Contracted Governmental Facilities Waste Costs

Agency Tons of Waste Per Annual Waste Annual Waste Cost @ Week Tonnage $50 Per Ton Western 19.8 1,029.6 $51,500.00 Chinle 16.2 842.4 $42,100.00 Fort Defiance 49.6 2,579.2 $129,000.00 Shiprock 5.8 301.6 $15,100.00 Eastern 8.7 452.4 $22,600.00 Totals 100.1 5,205.2 $260,300.00

9.5 Commercial Facilities Waste Costs

Estimating the cost for municipal waste collection and disposal for individual commercial facilities is difficult to estimate. Waste disposal firms have been reluctant to discuss collection costs on an Agency-wide basis. Contracts with individual businesses are commonly negotiated on the basis of waste volumes generated, frequency of collection negotiated on the basis of waste volumes generated, frequency of collections, distance to the closest landfill and landfill disposal fees. A 30- to 40-cubic yard container can vary in pickup charges, from $250 to $500 with an additional tipping fee charge between $21 to $50 for landfill disposal. Most waste collection company’s charge, on the basis of the total size of the container regardless of how full it is, at the time of collection. The container’s weight also varies considerably depending on the relative percentage of building materials included in the container. Domestic-type wastes are the lightest per cubic yard in comparison to construction-type waste (i.e., drywall, cement, etc.) that requires very heavy containers. The approach taken to estimate commercial waste collection costs was the same approach used to estimate governmental waste costs. A $50.00 per ton waste collection and disposal cost was used in conjunction with the Chapter Images Waste Model Data to determine an average cost for commercial establishments on the five Agencies on the Navajo Nation. Table Thirty summarizes the commercial waste cost estimates.

Table Thirty Estimated Commercial Waste Costs

Agency Tons of Waste Per Annual Waste Annual Waste Week Tonnage Cost @ $50 Per Ton Western 89.7 4,664.4 $223,200.00 Chinle 91 4,732.0 $236,600.00 Fort Defiance 146.1 7,597.2 $380,000.00 Shiprock 106.7 5,548.4 $277,400.00 Eastern 102.2 5,314.4 $265,700.00 Totals 535.7 27,856.4 $1,392,900.00

In summary, when the estimated waste collection and disposal costs for the five major categories of contracted waste are added together, it is estimated that governmental and private entities are currently spending almost $5,700,000 per year. Residential waste collection and school waste contracts make up almost 68 percent of the total of these contracted costs. Table Thirty-One shows the differences in the five major contracted waste categories and the total for collecting all of these wastes.

Table Thirty-One Summary of Contracted Waste Pickup Costs

Waste Stream Annual Estimated Contracted Waste Costs Contracted Residential Pickup $1,968,000.00 Medical Facilities $171,600.00 Schools $1,881,000.00 Governmental Facilities $260,300.00 Commercial Enterprises $1,392,900.00 Total $5,673,800.00

10.0 Waste Transportation Analysis

The methodology of regional solid waste collection of the various waste sources identified in Section 6.0 of this report can be quantified by establishing the costs the various system used to transport the waste. The following paragraphs will include a review of the existing transportation networks on the Navajo Nation with respect to the locations of the existing collection points and where this waste is taken. The impacts of climate on waste transportation networks on the Navajo Nation with respect to the locations of the existing collections points and where this waste is taken. The impacts of climate on waste transportation will also be discussed. This phase of the solid waste study will use a cost analysis approach to determine infrastructure locations within the Navajo Nation where waste can be centrally collected prior to the transportation to its final disposal destination.

The approach taken for the waste transportation analysis is to combine the results of the waste characterization studies, the costs of operating waste collection vehicles and the transportation distances traveled to estimate waste transportation costs. The unit of measurement selected to characterize waste hauling is the ton-mile cost. The ton- mile cost is the cost of hauling 1 ton (2,000 pounds) of waste one-mile. Tons per mile waste hauling cost were established for the different types of waste-hauling equipment commonly used on and around the Navajo Nation. The waste stream for each Chapter was apportioned for the various types of vehicles that are used to transport the waste. The vehicle-typed waste tonnages for each Chapter were then combined with the waste vehicle costs and the highway transportation distances to estimate a waste transportation cost for each Chapter. The costs for off-Reservation solid waste disposal were compared against the use of centralized Agency collection points and proposed Navajo Nation landfills.

11.0 Transportation Network

As indicated in Section 8.0 that addressed solid waste stream models, waste generation on the Navajo Nation is non-uniform. There are numerous and isolated, low population Chapters that generate very small tonnages of waste.

A large portion of the solid waste tonnage is generated in a small number of Reservation communities, such as Shiprock, New Mexico and Tuba City, Arizona that serves as regional commercial and educational centers. Table Thirty-Two lists the largest waste generation centers on the Navajo Nation. Table Thirty-Two Large Waste Generation Chapters

Agency Community Total Estimated Waste Tonnage (tons/year) Western Tuba City, AZ 8,000 Western Kayenta, AZ 5,000 Chinle Chinle, AZ 7,500 Chinle Pinon, AZ 3,000 Fort Defiance Fort Defiance, AZ 4,600 Fort Defiance St. Michaels/Window Rock, AZ 4,500 Fort Defiance Ganado, AZ 3,300 Shiprock Shiprock, NM 5,400 Eastern Crownpoint, NM 2,700

All of the Chapters that generate larger tonnage of waste, with the exception of St. Michaels, currently have operational transfer stations. The 44,000 tons of waste per year generated in the nine Chapters listed in Table One represents almost 40 percent of the total estimated 129,000 tons of waste generated per year across the entire 110 Chapters of the Navajo Nation.

The transportation system of the Navajo Nation consists of a variable network of roadways ranging in design from multi-lane interstate highways to unimproved, dirt roads. Road design and maintenance responsibilities range from the BIA to the State and County highway organizations. The transportation network on the Navajo Nation was analyzed from the capability of that roadway to handle waste hauling vehicles at highway speeds. Primary highway routes were designated as the all-weather, paved highways capable of handling all sizes of waste vehicles and also do not have excessive grades or curves that would impact waste vehicles and also do not have excessive grades or curves that would impact waste vehicle use or safety. Secondary routes are typically paved roads that would impact waste vehicle use or safety. Secondary routes are typically paved roads that are narrower in width than the primary highways and often require slower highway speeds. Tertiary roads are routes with significant portions of their lengths not being paved and may be subject to closure during periods of inclement weather. Road conditions on many tertiary- classed roads may preclude the use of larger waste hauling vehicles. Improvements to tertiary roads serving solid waste collection facilities would allow the use of more efficient solid waste vehicles and reduce wear on both vehicles and roadways. Appendix III includes additional information with regard to each of the transportation routes selected for waste hauling. Figure Four shows the primary and secondary transportation routes used in this study for the transport of waste on the Navajo Nation. The transportation analysis indicates that 58 percent of the Chapters have solid waste facilities on Secondary or Tertiary transportation routes.

11.1 Primary Transportation Routes

The primary transportation routes are those roads capable of handling all the legal and capable waste carrying transportation systems that are expected to be utilized on the Navajo Nation. Primary transportation routes can handle fully loaded large packet trucks and semi-tractors hauling transfer trailers at speeds sufficient to maximize equipment utilization. The primary routes include three East-West highways and eight North-South routes.

The following list includes the primary transportation routes serving the Nation.

US Highway 89 — Flagstaff, AZ to Page, AZ

US Highway 160/64 — Tuba City, AZ to Shiprock, NM US Highway 666 — Shiprock, NM to Gallup, NM

Interstate 40 — Flagstaff, AZ to Albuquerque, NM

US Highway 191 — Bluff, UT to Chambers, AZ

US Highway 550 — Farmington, NM to Shiprock, NM

New Mexico Highway 371 — Farmington, NM to Thoreau, NM

Arizona Highway 98 — Page, AZ to Highway 160 (Shonto, AZ)

US Highway 163 — Kayenta, AZ to Monticello, UT

New Mexico Highway 550 — Bloomfield, NM to Bernalillo, NM

Navajo Highway 12 — Lupton, AZ to Fort Defiance, AZ

11.2 Secondary Transportation Routes

The secondary transportation routes are typically two-land highways that may not have the design capabilities to handle the larger waste hauling vehicles at highway speeds. Portions of these highways may have grades or curves that result in significant slowing of loaded waste vehicles. Currently, large tonnages of waste are being hauled on these routes.

The following list includes the secondary transportation routes serving the waste transport needs of the Navajo Nation.

Navajo Highway 9 — Twin Lakes, NM to Torreon, NM

Arizona Highway 264 — Tuba City, AZ to Window Rock, AZ

New Mexico Highway 602 — Gallup, NM to Ramah, NM (Via Highway 53) Arizona Highway 77 — Holbrook, AZ to Jeddito, AZ Navajo Highway 15 — Winona, AZ to Ganado, AZ

Arizona Highway 87 — Winslow, AZ to Second Mesa, AZ (Hopi Reservation)

Navajo Highway 12 — Round Rock, AZ to Fort Defiance, AZ

Navajo Highway 59 — Kayenta, AZ to Many Farms, AZ

Navajo Highways 16 & 4 — Forest Lake, AZ to Chinle, AZ

Navajo Highway 221 – Shonto, AZ to Arizona State Highway 98 (upgraded in 2002)

11.3 Tertiary Transportation Routes

The tertiary transportation routes are those roads with significant percentages of their lengths not paved. Maintenance ranges from periodic grading of bus routes to no maintenance at all. The tertiary transportation routes are the most susceptible to closure due to inclement weather. These routes are not designed for use by larger waste haulage vehicles, both from a size standpoint and from increased maintenance costs. The recommended maximum-size waste vehicles to be used on these routes include the smaller packer trucks and/or roll-off trucks. These vehicles will have to operate much slower speed on these roads.

For those Chapters such as Black Mesa, AZ and Casamero Lake, NM, whose population centers are located on the tertiary routes, care must be taken when transfer stations or pickup point locations are being sited to minimize collection interruptions during inclement weather.

11.4 Chapter-Route Summary

The primary highway access routes to each Chapter House were classified using the highway rating system as listed above. The individual Chapter classifications are included in the Appendix of this report. Forty-two percent of the 110 Chapters are located on primary highway routes, 39 percent of the Chapters are on secondary highway routes and 19 percent of the Chapters are on tertiary routes. Of the nine Chapters that have waste generation rates of over 50 tons per week, only the Pinon Chapter, Pinon, Arizona is located on a secondary transportation route. Other large waste generating Chapters are located on primary transportation routes.

Chapters with moderate-sized waste generating tonnages (20 to 50 tons per week), such as Lukachukai, Tsaile, Red Mesa, and Dilkon, Arizona; Tsayatoh and Ramah, New Mexico, and Oljato and Aneth, Utah are located on secondary transportation routes. Some of the smaller, isolated Chapters that are located on tertiary routes include Navajo Mountain, Coppermine, Black Mesa, Hard Rock, and Shonto, Arizona; and White Rock, New Mexico. For many Chapters, the current collection point is not located at the Chapter House. The Eastern Navajo Agency transportation analysis shows that the Huerfano Chapter House, Huerfano, NM is located on a tertiary route; however, the current primary collection transfer station is located adjacent to a primary transportation route.

11.5 Climatic Impacts on Transportation

The climate on the Navajo Reservation ranges from arid to semi-arid. Summer temperatures rarely exceed 100ºF and winter temperatures can occasionally fall below 0ºF. Because of the considerable differences in altitude between the valleys and mountain areas, annual precipitation can range from the lows of eight to 10 inches per year in the valleys to 12 to 17 inches per year in the mountainous areas.

Snowstorm events can occur from November through April and annual totals can range from 18 inches in the lower areas to over five feet in the Chuska Mountains and Defiance Plateau areas. Many tertiary-classed roads also become impassable during the snowfall melt periods and during spring thaw.

Point-storm thundershowers associated with summer monsoon moisture are the source of 70 percent of the annual precipitation totals for most of the Navajo Nation. Summer thunderstorms are most common in July and August and can result in one to two inches of moisture falling in a matter of hours. Thunderstorms do not usually impact primary transportation routes unless hail is present or flash floods result in localized flooding of roads. The thunderstorms and snowmelt have the greatest impact on the non-paved, graded roads, especially those built on mudstone or shale. Often after a severe storm or a series of storms, some of these roads will become impassable for up to a week. Any solid waste planning that involves Chapter will collection points on tertiary-classed roads, should allow for sufficient waste storage for a two- to three-day interruption in waste hauling service due to weather-related interruptions.

12.0 Solid Waste Vehicle Transportation Costs

In order to quantify the transportation of waste on the Navajo Nation and to provide a common denominator for evaluating alternative waste collection and transportation plans, it was determined that costs need to be established to haul one ton of waste of one mile (2000 pounds per mile). The initial approach taken to quantity the costs of transporting waste was to establish the purchase and operational costs of the various waste transport systems used on the Navajo Nation. The Chapter Data Waste Model information was used to divide the various portions of waste stream from collection points at each Chapter. The bulk of the waste collected at the transfer stations, collections points, hospitals and some larger businesses is deposited in 30-cubic yard waste containers that are transported off of the Navajo Nation by roll-off trucks. Most residential, business, school and governmental waste is picked up by large or small packer trucks for delivery to landfills off of the Navajo Nation.

Four different waste transportation systems were selected for analysis. On the Navajo Nation, the most common waste transport systems are the smaller waste collection packer trucks that are primarily used for residential pickup. These two-axle vehicles can either have rear or side deposit and can hold up to 20-cubic yards of waste and normally require two-man crews. Large, three-axle packer trucks with hydraulic lift systems are used to empty the five- to eight-cubic yard metal containers. The larger packer trucks, operated by one man, are used to service dumpster-containers most often used by commercial establishments, schools, hospitals, and governmental agencies on the Navajo Nation. The larger packer trucks commonly hold 24-cubic yards of waste and have the capability for two-to-one compaction of waste.

The 30- and 40-cubic yard roll-off containers, commonly used at transfer stations and collection points, are picked up with three-axle roll-off trucks. The roll-off trucks, with a single operator, are used to collect the larger containers used at transfer stations, larger businesses, schools, hospitals and governmental institutions and haul this waste directly to the landfills. These trucks can also pick up containers from compactor systems.

Costs were also developed for the larger semi-truck and trailer-transfer trailer combination systems similar to those used by the NWNMRSWA to haul waste from its two centralized transfer stations to the Red Rocks Regional Landfill. Transfer trailer systems require larger constructed facilities with “live” or “walking” floors are self-unloading systems. Transfer trailers can carry 110-cubic yards of waste and are efficient waste handling systems when larger volumes of waste have to be hauled longer distances.

The initial step used to establish costs for the four waste-hauling systems was based on a telephone survey of equipment suppliers to establish new vehicle costs. Vehicle purchase was assumed to be cash with a 5.5 percent sales tax. No property tax or license fees were assigned to these vehicles. Daily mileage and driver compensation rates were adjusted for the region. The diesel fuel rate was set at $1.50 per gallon. Daily maintenance costs were supplied by equipment suppliers and compared with costs incurred by the Authority in the maintenance o its waste hauling equipment. The fixed cost per mile represents the purchase price of the waste vehicle spread over its expected lifetime. Ton-mile costs were based on a vehicles round-trip with only one leg of the trip having the vehicle fully loaded. The cost analysis for the four waste systems is included in Appendix III of this Plan. The results of the cost analysis of the four different hauling systems are shown in Table Thirty-Three.

Table Thirty-Three Waste Transport System Cost Analysis (Dollars) Residential Commercial Roll-Off Box Semi/Transfer and Truck Packer Truck Packer Truck Trailer New Cost $100,000.00 $165,000.00 $106,000.00 $195,000.00 Fixed 0.427¢ 0.491¢ 0.269¢ 0.380¢ Cost/Mile Fuel Cost/.Mile 0.300¢ 0.300¢ 0.250¢ 0.250¢ Maintenance 0.158¢ 0.140¢ 0.121¢ 0.141¢ Cost/Mile Crew Cost/Mile $1.413 $1.060 0.509¢ 0.424¢ Total Cost/Mile $2.298 $1.990 $1.148 $1.194 Cost/Ton-Mile 0.657¢/ton/mile 0.362¢/ton/mile 0.209¢/ton/mile 0.140¢/ton/mile (Round-Trip) NOTE: CPI may change rates to +/- 5%.

The cost analysis indicates that the smaller, residential-sized packer truck is the most expensive to operate even though it is the cheapest to initially purchase. The costs for the smaller, packer truck are increased because of the need for a two-man operating crew and the shorter distances one of these waste systems can travel in a day. The time necessary to empty the waste containers into the truck and the short distances traveled between stops also increase the ton-mile costs for this system. The roll-off box and the semi/transfer trailer systems are more cost effective from a ton-mile standpoint than packer trucks. Waste haul trips, using roll-off and transfer trailer systems, are usually made for higher highway speeds with point-to-point trips.

13.0 Waste Haulage Cost Models

In order to compare different waste collection and haulage alternatives, it was necessary to quantify the costs associated with the current and alternate collection systems. Four different waste haulage scenarios were developed for determining the waste haulage costs for the Chapters that comprise the five different Agencies on the Navajo Nation. The alternative waste collection systems analyzed in this Plan are designed to concentrate the waste tonnages near the larger waste generating centers on the Navajo Nation. For the most part, each Agency has one or two centers of population and increased waste generation. For modeling simplicity, it is assumed that each Agency is a stand-alone entity and waste would be concentrated at or near the population center of that Agency for later haulage to a landfill. In actuality, there are some Chapters where the nearest waste tonnage center is in a different Agency. This type of analysis does result in some backhaul situations that locally increase waste transportation costs.

The goal of the analysis of the modeled alternative systems was to determine what overall system of waste transportation would result in the lowest transportation costs. For the waste tonnages modeled, only the waste currently being picked up or delivered to transfer stations is being considered in these analyses. The transportation cost analysis of the transportation alternatives presented in this report does not consider the cost of construction of central transfer stations or landfills on the Navajo Nation. The complete compilation of Chapter waste tonnages, ton-mile and transportation cost estimates for this model is included in Appendix III of this Report. The following paragraphs describe the four different waste collection scenarios.

13.1 Existing Collection System

Costs were estimated for the current off-Reservation waste haulage scenario where solid waste from the individual Chapters is transported to landfills off-Reservation. Commercial, school, hospital, and official waste is picked up by commercial haulers and taken off-Reservation for disposal. Transfer station waste is hauled in roll-off boxes operated by the County or commercial firms. Some of the Chapters in the Western, Chinle, and Fort Defiance Agencies have some of the longest distances for waste to be hauled. In these western Agencies, typical one-way waste hauls can be from 75 to 100 miles. The haulage distance from a Chapter to a landfill was based on the mileage distance to the nearest permitted landfill. In some cases waste is currently hauled longer distances to permitted landfills due to relationships between the hauling and disposal entities. Table Thirty-Four summarizes the weekly ton-miles of waste and estimated waste transportation costs for waste hauled off-Reservation for each Agency on the Navajo Nation.

Table Thirty-Four Total Agency Waste Hauled Off-Navajo Nation Agency Total Weekly Waste Ton- Total Weekly Cost Miles (Dollars) Chinle 29,032 $9,853.00 Eastern Navajo 30,567 $11,469.00 Fort Defiance 29,612 $11,186.00 Shiprock 24,597 $7,127.00 Western 10,816 $4,093.00 Navajo Totals 124,634 $43,728.00

The waste totals and weekly costs for the Western, Chinle and Fort Defiance Agencies are very similar. The lower costs estimated for the Shiprock Agency are primarily due to the large volume of waste hauled from the Shiprock transfer station by roll-off box truck systems. The lower waste tonnages and costs for the Eastern Agency are due to part to smaller populations in this Agency and the closer proximity to the Red Rocks Regional Landfill reducing ton-mile haulage.

13.2 Central Transfer Station to Off-Reservation Landfill Model

The second model assumes that the waste from the various Chapters within each Agency is brought to one or two central transfer stations where the waste can be concentrated and then transported via transfer trailers to off-Reservation landfills for final disposal. This model would eliminate the need for packer trucks and roll-off to leave the Agency. The central transfer station would involve the construction of a two-story facility where waste can be deposited on an upper floor tipping surface for inspection and sorting prior to the waste being loaded into a transfer trailer positioned on a lower level. This model assumes that roll-off trucks collecting waste from the area around the central transfer station would empty roll-off boxes at the stations instead of hauling directly to a landfill. Figure Five shows the locations of the proposed central transfer stations and the Chapters whose waste will be directed to each of the central stations.

For the Western Agency, central transfer stations were located at Tuba City and at Kayenta, the centers of the highest waste generation. The waste collected at the Tuba City station would then be hauled 68 miles to Flagstaff’s Cinder Lake Landfill. Waste from the Kayenta station would be hauled 76 miles to the White Mesa Landfill in San Juan County, Utah. For the Chinle Agency, one central transfer station would be located at Chinle. Waste from the Chinle station would then be hauled 100 miles North to the White Mesa Landfill. For the Fort Defiance Agency, central transfer stations would be located at Ganado and at St. Michaels, AZ. Fort Defiance Agency waste generated East of the Defiance Plateau would be concentrated at the St. Michaels facility and then hauled 66 miles East to the Red Rocks Regional Landfill located Northeast of Thoreau, NM. Waste generated West of the Defiance Plateau would be concentrated at Ganado and then hauled 98 miles to the Painted Desert Landfill located immediately North of Joseph City, AZ.

For the Shiprock Agency, central transfer stations would be located at Shiprock, NM and Mexican Water, UT. Waste from the Chapters in New Mexico would be funneled through the Shiprock station and then hauled 37 miles East to the Crouch Mesa Landfill, located East of Farmington, NM. Chapter waste generated in the Arizona and Utah portions of the Agency would then be concentrated at a central collection point at Mexican Water and then transported 35 miles North to the White Mesa Landfill. The Mexican Water facility, Mexican Water could also be located at Red Mesa, AZ.

Because of its large aerial extent and road network, waste from the Eastern Navajo Agency would have to be directed to three separate central transfer stations. Waste in the East central portion of the Agency would be concentrated at a Crownpoint station and then hauled 23 miles South to the Red Rocks Regional Landfill. Eastern Agency Chapters located in the Gallup area would have their waste hauled to the St. Michaels station. The downside of this scenario would be the necessity of hauling waste on the busy Highway 666 corridor through Gallup, NM. Waste in the northern part of the Agency would be taken to a central station at Huerfano, NM where it would be hauled 27 miles Northwest to the Crouch Mesa Landfill. Waste generated at the Tohajiilee and Alamo Chapters would not be part of this system because of the distance from the central transfer stations. Tohajiilee is approximately 20 miles from the Cerro Colorado Landfill.

Table Thirty-Five summarizes the weekly ton-miles of waste and estimated waste transportation costs for waste hauled to Agency central transfer stations and then hauled off-Reservation.

Table Thirty-Five Total Agency Waste Hauled to Central Transfer Stations and to Off- Navajo Nation Landfills Agency Total Weekly Waste Total Weekly Cost Ton-Miles (Dollars) Chinle 33,660 $6,042.00 Eastern Navajo 15,594 $3,663.00 Fort Defiance 38,983 $7,604.00 Shiprock 30,153 $5,406.00 Western 34,162 $6,514.00 Navajo Totals 124,634 $29,229.00

13.3 Central Transfer Station to Navajo Nation Landfill Model

The third waste transportation cost model would involve the construction of central transfer stations at the same locations as indicated in the second transportation model, but the final destination for the waste would be new permitted RCRA Subtitle D landfills located on the Navajo Nation. The hypothetical Agency-centered landfills that were used for this model were based solely upon their proximity to large waste generating areas to minimize ton-mile waste hauling costs and their proximity to primary transportation routes. The proposed landfill locations are not based upon any site-specific factors that would influence their acceptability from a RCRA compliance standpoint. Figure Six shows the locations of the transportation-centered landfills and the Chapters whose waste will be directed to these waste depositories.

Fort the Western Agency, a landfill was assumed to be located between Tuba City and Kayenta, AZ the two main waste generation centers, near the junction of U. S. Highway 160 and Arizona State Highway 98 in the Shonto Chapter. The Western Agency Landfill would also be reasonably close to the Kaibeto area and potentially serve as a destination for waste generated off-Reservation in the Page, AZ area.

For the Chinle Agency, the modeled landfill was located south of Chinle, near the junction of Navajo Highway 4 and U. S. Highway 191. The Chinle Agency Landfill would be the destination for waste generated at the proposed Chinle and the Ganado central transfer stations. It was determined it would be more advantageous to haul waste from Ganado to the Chinle area than to the Window Rock area because the transfer trailer trucks would not have to haul waste over the Defiance Plateau. A landfill located south of Chinle would also provide a local waste destination for Chapters in the Pinon area along Navajo Highway 4.

In the Fort Defiance Agency the bulk of the waste is generated in the Fort Defiance, St. Michaels and Window Rock area. To serve this area, a hypothetical landfill was located a few miles east of Window Rock adjacent to Arizona Highway 264. The location of a landfill in this area would provide a close destination for waste generated in the Fort Defiance and St. Michaels areas as well as adjacent Chapters in the eastern Fort Defiance Agency and Chapters in the westernmost portions of the Eastern Agency.

In the Shiprock Agency, the bulk of the solid waste is generated in the Shiprock Chapter. A hypothetical landfill was located within five miles of the existing transfer station. A landfill in this area would reduce waste hauling mileage to the Crouch Mesa Landfill, located 37 miles east of Shiprock or to the Montezuma County Landfill located 38 miles north of Shiprock.

No new landfills were projected for the Eastern Agency because the existing Red Rocks Regional Landfill is well located in close proximity to Crownpoint and a number of Chapters in the Thoreau-Baca area. Table Thirty-Six summarizes the weekly ton-miles of waste an estimated waste transportation costs for waste hauled from Agency central transfer stations to Navajo Nation Landfills.

Table Thirty-Six Total Agency Waste Hauled to Central Transfer Stations and to Navajo Nation Landfills Agency Total Weekly Waste Ton- Total Weekly Cost Miles (Dollars) Chinle 9,580 $4,962.00 Eastern Navajo 11,495 $3,090.00 Fort Defiance 15,500 $4,317.00 Shiprock 12,461 $5,069.00 Western 23,074 $4,962.00 Navajo Totals 72,110 $20,109.00

13.4 Chapter Waste Directly to Navajo Nation Landfills

The fourth waste transportation model considers waste hauled directly from individual Chapters to an Agency-sized landfill or a close-proximity off-Reservation landfill. This model would allow the cost comparison with the third transport model without the costs of transfer stations and transfer trailers. Waste would be hauled from the current transfer stations and collection points as well as businesses, schools, hospitals and governmental agencies using the packer and roll-off trucks to haul waste directly to the local permitted Navajo landfill. The landfills used for this model were the same facilities used in Model No. 3. Table Thirty-Seven summarizes the weekly ton-miles of waste and estimated waste transportation costs for waste hauled from Agency Chapters directly to the Navajo Nation Landfills.

Table Thirty-Seven Total Agency Waste Hauled from Chapters to Navajo Nation Landfills Agency Total Weekly Waste Ton- Total Weekly Cost Miles (Dollars) Chinle 7,241 $2,757.00 Eastern Navajo 9,039 $3,406.00 Fort Defiance 15,846 $6,163.00 Shiprock 11,467 $3,580.00 Western Navajo 19,267 $7,929.00 Totals 72,110 $23,835.00

13.5 Summary of Transportation Cost Model Analysis

When the ton-mile and transportation cost data is summarized for the five separate Agencies of the Navajo Nation, the differences between the four separate waste hauling scenarios are clearly illustrated. Table Thirty-Eight summarizes the four separate waste transportation models and the annual ton-mile estimates for each Agency.

Table Thirty-Eight Annual Agency Waste Transportation Tonnages (Ton-Miles) Agency Model 1 Model 2 Model 3 Model 4 All Waste Waste to CTS – Waste to CTS Waste to Off-Nation – Navajo Navajo Off-Nation Landfill Landfill Chinle 1,590,000 1,750,000 498,000 377,000 Eastern 560,000 810,000 598,000 470,000 Fort 1,540,000 2,030,000 806,000 824,000 Defiance Shiprock 1,280,000 1,570,000 648,000 596,000 Western 1,510,000 1,780,000 1,200,000 1,001,000 Totals 6,480,000 7,940,000 3,750,000 3,268,000

The current waste hauling system generates almost 6.5 million ton-miles each year for the entire Navajo Nation. The greater the distance the waste has to be hauled in the Western Agencies results in the largest ton-mile generation. The Eastern Navajo Agency has the smallest ton-mile waste generation. Hauling waste to the central transfer stations and then transporting waste outside the Navajo Nation, as shown in the second model, results in increasing the annual ton-mile estimate to just below eight million ton-miles. This increase is due to increases in distances hauled to the central collection points and continuing the long hauls to the off-Reservation landfills. When landfills are placed on the Navajo Nation, in close proximity to major waste generation areas, the annual ton-mil numbers are reduced to less than four million ton-miles. The lowest annual ton-mile numbers are generated where wastes are hauled directly to local landfills from individual Chapters.

When transportation costs for the four primary waste transport systems are applied to the waste ton-mile figures, a different result is produced. Comparisons of the total transportation costs for the four different modeled scenarios indicate there is an opportunity to achieve significant transportation cost savings by concentrating the waste near the larger waste generating areas and eliminating the need to haul waste off the Navajo Nation. Table Thirty-Nine summarizes the waste transportation costs for each of the five Agencies of the Navajo Nation.

Table Thirty-Nine Annual Agency Waste Model Transportation Costs (Dollars) Agency Model 1 Model 2 Model 3 Model 4 All Waste Waste to CTS – Waste to CTS Waste to Off-Nation – Navajo Navajo Off-Nation Landfill Landfill Chinle $596,000.00 $314,000.00 $139,000.00 $143,000.00 Eastern $213,000.00 $191,000.00 $161,000.00 $177,000.00 Fort $587,000.00 $395,000.00 $224,000.00 $320,000.00 Defiance Shiprock $371,000.00 $281,000.00 $152,000.00 $186,000.00 Western $512,000.00 $339,000.00 $258,000.00 $412,000.00 Totals $2,279,000.00 $1,520,000.00 $934,000.00 $1,238,000.00

This analysis indicates that the use of roll-off box and transfer trailer waste systems to haul waste longer distances can significantly reduce the higher ton-mile costs produced when packer trucks haul waste similar distances. Of the four model cases, the current method of hauling waste to landfills off the Navajo Nation is the most expensive option. The use of central transfer stations and continuing to haul waste off-Reservation would realize projected savings of $789,000.00 per year or 33 percent over the cost of the current system. Hauling waste directly from individual Chapters to Navajo Nation Landfills, with the current system of transfer stations and collection points, would realize a projected annual savings of $1,041,000.00 or 46 percent. The greatest projected reduction in transportation costs would be realized through the use of a combination of central transfer stations and local Navajo Nation Landfills. The central transfer station/Navajo Landfill model project would incur an annual savings of $1,345,000.00 or 59 percent over the current waste hauling system.

The use of the low-cost transfer trailer system in the combination station/Navajo Landfill model is the one factor that significantly reduces transportation costs for this model.

14.0 Facility Optimization

For the waste models utilizing either central transfer stations or Navajo Nation Landfills, an analysis of the expected waste tonnages to be handled under the current scenarios and the maximum expected tonnages is important in developing costs for these systems. Table Forty lists the projected weekly and annual tonnages to waste that are expected to be handled by each of the central transfer facilities that were discussed in Model Numbers Two and Three.

Table Forty Central Transfer Stations – Estimated Current Waste Tonnages Central Transfer Waste Tons Per Waste Tons Per Station Week Year Tuba City, AZ 237 12,234 Kayenta, AZ 145 7,540 Chinle, AZ 283 14,716 Ganado, AZ 124 6,448 St. Michaels, AZ 356 18,512 Shiprock, NM 566 29,432 Mexican Water, UT 67 3,484 Crownpoint, NM 132 6,864 Huerfano, NM 54 2,808 Totals 1,964 102,128

It is important to identify the expected waste tonnages for the central transfer station as this is one of the critical parameters needed to be able to properly size and design this type of waste handling facility. Only the current waste hauled by commercial and governmental agencies was considered in this transportation cost analysis. Additional waste capacities will need to be used in planning and designing these systems. Each of the facilities should have a sufficient capacity to handle an additional 50 percent of the waste stream in order to handle future waste growth, seasonal waste generation events or temporary storage in the case of inclement weather closing primary transportation routes. In some cases, additional waste from outside the Navajo Nation could be hauled to a central waste facility. In the case of the Kayenta station, waste from the Page, AZ community could be added to the current waste projections. Table Forty-One shows the design capacities that should be planned for each of the central transfer stations.

Table Forty-One Central Transfer Stations – Waste Capacity Estimates Central Transfer Waste Tons Per Waste Tons Per Station Week Year Chinle, AZ 425 22,000 Crownpoint, NM 200 10,400 Ganado, AZ 200 10,400 Huerfano, NM 75 4,000 Kayenta, AZ 250 13,000 Mexican Water, UT 100 5,300 Shiprock, NM 850 44,000 St. Michaels/Window 550 28,600 Rock, AZ Tuba City, AZ 360 18,500 Totals 3,010 156,200

Transportation cost for Model Numbers Three and Four would require the construction of four new landfills on the Navajo nation and the continued use of three landfills off-Reservation that are not owned by the Navajo Nation. Table Forty-Two shows the expected weekly and annual tonnage of waste to be deposited at these landfills.

Table Forty-Two Navajo Nation Landfills – Expected Waste Tonnages Landfill Waste Tons Per Waste Tons Per Week Year Chinle Agency 407 21,164 Fort Defiance Agency 356 18,512 Shiprock Agency 687 35,724 Western Navajo Agency 382 19,864 Cerro Colorado Landfill 10 520 Red Rocks Regional 132 6,864 Landfill Socorro County Landfill 8 416 Totals 1,982 103,064 In order to provide an estimate of the size and capacity of the landfills that may require construction on the Navajo Nation, capacity and size calculations were made for the Navajo landfills using the above listed expected waste tonnages and the following assumptions:

• Fifty percent (50%) increase in annual capacity for unaccounted-waste and future growth. • Waste compaction of 1,250 pounds per cubic yard. • Daily and final cover material will make up 25 percent (25%) of landfill volume. • Average depth of waste will be 30 feet. • Twenty-year (20) landfill life.

Table Forty-Three shows the calculated annual capacities and the 20 year basic landfill footprint sizes for the four Navajo Landfills that would be needed to handle waste derived from the centralized transfer stations or waste that is hauled directly from the Chapters to these landfills.

Table Forty-Three Proposed Navajo Nation Landfills Capacity Estimates Landfill Estimated Annual Twenty Year Capacity (Tons) Facility Size (Acres) Chinle Agency 32,000 26 Fort Defiance Agency 28,000 23 Shiprock Agency 54,000 45 Western Navajo Agency 30,000 25

15.0 Solid Waste Infrastructure Costs Background

In the preceding paragraphs, the waste transportation studies compared the existing system of transporting waste off the Navajo Nation to a system of centralized collection points and local solid waste landfills. The transportation cost analysis indicated that significant cost savings could be realized by concentrating the waste streams near the larger sources of waste then hauling this solid waste a relatively short distance to a permitted Navajo Landfill.

The next step in the Comprehensive Solid Waste Management Plan is the determination of the most-cost effective, environmentally sound method for the final disposal of solid waste generated on the Navajo Nation. The solid waste infrastructure cost analysis involves the determination of the costs of permitting, designing, constructing and operating solid waste infrastructure facilities on the Navajo Nation and the comparison of these costs to the previously outlined waste collection and disposal models. Costs would be developed for several different sizes of central transfer stations and landfills appropriate for the expected range of Agency- sized solid waste generation. The waste transportation cost data developed for the various Agencies on the Navajo Nation would be combined with the infrastructure costs to provide an economical basis for decisions regard the implementation of permanent solid waste gathering and disposal facilities. Only the waste stream, as generated on the Navajo Nation, was considered for this analysis.

The short- and long-term infrastructure needs will be determined. Included will be estimates of infrastructure costs (capital costs), equipment, staffing and other costs related to the handling and disposal of the solid waste. Based upon these costs, a cost model showing annual costs, cost per ton, etc., will be developed. Included in the analysis will be a discussion on the employment opportunities that may be created as a result of the handling and disposal of the waste. Costs are assumed to be either entirely borne by the Navajo Nation for simplicity of analysis, or to the business entity that would implement a compliance landfill within Navajo Nation. In actuality, cost sharing should continue between some of the local governmental entities and that should help reduce construction or operational costs.

The following flow chart provides the necessary step-by-step information with associating costs to implement a compliance landfill within Navajo Nation, either as an Navajo Nation enterprise or by separate business entities who wish to undertake the permitting, and all regulatory requirements as established under the Navajo Nation Solid Waste Act and Regulations necessary to gain a compliance landfill, and fulfill the technical requirements as established for any RCRA Subtitle D permitted compliance landfill.

New Landfill Process Under Navajo Nation Solid Waste Act and Regulations Initiated by Individual(s) or Business Entity

Siting Land Withdrawal Public Meetings and Requirements for Completed Hearings as required land as defined Under Navajo under the Navajo Nation under Part IV, Nation L aw with Solid Waste Act as stated Section 402 Supporting under Subchapter 4, Resolutions Section 405

Appropriate Geo- Permit Application as stated under Navajo Sufficient hydrologic Surveys Nation Solid Waste Act, Subchapter 4, Sections Review Period and Testing to Qualify 401, 402, 403, 404, and 405; and Navajo Nation and Public Siting Requirements = Solid Waste Regulations, Part II, Section 202. Comments $75,000.00 to Permit Required; and Part V, Permit $150,000.00 Requirements for Solid Waste Landfill Facilities, Section 501, 502, 503, 504, 505, 506, 507, 508, and 509 = $50.00 for permit

Entity must demonstrate appropriate business plan, financial responsibility, and commitment to seek USEPA Permitting which incorporates all regulatory requirements to satisfy the Navajo Nation Solid Waste Act and Permit Application Overall Regulations 258; as stated under Part Completion and Permit IV, Standards for Solid Waste Landfill Filing Fee = $1,000.00 Approval by Facility, Sections 401, 402, 403, 404, all Parties 405, 406, and 4 07; and Par t VI, Financial Responsibility for Owners and Operators of Solid Waste Landfill Facilities, Sections 601, 602, 603, 604, 605, 606, and 607, and technical support/guidelines as stringent as RCRA Subtitle D landfill requirements.

Permit Application Review by Navajo Nation Submittal and copy of Environmental USEPA Permit Protection Agency application to NNEPA for rev iew with Executive Director Navajo Nation permit

Approval Process Enacted for 60 days review as stated in the Navajo Nation Solid Waste Act

Disapproval Due to Approved with Inadequacy with all or without Applicable Regulations Modifications and Laws

Bonding for Facility

@ $1.5 END million or more

Begin construction of designated transfer Work with station or landfill facility with all Navajo regulatory aspects at a cost of $9.8 million Nation on to include an operating budget of $3.8 Solid Waste million dollars startup Authority

App ly RCRA Subtitle D landfill technical standards in construction to equal or better Modification engi neering and monitoring applications. Since the NNSWR has the permitting process necessary for and other landfill guidelines. Closure cost is Permit considered at $6.3 million.

See Section 16.0 of this Plan

16.0 Infrastructure Cost Analysis

In order to be able to compare the solid waste transport and infrastructure alternatives discussed in Section 13.0, design, construction and operational costs must be established for the central transfer stations and landfills that may be required to be constructed on the Navajo Nation. Based upon the differences in waste tonnage generated from the various Chapters, JHC determined that three different-capacity designs, ranging from 250 to 850 tons per week, could handle the expected waste tonnage for those Chapters selected as centralized collection points.

JHC used its own solid waste facility economic model to develop costs for the proposed solid waste infrastructure improvements discussed in this report. The JHC solid waste facility economic model is a PC-based spreadsheet analysis tool that has the capability to identify the significant components of solid waste infrastructure and waste transport and to generate both annual and capital costs.

This tool is also sensitive to operation and maintenance costs, salaries and benefits and financing mechanisms. The economic data analysis can be used to develop costs for both transfer stations and solid waste landfills. The complete Volume II, Appendix IV of this report. Because of the many variables governing Reservation landfill tipping fees would remain constant. It is assumed that if the Navajo Nation were operating its own solid waste collection and disposal system, it would be under the same economic constraints as contracted hauler parallel each other. This cost analysis also assumes that the total costs for collection, transport and disposal would be borne b the Navajo Nation for cost comparison purposes. It is uncertain how the waste cost sharing arrangements with other governmental entities, such as Coconino County, Arizona and San Juan County, NM would continue if the Navajo Nation took over total operation of the waste system. Undoubtedly, if these entities were included on the Authority Board, some operational monies would be available to reduce the total waste collection and transport costs.

The following paragraphs describe the assumptions made with regard to the design and cost of these facilities.

17.0 Central Transfer Station Construction and Operational Costs

Three different sized central transfer station designs were considered to handle the various waste tonnages predicted by the waste stream analysis. The largest station would be designed to handle 850 tons of solid waste per week, which is the size of the facility necessary to handle the expected waste at the proposed Shiprock and Fort Defiance Agency central transfer stations. The medium-sized transfer station would be designed to handle a maximum of 500 tons per week and this design could be used at Tuba City and Chinle. The smaller transfer station design, which can handle up to 250 tons of waste per week, would be used for centralized waste collection at communities such as Kayenta, AZ, Ganado, AZ, Crownpoint, NM, Huerfano, NM, and Mexican Water, UT. Cost analyses were prepared for the pre-development expenses, design, construction and operation for these facilities. The facility costs were based on a twenty-year operating life and are complaint with Navajo Nation Solid Waste Regulations. Equipment is based on a seven-year life. Monies were allocated for equipment replacement and building maintenance. The complete cost analysis for the three separate transfer station designs are included in Appendix III of this Report.

Table Forty-Four shows the capacities, building size and the minimum facility area expected to be required for the three different transfer station designs. Table Forty-Four Central Transfer Station Parameters Transfer Capacity Building Size Facility Station (Tons/Week) Footprint Large 850 150’ x 150’ 600’ x 600’ Medium 500 100’ x 150’ 500’ x 500’ Small 250 75’ x 150’ 400’ x 400’

The transfer stations would be designed as two-story structures, with waste being deposited by private vehicles, packer trucks and roll-off boxes on the upper tipping floor. A lower level bay would be required so that transfer trailers could be loaded by gravity from the upper tipping floor. The tipping floor and building foundations would be constructed of reinforced concrete. The upper skin of the transfer station would be constructed of sheet metal covering a steel frame. The facility would be enclosed to prevent scattering of waste by wind, keep the waste dry and provide a more esthetic appearance for the facility. Ideal locations for the two-story transfer stations would be on areas of sloping ground, which would reduce the need for more extensive site work, that are necessitated by transfer stations located on flat terrain. For this cost analysis it was assumed that transfer stations would not be charging on a tonnage basis and the stations were designed without scales. The facility would be fully fenced, with locked gates to maintain security when the facility is closed.

It is anticipated that the transfer facilities would be open six days per week. Personnel requirements would require a minimum of three personnel: An operator and two assistants. The operator would oversee operations and coordinate waste hauling by the transfer trailer systems. It is uncertain at this time if disposal fees would be collected at these facilities or not. Two assistant operators would be required to direct customers to unloading locations, inspect waste, operate the equipment used for loading the transfer trailers and maintain facility cleanliness. Transfer stations would also require the purchase of a backhoe or skid-steer loader to handle waste on the tipping floor and help load the transfer trailers. The facility would also need one pickup truck for personnel transport and general use requirements.

No costs were assigned for land acquisition, but costs for Environmental Site Assessments, archaeological and threatened and endangered species surveys, traffic studies and RCRA facility permitting were included in the cost estimates. Engineering fees and contingency costs were set at a very conservative ten percent (10%) of the facility cost. Legal and administrative costs were estimated at five percent (5%) of the facility cost. The transfer station was assumed to have a 20-year life. Vehicles were assumed to have a seven-year life and replacement costs for the vehicles were included in the operational budget. Table Forty-Five summarizes the primary costs for construction of the three different transfer station designs and Table Forty-Six summarizes the annualized construction and operating costs for these facilities. Table Forty-Five Central Transfer Stations – Construction Costs Cost Item 850-Tons/Week 500-Tons/Week 250-Tons/Week Transfer Station Transfer Station Transfer Station Pre-Development $183,700.00 $183,700.00 $183,700.00 Design and $1,387,920.00 $1,187,000.00 $1,073,040.00 Construction Equipment $100,000.00 $100,000.00 $100,000.00 Replacement Total Costs $1,671,620.00 $1,471,340.00 $1,356,740.00 NOTE: CPI may change rates +/- 5%. In comparison the McKinley County Transfer Station, operated by the NWNMRSWA, which is located on the northeast side of Gallup, NM, was designed to receive 1,200 tons per week of solid waste and this facility cost $1,200,000.00 in 1995. The Cibola County Transfer Station, also operated by the NWNMRSWA is designed to receive 400 tons per week and this facility costs $7,000,000.00 in 1995.

Table Forty-Six Central Transfer Stations – Annual Costs Cost Item 850-Tons/Week 500-Tons/Week 250-Tons/Week Transfer Station Transfer Station Transfer Station Pre-Development $9,185.00 $9,185.00 $9,185.00 Construction $69,396.00 $59,382.00 $53,652.00 Equipment Replacement $17,143.00 $17,143.00 $17,143.00 Operating Expenses $98,800.00 $92,800.00 $88,300.00 Total Annual Costs $194,524.00 $178,510.00 $168,280.00 Cost Per Ton of Waste $4.40 $6.87 $12.94 Handled NOTE: CPI may change rates to +/- 5%

The pre-development, equipment replacement, and operational costs for the three different sized facilities are the same. The design and construction cost variability indicates increased costs for the larger-sized transfer stations. On a cost per ton basis, the larger transfer stations are more economical to operate than the smaller 250 tons per week stations.

18.0 Navajo Nation Landfills Construction and Operational Costs

A similar cost analysis approach used for the transfer station analysis was utilized to develop costs for the proposed Navajo Nation solid waste landfills. The landfill designs are based on meeting the regulatory requirements of Navajo Nation Solid Waste Regulations. Based upon the solid waste generation and transportation analyses, two different sized landfill capacity designs were deemed necessary to be able to handle the predicted waste tonnages. The larger landfill layout would be designed to handle 50,000 tons of solid waste per year and a smaller-sized landfill which has 30,000 tons per year capacity that would be needed for those Agencies with smaller waste streams. JHC also prepared a cost estimate for a 15,000 ton per year landfill for cost comparison purposes. The complete cost analysis figures for the 30,000 and 50,000 ton per year landfill designs is included in the Appendix of this Plan. The proposed Shiprock Agency Landfill would require a 50,000-ton per year landfill design. The proposed Chinle, Fort Defiance, and Western Agency Landfills would require the 30,000 tons per year landfill design. To provide size comparisons to other regional landfills, the large Cinder Lake Landfill located north of Flagstaff, AZ averages 135,000 tons per year and the Red Rocks Regional Landfill, located northeast of Thoreau, NM, averages 100,000 tons per year. The Montezuma County Landfill in Colorado averages 27,000 tons per year and the San Juan County, Utah’s White Mesa Landfill currently averages 12,000 tons of waste per year.

18.1 Pre-Development

The pre-development costs for the two different-sized landfill designs would be identical. Landfill pre-development costs include fees for archaeological and threatened and endangered species surveys, site assessments, geotechnical investigations and traffic studies. Site assessments would include specific assessments to address the Navajo Nation Solid Waste Act siting criteria as well as Environmental Impact Assessments. Prior to opening the landfill it was assumed that three ground water monitoring wells would need to be constructed with one upgradient well and two wells on the down gradient side of the landfill. A minimum of four ground water sampling events would be required prior to opening the landfill to establish background water quality standards are included in the cost estimates. The pre-development expenses for both landfill designs would total $583,000.00.

18.2 Initial Landfill Construction

Landfill designs are often uniquely designed and optimized for local geology, soil, topographic and volumetric considerations. The landfill design used for the cost analysis is a design that exceeds Navajo Nation Solid Waste Act requirements and technical applications of the Resource Conservation and Recovery Act to parallel Subtitle D landfill requirements, and is sized for expected solid waste volumes in the arid Southwest. For landfill sites located on very low permeability soils with depths to ground water of over 300 feet, a composite synthetic bottom liner could be replaced with a liner constructed with natural materials. Each landfill site will be designed for its unique geologic and surficial environment. It is assumed that the Navajo Nation would want a landfill design that would reduce the potential for subsurface contamination to a very low level.

The construction of the proposed landfills would involve the construction of an initial 2.3-acre cell, which covers 200 feet by 500 feet in aerial extent. The cell would require excavation 10 feet deep below the surface grade. The construction specifications for the landfills would be subject to adherence to 40 CRF Part 258 requirements. For cost estimating purposes, the bottom liner would be designed with a 60-mil thick, high- density polyethylene (HDPE) layer covering a geo-synthetic clay (GCL) mat. The proposed bottom liner design provides the landfill cell with the slope to allow drainage through leachate collection piping positioned down the center of the cell. The bottom liners would be covered with a two-foot thick clean sand drainage layer, whose purpose would be to facilitate downward movement of leachate fluids to the leachate collection system, and to physically protect the HDPE liner from punctures. Leachate would drain from the landfill to an HDPE-lined leachate evaporation pond down slope of the landfill. If the construction design of the landfill requires a site-specific flexibility petition, increased regulatory review costs would increase the overall construction costs. Typical landfill cell excavation plan and final cover contours along with some key recommended construction details are included in the Appendix of this Report.

The maximum above ground elevation of the filled landfill would be 20 feet to minimize visual impacts of the structure and help with local community acceptance. Typically, waste cells are normally filled with waste and daily cover materials, such that the top of the final cover would be from 30 to 40 feet above ground level. The proposed design is not as efficient from a cost standpoint as a much deeper landfill design, but the lower profile of the final structure would be a more visually aesthetic design. The initial cell construction would require the services of an outside contractor.

The landfills would also require the construction of a scale house and scale at the entrance to the facility to monitor tonnages of waste being accepted. The landfill facility would require security fencing and screening would be necessary on the down wind side of the landfill to help control blowing paper and plastics. A pole barn structure would also need to be constructed adjacent to the landfill cell to store landfill equipment and provide a protected location fro maintenance and repairs. Costs for on-site roads and storm-water drainage were also included in this cost analysis. Costs were not included for improvement of access roads to the landfill. Depending on the final site selection, a more remote landfill location could add significant costs to upgrade the roads to the facility. The initial construction costs for the smaller design would be $840,000.00 and the construction costs for the larger 50,000-ton per year landfill would be $934,000.00.

18.3 Equipment

Operation of an RCRA-compliant landfill requires the use of specialized equipment. The three key pieces of heavy equipment necessary for solid waste landfilling include a compactor, a tracked dozer and a scraper. Cost estimates were based on 2001 costs for typical equipment. The compactor, equivalent to a Caterpillar 826 with Caron wheels, which typically costs $265,000.00 is used to work across the deposited waste to achieve a compacted density of 1,250 pounds per cubic yard. A tracked- dozer is used for spreading the dumped waste and daily-soil cover placement. A dozer of sufficient size to handle landfilling operations will cost $200,000.00. A scraper, costing $215,000.00 is necessary for pre- excavation of future cells and the placement of daily soil cover material. Additional equipment required for landfill operations would include: A grader, water truck, three pickup trucks, a welder, generator, and maintenance tools. The total initial equipment costs for both landfills would be $1,133,000.00. Equipment life is expected to be seven years.

Funds are set aside for complete equipment replacement every seven years. Annual fuel and maintenance costs for this equipment was also included in the cost estimates.

18.4 Personnel

Operational personnel at each landfill will include a landfill operator/manager, three equipment operators, one mechanic, a scale attendant and three laborers. Annual operating expenses, including personnel salaries, supplies, fees, equipment costs, annual monitoring and compliance expenses will total $334,000.00 per year.

18.5 Landfill Expansion

Both landfill designs are based on 20-year operational lives, which is typical for most solid waste permits. Landfilling is expected to be able to continue at the existing facility but a new permit would be expected prior to further expansion. For the 30,000 ton per year design, the 20-year footprint is expected to be 20.4 acres. The maximum combined cell size for the 50,000-ton per year landfill is 35.5 acres. The Navajo Nation’s own equipment and personnel would excavate the expansion landfill cells. Normally, the excavated soil from the future cells is used as daily cover in the normal landfilling operations to advance cell excavation ahead of need. The use of alternative daily covers could result in a need to contract out future cell excavation. Expansion cell liners would continue to have to be constructed by outside, specialized contractors. Expansion costs per year for the small design are expected to total $131,000.00 and the larger landfill would have $226,000.00 per year added in costs for expansion.

18.6 Closure and Post-Closure

The NNEPA’s Solid Waste Act and Solid Waste Regulations require that landfills be properly closed and monitored after the solid waste facility is closed to the acceptance of solid waste. A 30-year post-closure care period was used for developing these costs.

The landfill cost estimates include an evapotranspiration final cover that includes two feet of a soil infiltration layer, a one foot layer of soil capable of supporting vegetation and six-inches of armor-gravels to be mixed in with the vegetative layer. The armor-gravels are anticipated in those areas with fine-grained natural soils and high potential for wind erosion. Individual cells would be closed as they are filled. Closure costs would then be spread across the active 20-year life of the landfill.

The cumulative costs to close the 30,000-ton per year landfill would be $775,000.00 and $1,293,000.00 for the larger landfill design. These costs would also include surface drainage and gas vents.

Post-closure care for the landfills will encompass the 30-year period after the last acceptance of solid waste at the facility. Post-closure operations will include continued ground water and methane monitoring. Costs were also included for monitoring well replacement in anticipation of well failure or pump replacement. During the operational life of the landfills, funds will need to be set aside for cover repair, leachate removal, inspections and compliance reporting costs during post-closure care. The 30-year lifetime closure care costs for the 30,000-ton per year landfill would be $1,100,000.00 and $1,300,000.00 for the larger landfill design.

18.7 Landfill Cost Summary

Costs from the siting, construction and equipment phases of the costs analysis were summarized in Table Forty-Seven for both the 50,000 and 30,000 ton per year landfills. The total costs represent the minimum funds necessary to site and construct the landfill and have equipment available for the first day of operation. The site assessment and equipment costs are identical for both sized landfills. The lower costs for the smaller landfill are due to smaller areas of excavation and liner square footages. Table Forty-Seven Landfill Initial Siting and Construction Costs Landfill Construction 30,000 Ton Per 50,000 Ton Per Component Year Landfill Year Landfill Site Assessment & $583,000.00 $583,000.00 Permitting Design & Construction $840,000.00 $935,000.00 Equipment $1,135,000.00 $1,135,000.00 Totals $2,558,000.00 $2,653,000.00

Table Forty-Eight summarizes the key cost elements to construct, operate and close a 30,000 and 50,000 ton per year landfill over its lifetime. The operational period is assumed to last 20 years and a post-closure care period of 30 years. The total costs cover a 50-year period.

Table Forty-Eight Landfill Facility Lifetime Present Worth Costs Cost Item 30,000 Ton Per 50,000 Ton Per Year Landfill Year Landfill Pre-Development $583,000.00 $583,000.00 Initial Construction $840,312.00 $933,670.00 Expansion $2,629,389.00 $4,528,467.00 Equipment Financing $161,857.00 $161,857.00 Operating Expenses $6,681,000.00 $7,541,000.00 Closure $775,237.00 $1,292,894.00 Post Closure $1,106,305.00 $1,314,742.00 Totals $15,852,385.00 $19,430,917.00

Costs were annualized on a 20-year basis to coincide with the operational period of the landfill when waste was being accepted. The two different sized landfill annualized costs are shown in Table Forty-Nine. Even though the larger landfill design costs almost $180,000.00 per year more to operate than the smaller landfill, the per ton costs for the larger landfill are almost $7.00 per ton less to operate.

Table Forty-Nine Landfill Annualized Costs Cost Item 30,000 Ton Per 50,000 Ton Per Year Landfill Year Landfill Pre-Development $29,150.00 $29,150.00 Initial Construction $42,016.00 $46,684.00 Expansion $131,469.00 $226,423.00 Equipment Financing $161,857.00 $161,857.00 Operating Expenses $334,050.00 $337,050.00 Closure $38,752.00 $64,645.00 Post Closure $55,315.00 $65,737.00 Totals $792,619.00 $971,546.00 Average Cost Per Ton $26.42 $19.43

An additional cost estimate was prepared for a smaller 15,000-ton per year landfill to provide a comparison if multiple, smaller landfills are to be considered to further reduce haulage costs. Table Fifty shows the annualized cost breakdowns for a smaller-design landfill that could accept 60 tons per day. The cost of designing, constructing, operating and closing a 15,000-ton per year landfill would be almost $40.00 per ton of waste handled over its operational life. This is twice the cost per ton to construct and operate a 50,000-ton per year landfill.

Table Fifty Annualized Costs – 15,000 Ton Per Year Landfill Cost Item 15,000 Ton Per Year Landfill Pre-Development $29,150.00 Initial Construction $31,925.00 Expansion $73,486.00 Equipment Financing $159,000.00 Operating Expenses $234,000.00 Closure $21,199.00 Post Closure $48,228.00 Totals $597,287.00 Average Cost Per Ton $39.82

19.0 Navajo Nation Solid Waste Authority (NNSWA) Administration Costs

A Navajo Nation Solid Waste Authority Administration (NNSWA) system is proposed to manage all of the solid waste equipment, transfer stations and landfills on the Navajo Nation. The details of the organization of the NNSWA is included in Section 25.0. The costs for the Authority would include salaries and the construction and operation of an administration office center.

The administrative staff necessary to manage the Navajo Nation Solid Waste Authority (NNSWA) would involve the following individuals:

Solid Waste Authority Coordinator

Operations Manager

Transportation Equipment Manager

Recycling Coordinator

Secretary/Word Processor

Bookkeeper

Clerk/Records Custodian

Receptionist

The Solid Waste Coordinator would have responsibility for the entire operation of the solid waste system on the Navajo Nation and should be an individual strongly based in solid waste environmental compliance, operations, equipment, and personnel management. The Operations Manager would be responsible for coordinating the operations of the transfer stations, collection points and environmental compliance. The Transportation Equipment Manger would have operational responsibility over the waste hauling trucks and systems. The Recycling Coordinator would coordinate recycling and waste reduction efforts with the Chapters, transfer stations and potential sources for recyclable reuse. The support staff for the administrative office would include four individuals that would work with the Authority Coordinator and the professional staff.

It is assumed that an administrative building and staff would be located in the St. Michaels/Window Rock area, but this facility could be located in Shiprock or at one of the Navajo Nation Landfills. Other significant expense items necessary for the operation of the Authority office would include office furnishings, computers, three automobiles and two pickup trucks. The cost analysis for the Authority building and staff are included in the Appendix of this Report.

The Authority Office building would require sufficient space for eight offices and a conference room. Costs for a 4,000 square foot, pre-engineered single-story building on a concrete slab, to house the administrative staff, are estimated to be $500,000.00. Pre-construction costs would include site assessments and archaeological and endangered species surveys. Annual operating costs, based on 2001 costs, which include salaries, vehicles, utilities and office supplies would total $330,250.00. Based on the total tonnage of waste generated on the Navajo Nation, the costs of the administrative department would add $3.59 per ton of waste handled to the total cost of waste collection and disposal.

20.0 Waste Model Cost Comparisons

The various infrastructure costs outlined in the preceding paragraphs were then used to establish total transport, handling and disposal costs for the four different waste handling models that were presented in the waste transport analysis. The approach taken to compare costs for the proposed waste systems was to determine the total waste transport and landfill deposit costs for each of the Agencies on the Navajo Nation. Administrative costs were also added to each model where the proposed NNSWA would manage the waste transport and disposal operations. The infrastructure cost comparisons for each Agency, which include the key waste tonnage and operational cost assumptions, are included in Volume II, Appendix IV of this Report.

Waste Model One is the current waste handling system where the waste generated at the individual Chapters is hauled off the Navajo Nation through a complex system of contracted waste haulers and governmental-operated transfer stations and pickup points to landfills located outside the Navajo Nation. The solid waste transportation costs developed in Section 13.0 for this scenario were combined with the current off- Reservation landfill tipping fees to determine the costs for this system. Table Forty- Nine shows the transport and off-Reservation costs for each of the five Agencies on the Navajo Nation. The current total cost for the Navajo Nation waste disposal is estimated at more than $8 million per year, of which $4.9 million is known and defined below (see Section 9.0).

Table Fifty-One Current Annual Waste Transport and Disposal Costs Agency Commercial Transfer Station Total Pickup Chinle $597,000.00 $337,000.00 $933,000.00 Eastern $213,000.00 $329,000.00 $542,000.00 Fort Defiance $587,000.00 $854,000.00 $1,441,000.00 Shiprock $371,000.00 $648,000.00 $1,019,000.00 Western $513,000.00 $546,000.00 $1,059,000.00 Totals $2,281,000.00 $2,714,000.00 $4,995,000.00 NOTE: CPI may change rates to +/- 5%

Waste Transport Model Two utilizes the concentration of waste within each Agency at central transfer stations prior to transportation to a landfill. Waste from the transfer stations would be hauled off the Navajo Nation by transfer trailers to the same landfills where the waste is currently being deposited.

Waste Transport Model Three involved the same system of central transfer stations as presented in Model Two, but the waste would be transported to Navajo Nation- permitted (utilizing RCRA technical standards or more critical), or USEPA permitted landfills located on the Navajo Nation.

Waste Model Four uses the system of Navajo Nation landfills as presented in Model Three, but the waste would be hauled from individual Chapter sources to the Navajo Nation landfills. Model Four would not utilize central transfer stations. Table Fifty- Two shows the infrastructure, transportation and landfilling cost comparisons for each Agency.

Table Fifty-Two Waste Model Agency Annual Transportation and Infrastructure Cost Comparison Waste Western Chinle Fort Shiprock Eastern Totals Model Agency Agency Defiance Agency Agency Agency Chapters to Off-Nation Landfills $1,059,000.00 $933,000.00 $1,441,000.00 $1,019,000.00 $542,000.00 $4,995,000.00 CTS to Off-Nation $1,138,000.00 $881,000.00 $1,585,000.00 $1,215,000.00 $715,000.00 $5,333,000.00 CTS to Navajo Landfills $1,035,000.00 $703,000.00 $1,373,000.00 $1,079,000.00 $717,000.00 $4,776,000.00 Chapters to Nav. Ldfills. $1,007,000.00 $603,000.00 $1,245,000.00 $944,000.00 $590,000.00 $4,258,000.00 NOTE: CPI may change rates to +/- 5%.

For the Western Agency the cost estimates for the four different waste models average just over $1,000,000.00 per year. The use of central transfer stations to concentrate the waste and haul waste off the Navajo Nation with transfer trailers is the most expensive option at $1,138,000.00 per year. The most cost-effective solution of the four waste models, at $1,007,000.00 per year, is to haul the waste directly from the Chapters to a local landfill and not utilize central transfer stations. The use of transfer trailers to haul waste longer distances on the Western Agency reduces the transportation costs from the current system of packer and roll-off trucks; however, the costs of constructing and operating two central transfer stations at Tuba City and Kayenta off-set the savings in transportation costs. The proposed, smaller capacity Kayenta Transfer Station is projected to cost $12.94 per ton of waste handled, which is almost twice as much to operate per ton than the Tuba City Transfer Station at $6.87 per ton. The operational cost of a Western Agency landfill, at $26.42 per ton, is more cost effective than the average $27.50 per ton cost of the Cinder Lake and White Mesa Landfills. The waste model comparison for the Chinle Agency shows a significant spread in the total cost for these options. The most expensive waste model is the current system of hauling waste off-Reservation at $933,000.00 per year.

The use of a central transfer station at Chinle can reduce the waste costs from $120,000.00 to $230,000.00 per year depending on where the waste is transported for disposal. The average central transfer station costs are $6.87 per ton. The most cost- effective alternative is the haulage of waste from the Chapters directly to a Chinle Agency Landfill, even though the operating cost of the Chinle Agency is over $4.00 per ton over the average off-Reservation tipping fees. Hauling directly to the Agency Landfill would save over $300,000.00 per year over the current system of hauling either to Utah, New Mexico or Arizona landfills. The close proximity of the proposed Chinle central transfer station and the Chinle Agency Landfill does not produce significant transportation savings over current waste hauling systems.

For the Fort Defiance Agency, the waste model with the highest cost is the use of central transfer stations to haul waste off-Reservation at $1,585,000.00 per year. The current waste situation and the use of central transfer stations and an Agency landfill will result in costs of approximating $1,400,000.00 per year. The average central transfer costs for the Fort Defiance Agency would be $7.27 per ton. The lowest cost waste alternative is the direct hauling of waste from the Chapters to an Agency landfill. In this case, the use of a local landfill alone would cost $1,245,000.00 per year, which is a savings of $196,000.00 per year over the current system. Agency landfill costs are expected to be $26.42 per ton, which is slightly more cost effective than the current $27.72 per ton off-Reservation tipping fees.

In the Shiprock Agency, the cost spread between the various waste models is relatively small. The highest cost alternative would be the construction of a central transfer station at Shiprock to haul waste to the Crouch Mesa Landfill east of Farmington, New Mexico. The use of Agency central transfer stations at Shiprock, NM and Mexican Water, UT result in higher overall costs than the current waste transport and disposal system. The use of an Agency landfill can result in savings of $75,000.00 per year over the current system. The difference in tipping fees between the off-Reservation landfills and the proposed Agency landfill would only be $8,000.00 per year.

The Eastern Agency waste models did not include constructing an Agency landfill because of the proximity of the existing Red Rocks Regional Landfill at Thoreau, NM. Waste from the Chapters in and around Gallup, NM was diverted either to the St. Michaels area central transfer station or to the proposed Fort Defiance Agency Landfill. The Eastern Agency waste model cost analysis indicates that the current waste transport and disposal system is the most cost effective. The proposed Crownpoint and Huerfano central transfer stations would both cost $12.94 per ton of waste handled. In comparison, the waste diverted to the larger St. Michael central transfer station would cost $4.40 per ton to handle.

In summary, the option of hauling waste off-Reservation with the use of centralized transfer station, is the most expensive option. Approximately $200,000.00 per year can be saved over the current off-Reservation waste system by utilizing central transfer stations and local Agency landfills. The most cost effective waste model is the direct haulage of waste from the Chapters to the Agency landfills. This last option can save a projected $700,000.00 per year by reducing waste transport costs and some landfill tipping fees.

21.0 Alternative Waste Systems Costs

The previously discussed waste models assumed an Agency-wide waste transport and disposal system. In order to provide some alternative infrastructure waste handling and disposal comparisons, some of the Agencies were analyzed on the basis of combination waste system costs. Where possible, the Agency waste stream was divided into component Chapters where multiple waste systems could further reduce costs. In some Agencies, individual Chapters may be closer to an off-Reservation landfill than a Reservation landfill. For other Chapters, it may be advantageous to haul waste to an adjacent Agency for disposal rather than trying to transport it within that Agency. The following paragraphs address those Agencies where the cost differential between the four basis waste models is relatively small.

21.1 Western Agency Alternative Waste Models

For the Western Agency two different approaches were taken to subdivide the waste stream into smaller elements based on infrastructure costs and proximity to alternative disposal sites. Because of the higher costs per ton to handle waste at the smaller central transfer stations, the central transfer station model was modified by eliminating the Kayenta Central Transfer Station and having this waste hauled directly to the Western Agency Landfill. Only the Chapters adjacent to Tuba City would send their waste to a central transfer station. The three Western Agency Chapters in the very southern portion of the Agency are closer to the Flagstaff area than to Tuba City, so costs were estimated to send waste from these Chapters directly to the Cinder Lake Landfill. Utilizing this waste handling approach, the annual waste handling and transportation costs for the Western Agency would be $903,000.00 per year.

A second alternative approach for the Western Agency is to have the waste hauled directly to the Agency Landfill from the individual Chapters. The alternative would have the waste from the southern-most three Chapters sent to Cinder Lake, Flagstaff, AZ and the remaining Chapters would send their waste directly to the Agency landfill. This alternative would cost $974,000.00 per year.

Table Fifty-Three shows the various cost components developed for these two alternative waste models for the Western Agency.

Table Fifty-Three Western Agency Alternative Waste Models Waste Cost Component Tuba City Transfer Waste Except Station-Chapters to Southern Chapters to Agency Landfill Agency Landfill Transport Costs $228,000.00 $378,000.00 Off-Nation Landfill Tipping $34,000.00 $34,000.00 Fees CTS Tonnage Costs $75,000.00 0 Agency Landfill Tipping Cost $495,000.00 $495,000.00 Administrative Costs $71,000.00 $71,000.00 Total $903,000.00 $978,000.00 NOTE: CPI may change rates to +/- 5%. 21.2 Shiprock Agency Alternative Waste Model

A similar approach was taken for the Shiprock Chapter to determine if a combination waste transport model could reduce overall costs. The cost analysis in Section 20.0 indicates the most cost effective waste model is the direct transport of waste from the Shiprock Agency Chapters to a landfill near Shiprock, NM. An alternative waste model would reduce transportation costs by continuing to haul waste from the westernmost Chapters northward to the White Mesa Landfill in Utah and reduce the 50- mile haul distance from the Mexican Water, UT area to Shiprock, NM. The net result of hauling western Shiprock Agency Chapters solid waste to White Mesa, UT would be a $14,000.00 per year reduction in the total costs of hauling all the Chapter waste to Shiprock. Table Fifty-Two shows the various cost components developed for this alternative waste model for the Shiprock Agency.

Table Fifty-Four Shiprock Agency Alternative Waste Model Waste Cost Component Shiprock/Western Chapters to Utah – Other Chapters to Agency Landfill Transport Costs $163,000.00 Off-Nation Landfill Tipping Fees $77,000.00 CTS Tonnage Costs 0 Agency Landfill Tipping Costs $572,000.00 Administration Costs $118,000.00 Total Costs $930,000.00 NOTE: CTI may change rates to +/- 5%

21.3 Chinle and Western Agency Combined Waste System

When waste infrastructure costs for different-sized landfills are compared, a 50,000-ton per year landfill can save approximately $7.00 per ton of waste handled over a 30,000 ton-year design. The waste streams from the northern half of the Western Agency, the entire Chinle Agency and the western-most portion of the Shiprock Agency were combined at one facility to take advantage of the economics of the larger waste facility. A hypothetical landfill was placed near the center of the Aneth-Kayenta- Chinle waste centroid for cost analysis purposes. The hypothetical North- Central landfill was located between Rock Point and Round Rock, AZ adjacent to Highway 191, a primary transportation route.

The use of a Rock Point/Round Rock landfill poses a problem for the Tuba City area Chapters as to where the most economical location for this waste is to be transported. The waste haul from Tuba City to the North- Central landfill would be approximately 140 miles one-way. In comparison, the transportation distance to the Cinder Lake Landfill from Tuba City is 68 miles. The Tuba City area Chapters would only generate an annual waste stream of 11,000 tons per year. A local landfill, in the Tuba City area to handle the waste from this area, would cost over $40.00 per ton to build and operate, based on 2001 costs, which is significantly higher than Cinder Lake’s current $30.85 per ton tipping fee. The cost effective solution in this scenario is to centralize the waste stream from the central-Western Agency Chapters at a Tuba City central transfer station and then haul this waste by transfer trailers off-Reservation to Cinder Lake. The southern-most Western Agency Chapters would have their waste hauled by conventional transport to Cinder Lake.

The impact of this alternative waste system on the Shiprock Agency would be similar to the impact of directing waste to White Mesa Landfill rather than hauling this waste to a Shiprock Agency Landfill. Cost comparisons for a North-Central landfill were made for the Western and Chinle Agencies and this information is shown in Table Fifty-Five.

Table Fifty-Five North-Central Landfill Model Cost Analysis Waste Cost Component Western Agency Chinle Agency Transport Costs $228,000.00 $257,000.00 Off-Nation Landfill Tipping $332,000.00 0 Costs CTS Tonnage Costs $75,000.00 0 Agency Landfill Tipping Costs $153,000.00 $297,000.00 Administration Costs $75,000.00 $55,000.00 Total Costs $859,000.00 $609,000.00 Note: CPI may change rates to +/- 5%

The total annual costs to consolidate the bulk of the waste stream from these two Agencies at one landfill would be $1,468,000 per year, which is a savings of $140,000.00 per year over the $1,610,000.00 cost of operating separate landfills in each Agency. The combined current waste disposal system cost for both Agencies would be $1,992,000.00 per year.

22.0 Infrastructure Cost Analysis Summary and Recommendations

A review of the cost analysis of the four waste transport and disposal models in Section 20.0 shows the current system of hauling waste off-Reservation is more expensive than keeping the waste on the Navajo Nation. The highest cost option is the use of central transfer stations to centralized waste for transport off the Navajo Nation. The higher operational costs of smaller central transfer stations off-set the waste transport savings offered by the lower ton-mile costs of the transfer trailer systems. Central transfer stations handling less than 500 tons per week with transfer trailers should not be considered on the Navajo Nation. The system currently used for lower cost roll-off box transfer stations and pickup points is a more cost effective system for waste haulage from smaller Navajo Chapters. The use of central transfer stations to haul waste to Agency landfills is more cost effective for the larger waste generating communities, such as Tuba City, St. Michaels, Fort Defiance, Chinle, AZ; and Shiprock, NM.

The direct haul of waste to local landfills, using existing waste transport systems from individual Chapters to Navajo Nation Landfills, is the most cost effective alternative for most Agencies. The ton-mile cost savings available through the use of transfer trailer systems is not enough to balance the capital, operational and maintenance costs of central transfer stations.

The cost analysis indicates that landfills handling less than 30,000 tons per year cannot compete economically with hauling solid waste off-Reservation. Ideally, landfills handling at least 50,000 tons per year or more of waste are more economical to operate, but in most cases, larger transport costs will be incurred in order to consolidate this much waste in one landfill. Ideally, landfills handling 30,000 tons per year or more of waste should be located within 20 miles of the largest waste generation centers for each Agency. Administrative costs to manage the solid waste collection and disposal systems on the Navajo Nation are expected to add an additional $3.50 to $4.00 per ton to the cost of operating a solid waste landfill on the Reservation.

The following paragraphs outline waste transport and disposal systems that the Navajo Nation should consider implementing for each of the five Agencies of the Reservation.

22.1 Western Agency

Of the seven different waste hauling options considered for the Western Agency, two of the alternative options offer the lowest annual operational cost. The original four models considered averaged just over $1,000,000.00 per year to implement.

An alternative option would be to construct a central transfer station at Tuba City and haul waste via transfer trailers to a Western Agency landfill located between Tuba City and Kayenta. Waste from the southern-most Chapters in this Agency would be hauled directly to the Cinder Lake Landfill, Flagstaff, AZ, and the waste from the Northern tier Chapters would be hauled directly to the Agency landfill. This option is expected to cost $930,000.00 per year based on 2001 costs.

The second alternative option is to utilize a Tri-Agency Landfill located in the northern Chinle Agency and transport waste from the Chapters in the Kayenta area to this facility. Waste from the central Western Agency Chapters would go to a central transfer station at Tuba City and this waste would be transported, via transfer trailers, to Cinder Lake. The waste from the southern-most Chapters would be hauled to Cinder Lake, which has a minimum of ten years capacity at the current rate of landfilling. Based on 2001 costs, this waste option would cost $859,000.00 per year.

A well-placed Western Agency landfill also has the potential to serve as a viable alternative for disposal of off-Reservation waste from the Page, Arizona area. A landfill located between Tuba City and Kayenta would be attractive to securing waste from the Page area. A Tri-Agency Landfill closer to Chinle would not be as cost effective. Depending on the potential tonnage of waste that might be derived from the Page area, the tonnage capacity designs for a Western Agency landfill may need to be increased.

The Tuba City central transfer station is the only one of this facility type proposed for the Navajo Nation that appears to have economic viability. The Navajo Nation will have to decide if operating only one transfer trailer/central transfer station system is worth the cost of developing this system for one facility. The alternative for Tuba City would be to continue the use of roll-off trucks for longer waste hauls to landfills.

22.2 Chinle Agency

For the Chinle Agency there are two waste transport and disposal options that offer significant savings over the current waste system. Both of these options involve the direct haulage of waste from the Chapters to a landfill located on this Agency. The costs for locating and operating a landfill within 15 miles of Chinle are $603,000 per year, based on 2001 costs.

Locating a landfill in the Rock Point/Round Rock area and accepting waste from the Kayenta and Aneth areas would result in a projected annual cost of $609,000.00, based on 2001 costs. The savings of operating a larger-design landfill at the northern edge of the Chapter would off-set the increased transportation costs to haul waste to the facility.

22.3 Fort Defiance Agency

In the Fort Defiance Agency area, the bulk of the waste is generated in the Fort Defiance, St. Michael and Window Rock triangle. The cost effective waste solution for this Agency is to locate a landfill within 15 miles of St. Michaels and haul waste to this facility with packer trucks and roll-off transport equipment. This option is expected to cost $1,245,000.00 per year, based on 2001 costs.

Due to the traditional values and cultural concerns associated with the location of a major solid waste facility in the Window Rock/St. Michaels/Fort Defiance area, it may be difficult to find an acceptable location for a landfill in this area. The use of a higher cost waste transport and disposal system may be necessary rather than having to deal with the complex issues that could be necessary rather than having to deal with the complex issues that could be involved with locating a large landfill in this sensitive area. A large, centrally located central transfer station would not require a large footprint and would be visually aesthetic. Unfortunately, the use of a central transfer station to haul waste off the central Agency, is the highest cost waste option at $1,585,000.00 per year, based on 2001 costs.

The waste generated West of the Defiance Plateau in the Ganado area Chapters should be diverted to landfills west of the Plateau.

22.4 Shiprock Agency

For the Shiprock Agency the cost effective waste transport and disposal solution is to haul waste by conventional means to an Agency landfill located within 10 miles of Shiprock. It is assumed, for this study, that only Navajo Nation Waste would be deposited in this facility. A Shiprock area landfill option is expected to cost less than $950,000.00 per year, including transportation costs, based on 2001 costs. The current system of hauling waste to the Crouch Mesa, Aztec, NM and White Mesa Landfills, Bluff, Utah costs $1,019,000.00 per year, which is only a $69,000.00 per year difference from locating a new landfill on the Reservation, based on 2001 costs. Locating a landfill near Shiprock would result in having four regional Subtitle D landfills located near the Four Corners area. Splitting the waste stream into four slices may not be economically viable for all the landfills in this region. This waste analysis also does not take into account the subsided contributions of San Juan County, New Mexico, who is currently operating the transfer stations in the larger Chapters in the New Mexico portion of this Agency. If San Juan County continues to absorb 50 percent of the operation and transportation costs, then the continued current system of waste transport and disposal would be recommended for the Shiprock Agency.

22.5 Eastern Agency

For the Eastern Agency, the Red Rocks Regional Landfill, Thoreau, NM serves the purpose of being close to the Agency waste centroid that is located between Thoreau and Crownpoint, and there is not a need to construct a Navajo-operated landfill in this area. The current tipping fees for the Red Rocks Regional Landfill are less than a 30,000-ton per year landfill located on the Reservation. Waste in the Huerfano area should continue to be hauled to the Crouch Mesa Landfill. Arrangements could be made with San Juan County, NM, the current operator of the Huerfano transfer station, to continue providing this service. Because of the transportation distances involved, waste from the Tohajiilee and Alamo Chapter waste should continue to be transported off the Navajo Nation.

23.0 Waste Authority Personnel and Equipment Requirements

A NNSWA would provide a significant number of job opportunities to members of the Navajo Nation. An Authority administrative staff would require a minimum of four professional staff members and four support staff individuals. It is assumed that these positions would be located in the Fort Defiance/St. Michaels area.

Assuming three landfills would be constructed on the Navajo Nation, in the Western, Chinle, Shiprock or Fort Defiance Agencies, each landfill would require nine individuals for the daily operations. Positions would range from foremen to equipment operators to laborers.

A total of 27 jobs would be necessary for these facilities. A transfer station at Tuba City would require three individuals. If the NNSWA decides to operate the waste collection equipment on the Reservation, a significant number of jobs would be created. Table Fifty-Six shows the estimated number of waste hauling vehicles currently necessary to collect and haul waste off the Navajo Nation. This table also shows the number of drivers and helpers required to operate the waste vehicles. Additional positions will be necessary to maintain these vehicles.

Table Fifty-Six Waste Hauling Vehicles and Personnel Requirements Agency Smaller Packer Trucks Large Packer Roll-Off Trucks Trucks Chinle 1 2 1 Eastern 2 2 2 Fort Defiance 2 3 2 Shiprock 2 2 3 Western 1 2 2 Total Vehicles 8 11 10 Total Personnel 16 11 10

Table Fifty-Two analysis indicates the waste collection equipment for the Navajo Nation would require a minimum of 29 vehicles and 37 drivers and helpers. This analysis does not include a five to six-member maintenance staff necessary to maintain a vehicle fleet of this size.

24.0 Project Capital Costs

Project capital costs were developed for the solid waste collection, hauling and disposal system indicated in the preceding cost analysis paragraphs. The Navajo Nation will have several options available to customize the solid waste collection and disposal stream to the needs of individual Agencies and Chapters. The following project cost summary is based on the construction of the following infrastructure facilities.

Western Agency Landfill (30,000 tons per year design)

Chinle Agency Landfill (30,000 tons per year design)

Shiprock or Fort Defiance Landfill (50,000 tons per year design)

Tuba City Central Transfer Station (500 tons per week design)

Administration Building

The cost summaries for these five key infrastructure facilities will provide useful budgetary planning numbers for the Navajo Nation. The landfill costs are shown in Table Fifty-Seven and are divided into first year construction and other capital outlay costs, the total expansion costs for twenty years of operational life and thirty years of post-closure care.

Table Fifty-Seven Capital Cost Analysis for Three Landfills Cost Item Initial Twenty Year Closure/Post Totals Construction Operational Life Closure Care Pre- $1,750,000.00 0 0 $1,750,000.00 Development Initial $2,614,000.00 0 0 $2,614,000.00 Construction Expansion 0 $7,160,000.00 0 $7,160,000.00 Equipment $3,400,000.00 0 0 $3,400,000.00 (Initial) Equipment 0 $6,320,000.00 0 $6,320,000.00 (Lifetime) Operating 0 $20,900,000.00 0 $20,900,000.00 Expenses Closure 0 0 $2,840,000.00 $2,840,000.00 Post-Closure 0 0 $3,535,000.00 $3,535,000.00 Totals $7,764,000.00 $34,380,000.00 $6,375,000.00 $48,519,000.00 NOTE: CPI may change rates to +/- 5%

The central transfer station and administration building construction costs are shown in Table Fifty-Eight.

Table Fifty-Eight Transfer Station and Administration Building Construction Cost Analysis Cost Item Central Transfer Administration Building Station Pre-Development $184,000.00 $39,000.00 Construction $1,190,000.00 $439,000.00 Equipment $100,000.00 $94,000.00 Totals $1,474,000.00 $572,000.00 NOTE: CPI may change rates to +/- 5%

The total initial construction costs for three landfills, a central transfer station and an administration building are $9,810,000.00. The annual operational costs for the three landfills, central transfer station, waste hauling and administration building are shown below.

Landfills Estimated Annual Costs Pre-Development $ 87,600.00 Initial Construction $ 131,000.00 Expansion $ 489,500.00 Equipment $ 486,000.00 Operating Expense $1,045,000.00 Closure $ 143,000.00 Post-Closure $ 176,000.00 Total $2,258,100.00

Central Transfer Station Pre-Development $ 9,000.00 Construction $ 60,000.00 Equipment $ 17,000.00 Operating Expenses $ 93,000.00 Total $ 179,000.00

Administration Building Pre-Development $ 1,900.00 Construction $ 22,000.00 Equipment $ 16,300.00 Operating Expense $ 330,300.00 Total $ 370,500.00 Annual Cost-Hauling $ 1,180,000.00 Total Estimated Annual Cost $3,987,500.00

The above listed annual costs were then converted into cost per ton of waste. The cost per ton basis for the entire Navajo Nation is based on the projected annual waste tonnage of 113,402 tons. Table Fifty-Nine shows the cost per ton for each of the major infrastructure cost components of the proposed solid waste system.

Table Fifty-Nine Estimated Cost Per Ton Waste System Component Cost Per Ton Landfills $19.91 Central Transfer Station $1.58 Administration $3.27 Hauling $10.40 Total Estimated Cost Per Ton $35.16 NOTE: CPI may change rates to +/- 5%

The annual waste stream for the entire Navajo Nation is divided into three major components based on the type of pickup. Commercial businesses with bins or roll-off boxes account for 24.3 percent of the waste total or 27,557 tons per year. The solid waste costs for the 633 business enterprises, whether commercial or governmental, on the Navajo Nation for the proposed system would be $127.60 per month.

Governmental and Tribal Agencies collect waste at hospitals, schools, residential housing units and governmental agencies, themselves. The contracted waste disposal for these sources represent approximately 51 percent of the waste stream or 64,792 tons per year. It is unknown as to how many contract pickup points exist on the Reservation but the annual waste disposal costs of the proposed waste system would be estimated at $1,914,604.00 per year if this percentage stays relatively the same. The cost would take into account the estimated average $29.55 tipping fee.

There are over 31,063 residential units on the Navajo Nation, which have the responsibility to bring their own waste to a collection point, transfer station, or have contracted household pickup, without regard to other bulky RCRA Subtitle D type solid waste, such as furniture or appliances. The tonnage and costs for these bulky solid waste items were not taken into account with this Plan. The household waste alone represents an estimated 42 percent of the waste stream or 53,716 tons per year. The average monthly cost for the proposed waste system would be $3.90 to $4.00 per month for each residence without contracted pickup.

The project costs outlined above include an annual hauling cost based on the type of waste vehicle required for each Agency’s waste hauling requirements. Table Sixty outlines the minimum number and specific costs for the waste hauling vehicles required too implement a complete Navajo Nation waste hauling operation. To purchase all of these vehicles new would cost just under $4,000,000.00.

Table Sixty Waste Vehicle Requirements and Costs Waste Vehicle Number Cost Each ($) Total ($) Required Small Packer Trucks 8 $100,000.00 $800,000.00 Large Packer Trucks 11 $165,000.00 $1,815,000.00 Roll-Off Trucks 10 $106,000.00 $1,060,000.00 Transfer Trailer 1 $195,000.00 $195,000.00 Systems Total 30 $566,000.00 $3,870,000.00

25.0 Navajo Nation Solid Waste Authority (NNSWA)

The NNSWA would be managed by an Executive Board made up of five to seven members appointed by the President of the Navajo Nation. An Advisory Board consisting of representatives of governmental agencies with interest in solid waste issues should be formed to provide input to the Executive Board. The Advisory Board at a minimum should have representatives from the I.H.S, B.I.A., Navajo Housing Authority (NHA), Navajo Tribal Utility Authority (NTUA), NWNMRSWA, San Juan County, New Mexico, Coconino County, Navajo County, and Apache County, Arizona; and San Juan County, Utah. Representation on the Advisory Board from other entities should be solicited and encouraged, especially in relation to solid waste facilities, organizations, etc.

After the formation of the NNSWA, the initial task of the Board will be the selection of a Director or Authority Solid Waste Coordinator. The Director will have the overall responsibility for overseeing the waste collection, transport, and disposal of waste across the Navajo Nation. This individual will make recommendations to the Board with regard to budgets, personnel, facility location, construction and operation, equipment purchases, operation and overall daily management of the municipal solid waste collection, transport and disposal systems operated by the Authority. This individual should have extensive experience with solid waste regulations, waste economics, landfill operations, waste collection and transport systems. This individual should also have organizational and people skills in order to effectively manage the Solid Waste Authority and to interact with other Navajo Nation Agencies and political entities of the Reservation. It is recommended that the Director should have 15 or more years of hands-on municipal solid waste experience.

The Authority Director will interview and recommend to the Board additional staff as the various infrastructure elements of the Solid Waste Authority become operational. Prior to selecting a Director, the Board will need to locate temporary office space for the Director and the staff until the Solid Waste Authority Administration Building is constructed. Figure Seven is an organizational chart for the proposed Solid Waste Authority.

Figure Eight is the schedule for the implementation of the Authority staff, vehicles and temporary office space. The schedule is based on starting the Solid Waste program in the fall of the first year. The Director should be selected by the end of January of the second year. It is anticipated that the initial hiring of the support staff will be required during the First Quarter of year two. Additional staff will be required when the Administration Building is completed in the third year and potentially later in the fourth year when other portions of the solid waste infrastructure become operational.

26.0 Landfill Scheduling

The previous paragraphs describe the costs of constructing and operating a permitted solid waste landfill on the Navajo Nation. Recommendations were made in the landfill analysis for the generalized location of solid waste landfills on a number of Agencies on the Reservation. The following paragraphs describe the various tasks involved with the opening of a permitted solid waste landfill anywhere on the Reservation.

The site selection, pre-development, permitting, design and construction processes for a single landfill utilizing both Navajo Nation Solid Waste Regulations (“NNSWR”) and technical requirements of RCRA Subtitle D compliant municipal solid waste landfill guidelines are potentially the most time consuming activities of any of the solid waste infrastructure elements required for the NNSWA. The initial step in the development of a municipal solid waste landfill is the site selection and pre-development activities. The schedule for these activities is shown in Figure Nine. The pre-development process takes approximately one year, assuming there are no unforeseen location problems that slow the process. Pre-development involves the physical evaluation of the landfill site to determine its suitability to meet the RCRA Subtitle D location and NNSWR requirements. A key step in the process is the retention of a consulting engineering firm to manage the siting through construction processes.

The archaeological surveys and environmental site assessment tasks are expected to take at least three months each to accomplish. The Navajo Nation has previously conducted geologic and archaeological investigations at several sites in the western portion of the Reservation. If one or more of these sites meet the criteria for selection, there may be some significant cost and time saving measures if the Navajo Nation wants to pursue these sites. This schedule takes into account that there are a number of landfill sites that have been under consideration by the Navajo Nation and portions of the site selection process have already been completed. Because of the long and complex cultural history of the Navajo Nation, the archaeological and cultural resources surveys and clearance process involves the most uncertainty. The identification, surveying and clearance process was assumed to take a minimum of three months. The presence of significant cultural features or objections related to traditional values can add significant additional time to the pre-development process or even cause a site to lose its feasibility.

An important phase of this part of the site evaluation process is the subsurface characterization of the landfill site. This geologic and hydrogeologic information is critical for design considerations as well as permitting and potential future monitoring requirements. Assuming ground water is present at a sufficiently shallow depth, the construction of ground water wells and the establishment of background water quality parameters should begin as soon as the decision is made to accept the site for landfill development.

After the landfill site is deemed acceptable, the solid waste permit process will begin. Construction at the landfill cannot begin until the permit is approved. It will be assumed that the permitting authority will be either the NNEPA or the USEPA. Figure Ten shows the key elements of a solid waste permitting process. The permit assembly process assumes that the key information necessary for inclusion in the permit was developed during the Pre-Development Phase. The preparation of the permit should take approximately three months. The permit should take the form of two volumes. The initial volume will list all of the specific regulations related to the siting, permitting, design, construction, operation, financial assurance, closure and post-closure care of the solid waste facility. The second volume will contain documentation necessary to support the regulatory responses in the initial volume. The anticipated sections in the second volume should address the following topics:

Site Characterization/Geology/Hydrogeology Preliminary Facility Design Monitoring Programs Transportation Plan Contingency Plan Landfill Gas Management Operational Plan Closure and Post-Closure Care Plans Financial Assurance

The schedule anticipates an additional six-month period in which the Permit Application will be deemed complete, a public hearing scheduled, and final regulatory review, and permit issuance. At a minimum, the solid waste permit process from inception to permit issuance should take nine months. With the current uncertainty, with regard to Regulatory review authority for solid waste facilities on the Navajo Nation, the permitting process could exceed one year.

After the Solid Waste Facility Permit is issued, the final design, bidding and construction of the various systems necessary to open the landfill can begin. The most cost effective approach to landfill construction is to divide the project into segments based on the type of contractor that specializes in that type of work. Figure Eleven shows the various tasks related to landfill design and construction.

The initial design package will include all of the excavation and soil preparation tasks into one contact. This bidding package will include the complete designs for cell excavation and grading, storm water diversion, leachate evaporation pond, access road from the nearest highway to the facility, on-site roads and site preparation for the scale and scale house. A separate bid package may be necessary for specialized road construction, if the access road requires connection to a paved Navajo or State Highway. Acceleration/deceleration lanes may be needed for the main highway to address highway safety issues.

The second bid package, assuming the modeled landfill is constructed, will be for the liner and leachate collection system. The landfill is assumed to include a GCL underlying barrier that is covered with a 60-mil thick HPDE or PVC sealed liner. A leachate collection pipe will be placed near the center of the cell and covered with porous sand that acts as a protective layer for the liner and as a hydraulic conduit for any leachate-related fluids to easily travel through the bottom of the cell to the leachate collection system. The landfill site conditions may be such that a great thickness of very low permeability soils may be present or with depths of ground water deep enough that a demonstration can be made that the chances of any solid waste-derived fluids cannot reach the ground water within several multiples of the operational life and closure period of the landfill. In those circumstances, a manufactured liner may not be necessary. The on-site low permeability soils can be compacted to a degree the leachate collection system can be placed directly on the on-site soil and covered with the protective sand layer. Leachate collection piping is normally a gravity drainage system to a leachate evaporation pond. It may be necessary to have the leachate from a cell be collected at a temporary reservoir and then transported to a leachate pond or wastewater treatment plant. The liner construction phase cannot begin until after the initial cell excavation is complete.

At the entrance to the landfill, a scale house and office will be needed. Often the scale and scale house are separate bid packages due to the specialized nature of the construction necessary for the scale foundation construction and scale installation and set-up. A maintenance building will also be needed to store some of the specialized landfill equipment when it is not in use. This facility would also provide a semi-protected area for routine equipment maintenance. Both the scale house and maintenance buildings will need electrical, telecommunications, and sanitary facilities. Provisions will also need to be made for an on-site water supply, which will be needed for human needs, road watering and fire protection. Electricity, gas, and wastewater facilities will also need to be planned for. The landfill facility will also need to be fences with lockable gates at the facility margins. A five-strand barbed wire fence will be needed to enclose the landfill and the scale house. This bid package can also include portable wind fencing to minimize the effects of wind on domestic waste before daily cover can be placed on it.

The design, bid and construction process is expected to take an entire year. The only component that might involve an extended ordering period would be the scale. Depending on the type of scale and the computer software needed by the Authority, these items may require additional procurement time allowances.

27.0 Waste Transportation Equipment Scheduling

Scheduling of the larger pieces of waste handling equipment needed for landfilling operations may take up to six months. Figure Twelve shows the anticipated scheduling times for the specialized waste handling equipment. Compactors require special transmissions, blades and compactor wheels and are not shelf items. If non-equipment manufacturing compactor wheels are specified, additional time may be needed for ordering these separate components. The compactor should be specified such that a minimum six-month delivery time is built into the schedule. Scrapers and dozers often have a 90- to 120-day ordering period. Graders, water trucks and pickup trucks should be available on a 30-day basis.

Initial specifications for equipment will be needed for the permit preparation process as this information will be needed for the operational plan and budget preparation. The final specifications for major equipment should be started at a minimum of 300 days before the opening of the landfill in order to have sufficient time for delivery, set-up and personnel training prior to the start of landfilling operations.

28.0 Authority Administration Building Schedule

The Solid Waste Authority Administration building is expected to take just less than two years from the decision to proceed to facility completion. Figure Thirteen shows the schedule for the Administration Building pre-development, design and construction. The site selection, environmental site assessment and archaeological clearance process should take nine months. The design work can be initiated during the site approval process and finalized subject to site-specific requirements. The construction process should take an entire year. The design should utilize standardized manufactured building designs in order to reduce costs and minimize the time available to have the building components delivered. The building will have a customized interior utilizing steel wall supports and drywall walls. The site should be paved and will require some fencing in order to safeguard equipment and vehicles that might be stored at this facility.

The facility design will need to be coordinated with the Navajo Tribal Utility Authority or other utility providers so that sufficient time can be allowed for water, sewer and electrical service to be provided to the site. Communications may require additional scheduling time in order for telephone, radio and information technology systems to be in place at the facility start-up.

29.0 Central Transfer Station Scheduling

The Task III infrastructure cost report recommended the construction of only one centralized transfer station on the Navajo Nation. Depending on the Authority plans for locating or not locating solid waste landfills, additional central transfer stations may be needed at some of the larger Navajo communities. The following paragraphs outline the key tasks involved with the construction of larger transfer stations and the time necessary to implement their construction.

The scheduling of the siting, pre-development, design, bidding and construction of the larger municipal solid waste transfer stations follows a similar format as the scheduling process for a municipal solid waste landfill. The primary difference between the schedules for the two different infrastructure facilities is the lack of the extensive permitting process for transfer stations. Depending on the permit requirements, if under NNEPA or USEPA, documentation will follow the policies and guidelines for each landfill proposed for development and permitting. Each proposed landfill will have to suffice all regulatory requirements for design, and other satellites in association, such as a transfer station(s), and will be subject for all regulatory review processes and public hearings, as applicable for the locations intended.

The pre-development process for a transfer station is shown in Figure Fourteen. The process begins will the retaining of an engineer and architect that will oversee the siting, design and construction process. Pre-development activities will include site review and evaluation, environmental site assessment, archaeological clearance, threatened and endangered species evaluations, and a preliminary traffic study. Special attention will be given to those tracts already selected for land withdrawal, as those tracts can be evaluated much more quickly than non- withdrawal tracts. The preliminary evaluation studies will then be summarized in a report for the Navajo Nation and any regulatory review agencies. The pre- development process is expected to take approximately nine months. The start of the site selection process for the transfer stations is scheduled for the beginning of 2003 in order to coordinate the opening of the transfer stations with the opening of Navajo Nation landfills. In the case where Navajo tribal waste would be hauled off-Reservation, the transfer station initiation process could begin in early 2002. Figure Fifteen illustrates the anticipated schedule for the design, bidding and construction of a central transfer station. The station itself involves two separate design packages, the foundation and the superstructure of the building. The magnitude of the foundation excavation will be dependent on local topography. It the station can be located on a side slope, the design is simplified over a flat site and the resulting larger volumes of soil necessary to provide access to the upper level. Transfer stations involve specialized concrete and foundation design. Tipping floors need to be constructed with hardened concrete and the two-story structure requires additional re-bar support. The transfer station superstructure cannot begin until after the foundation is complete. The superstructures are normally ordered as manufactured steel buildings. The larger clear spans necessary to keep vertical support members to a minimum can result in longer order times if specializes steel shapes are required. Access to a three-phase power supply is a major consideration, but the facility can operate on a two-phase electrical supply.

Additional soil excavation and preparation around the transfer station will be necessary to handle the inflow and outflow traffic to the station and a separate road for the transfer trailers to reach the lower level of the facility. Access roads from the nearest highway to the station may require additional paving and deceleration lane planning. Scales were not included in the design or construction of the proposed transfer stations. If scales are included for the station at a later date, the procurement and construction process should take nine months. The design and construction of the transfer station should take a minimum of 12 months.

30.0 Waste Collection Scheduling

Currently waste collection is handled through both public and private contracting with commercial waste collection companies. Waste hauling contracts range from monthly to multi-year terms. Waste deposited at transfer stations is primarily handled by public agencies with some commercial hauling of this waste to off Navajo Nation landfills. The NNSWA will have a number of options available with regard to waste hauling. The Authority can contract the waste collection and transport of the entire waste stream out to commercial waste haulers. The Authority can purchase waste collection equipment and haul a portion of the waste or capture the entire waste stream. These decisions will need to be made by the Authority Board on the basis of waste hauling economics in the first and second year.

Currently, waste contracts for hauling of waste from schools, hospitals, and residential units are on a yearly contract. Some of these contracts have multi-year options. Depending on the expiration dates of these contracts, it may take as much as two years for some of these waste collection contracts to expire such that the Authority can take over these operations through the bidding process. Waste transportation from transfer stations in Coconino County, AZ and San Juan County, NM is provided by these counties as part of a cost-sharing basis. Waste pickup from commercial establishments is currently on a local contract basis. In some of the larger Navajo communities there may be two options for businesses to contract their waste pickup with or with one entity, either Navajo Sanitation and/or Waste Management. Navajo Sanitation does do some contracts for Waste Management in some areas of Navajo Nation.

It is currently uncertain as to what type of legal authority the NNSWA will have over mandatory contracting of waste from governmental and private entities. The Authority may have to complete with commercial waste haulers for commercial and governmental businesses. Depending on the level of waste collection the Authority decides to take on, appropriate waste hauling equipment will need to be specified and put out for bid. Both large and small packer are currently under considerable demand and new equipment often requires 300-days of lead-time between placement of orders and delivery. Roll-off trucks are currently requiring 120-days for delivery. Specialized transfer trailer systems are typically requiring a 120-day delivery period. The tractors for the transfer trailers can typically be acquired within 30-days of order.

Figure Sixteen shows the anticipated schedule for implementing waste collection from all sources on the Navajo Nation. The contracting process for residencies, hospitals and schools can take up to two years. Contracting waste hauling for Navajo Nation governmental agencies is expected to take an entire year. Contracts for commercial waste hauling is expected to take six to seven months. The schedule was set up to coincide with the opening of the transfer stations and solid waste landfills.

31.0 Critical Scheduling Milestones

The process from initiation of the NNSWA through the siting, permitting, design and construction of the key components of the solid waste infrastructure is a process that is expected to take a minimum of three years. Figure Seventeen summarizes the critical components taken from the nine other components schedules shown as Figure Eight through Figure Sixteen. For the implementation of a Solid Waste Authority to be able to manage the collection and disposal of solid waste on the Reservation, the initial decision to proceed with the project must be made before the end of the second year. The immediate task for the Authority will be the selection of a Director and the hiring of key administrative staff to support the Director.

The landfill site selection and evaluation process should begin in the early part of the second year. If multiple landfill locations are to be implemented, they can be developed simultaneously and should not add any additional scheduling time for location and construction. The bulk of this additional work and the need to meet schedules would be borne by the consulting engineers selected by the Authority to implement the infrastructure components. The permit review and approval process may be lengthened if multiple solid waste landfills are proposed.

The Authority Administration Building should take less than two years to locate and construct. The Administration Building is not critical to the opening of the other solid waste infrastructure components and its start schedule can be moved into the third year. Having a centralized home for the Solid Waste Authority would provide a centralized location to coordinate the construction phases and the acquisition of critical equipment needed for waste transport and landfilling operations.

The transfer stations have some flexibility as to start dates. Once construction begins, the foundation construction must be completed prior to the installation of the steel covering skin. Transfer station operations can begin when the foundation and access roads are in place, but this process will certainly delay the completion of the building’s upper structure. It is recommended that the transfer stations open shortly after the opening of the landfills in order to be sure that the waste does not have to be transported off-Reservation.

Project scheduling will be a critical component in coordinating this project, especially if multiple landfills and transfer stations are to be constructed, simultaneously. Updated and current schedules will be a critical oversight tool in the oversight review of the construction process for the Solid Waste Authority.

32.0 Community Participation Overview

The primary purpose of the NNSWA are to institute a Tribal-operated waste collection and disposal system for the Navajo Nation and to provide another alternative to illegal waste dumping on the Reservation. One of the primary goals of the Long-Range Comprehensive Solid Waste Management Plan is the development of an alternative solid waste disposal system to allow the additional closure of the existing illegal dumpsites currently existing on the Reservation. The cooperation of the residents of the Navajo Nation will be necessary to allow the Long-Range Plan to achieve its goals. In addition to providing the solid waste infrastructure, equipment and personnel to operate the proposed solid waste system, a portion of the Authority’s efforts should be focused on community participation and education programs. The informational programs should be geared toward emphasizing the benefits of proper disposal of municipal solid waste and waste reduction alternatives. Additionally, the key to the economic viability of the NNSWA will be the capture of as much of the waste stream generated on the Reservation as possible, and having this waste deposited at Navajo-operated solid waste facilities.

In order to garner support from the residents on the Navajo Nation, the NNSWA will have to embark on an informational and educational program aimed at all segments of the Reservation’s population. Educational-oriented programs for elementary through high school-aged students will emphasize proper waste disposal followed with recycling concepts. Informational programs aimed at Chapter residents will emphasize how the waste collection system works and the necessity for ceasing the older practices of waste incineration and illegal dumping. The NNSWA should also be proactive in being involved at larger events on the Nation, developing recycling programs and assisting Chapters in special cleanup events. The following paragraphs will provide more specific information as to how to bring community participation and support into the solid waste management process on the Reservation.

33.0 Solid Waste Authority Community Relations Program

The NNSWA’s initial involvement with the residents of the Navajo Nation will be the siting process for the solid waste infrastructure facilities. The Authority should involve local Chapters in the location process for the new solid waste facilities. Copies of the Navajo Nation Solid Waste Act and the Solid Waste Regulations have been given to all 110 Chapters. The location of both the facilities and access roads will be vitally important to local residents from an increased traffic impact on their communities as well as providing disposal convenience. Hopefully, solid waste facilities can be located on tracts that have already been withdrawn. A 30,000 tons per year landfill would require a minimum of 23 acres of cell are for a 20 year filling program. A 50,000 tons per year landfill would fill 35 acres of cells over 20 years. For future expansion of landfills and the necessity of having an uninhabited buffer zone around them, the facilities should be located on a 640-acre minimum sized tract.

Chapter informational meetings will need to be held prior to final siting and the public hearing process. These Chapter meetings will provide the foundations for future community involvement in the waste collection and disposal process. Information with regard to user fees and how the program will be funded will also be an important discussion topic at these meetings.

The NNSWA’s on-going Community Participation Program should involve two primary focuses, recycling and community education. Recycling of items such as newspaper, glass, metal, and plastics will be encouraged not only for waste reduction purposes, but these programs increase individual and community awareness of their individual waste generation. Education of the community as to the rationale for proper waste disposal and the consequences of illegal waste disposal will be tailored for different age groups in the Navajo population. The NNSWA will also develop specialized community programs for cooperative cleanup efforts.

The Community Relations Program will be centered at the Authority’s Administrative Building. The Director will have the responsibility for overseeing the development and implementation of the Authority’s Community Relations Program that is approved by the Authority Board. The Director’s interaction with the Community will be primarily in the form of developing cooperative Inter-Agency waste coordination programs. The Authority’s Recycling Coordinator will have the day-to- day responsibility for managing both the recycling program and the community education program. It is anticipated that a major recycling effort will not be phased in until after the solid waste infrastructure system is in place. During the early development of the Authority, the Recycling Coordinator will have more available time for development of solid waste awareness programs.

After waste infrastructure startup begins and the recycling efforts take more time from the Recycling Coordinator, a Community Programs Spokesperson should be added to the Authority’s staff. This Spokesperson would be supervised by the Recycling Coordinator and would have responsibilities for developing educational presentations for educational institutes, Chapter presentations, and media news releases. Qualifications for the Spokesperson position should include fluency in Navajo and English, have an education or community relation’s background, willingness to travel and have an out-going personality.

34.0 Community Solid Waste Education Recommendations

On the Navajo Nation, the practice of directly disposing of waste or ash from burn barrels at illegal dumpsites has gone on for many years. For many remote Chapters there has not been an easy alternative to the illegal burning and disposal of waste. The illegal dumping practices have gone on for long periods of time that they have become acceptable traditions for many residential areas. The process to break this cycle of illegal waste disposal will not be solved over night or through the use of tribal legislation and fines. Education of younger members of the tribe as to the proper methods of waste disposal is an excellent method to break some of the older patterns of waste disposal. This method will necessitate bringing the correct waste disposal message to students at the earliest ages with continuing reinforcement as they get older through high school and colleges.

The NNSWA could serve as a resource center for schools both in the capacity of presenting programs directly to students and helping educators locate materials for their own programs. Presentations should be prepared in dual languages for the following municipal solid waste topics:

• Anti-Littering/Green Earth Programs • Recycling/Reuse Programs • How the Waste System Works Program • Composting

Elementary school presentations should involve generally simple concepts regarding protecting the earth, anti-littering campaigns, proper waste disposal and simple recycling concepts. Junior and senior high schools can be exposed too more sophisticated concepts of waste reduction, alternative materials uses, recycling and environmental impacts. Solid waste and recycling concepts and issues can make excellent science fair projects. Field trips to see illegal dumpsites and contrasting operating waste disposal systems would be encouraged. Solid waste information programs targeted to colleges and trade schools can emphasize solid waste career paths in addition to continuing the message of proper waste disposal and recycling.

Community participation programs for older Reservation residents should be directed through presentations to Chapters and at senior citizens centers. The initial Chapter presentations should take the form of informational sessions where changes to the solid waste collection system may impact individual Chapters. As many Chapters need assistance with collection points, the NNSWA, in cooperation with DCD/SWMP, can utilize these meetings for input as to the most effective locations for roll-off boxes and fenced-in areas. The NNSWA could also coordinate Chapter clean-up projects with the use of additional roll-off boxes and prompt pickup. The Authority Board would have to decide if NNSWA equipment and personnel could be used in the actual clean-up efforts. For some of the larger Chapters, presentations regarding recycling and reuse may be appropriate. The important part of this process will be the visibility of the NNSWA to individual Chapters for more than just the vehicle that takes the waste away.

The NNSWA should avail itself of opportunities to make it visible to as many Reservation residents as possible in order to be able to answer questions about its service and promote its program. The Authority should be involved with some of the larger public events on the Navajo Nation, such as the Navajo Nation Fair, Fourth of July Rodeo, and Youth Fairs that are held annually in Window Rock, AZ. The Authority should develop an informational booth available for setup at these events where solid waste educational materials could be distributed as well as displaying information about the waste services available and how the waste system works on the Reservation. The NNSWA could also have open-house days where individual Chapters or educational groups could tour the Authority’s facilities. The print, radio, and television media should be utilized by the NNSWA to make announcements about its solid waste services, provide on-going information about recycling and promote special cleanup programs. A weekly or monthly column in the Navajo Times could also serve as a portal to providing solid waste information and re- enforcement about the need to deposit waste only in acceptable containers. Solid waste informational posters could be prepared for posting in facilities such as schools, Chapter Houses and Navajo Nation tribal buildings.

The Authority staff responsible for Community Participation Programs will find additional sources for educational materials and programs through the Internet. The USEPA Office of Waste Management, the Solid Waste Association of North America, Arizona and New Mexico Clean and Beautiful programs, and the Arizona Department of Environmental Quality are excellent organizations whose websites can provide excellent sources of ideas for presentations and programs. Additional solid waste educational information can be found at numerous State Environmental Agency websites.

Some investment into presentation materials and presentation methods will need to be made by the NNSWA. Posters and handouts will need to be printed. Where possible, these materials should be solicited from professional organizations and trade organizations to reduce costs. One of the best tools available for the Recycling Coordinator and the Community Relations Spokesperson is the use of a portable computer and projector. Presentations can easily be prepared for educational or information programs with software programs such as PowerPoint©. Using the presentations to audiences with different needs and education levels. The computerized presentations can reduce the cost of larger, formatted boards or prepared slides. Handout materials can also be easily generated from these software packages. The Authority may want to create its own website on the Internet to post information about services, programs, special events and educational resource links.

35.0 Recycling – Reduce – Reuse Programs

Recycling and waste reduction programs will reduce the total tonnage of waste that will find its way to Navajo Nation landfills and will increase their operating lives. Recycling programs are popular with younger people and gaining acceptable with older adults. The opportunity to recycle is an excellent program for individuals to become more aware of the waste they generate. The success of any recycling program will depend on community involvement and participation.

Waste recycling is a market-driven business with transportation costs to deliver the recycled waste to a sales location a major factor as to the viability of this program. Solid waste reduction for Navajo Nation is still in infancy because recycling has no markets close to Navajo Nation for all identified recyclable waste streams, they exist in Denver, CO; Phoenix, AZ; and Salt Lake City, UT. Outlying border towns, such as, Winslow and Flagstaff, Arizona and Gallup and Farmington, New Mexico has opened a small doorway into recycling products (i.e., glass, plastics, paper, cardboard, and aluminum cans). All recycling program will have to be compliance with the Navajo Nation Solid Waste Regulations. The current materials that lend themselves to recycling include aluminum, steel, glass, newspapers, cardboard, plastics, tires, and white goods, such as large appliances. Recyclable materials are economically sensitive to the market place and often it is difficult to profit from the collection and handling of materials, such as plastics or lower grades of paper. Aluminum is a successful program with many local sources for individuals to resell soft drink cans, such as, with the business Bashas’, located in five locations: Window Rock/St. Michaels, Chinle, Kayenta, and Tuba City, Arizona, and Crownpoint, New Mexico, with an additional business soon to open in Dilkon, Arizona in 2002. There are local sources for cardboard recycling in Northwestern New Mexico and Northeastern Arizona. A Navajo Nation recycling program could coordinate its efforts with local organizations such as Zuni and McKinley Recycling and Arizona. Currently, 57 Navajo Chapters located within Arizona have the toll free telephone number of a recycling avenue provided by the State of Arizona using the zip code as a key identifier in the menu process after calling the telephone number of 1-800-CLEANUP (1-800-253-2687). All Navajo Nation communities can gain further solid waste information from the “Keep American Beautiful, Inc., Order Department, 9 West Broad Street, Stamford, Connecticut 06902” for free copies of “Take Care of America,” and “Tips for Preventing Litter in Your Community”.

In comparison to similar sized municipalities of border towns to Navajo Nation, the following larger populated Navajo Chapter communities have similar waste streams: St. Michaels/Window Rock, Kayenta, Tuba City, Chinle, Arizona, and Crownpoint and Shiprock, New Mexico.

In referencing the amount of solid waste generated each year within a municipality in millions of tons of the nine (9) areas of products considered for recycling or composting, the available markets or agricultural processes are developed through businesses who possess the technology. It is possible Navajo Nation can possess the same market avenues, if a business so chooses to initiate a market for any of these products. The chart below demonstrates how the new technology of different products (tons per year) is recycled or composted (%) from a city in comparable size to a large Navajo Chapter in percentage (%).

90 Paper 80 Yard 70 60 Plastics 50 Food 40 Metals 30 Textiles 20 Glass 10 Wood 0 Tons ("C") % City Tons ("N") % Navajo Other

A comparable sized city vs. any large Navajo Chapter community, and how recycling or composting has been more advantageous for a city.

Vehicle tires are a current problem with the nearest market that purchases tires being in the Phoenix, AZ area. Recycling of tires through bailing does offer some secondary uses in erosion control and stream bank stabilization, if they are suitably covered with an outer shell that will not deteriorate. Additionally, changes in the recyclable materials market often make consistent demand for these materials problematical. The NNSWA Board will have to make decisions with regard to what materials they will want to handle and how much of the Authority’s budget can be spent on uneconomic recyclable collection in order to foster the good will of the Navajo Nation residents that want to participate in these programs.

In addition to recycling municipal solid waste, the NNSWA, through the education programs, will encourage waste reduction and reuse. Waste reduction is the process of selecting products for purchase that result in minimal waste being generated. Reuse is the process of utilizing containers that normally would be discarded for other uses. Examples of reuse would be using baby food jars for craft part storage and reuse of plastic and paper garbage containers when returning to the market for the next week’s groceries. The United States waste stream studies indicate that there is the potential for a two percent reduction in the total waste tonnage if the population was willing to reuse containers.

Estimating the tonnages of potentially recyclable materials on the Navajo Nation is a difficult process because of the uniqueness of the waste stream, i.e. minimal yard waste, and the distances that materials have to be transported both on the Navajo Nation and to recyclable markets. The recycling industry estimates that up to 25 percent of the waste stream in the United States is potentially recyclable. On the Reservation, a more realistic estimate of 10 percent of the waste stream as being recyclable. Based on Table 22 findings, and assuming the total current waste stream for the Navajo Nation is 242,405 tons per year, then just over 15,000 tons per year of recycled waste per year could be collected. This waste tonnage goal would represent one transfer trailer load of waste per day, every day.

Recycling drop-off containers at collection points and transfer stations could be used as sites for rural residents to bring their recyclables. In the larger populated communities, individual residences could be supplied with appropriate recycling containers and these items could be collected bi-weekly using specialized waste collection vehicles. Home pick-up of recyclables could be effective in Arizona and New Mexico. Again the expenses related to residential recyclable pickup would represent a significant investment for the NNSWA and would probably not be an economically viable enterprise. The NNSWA could coordinate its efforts with local community recycling programs so that it would not have to assume the entire financial costs of subsidizing these programs.

Composting is an excellent method of reducing yard waste from filling up landfills in many communities across the United States. Yard waste is not a large component of the waste stream on the Navajo Nation. Composting concepts can be introduced as part of the education program for local projects aimed at developing better soil for gardens and agriculture. Composting concepts add to the general awareness of the community to the types of waste they generate and alternative methods to disposal. Within the Navajo Nation, the following locations have conservation programs under the Natural Resources Conservation Program to reuse tree branches/limbs for rock and brush dams: Chinle, Kayenta, St. Michaels, Tuba City, Arizona; and Crownpoint and Shiprock, New Mexico.

As previously mentioned, the NNSWA’s Recycling Coordinator will have responsibility for evaluating the potential for recycling on the Navajo Nation, making recommendations to the Director and the Board and implementing those programs that are deemed viable for the Navajo Nation. The Coordinator will also have responsibilities for developing informational and educational programs regarding the NNSWA’s Recycling Program. The Coordinator and the Community Relations Spokesperson would provide a presentation on the recycling program to localized interest groups. The Coordinator would also have responsibility for centralization of recyclable materials and providing a safe storage site for these materials until sufficient tonnages can be assembled for economic transportation. Often, undeveloped portions of landfill sites are excellent locations for recyclable storage. If the NNSWA’s Board decides that residential recycling pickup is viable then additional containers and recycling vehicles purchased and recycling waste collection personnel hired.

In comparison to large urban areas within the United States for major cities, recycling facilities are built due to the large waste tonnage per week and the funding mechanisms are more readily available in comparison to rural and tribal Nations. Costs development for these large cities studied would have the associated costs: $16 million for a landfill; $18 million for curbside pickup of household waste; $19 million for expanded recycling infrastructure; $21 million for recycling and composting; and $25 million for waste to energy facilities. One type of waste to energy is utilization of the built-up methane gas from the leachate collection of older waste cells from an older landfill, such as the Salt River Pima- Maricopa Indian Community that has incorporated this type of infrastructure to supply energy to approximately 3,000 homes. Another waste to energy infrastructure utilizes combustion of daily waste but the facility must have a constant daily tonnage, i.e., 22,000 tons per week. Any Navajo Nation Agency could consider this combustion type of energy source if they have a waste stream to maintain a goal tonnage per week to a central location but all laws and regulations would have to complied with including the federal Clean Air standards.

36.0 Household Hazardous Waste

Residential and commercial enterprises use commonly purchasable materials such as paints, cleaners, oils, batteries and pesticides contain chemically hazardous materials. Typical homes in America contain an average of 100 pounds of stored hazardous materials. Containers containing variable quantities of these hazardous materials are either disposed of illegally by pouring them on the ground or illegal dumping. More common hazardous household wastes are deposited along with the regular municipal waste. Navajo Nation Solid Waste Regulations waste disposal regulations specifically prohibit hazardous materials from being deposited in solid waste municipal landfills. It is often difficult for landfill workers to spot some of these materials before they find their way to the landfill and eventually into the leachate fluids generated within the landfill. Signs, written both in English and Navajo, should be placed at transfer stations and drop- off points, which clearly indicate what materials cannot be deposited and who to contact if they need assistance.

Transfer station and landfill workers often find these hazardous materials in the waste or have them left at solid waste facilities. The NNSWA will have to develop a program for securing the hazardous wastes until the NNEPA can supervise the proper disposal of these items. The NNSWA and NNEPA will have to cooperate on joint policies and procedures for handling these wastes.

One of the best solutions for intercepting these small quantities of hazardous materials is a community awareness program to let people know what is not supposed to go into the landfill. Household hazardous waste awareness should be included in the informational and educational programs sponsored by the Authority. Special hazardous waste drop-off days can be coordinated with the NNEPA to try to generate sufficient quantities of these materials to reduce transportation costs. The NNSWA and the NNEPA will also need to encourage local businesses that sell automotive fluids, batteries and tires to accept these wastes for recycling.

37.0 Community Participation Summary

The NNSWA is clearly going to have to take a proactive approach to getting the local community involved in the waste collection and disposal process. Information and education programs should be aimed at garnering support for the cessation of illegal dumping on the Reservation and the use of provided waste collection systems. The Authority will have to make a commitment to establishing recycling programs to further involve the Navajo Nation residents in the waste reduction process. It is recommended that the Authority secure the services of a Recycling Coordinator and provide sites for recyclables at its infrastructure facilities.

The hiring of a Community Relations Spokesperson should also be an important item for consideration by the NNSWA Board, as this individual will be primarily involved with the educational programs developed to foster community support for cooperation with the Authority. Household hazardous waste collection programs developed with the NNEPA will also get the community involved in reducing the potential for illegal disposal of these materials.

The development of a community relations program is one that will require a long-term commitment by the NNSWA. The education program aimed at younger students will require periodic reinforcement and involvement.

38.0 Summary and Recommendations

The following paragraphs summarize the key findings of the studies of the current solid waste disposal system on the Navajo Nation and potential alternatives to having the municipal waste transported off-Reservation for disposal. Recommendations are also made for the development of a Navajo Solid Waste Authority and the solid waste infrastructure necessary to economically collect, transport, and dispose of the solid waste generated on the Navajo Nation. 38.1 Summary

At the present time there are no permitted solid waste disposal facilities on the Navajo Nation. Waste is transported off the Navajo Nation to four primary RCRA-permitted landfills: Cinder Lake near Flagstaff, AZ, Red Rocks Regional Landfill, near Thoreau, NM, Crouch Mesa near Farmington, NM and the Painted Desert Landfill near Joseph City, AZ. Smaller volumes of waste are being transported to the permitted White Mesa Landfill in San Juan County, Utah, Blue Hills in Arizona, and Sandoval County, Cerro Colorado and Socorro Landfills in New Mexico. Some waste is being transported to the Hopi Landfill. The average tipping fee for the off-Reservation landfills was $24.60 per ton in late-2000. There are twenty-eight (28) primary transfer stations in operation on the Navajo Nation. Most of these facilities are open-topped 30-cubic yard containers located near population centers. Transfer station operation ranges from local Chapters to County and regional agencies.

The primary sources of municipal solid waste on the Navajo Nation are individual residences (42%), commercial establishments (22%), schools (27%), hospitals (5%) and governmental facilities (4%). The known total tonnage of waste leaving the Navajo Nation is 242,405 tons per year as shown in Table Twenty-Three, in comparison to the estimated population tonnage of 108,423 in 1996. The solid waste does not take into consideration the amount of construction debris accumulated and disposed of each year but does significantly give a higher percentage of waste than residential areas. In the most recent cost estimate, the total estimated off- Reservation landfill tipping fees were more than $11 million. Approximately 84,081 tons of solid waste is unaccounted for, which would include an additional estimated $2.5 million dollars to the $11 million, thereby exceeding $13.5 million per year if all solid waste would be taken off Navajo Nation, with no illegal dumping.

The methodology used to analyze the current waste collection process on the Navajo Nation and to make future recommendations was to establish the cost to haul the waste and determine the transportation corridors the waste would be transported on. Transportation costs were established for two different sized packer trucks, roll-off trucks and transfer trailer systems. Transport costs for the following four different waste transport models were developed:

• Chapters to Off-Reservation Landfills • Central Transfer Stations to Off-Reservation landfills • Central Transfer Stations to Navajo Nation landfills • Chapters to Navajo Nation landfills

The transportation cost studies that the use of central transfer stations and Navajo Nation landfills was the most cost effective method to reduce waste transportation costs.

Solid waste facility infrastructure construction and operational costs were developed for three different sized central transfer stations with capacities ranging from 250 to 850 tons per week. Costs were also established for the location, permitting, construction, operation and closure of a 30,000 and 50,000 ton per year RCRA-compliant municipal solid waste landfill. Administrative costs for the establishment of a Navajo Solid Waste Authority administration building and staff were also developed. The solid waste infrastructure costs were then applied to the four different waste transport models to determine how solid waste infrastructure costs impact the transport cost models. Based on the most recent costs, the use of central transfer stations to haul waste to off-Reservation landfills is the highest cost option at $5.3 million per year. The most cost effective waste transport and disposal model at $4.2 million per year is the direct haulage of waste from individual Chapters to landfills located on the Navajo Nation. Several options were considered to split the waste stream between Agencies to take advantage of cheaper operational costs by creating larger landfills and reducing transportation costs.

Schedules were developed for the siting, permitting, design, construction and operation of solid waste infrastructure facilities. Assuming the decision was made to proceed with the formation of a Navajo Nation Solid Waste Authority in the Fall of the first year, it would take four additional years to have the landfills, central transfer stations, administration building and waste transport vehicles in place so that the Navajo Nation could take complete control of the waste collection and disposal on the Reservation.

In order to help reduce illegal dumping on the Reservation and promote the use of the Navajo Nation’s new solid waste system, a Community Relations and Participation Program was outlined. The Community Involvement Program would involve Navajo residents in educational, recycling and household hazardous programs.

38.2 Recommendations

The Navajo Nation should consider the following recommendations to implement a Long-Range Comprehensive Solid Waste Management Plan for the Reservation.

Navajo Nation Solid Waste Authority (NNSWA)

The Navajo Nation should proceed with the approval and formation of the NNSWA whose purpose would be the management of municipal solid waste collection, transportation and disposal of waste generated on the Reservation. An Executive Board appointed by the Navajo Nation President would manage the Authority and also work with the Navajo Nation in developing a budget and funding mechanisms to fund the waste collection and disposal operations.

An Advisory Board should represent other interested Navajo Governmental Agencies, such as the Indian Health Service, Bureau of Indian Affairs, and Division of Community Development. Additional Board members should represent those governmental entities that elect to participate with the Navajo Nation in the formation of the Authority. Suggested additional members should represent, Coconino, Apache, and Navajo Counties in Arizona; San Juan and Sandoval Counties in New Mexico; San Juan County, Utah; and the Northwest New Mexico Regional Solid Waste Authority.

The initial task for the Authority Board will be the selection of an Executive Director of the Authority whose responsibilities, with Board approval, will include the development of the solid waste infrastructure, management of the solid waste system and the direction of the operational staff.

Solid Waste Infrastructure

Western Agency:

For the Western Agency, the NNSWA will have two major options to consider with regard to the location of a regional landfill in the western portion of the Navajo Nation. If a landfill was located in the Kaibeto area to provide an economic alternative for disposal of waste from the Page, Arizona area, then waste from the Agency Chapters should be hauled to this facility using currently used waste transport.

If the regional landfill is located in the Chinle Agency, then the Authority should locate a central transfer station at Tuba City. The waste from the Tuba City area would be hauled to the Cinder Lake Landfill with transfer trailers. The waste generated at the southernmost Chapters would be hauled directly to Cinder Lake, Flagstaff, AZ. Waste from the Chapters in the Kayenta Area could be hauled directly to a regional landfill in the Chinle Agency.

Chinle Agency

The Authority should locate, permit and operate a municipal solid waste landfill in the eastern portion of the Chinle Agency. The size of the landfill would be dependent on how much waste is received from the Western and Fort Defiance Agencies that would be directed to this location. Waste from the Chinle Agency Chapters would be hauled directly to the Agency Landfill. A possibility of more than one landfill to be located within this Agency is possible, and could be developed as part of a small municipal solid waste landfill operation and permitted by USEPA.

Fort Defiance Agency

Waste from the Fort Defiance Agency Chapters located west of the Defiance Plateau should be hauled directly to the Chinle Agency Landfill. There is sufficient waste generated in the eastern one-third of the Fort Defiance Agency to locate a municipal solid waste landfill near the Fort Defiance or St. Michaels Chapters. Because of the sensitivity of locating a landfill near Window Rock and the Fort Defiance area, it may be necessary to construct a more costly central transfer station in this area and haul this waste to either the New Mexico or Painted Desert Landfills. A possibility of more than one landfill to be located within this Agency is possible, and could be developed as part of a small municipal solid waste landfill operation and permitted by USEPA.

Shiprock Agency

The cost effective waste disposal alternative for the eastern Chapters of the Shiprock Agency is to locate, permit, construct and operate a municipal solid waste landfill near Shiprock. This option would be more viable if the Navajo Nation looses the cost sharing with San Juan County. Assuming that San Juan County, New Mexico continues to contribute its 50 percent share of the costs to operate the transfer stations located in the Agency, it would be economically advantageous to continue to have the Chapters, located in San Juan County, have their waste hauled to the Crouch Mesa Landfill. Shiprock Agency Chapters located in Arizona and Utah should have their waste hauled to either the White Mesa Landfill in Utah or the regional landfill that should be located in the Chinle Agency. A possibility of more than one landfill to be located within this Agency is possible, and could be developed as part of a small municipal solid waste landfill operation and permitted by USEPA.

Eastern Agency

The Red Rocks Landfill is located near the waste generation central area of the Eastern Agency and the waste from the Chapters near this landfill should continue to be disposed at this facility or at the McKinley County Transfer Station located in Gallup, New Mexico. Municipal solid waste generated at the Chapters in the northern part of the Agency should be transported to Crouch Mesa for the Chapters located in San Juan County, New Mexico. The Authority will need to coordinate with Sandoval County to develop a workable solution for the economic disposal of waste from the smaller Chapters located in the eastern portion of this Agency. The waste from the Ramah Chapter should continue to be hauled from their transfer station to the Red Rock Regional Landfill, Thoreau, New Mexico. The Ramah Village, Ramah, New Mexico also has a transfer station that the village is hauling independent of the Ramah Chapter transfer station to the Red Rock Regional Landfill. The waste from the Tohajiilee Chapter should continue to be hauled to the Cerro Colorado Landfill, Bernalillo, New Mexico.

Capital Requirements and Potential Funding

In order to fully implement this comprehensive Long-Range Solid Waste Management Plan and to construct three landfills, one central transfer station, and an administrative building and purchase the necessary waste collection and haulage equipment, it will be necessary to have $13,700,000.00 in funding available. The annual cost for this program, including construction, operation, administration, vehicle replacement, facility expansion and closure would cost $4,000,000.00 per year. A smaller scale solid waste agency operating one landfill, collection and transport vehicles and an administration building would need $6,000.000.00 in start-up costs. Annual construction and operational cost for waste hauling and operating a single landfill and administration system would be $2,300,000.00 per year. Start-up funding would undoubtedly be derived from a combination of Navajo Nation-backed loans and governmental grants. This could include any of the following funding sources:

• Solid Waste Grants and Others – - U. S. Environmental Protection Agency - U. S. Department of Agriculture – Rural Development - U. S. Housing and Urban Development - U. S. Department of the Interior - U. S. Inter-Agency Open Dump Cleanup Grant - Arizona Department of Environmental Quality - New Mexico Environment Department - Utah Environmental Department - Private foundations - Commercial Bank Loan(s) - Navajo Nation Taxes (1/2 to 1%); and/or - Undesignated Navajo Nation Reserve

Governmental and private commercial waste pickup and disposal contracts for the Navajo Nation are conservatively estimated at $4,995,000.00 per year. Current cost sharing programs and Chapter-related waste hauling costs can easily elevate the current available waste spending to over $6,000,000.00 per year which would be more than is needed to run the solid waste program on an annual basis. In order to be able to secure the governmental and commercial waste contracts the NNSWA would have to be able to competitively underbid the current commercial waste haulers. Lower solid waste costs for governmental agencies and commercial establishments would potentially make commercial enterprises more profitable and make more governmental funds available for other tribal programs.

An alternative approach to implementing a Reservation-wide solid waste pickup and collection program would be for NNSWA to administratively manage the program, but competitively bid out the construction and operation of the Navajo Nation Landfills, waste collection facilities and waste pickup. The outsourcing of the details of the solid waste program would allow a company with solid waste experience to operate the system with Navajo Nation oversight.

Additional Recommendations

Because of the time involved in the locating, permitting, design and construction of solid waste infrastructure facilities, it is imperative that an early decision be made by the Navajo Nation to proceed with the recommendations of this Comprehensive Solid Waste Management Plan.

The success of the Solid Waste Authority in developing facilities that are accepted by the residents of the Reservation will be dependent largely on the part of a successful Community Relations and Involvement Program that will help to maximize proper disposal of municipal solid waste and discourage illegal dumping.

ACKNOWLEDGEMENTS:

Contractor: The Northwest New Mexico Regional Solid Waste Authority Subcontractor: Jacobson Helgoth Consultants

The following entities contributed information and oversight for Northwest New Mexico Regional Solid Waste Authority’s subcontractor to compose the information for the Plan.

Navajo Nation Division of Community Development – Solid Waste Management Program

Navajo Nation Environmental Protection Agency

Navajo Nation Land Administration

Navajo Nation Department of Justice

Navajo Housing Authority

U. S. Department of the Interior – Bureau of Indian Affairs, Navajo Regional Environmental Services

U. S. Department of Health and Human Services – Indian Health Service, Navajo Area