2016-302 WHATCOM COUNTY COUNCIL AGENDA BILL NO.

CLEARANCES Initial Date Date Received in Council Office AKendaDate Assi}{ned to:

Originator: JAH 8/3112016 10/11/16 Finance/Council ·-. r Division Head: [J) JW 8131/2016 rr:::,~VJIt; - ~Pi I Dept. Head: RAD 912/2016 0 4 2016 - Prosecutor: tt-Jq- I .. (J ~~ WHA1COM COUNTY - Purchasing/Budget: ~ A COUNC\L &e'""w ~'J V__,.~vto/:>11& TITLE OF DOCUM NT: Draft 2016 Whatcom County Comprehensive Solid and Hazardous Waste Management Plan Update

ATTACHMENTS: 1. Cover Memorandum 2. Draft 2016 Whatcom County Comprehensive Solid and Hazardous Waste Management Plan Update 3. Response to Comments 4. Resolution ofAdoption

SEPA review required? (X ) Yes ( ) NO Should Clerk schedule a hearing? ( ) Yes (X ) NO SEPA review completed? (X ) Yes ( ) NO Requested Date: September 13,2016

SUMMARY STATEMENT OR LEGAL NOTICE LANGUAGE: (If this item is an ordinance or requires a public hearing, you must provide the language for use in the required public notice. Be specific and cite RCW or WCC as appropriate. Be clear in explaining the intent of the action.)

Chapter 70.95 RCW, Solid Waste Management- Reduction and Recycling requires local jurisdictions to update comprehensive solid waste management plans every five years. The 2016 draft update to the existing plan describes the current solid waste system and makes recommendations for the planning period. The draft update has been reviewed and approved by the Solid Waste Advisory Committee and Solid Waste Executive Committee, received review and comment by the Department of Ecology and WUTC, and received public comment through both SEP A and separate solid waste program required reviews. Pending council review and approval, the draft update will be submitted to Ecology for final post-adoption approval as per RCW 70.95.

COMMITTEE ACTION: COUNCIL ACTION:

Related County Contract #: Related File Numbers: Ordinance or Resolution Number:

Please Note: Once adopted and signed, ordinances and resolutions are available for viewing and printing on the County's website at: www.co.whatcom.wa.us/council. WHATCOM COUNTY Regina A. Delahunt Health Department Director Greg Stern, M.D. Leading the community in promoting health and preventing disease.

TO: Jack Louws, County Executive llJl) FROM: Regina Delahunt, Director

DATE: September 1, 2016

SUBJECT: Draft Whatcom County 2016 Comprehensive Solid and Hazardous Waste Management Plan Update

Please find attached an Agenda Bill and copy of the Draft Whatcom County 2016 Comprehensive Solid and Hazardous Waste Management Plan Update for council review and approval by resolution.

Chapter 70.95 RCW, Solid Waste Management- Reduction and Recycling requires local jurisdictions to update comprehensive solid waste management plans every five years.

The draft update to the existing plan describes the current solid waste system and makes recommendations for the planning period. The draft update has been reviewed and approved by the Solid Waste Advisory Committee and Solid Waste Executive Committee, received review and comment by the Department of Ecology and WUTC, and received public comment through both SEPA and separate required solid waste program reviews. The Response to Comments summary is also attached.

The final draft update proposes no structural changes to the existing solid waste system. Recommendations, presented as goals and actions, are provided in summary form in tables at the end of each applicable chapter, as indicated in the plan table of contents. Primary goals and actions include increasing waste reduction and recycling community education and outreach, evaluation of regulatory changes to increase efficiency and management, supporting emergency management efforts to develop a disaster debris management plan, engaging with specific communities such as Pt. Roberts to identify potential improvements to levels of service, and increasing management options for special wastes such as organics, construction debris and waste pharmaceuticals.

Pending council review and approval, the draft update will be submitted to Ecology for final approval, as per RCW 70.95.

Please call Jeff Hegedus at ext. 6044 if there are any questions. Thank you.

509 Girard Street 1500 North State Street Bellingham, WA 98225-4005 PUBLIC HEALTH Bellingham, WA 98225-4551 l],tVV.-:tYS V;fc{HHiH~G fEH'? A. SAJT.f{ tk.N~} (360) 778-6000 HEALTHIER WHATCOM COUNTY (360) 778-6100 FAX (360) 778-6001 www.whatcomcounty.us/health FAX (360) 778-6101 (j WhatcomCountvHealth WhatcomCoHealth PROPOSED BY: ______INTRODUCED: ______

RESOLUTION NO. ____

A RESOLUTION ADOPTING AN UPDATE TO THE WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN

WHEREAS, Chapter 70.95 RCW, Solid Waste Management- Reduction and Recycling requires local jurisdictions to update comprehensive solid waste management plans every five years; and

WHEREAS, the approved 2008 Whatcom County Comprehensive Solid and Hazardous Waste Management Plan requires updating; and

WHEREAS, the Whatcom County Health Department Solid Waste Division, working in conjunction with the Solid Waste Advisory Committee, has drafted an update to the plan; and

WHEREAS, the draft update to the plan is in compliance with SEPA requirements, and has received a Determination of Non-Significance; and

WHEREAS, the draft update to the plan has received preliminary review and comment by the Department of Ecology; and

WHEREAS, the draft update to the plan has received review and comment by the Washington Utilities and Transportation Commission; and

WHEREAS, the draft update to the plan has received public review and comment through two advertised public comment opportunities, in addition to Solid Waste Advisory Committee participation; and

WHEREAS, all public, agency and committee comments to the draft update to the plan have been considered and incorporated; and

Page 1 WHEREAS, on July 19, 2016 the Solid Waste Executive Committee, comprised of the Mayors and County Executive, as per interlocal agreement, unanimously approved a recommendation to submit the draft update to the plan to the Whatcom County Council for approval;

NOW, THEREFORE, BE IT RESOLVED by the Whatcom County Council that it adopt the 2016 Whatcom County Comprehensive Solid and Hazardous Waste Management Plan, attached hereto and by this reference incorporated herein, as an update to the 2008 Whatcom County Comprehensive Solid and Hazardous Waste Management Plan.

BE IT FURTHER RESOLVED that the adopted plan shall be submitted, as required by law, to the Washington Department of Ecology for post-adoption final review and approval.

APPROVED this __ day of ____, 20_.

WHATCOM COUNTY COUNCIL ATTEST: WHATCOM COUNTY, WASHINGTON

Dana Brown-Davis, Clerk of the Council Barry Buchanan, Council Chair

Page 2 Whatcom County Response to Comments Preliminary Draft Revision Dated July 16, 2015 Comprehensive Solid and Hazardous Waste Management Plan Whatcom County, Washington

Ed Nikula, Whatcom County Solid Waste Advisory Committee Received July 20, 2015 1. I have reviewed the plan and only one question. In Appendix E, table 4.1.1 Recomps tons are shown as about 11,000. Is this county tons only and excludes City of Bellingham? Response: The 11,663.25 tons presented in the Cost Assessment Questionnaire Table 4.1.1 is the total quantity of solid waste handled, as reported by RDC as per WAC 173-350-3/0(d), Intermediate solid waste handling facilities, at their permitted solid waste handlingfacility.

Amber Jones, Whatcom County Solid Waste Advisory Committee Received July 22, 2015 1. Sections 1.2.4 and 6.1. Remove 'with the exception of Bellingham' as we do offer a 32 gallon service to those customers as well. Response: "... with the exception of Bellingham" will be removed from the text in both sections.

2. Section 1.8.1. Date should be changed to July 2015. Response: Based on the uncertainty at this time as to when local adoption will occur, the end date of the plan update process will be removed from the section.

3. Table 8-1, Goal2.A. Sham recycling is still not defmed correctly. The issue isn't recyclables being hauled to a landfill, the issue, which costs the county $8.50 per ton, is sham recyclers (companies that can only legally haul recyclables) illegally hauling garbage and calling it recycling. Response: Action 2.A will be revised to state "Investigate service provider compliance with applicable requirements to determine if there is an issue of illegaljy hauling solid waste under the guise of reryc!ing, and enforce requirements as applicable. "

4. Table 4-2, Goal3.B. SSC offers free waste audits; additional assistance with follow up on more properties is likely to increase participation and diversion. Response: While sse mqy be providing this service, it mqy not be provided !)!Stem-wide. Goal and associated actions developed by the SWAC Subcommittee and previousjy approved by SWAC remain valid. Action 3.A will be revised to state "Create or expand programs to provide ... "

5. Table 4-2, Goal 3.C. SSC now uses photo labels on multi-family recycling containers, and offers Spanish & Russian decals by request. Response: While sse mqy provide this service, it mqy not be provided !)!Stem-wide. Goal and associated actions developed by the SWAC Subcommittee and previousjy approved by SWAC remain valid.

6. Table 4-2, Goal 3.D. The current schedule is EOW across the system, and customers who want weekly pick-up can request it at additional cost. Response: The SWAC Subcommittee developed Action 3.D as a means of ensuring that the focus remains on means of improving multifamilY reryc!ing; action remains valid.

Response to Comments 1 Whatcom County CSHWMP,July 16,2015 Revision 7. Section 5.1.1. Some areas in the east county don't have a F+ option either. Response: Text will be added to the section indicating that curbside collection is not available in some portions of eastern Whatcom County.

8. Glossary -The source for legally or legislatively deftned terms in this glossary are: Response: The source ofglossary terms is Appendix A (Glossary of Terms and List of Acronyms) of the Department of Ecology's Guidelines for Development of Local Comprehensive Solid Waste Management Plans and Plan Revisions, Publication No. 10-0 7-005. A footnote to the glossary will be included that states the source.

9. Section 2.3.1. The source(s) for the following deftnitions is/ are: [they can supply citation(s)] Response: The source of difinitions is Appendix A (Glossary of Terms and List of Acronyms) of the Department of Ecology's Guidelines for Development of Local Comprehensive Solid Waste Management Plans and Plan Revisions, Publication No. 10-07-005.

10. Section 3.2. It should be noted that with contamination losses at <1 %, Whatcom County's effective recycling diversion per capita is actually signiftcantly higher than the state average, where contamination and processing losses from single stream recycling approach 25% by weight. Response: Comment will be incorporated into Section 3.2.

11. Section 4.2.2. While additional outreach will be helpful, it should be noted that the local multi­ family program is now, and has been very successful since 1992. Over 95% of all multi-family complexes participate, with an average 30% recycling rate, and a contamination rate below 5%. These numbers are better than virtually all states in the nation achieve for single family curbside. Response: Comment will be incorporated into Section 4.2.2.

12. Section 8.1.5. The Washington Refuse & Recycling Association did, and can in the future cooperate through equipment and manpower sharing during manmade and natural disasters, to provide safe and effective handling of larger quantities of solid waste than normal. Response: Comment will be incmporated into Section 8. 1.5.

13. Table 8-1, Goal2.A. Sham recycling is the act of hauling material for disposal, when the service has been represented to the original customer as being recycling. This includes the hauler allowing the customer to place non-recyclable material in the supposed recycling container. Response: See response to Amber Jones Comment No. 3.

14. Section 9.1.3. Each ton of contaminated CDL or sham recycling bypassing Whatcom County transfer stations results in the loss of$8.50/ton in County solid waste tax revenues. Response: Noted Comment is Jair!J specific relative to a section that provides a general discussion on waste management J)Stem financing.

Response to Comments 2 Whatcom County CSHWMP,July 16,2015 Revision Polly McNeill, Attorney representing Sanitary Service Company, Inc. Received July 23, 2015 1. Section 9.1.2: This section should state, "The Flow Control Ordinance's designation of specific facilities has no legal significance, because it was determined to be unconstitutional by a federal magistrate." Simply taking out the inaccurate statement that the FCO does not designate specific facilities is simply not enough, given the fact that the code language is still on the books. This situation is alluded to in the Financing discussion, and should be explicitly stated here in the section about the FCO itself because otherwise the entities operating under the current system appear to be in violation of County code. Response: Noted. An additional action 1.D will included stating that the county flow control ordinance will be reviewed and updated.

2. Section 8.2.1: Even though the flow control ordinance exempts C/D waste, state law still requires that it be hauled by the certified/ contract company. According to the numbers in the Plan, C/D waste contains 11 percent residual waste and is not recyclable material. Following, "This amendment allows disposal of C/D waste at undesignated disposal sites, including site outside the county," the section should state, "Collection of such waste by unauthorized haulers results in illegal diversion of C/D waste and loss of excise tax funds to the County." Response: Noted. As stated above, potential flow control and sham rerycling issues will be investigated, reviewed and responded to in the planningperiod.

3. Section 9.2 should include the following: "Under current conditions, the County is losing excise tax funds through loopholes in the system. One is that C/D waste is being delivered to out of county facilities following collection by unauthorized waste haulers. Another is that services being misrepresented to customers as recycling result in C/D waste being hauled for disposal without collecting or remitting the excise taxes due." Response: Noted. As stated above, potential flow control and sham rerycling issues will be investigated, reviewed and responded to in the planningperiod.

4. Table 9-1 should include a Goal to "Reduce the diversion of excise funds from the system" and the related actions should include, "Monitor hauling C/D waste out of the county" and "Police construction job sites to ensure proper C/D waste handling practices." Response: As stated above, flow control and sham rerycling issues will be reviewed and investigated.

5. In Table 6-1, the Goal is to, "Ensure that collectors are providing the required minimum service to all providers," by taking action to, "Investigate complaints regarding collection services and correct deficiencies." Yet there is nothing about current conditions suggesting any concern that minimum service levels are not being provided, and we are not aware of complaints regarding legal solid waste collection services. A more meaningful way to state this is, "Ensure that collection of waste is being provided by authorized haulers." Response: Allgoals, including Goai1.A, JJ/ere developed through the SW:';4C Subcommittee and z•etted through the SWA C. Goal from a .rystem-wide perspective remains valid.

6. In Section 9 .1.1: A new sentence was added in the description of Cities, saying, "The City of Bellingham has a municipal contract with SSC for collection, and an independent disposal contract." The description should note that the contract is for residential customers, and commercial are still governed by WUTC regulations. Response: Comment will be incorporated into Section 9. 1.1.

Response to Comments 3 Whatcom County CSHWMP,July 16,2015 Revision Larry McCarter, Recycling & Disposal Service Inc. Received July 23, 2015 1. What SSC says about FCO is and isn't true. What is true is we need NEW disposal agreements between ALL disposal sites. Within the scope of those agreements we can agree to any level of recycling WE agree to be the right amount. We can agree to accept and recycle c/d waste too. And we can agree to pay a county tax for self haulers. Response: Comment noted.

Diana Wadley, Washington State Department of Ecology Received November 25, 2015 Procedural Items that Must be Addressed Prior to Plan Approval 1. Resolutions of Adoption: Whatcom County and the cities with interlocal agreements need to approve the updated comprehensive solid and hazardous waste management plan prior to Ecology's approval of the final draft. Please include a statement assuring that the plan acceptance process outlined in the interlocal agreement has been fulfilled. Response: Text will be added to Section 1.3 indicating that "Each participatingjurisdiction, as represented qy the Solid Waste Executive Committee through interlocal agreement, adopted this revision to the Plan prior to its approval qy Ecology. " Diana Wadley Comment on January 15, 2016 Revision Received February 17, 2016: Thank you. It also appears you'll have the traditional appendix with the actual resolution of adoptions (Append. C.), which is great. Response: No response necessary.

Items that Must be Addressed Prior to Plan Approval 1. Required: In various places in the plan, such as in section 1.3, section 6.1, in the WUTC Cost Assessment, and on the map on page 17, it is stated that the planning area of this plan does not include the eastern portion of the county, and that that portion of the county is included in the Skagit County plan. That is an incorrect, and Whatcom County needs to plan for its entire county. Please revise your draft accordingly to include the full county, including the populace, haulers, needs, etc. therein. Response: Because the Newhalem area is isolated from Whatcom County service provision qy geographical and transportation infrastructure constraints, solid waste management services are provided qy Skagit County service providers. To provide clarity and compliance with solid waste planning requirements, an action 1.E will be added to Table 9.-1 stating that "Pursue an interlocal agreement with Skagit County that difines and establishes solid waste planning and service provision responsibtlities in the Newhalem /Diablo area. " Diana Wadley Comment on January 15, 2016 Revision Received February 17, 2016: Thank you. Please pay attention to all areas of the plan pertaining to this. For example, looking at section 2.1 of the Track Changes version, it appears the sentence, "This portion of the county constitutes the solid waste management planning area and encompasses 755 square miles, including the incorporated municipalities of Bellingham, Blaine ... " needs changed, since your planning area is the whole county (minus about 25 square miles of reservation land). There is also a sentence in 2.1.1 that says, "The eastern portion of the county, not included in the study area, is typically mountainous." which will need the middle piece deleted. It would also be good to remove the "both the western and central portion of'' from this

Response to Comments 4 Whatcom County CSHWMP,July 16,2015 Revision sentence in section 1.3, "The Plan encompasses both the incorporated and unincorporated areas of the western and central portion of the county, with the exception of the Lummi and Nooksack reservations." Response: Comment will be incorporated as suggested.

2. Required: Please correct Figure 2, the map of the planning area to encompass the eastern portion of the county, and highlight to show the Nooksack and Lummi reservations. Response: Figure 2-1 will be revised to indicate the locations of the Nooksack and Lummi reservations. Please reftr to the response to Diana Wadlry Comment No. 1 (Items that Must be Addressed) regarding inclusion of the eastern portion of Whatcom County into the planning area. A Figure 2-2 will be added that shows the western portion of Whatcom County, including city limits, urban growth areas and rural areas, and tribal lands in greater detail. Diana Wadley Comment on January 15,2016 Revision Received February 17,2016: Great start, but I don't see a purple line that correlates with the "Planning Area" given in the legend. Please add it, and when you do so, please draw it such that it includes all county lands (including federal), but does not include tribal lands. Response: The purple 'Planning Area" line is embedded in the "County Boundary" line. The figure will be revised to make more discernible, and to make clear that tribal lands are not part of the Planning Area.

3. Required: While it is understood that the solid waste system in Whatcom County is almost fully privatized, the county must still look ahead and ensure adequate facilities are in place. Additionally, the County is still responsible for its closed solid waste handling facilities (landfills). Please discuss with greater specificity the projected waste in relation to facility capacities and capabilities, as well as post-closure needs, with an eye on the six- and twenty­ year planning horizons. For example, this could be expounded upon in section 2.3.8 and/ or section 7 .2. This will help you meet the requirements for: A six-year construction and capital acquisition program for solid waste handling facilities. (Note: The date of the first year referenced in the six -year capital and acquisition projection will also mark the beginning of the new five-year planning window. Looks like from the rest of the plan that you'd want the first year to be 2016.) The estimated long-range needs for solid waste handling facilities projected twenty years into the future. Response: Discussion will be included in Section 2.3.8 and Section 7.2, and an action added to Table 1-3 indicating that the County will work with the private solid waste service providers to ensure that each is completing planning to maintain service capacity over the planning horizon. Diana Wadley Comment on January 15, 2016 Revision Received February 17,2016: Adding the sentence, "The County will continue to work with the private solid waste service providers to ensure that facility capacity is constructed in advance of need." in section 2.3.8 is not specific enough. Please show you have already discussed the waste disposal and recycling projections with each of the major facility operators and that they have analyzed that information alongside their facility capabilities and given you feedback to either assure their ability to meet demand over the six-year horizon (2016-2021), or show their plans for (via capital or other major acquisitions they'll need) meeting demand, or if you'll need to explore other options. Please also show such analysis related to the longer 20-year timeline. We are not asking you to do a detailed analysis, but rather to use the waste projection data you already have in

Response to Comments 5 Whatcom County CSHWMP,July 16,2015 Revision section 2.3.8 to inform a discussion around upcoming facility or capital needs over the six- and twenty-year horizons. Response: The following will be added as the second to the last sentence ifSection 2.3.8 "Solid waste service providers were apprised ifthese waste prqjections throughout development if this revision if the Plan and have ensured the County that thry will continue to plan for and construct sufficient .rystem capacity in advance if need."

4. Required: Please distinguish how you designate an area "rural" or "urban" for the purposes ofRCW 70.95.090 (7) (b). The 2008 plan included a map for this. This information could come more into play as the eastern portion of the county comes into the fold. Looks like the Kendall-Maple Valley area and/or Limited Areas of More Intense Rural Development mentioned in 9 .2.1 could be unique, too. Response: Figure 2-2 will be added to the Plan (rifer to response to Diana Wadlry Comment No. 2- Items that Must be Addressed) that will show city limits, urban growth areas (including the Kendall-Maple Falls LAMRD), and rural areas consistent with the County's current zoning map. Diana Wadley Comment on January 15, 2016 Revision Received February 17, 2016: The proposed Figure 2-2 is a great start. Please show distinctly which of the Comprehensive Plan Designations given in the legend will be considered "rural" and which will be "urban" for the purposes of RCW 70.95.090(7)(b). All components of the map should be so specified, with the exception of tribal lands. Also please discuss how the updated map will correlate with the table and text given in Section 2.1.2.

Does Newhalem/Diablo have the minimum program for collection of source separated recyclable materials as defined for rural areas in RCW 70.95.090(7)(b)(i)? The final sentence in section 2.1.3 mentions "community services" as part of what's discussed in the Whatcom Co. Comp Plan updated in 2014. I would consider programs for the collection of source separated recyclables to be a kind of community service. However, looking at that plan, I see in Chapter 5 that it is pulling information from the 1999 SWMP (though they should've been utilizing the 2008 plan at that time). Please ensure that future Comp Plans pull from this updated plan, especially since the Whatcom Co. Comp Plan notes that Newhalem is excluded, but in reality it must be included. In the meantime, please discuss in this Solid Waste Management Plan update how the minimum programs for the collection of source separated materials from residences in urban and rural areas are being met. Response: Figure 2-2 will be revised to more clearfy designate "rural" and "urban" designations. Section 2.1.2 is specific to a description if the planning area- not services provided in that area; discussion related to source separation requirements in both incorporated and unincorporated portions if the county are presented in Section 4.1.1 (related to rerycling) and Section 5.1.1 (related to organics collection).

Diana Wadley Comment on January 15, 2016 Revision, Received March 21, 2016: Section 4.1.1, is lacking a description of recycling in the unique Newhalem/Diablo area. Since the Newhalem/Diablo area is not required to have curbside recycling service per Whatcom County's Solid Waste Collection District exclusion described in wee 8.11.010., please show readers that the area is meeting the minimum program for collection of source separated recyclables materials as defined for rural areas in RCW 70.95.090(7)(b)(i). My research concludes this area does meet the program requirements, as residents and businesses have the option to self-haul to local

Response to Comments 6 Whatcom County CSHWMP,July 16,2015 Revision recycling depots. Thus, you could insert the following into section 4.1.1 to satisfy this requirement, if you concur. It could fit at the end of the second paragraph under the "Residential Curbside Recyclable Collection" section.

"The unincorporated N ewhalem/Diablo area is serviced by Waste Management and has an exclusion from mandatory curbside recycling service per WCC 8.11.010. However, this area meets the minimum program requirements for collection of source separated materials as described in RCW 70.95.090(7)(b)(i) through recycling depots to which residents may self­ haul their recyclables." Response: Comment will be incorporated as suggested.

5. Required: Please include at least one example of each SWAC and SWEC minutes showing discussion of this plan. · Response: Copies ifSW AC and SWEC meeting minutes discussing the Plan revision will be included in Appendix C.

6. Required: WUTC Comments: The WUTC conducted a formal review of the Plan and forwarded their comments to Ecology and to the County in a letter dated September 10, 2015. The WUTC comment letter, assigned as an attachment to Ecology's comments, showed no actionable items, but still must be attached to your Final Plan. Response: Text will be added to Section 1.8.4 indicating that the W'UTC issued a letter dated September 10, 2015 indicating that it had no comments on the draft revision if the Plan,· the letter will be included in Appendix E.

Other General Comments 1. Mention of any contracts or agreements between the County and the private facilities that manage the county's solid waste would be helpful. Response: Reference to af!Y associated contracts/ agreements will be included in Sections 7.1.1 and 7.1.2.

2. Note that the State Plan has been published as of June 2015. Preferred names are the full name of The State Solid and Hazardous Waste Plan; Moving Washington Beyond Waste and Taxies or "the State Solid and Hazardous Waste Plan"

The 2015 state waste plan update contains 53 goals with 177 supporting actions. It looks like the column "Connecting to Beyond Waste" in the table at the end of most chapters is ready to be updated to match the now-published plan. For example, here's a goal from the State Plan that seems very applicable to table 3-1 of your plan: "Goal SW 4: Waste generation will be reduced throughout the system by both businesses and residents." Other goals/ actions from the state plan may also apply. Thank you for drawing connections between your plan and the State Plan! Response: Document will be revised to riflect 2015 adoption ofthe State Solid and Hazardous Waste Plan. Connections to the Bryond Waste Plan in the goals and actions tables at the end if each applicable chapter will be revised to accurate!J riflect the Priorities and Kry Principles presented in the Bryond Waste Plan; identification if each specific goal in the Bryond Waste Plan would make the goals and actions tables unwielc!J and mqy generate confusion in trying to tie each Whatcom Counry goal to all applicable Bryond Waste Plan goals.

Response to Comments 7 Whatcom County CSHWMP,July 16,2015 Revision 3. Figure 2-3 shows the Whatcom County Waste Stream Composition, but I had trouble finding the matching graph or data in the 2009 Waste Characterization Study (https:/ / fortress.wa.gov / ecy /publications/ summarypages/1007023.html ). Please cite the page and source of data. Additionally, as I looked at the 2009 Waste Characterization Study data for Whatcom County (fortunately for you the only sample area for the Northwest Waste Generation Area!), I became unsure that Whatcom is as similar to the rest of the state as said in this draft plan. On page two of the study is Figure 1: Overall Statewide Disposed. Figure 29 on page 69 of 2009 study shows overall NW and reveals that of all the areas, this study area has the highest organics, and that organics seems to be the largest difference between Whatcom and the other study areas. Table 38 on page 85 shows NW's residential data. It shows residential organics at 49.2%! And of that, vegetative food was the highest portion, followed by animal manure. I just wonder if this reveals an opportunity you might want to address in the plan. Response: Figure 2-3 was created using the data for all four quarters/ seasons specific to What~om County provided in the 2009 Stucfy.

4. Due to the online nature of most Solid and Hazardous Waste Management Plans today, please include links to items discussed when possible. Examples include studies and Whatcom County Code referenced, and online databases/ directories discussed. Response: Hyper/inks to on-line resources (e.g., Revised Code of Washington, Washington Administrative Code, Whatcom County Code, etc.) will be embedded in the document.

5. Please use "multifamily" instead of "multi-family," as that is how it is spelled in both County Code (8.10.060) and the Washington State Recycling Association study. Response: All references to "multifami!J" will be revised to "multifami!J."

6. Counties are encouraged to plan for disaster debris, whether within their solid waste management plans or via their emergency management teams. There is also a growing focus on this within the solid waste world as we are faced with increased severe weather events and seek solutions to mitigate climate change. An example of this is in the EPA's Sustainable Materials Management Program (SMM) Strategic Plan for FY 2017 - 2022 (see the built environment section): http: //nrcrecycles.org/mobius/nrcwp­ content/uploads/2015/02/SMM-Strategic-Plan October-2015.pdf Ecology is aware and supportive of the current disaster debris planning efforts by Wallace Kost of the Whatcom County Sheriffs Office. I would encourage inclusion of participation in that effort as a goal or action within this plan. Section 8.1.5 seems primed to discuss it. Response: Discussion will be added to Section 8. 1.5 and goal/ action associated with integration of waste handling and disposal if.forts with the Division ofEmergenry Management's emergenry response documents will be added to Table 8.3. Diana Wadley Comment on January 15,2016 Revision Received February 17, 2016: Thank you for the improvements to section 8.1.5. I ran this section by our specialist on disaster debris, who had some useful suggestions, including the below:

• You might expand language to include the Health Department as having a role in approval of suitable alternative staging areas. The Sheriff and Health Department will need to work together for approval. This is important because

Response to Comments 8 Whatcom County CSHWMP,July 16,2015 Revision FEMA will likely be asking if storage and management meets regulatory requirements. Federal reimbursement is usually tied to this.

• Because the work of "designating certain locations and facilities for accumulating large volumes of disaster debris ... " will occur later, I suggest leaving the door open to unusual, temporary sites. A text edit that could accomplish this may be, "Disaster debris will be managed through the appropriate existing facilities, including transfer facilities, permitted inert waste landfills, building materials recovery centers, and composting facilities as feasible. The County may also need to designate certain locations and facilities for accumulating large volumes of disaster debris."

• It is true that the Sheriff's Office is responsible for coordinating continuity of services (though local emergency management) but it is as a coordinating entity. The role of the Health Department should be identified this plan, including being at the table during response and recovery.

• The certificated haulers have the right to the waste in their territories. Emergency situations don't negate that and most franchise agreements include contingencies. Additionally, not all certificated haulers are WRRA members, including a couple of the larger ones. I would suggest editing your text to remove this mention of the WRRA, unless you're aware of services that I am not. Response: The Department ofEmergenry Management is active!J completing the disaster management plan, using the Snohomish County plan as a template. An update ofthis effort, and how it ties with solid waste, was presented to the SWAC during its January 2 8, 2016 meeting. Citation ofthe Health Department's involvement in emergenry response plannin.JY as well as designation oflocations for large volumes ofdisaster debris, will be included in the text. Riference to WRRA will be removed (note this was included per Amber Jones Comment No. 12).

7. The County's Flow Control Ordinance (codified within County Code 8.15) requires that solid waste generated in the county be processed or disposed of at a designated waste facility. It appears to me that the code gives a mechanism by which new facilities may be designated as part of the system (County Code 8.15.080). Would it be helpful to include the agreements executed per County Code sections 8.15.080 (D) and 8.15.060(B) to show which facilities are designated and their responsibilities? Response: Whatcom County Code 8.15.030 current!J designates disposal at the Recomp and Olivine facilities, both of which are no longer current. Table 9-1 will be revised to include update to WCC 8.15.030.E.

8. Diana Wadley Comment on January 15, 2016 Revision, Received March 21, 2016: We concur with the Polly McNeill Comment No. 1, in regard to the private solid waste facilities. Because the Point Roberts facility is on County property, however, it has the potential for flow control. Suggested text for the end of section 9.1.2 follows: "The Flow Control Ordinance's designation of specific private facilities has no legal significance, because it was determined to be unconstitutional by a federal magistrate." Response: Comment will be incorporated as suggested.

Response to Comments 9 Whatcom County CSHWMP,July 16,2015 Revision Updated Response: June 14, 2016. Upon further consideration and discussion with Diana Wadlry, the comment will not be incorporated. An additional action 1.D will be included stating that the county flow control ordinance will be reviewed and updated.

Other Specific Comments by Section 1. In the Acronyms and Abbreviations section, for MFS, I would suggest saying, "Minimal Functional Standards, such as those found in Chapters 173-304 and 173-350 WAC." Response: Comment will be incorporated as suggested.

2. In 1.1 and 1.4, it appears this is only a solid waste management plan. However, this is a joint solid and hazardous waste management plan. Please make that clear, even if by simply pointing the reader to Chapter 11. Response: Sections 1.1 and 1.4 will be revised to specify that planning associated with hazardous waste management has been in accordance with RCW 70.105 and is presented in Chapter 11.

3. In 1.2.5, are the five closed landfills the county landfills that are later referenced? Is so, you might clarify by adding the word "county." Also, "status" was spelled "statues." This section also says, " .. .in addition to several others regulated as MTCA sites." In Section 7.1.3, it says the two Y-Road closed county landfills are MTCA sites. Are there other landfills that are MTCA sites, and if so, should they be named as well? Or perhaps in this section you could limit to naming just the landfills accepting MSW and the closed landfills, and then provide greater detail in section 7.1.3 and point readers that way? Response: Comments will be incorporated as requested. Diana Wadley Comment on January 15,2016 Revision Received February 17,2016: Please further clarify the text in section 1.2.5. Specifically, if the two Y-road, county­ owned landfills are the only closed landfills in the county currently under MTCA process, you might consider the following text:, " ... While there are no active landfills, there are five closed county landfills maintained under permit in post closure status. Two of these landfills are regulated as MTCA sites (see Section 7 .1.3.)" Response: Text will be revised to read "Other closed lanrijills, such as the Y Road lanrijills, are regulated as MTCA sites (see Section 7.1.3)."

4. In section 1.3, the eastern portion of the county needs included, please. And regarding exclusion of the Nooksack and Lummi reservations, please show them (at least the Lummi) on the maps accordingly. Response: Please rifer to the response to Diana Wadlry Comment No. 1 (Comments that Must be Addressed Prior to Plan Approval).

5. In section 1.5, please update to show that the State Solid and Hazardous Waste Plan has been completed as ofJune 2015 (http:/ /www.ecy.wa.gov /wasteplan/index.html). Response: Comment will be incorporated as requested.

6. In section 1.6, it would be nice to have the names of the SWAC members by their positions (at the very least the subcommittee members).

Response to Comments 10 Whatcom County CSHWMP,July 16,2015 Revision Response: Do not concur. Section 1.6 describes the roles and make-up rif the SWAC and SU?EC and is meant to be applicable throughout the life rif the Plan. Given the limited nature rif committee service (less than the life rif the Plan), listing specific individuals in Section 1.6 is not appropriate. Please note that specific SWAC members that participated in revision to the Plan are listed on the Acknowledgements page rif the Plan.

7. Suggested rewording oflast paragraph of 1.8.4, mostly to avoid the word "amendment": "The County Health Department revised the Plan to address comments received from all parties. The revised preliminary draft was submitted to Ecology for its 120 day review and comment. Once the County incorporated Ecology's comments, the County carried out the local adoption process, including revisiting existing interlocal agreements .... (etc.)" Response: Comment will be incorporated as suggested.

8. In section 2.1.2, you say, "The U.S. Census defmes rural areas as... " did you mean to say "urban" here? Response: Concur; text will be revised to indicate "urban" rather than "rural. "

9. In section 2.1, are there any larger waste-generating industries to note in Whatcom County, such as food processors, oil refineries, or pulp and paper mills? Response: There are no industries operating that generate waste at quantities requiring specific planning relative to the countywide planning iffort.

10. In section 2.2, please note when the incinerators closed. Response: Year the last incinerator ceased operation will be included in the text.

11. In section 2.3.1, could note that waste reduction is sometimes called waste prevention. Response: Comment wzJI be incorporated as suggested. Diana Wadley Comment on January 15,2016 Revision Received February 17,2016: Thank you. A similar edit to the glossary's definition of "waste reduction" would be appreciated. Response: Comment will be incorporated as suggested.

12. In section 2.3.2, it would be helpful to clarify what kinds of waste you are talking about. For example, the total 311,842 tons is inclusive of tons recycled, diverted, MSW AND industrial and inert wastes. It's everything. The percentages given are again of everything. It also would be helpful to include the type of waste disposed at BP, Cemex, and Greater Wenatchee. Only MSW is mentioned in this paragraph, but these facilities take other types of waste. Note also that the Cowlitz County landfill mentioned in section 7 .1.1 is missing here.

Also missing is Graham Road Recycling and Disposal (from your list of where the 8% (of non-MSW) goes.

Thank you for including a complete list of facilities accepting various items, though. Such information may help inform people like Wally Kost working on the Disaster Debris Management Plan. Response: Comment will be incorporated as requested.

Response to Comments 11 Whatcom County CSHWMP,July 16,2015 Revision Diana Wadley Comment on January 15,2016 Revision Received February 17,2016: Thank you for adding in the Graham Road Recycling and Disposal facility. To add in the Cowlitz Co. Headquarters Landfill, we offer this text edit suggestion for section 2.3.2: " ... Most of the total solid waste generated in the county is MSW, with roughly 56 percent of total county wastes disposed of at Columbia Ridge landfill in Arlington, Oregon (RDS}, roughly 36 percent disposed of at the Roosevelt Landfill in Roosevelt, Washington (RDC), and a very small amount disposed of at the Headquarters Landfill in Cowlitz County, Washington." Response: Comment will be incorporated as suggested.

13. Table 2-8 reflects data from the Ecology Recycling Survey, which includes construction and demolition debris. Because construction and demolition tends to be a large and weighty portion of the waste stream, it is reasoned that much of the decline in tonnages during the recession was due to a slowdown in housing construction. . Response: Concur as text in accompanying Section 2.3.8 acknowledges the recession that began in 2008 as being a factor in the temporary decline.

14. The second paragraph of Chapter 3 gives two primary reasons for promoting waste reduction (reduce toxicity and reduce quantity of discarded materials). It does mention this "conserves natural resources," but I would encourage stronger language focused on this conservation piece, and a nod to the full life cycle of materials. We are seeing shift away from the traditional end-of-life focus, as seen in the new State Solid and Hazardous Waste Management Plan, which uses a "sustainable material management" lens. A key reason for promoting waste reduction/prevention is the avoidance of resource use and pollution associated with creating the materials in the flrst place (the "upstream" environmental costs.) From the new state plan: "To represent the current system and focus on reducing waste and toxics, we used a sustainable materials management approach, which is also used by the U.S. Environmental Protection Agency (EPA). The sustainable materials management approach is illustrated in the materials life cycle graphic [visible if you follow the link below] that Ecology adapted from Oregon's Department of Environmental Quality. Materials management looks at the full life cycle of materials from the design and manufacturing phase, through the use phase, to the end-of-life phase when the material is either disposed or recycled. Materials management still focuses on recycling and disposal issues. However, looking at production and use phases can help identify more sustainable ways to design products that use less energy, water, and toxics. This is important because the adverse environmental impacts of extraction, production, and use can be far greater than those associated with disposal when a material becomes a waste. According to EPA, a sustainable materials management approach is essential to conserving our natural resources to meet both today's needs and those of future generations."

Source: https://fortress.wa.gov /ecy/publications/documents/1504019.pdf page 4 (Executive Summary). And while I see your point that waste prevention is a tough sell (because there's no object to sell and usually no money to be made), I suggest you can also use Washington's, Oregon's, and EPA's recent plans to show that there is a trend for more "political support" of waste prevention and pollution prevention via the promotion of whole systems thinking.

Response to Comments 12 Whatcom County CSHWMP,July 16,2015 Revision Response: Chapter 3 will be revised to riflect increased support for waste and pollution prevention.

15. In Section 3.1.1, you could put in a graphic of the EnviroStars logo to enhance brand recognition by readers. A link to the online EnviroStars directory would also be great. On a related note, have you heard about the effort going on in the I

16. In Section 3.1.2, you need to add the word "Materials" between "Industrial" and "Waste," and I suggest also including the acronym "IMEX." Response: Comment will be incorporated as requested.

17. In Section 3.1.3, is this Green Classroom Certification program associated with Washington Green Schools? If not, I would suggest putting exploration of potential synergies with Washington Green Schools as a goal or strategy of this SWMP. See www.wagreenschools.org . Response: RE Sources' Green Classroom certification is independent ofthe Washington Green Schools program; however, per Washington Green Schools program website, there are a hanciful ofWhatcom County schools also participating in that program. Text will be added to Section 3.1.3 regarding the Washington Green Schools program, as well.

18. In section 3.1.4, please note County residents may also utilize a recycling hotline operated by the State of Washington that is both online (http:/l1800recycle.wa.gov and https://www.facebook.coml1800recycle.wa.gov) and via live phone assistance during the week (9:00-3:00 at 1-800-RECYCLE (1-800-732-9253)).

Please also expand upon the "Permanent Information Centers," so the reader can imagine what they look like/how they function. Are they brochure racks? How are they maintained?

For Event Recycling, You could note that this is required by law: http://www.ecy.wa.goviPROGRAMSISWFAieventrecyclingl Also, Skagit County is currently doing a lot in this area, FYI: http: I I www. skagitcount;y.netiDepartments ISustainabilit;ylzerowaste.htm

The Electronics Recycling area could mention many electronic items are now able to be recycled for free via a product stewardship program that launched in 2009 called E-cycle Washington: www. ecyclewashington.org. Response: Comments will be incorporated as requested.

Response to Comments 13 Whatcom County CSHWMP,July 16,2015 Revision 19. In Section 3.2, it notes how critical it is to raise public awareness of County-funded waste programs, but I believe we want to raise awareness of both County-funded and non-County funded programs. Response: Text will be revised to indicate "... awareness ofCounry- and non-Counryjunded waste programs ... "

20. Table 3-1 notes support for Master Gardeners, but on page 31, this is called a "Master Recycling & Composting Program," which seems to be a better fit. Same comment for section 5.1.1. Response: Both Table 3-1 and Section 5.1.1 will be revised to riflect the Master Composting and Reryc!ing program rather than Master Gardener program.

21. Required Chapter 4, Recycling, only touches on commercial recycling to say it is unregulated. While this is true, commercial waste is a large portion of what's out there (43.7% of all MSW, according to the 2009 Washington Statewide Waste Characterization Study (page 9).) It is also required to include programs to monitor the collection of source separated waste at nonresidential sites as part of your waste reduction and recycling element (RCW 70.95.090 (7) (b) (ii).) Please expand upon commercial recycling. For example, are the materials collected typically sorted in a similar way as the residential bins (paper separate from containers)? Does there seem to be high participation? Is it costly for businesses? Any creative rate structures to incentivize it? Response: Commercial Reryc!able Collection discussion in Section 4.1.1 will be expanded, including addressing the questions presented in this comment.

22. Section 4.1.1 is not actually what Ecology and the Utilities and Transportation Commission would consider the "list of designated recyclables," as that is found in Whatcom County Code Section 8.10.050, Section C, as noted in section 4.1.3. However, the list shows foil. I don't see foil listed in WCC 8.1 0.050, Section C, and I actually would advise against collection of foil, unless Whatcom Co has a special end market for it. During the presentation from an aluminum recycler at the NW Commingled Workgroup, it came to light that foil basically just gets burnt up in the recycling stream with no recovery of metal. While it is possible to recover it, you'd need a recycler whose system is set up specifically for foil. You might double-check your end market.

And within Section 4.1.3, a process for proposed changes to the designated recyclables list is given. Note that WCC 8.10.050, section L outlines a method by which an item may be removed from the list. Please ensure the protocol for changes to this list outlined here in the plan does not conflict with the protocol outlined in the County Code. Additionally, please have list updates sent to both Ecology and the Utilities and Transportation Commission. Response: Reference to foil as an accepted reryc!able material will be removed from Section 4. 1. 1. Section 4.1.3 will be revised to indicate that the SW/,4C will make a recommendation to the Counry exectttit'e rather than the Counry council to be consistent with WCC 8.10.050(L).

23. Section 4.2.1 on residential recycling starts off with some data on recycling participation and diversion. If by recycling participation you mean the number of residents setting out recyclables compared to those not source-separating out recyclables, it would seem to me that 40 to 50 percent would be a low number, especially for a county with a collection district. The diversion number given also seems a bit odd in a section devoted to residential

Response to Comments 14 Whatcom County CSHWMP,July 16,2015 Revision recycling, as I believe that rate is from our data that includes commercial and some industrial waste, as well. Please cite your data source? Response: Use rif the word "participation" was incorrect and will be removed from the text.

24. Section 4.2.1 begins the discussion of three-bin collection in comparison to single-stream collection. You may wish to note the regional effort to which you are invited and which is currently underway, the Northwest Commingled Workgroup: http:!/www.ecy.wa.gov/programs/swfa/commingled/. And although Ecology does support the collection of source-separated materials through RCW 70.95.090 (7)(b) as stated in the plan, source-separation simply means sorting recyclables from garbage at the source of generation. It does not necessarily mean the three-bin method. Response: Comment noted.

25. In Section 4.2.1, education is given as the answer to overflowing bins, but I wonder if there are other solutions? How do the haulers mitigate issues associated with the three-bin system such as limited bin size and weather-related issues (blown away or wet materials)? Response: Text will be added indicating that haulers will accepted appropriate!J separated materials in alternative containers.

26. At the end of section 4.2.2, I suggest expanding upon the "targeted focus" with wording such as: " ... relatively low multifamily recycling rates, and that an approach with three prongs can help boost rates. The three components are: 1) Collection logistics, 2) Policies and regulations, and 3) Education and outreach." (Those focus areas are from the Washington State Recycling Association study.) I suggest playing up options beyond education in Table 4-2, as well. Response: Comment will be incorporated as requested.

27. The flrst sentence in Chapter 5 is technically incorrect. If there is waste to compost, that waste has already been generated. I suggest "Significant diversion of waste is commonly accomplished... " Response: Comment will be incorporated as suggested.

28. Please define green waste in your glossary so we know what we're discussing in Chapter 5. Additionally, please specifically cite the "seasonal waste sort" mentioned at the start of Chapter 5. The 2009 Statewide Waste Characterization Study was conducted over all four seasons, so if that's the study you're citing, I'm not sure what you mean by seasonal. However, the data from that study is pretty interesting when looking at Whatcom and its organics: The Northwest WGA chart shown as Figure 29 on page 69 shows organics at almost 30%. Table 37 shows Organics from Commercial as only 24.7%. (Food-Vegetative 14.7% is largest, followed by Food non-vegetative at 8.2%)(Animal manure only 0.6%). Table 38 shows Organics from Res. as 49 .2%. (Food-Vegetative 17. 9%, followed by Animal Manure 12.6%). Response: A difinition rif green waste will be included in the glossary. The second paragraph rif Chapter 5 will be revised to indicate "In 2009-2010, Ecology conducted a four-season MSW characterization stucfy in select counties across the state, one rif which was Whatcom County. The stucfy found that organic material ... "

29. In Section 5.1.2, are any of the digesters accepting waste from offsite? If so, what kind of waste and who is hauling it? Similarly, in section 5.2.2, please discuss any issues or

Response to Comments 15 Whatcom County CSHWMP,July 16, 2015 Revision opportunities related to the digesters. How do you think the various organics facilities will handle the waste stream projected 6 and 20 years into the future? Response: Digesters operating in Whatcom County accept waste from riff-site that are se(ftransported to each digester 1!J the generator, as regulated under WAC 173.350.250.

30. In the flrst sentence of 5.2.1, do you mean to say" ... drop-off facilities, and onsite composting"? Response: Text will be revised to clarijj "on-site composting. "

31. In Table 5-1, there's a suggested action to require compostable service containers at commercial locations. Just as a word of caution, we have seen a lot of contamination issues related to acceptance of such compostable items at other compost facilities in the state. One has even reversed its policy and now accepts no compostable service ware. Response: Comment noted.

32. As with other tables, the flnal column may now be updated. State Plan goals that may flt well include SWM 17 and SWM 22, as well as others. Response: Please rqer to response to Diana Wadlry Other General Comments Comment No. 2.

33. First sentence of 6.1 should technically say "certificated" instead of "certifled." Also in 6.1, "biweekly" can have two meanings ... one is "every other week" and the other is "twice a week." I suggest clarifying by saying "every other week." Furthermore, it says Bellingham is an exception regarding the containers listed. What do Bellingham citizens use? Response: Text will be revised to indicate "certificated" rather than "certified;" to riflect "every other week" rather than "biweek(y;" and the exception to Bellingham will be removed (see response to Amber Jones Comment No. 1).

34. In the flrst column of table 6-1, I suggest adding clarifying source language such as " ... required minimum service to all subscribers as outlined in [the ILAs, County Code... etc..]" Response: Comment will be incorporated as suggested.

35. Section 7.1.3 starts out by saying the MSW generated in the county ultimately goes to one of the following landfills. However, of the list of six facilities, it seems to me that only three actually receive traditional Whatcom MSW (Columbia Ridge, Roosevelt, and Headquarters). This is based on the table of Solid Waste Disposal Data by County for 2013 found on Ecology's data page here: http://www.ecy.wa.gov/programs/swfa/solidwastedata/ (and the addition of Headquarters, which would be a very small amount and may have been overlooked on our table). What is the source of data/MSW for the remaining landfills listed? The bullet for the Graham Road facility even notes it does not accept MSW. As you clarify this section (including adding in where waste from the eastern portion of the county goes), you might note on the Cemex Inert Waste Landfill that the petroleum contaminated soils are not inert until they are treated. Suggest adding "The contaminated soils are treated with a thermal desorption process before they are landfilled." Additionally, you might reference how this data is presented in the table on page two of Appendix A (and within that table, it may be good to have "MSW" listed in the "materials accepted" column where applicable, or clarify that traditional MSW is what is meant by the "Waste" column).

Response to Comments 16 Whatcom County CSHWMP,July 16,2015 Revision Response: Text will be revised to indicate that Columbia Ridge, RoosetJelt, and Headquarters facilities receives most if the MSW generated in the counry, and that the other three facilities receive other waste. Cemex contaminated sozl treatment process will also be added

36. In 7.1.3 on the Cedarville Landfill, I suggest adding, "The leachate collected is treated and discharged under an NPDES permit issued by Department of Ecology." Response: Comment will be incorporated as suggested.

3 7. In Section 9 .1.1, please explain the contracts with certain tribal businesses more. The contract is between whom? The County and the tribal business? For what service(s)? Additionally, for the cities that have municipal contracts for both residential and commercial solid waste collection, is recycling a part of the contract, or does the contract only refer to trash destined for landfill? If recycling collection is part of the contract, is it for residential or commercial or both? (Commercial recycling is unregulated, but sometimes a city will "embed" commercial recycling within a solid waste collection contract.) Furthermore, since you point out Bellingham has a separate disposal contract, should it be clarified here that for the cities of Everson, etc. that the solid waste collection contract includes disposal? Response: Tribal contracts for solid waste services are direct!J between the tribes and solid waste service providers. Diana Wadley Comment on January 15, 2016 Revision Received February 17, 2016: Thank you. A suggestion to add clarity to section 9.1.1 is to remove the sentence under the header "Cities" that reads, "Solid waste collection in the county is regulated under municipal contracts and through contracts with certain tribal businesses on the Lummi Reservation, in addition to regulation under the WUTC," and instead create a header for "Native American Tribes." Under that header, you could insert this language from the 2008 plan, if it still holds true:

"Lummi and Nooksack tribal lands are not subject to this Plan. However, non-tribe residents living within reservation boundaries are subject to provisions of County solid waste ordinances. Both the Lummi and Nooksack Tribes contract with private WUTC certified haulers for garbage pickup." Response: Comment wzll be incorporated as suggested.

38. In section 9.1.1 related to Ecology's roles, please say "including RCW 70.95," as we are governed by additional portions of RCW. Also please note we approve both local solid and hazardous waste management plans. Response: Comment will be incorporated as requested.

39. In section 9.1.1 related to the Northwest Clean Air Agency, please note how they dovetail with asbestos. Response: Section will be revised to add "NWCAA is also responsible for regulation ofany construction that mqy result in handling and/ or disposal ifasbestos containing materials."

40. In section 9.1.2, please cite how it's now codified, so a reader can more easily locate the current regulatory text. Something like " ... 1991... and codified as WCC 8.15.030" (or perhaps the whole chapter of 8.15?) Response: Comment will be incorporated as requested.

Response to Comments 17 Whatcom County CSHWMP,July 16,2015 Revision 41. In section 9.2, landfill leases are mentioned. What leases would this be referring to? Response: Text will be revised to indicate that revenues include lease pqyments ry private solid waste service providers for lease of County-owned land (SSC leases land upon which Cedarville and Birch Bqy-Lynden drop box facilities are located, and Cando leases the land at which its transfer station facility is located).

42. In the organics portion of the implementation table found in chapter 10, it seems to me that 2B and 2D would better be done concurrently. Response: Concur, comment noted.

43. On page two of Appendix A, the data for Ryzex is missing. Response: Ryzex was inadvertentlY lift in the table and will be deleted.

44. On the next-to-last page of the draft plan, a portion of the budget is shown as a payment to the Health Department. What does this cover? Is it staff for inspections/permitting and solid waste enforcement like illegal dumping work? Response: To supplement Ecolo!!J! grant revenue for solid waste compliance enforcement activities, an allocation of$25,000 per quarter ofsolid waste excise tax revenue is utilized to finance staff-conducted solid waste enforcement activities.

Specific Comments by Section-Hazardous Waste 1. The last paragraph of 11.1.1 has an incorrect statement. The 2008 plan updated the Haz Waste Plan as well, as stated on page 9 of Section Two of that plan. Response: Text will be revised to indicate "Since then, updates to the Plan (most recent/y completed in 2008) have included riference to the 1991 Hazardous Waste Management Plan ... "

2. Sections 11.1.2.3 and 11.1. 7.3 both mention technical assistance to businesses. It is advised to mention the EnviroStars program, which could be done by referring the reader to section 3.1.1 of the solid waste portion of this plan. Response: Comment will be incorporated as requested.

3. In section 11.1.4, they're technically "certificated" haulers, instead of "certified." Response: Comment will be incorporated as requested, and elsewhere in the document, where appropriate.

4. Are the interlocal agreements referred to in section 11.1.5 the same ones as found in Appendix C? If so, please cite accordingly. Response: Riference to Appendix C will be added to the text.

5. In section 11.1. 7.4, is there any kind of fee associated with either program? How is the fee structured? Response: CESQGs are required to pqy for hazardous 111aste disposal at the MRWfacility in accordance with the established and approved fee structure defined in the Disposal ofToxics Program operations plan. Diana Wadley Comment on January 15,2016 Revision Received February 17,2016: To help readers understand that CESQGs must pay a fee, please note as much in the text, such as by adding "and must pay for hazardous waste disposal in accordance with the fee structure defined in the Disposal ofToxics program operations plan." to the end of the final sentence. Response: Comment will be incorporated as suggested.

Response to Comments 18 Whatcom County CSHWMP,July 16,2015 Revision 6. In section 11.2 and throughout, the hazardous waste planning period is given as 2015-2020. I suggest shifting it to match the solid waste management plan's period of 2016-2021. Response: Comment will be incorporated as suggested.

7. In areas where you plan for the future and say the County will be contracting with Stericycle, you might loosen your wording to allow for other contractors. (For example, " ... County (through contractor such as Stericycle Environmental Solutions)" Response: Applicable goals difned in Section 11.2.2.1 will be revised as suggested.

8. Regarding used oil, Ecology has seen a recent rash of Polychlorinated biphenyls (PCBs) from public used oil collection sites. If this contamination spreads to larger loads as the contents of the tanks are collected for recycling, local governments can incur large expenses. If Whatcom County has safeguards in place to watch for PCBs, such as staffing used oil collection sites or other means, please include them in the plan. If no such safeguards are in place, please recognize the potential for contamination of PCBs within the plan and consider recommending creation of safeguards against them. Furthermore, to more fully comply with Chapter 70.951 RCW, the Used Oil Recycling Act, please include a description of how used motor oil from watercraft is addressed, how signage is monitored/assisted, and what public education, if any, is focused on motor oil. Response: The contracted waste motor oil collection compaf!Y uses Chlor-detect for detection of PCB contamination prior to pumping out each used oil tank at each pick-up; no PCBs have recent/y been detected. The Disposal ofToxics program accepts motor oil from watercraft S tciffprovide technical assistance on handling and disposaL Additionai!J, staff have worked with Port ofBellingham to achieve EnviroS tars status and educate the public on proper watercraft motor oil disposal through signage.

Additional Items to Address Before Submission of the Final Draft 1. Required Please show how each of these comments from Ecology has been addressed in your flnal draft plan, citing the speciflc section(s) and/or page(s) within the flnal draft. Response: Revisions to the draft Plan will be maintained in track changes mode in a file separate from the final revision that is submitted for Ecology approvaL Diana Wadley Comment on January 15,2016 Revision Received February 17,2016: This document and the accompanying track changes document have been very helpful. Thank you! Response: You are welcome!

Response to Comments 19 Whatcom County CSHWMP, July 16, 2015 Revision Lisa Friend, Citizen Received December 7, 2015 General Observations 1. Attention should be paid to issues of Extended Producer Responsibility (EPR, also known as "Product Stewardship") and the management of marijuana residuals, both of which could face the county in future years. Opportunities for producer management of paint, in particular, are likely to come before SWAC again in future. Response: Comment noted.

Acronyms and Abbreviations 1. The term "CDL" is referenced on Page 56. Perhaps is should be added to this list, as a variation of C/D. Response: Riference to CDL in Table 7-1 will be revised to "C/D Waste."

Introduction 1. Page 4, figure 1-1: Please include the Cedarville Drop-Box site. Response: Cedarville Drop-Box site will be added to Figure 1-1.

Planning Area 1. Table 2-3, Whatcom County Employment Sectors: Consider including the Materials Management sector in this data, as a baseline for tracking the economic impact of the local solid waste and recycling industries in future years. Many communities are having success with demonstrating the positive economics associated with employment in the recycling, composting and related materials management sectors. Response: Materials Management sector-specific data for Whatcom County is not available (20 13 U.S. Census American Community S urvry).

2. Section 2.3.1, Solid Waste Definitions: Please include a definition of "Organics Management" and/ or "Composting." Also, under "diversion," perhaps clarify whether "alternative daily cover" is viewed by the County as a "beneficial use." Response: Please rifer to the Glossary at the end ifthe document. The source ifglossary terms is Appendix A (Glossary if Terms and List ifAcronyms) if the Department ofEcology's Guidelines for Development of Local Comprehensive Solid Waste Management Plans and Plan Revisions, Publication No. 10-07-005 and should be maintained consistent with the drjinitions presented in that publication.

3. Section 2.3.7, Diversion and Recycling Rates: Please note that incineration and, if appropriate, alternative daily cover, are prevented, in addition to landfill diversion. In the second paragraph, are "organics" appropriately listed under both diversion and as a recycled stream? The repetition confused me. Response: Comment Noted. Rerycling is considered a component if lanr!fill diversion, so it is appropriate to list organics 11nder both. As shoum in Figtm 2-4, Organics (at 1.9%) are third highest component if the rerycled stream (with metals and paper, at 3.9% and 31%, respective!J, being the on!J larger components).

Waste Reduction and Public Education 1. Could "Extended Producer Responsibility" (Product Stewardship) be appropriately listed in this chapter? Response: Do not concur.

Response to Comments 20 Whatcom County CSHWMP,July 16,2015 Revision 2. 3.1.1., Public Sector Activities: Program evaluation/assessment is a primary County role that could appropriately be listed with "public outreach and education." The purchase of recycled-content goods, recycled-asphalt pavement, and finished compost are also functions of County government that could be listed here. This is an ideal place to note the role of County government in the financial management of the materials management sector and opportunities for the county to apply for and administer state and federal grants. The final sentence of this section, could we reference data that prove the plastic bag ordinance "is a big step forward in reducing litter and unnecessary waste," etc.? While this is intuitively true, information about how much litter has been reduced and money saved since 2012 should be incorporated or referenced. Response: Riference to the Counry's role as overall solid waste management program assessment will be added to Section 3. 1. 1. However, citing the listed operational functions are not considered relative the public education functions the Counry leads. No data is available relative to the Ciry ifBellingham's plastic bag ordinance.

3. Table 3-1, Goals and Actions: Please add items 2F and 3 E, each reading "Evaluate effectiveness of outreach efforts and use data to fine-tune program elements," which would support "Beyond Waste" principle of "Strive for Continuous Improvement." Response: Goals and associated actions provided in the Goals and Actions table were the outcome if significant deliberation ifthe SWAC subcommittee relative to tangible results and careful consideration if available Counry resources for action implementation.

Recycling 1. Section 4.1.1, Programs. In the second paragraph, address the issue of enforcement of the garbage collection exemption and provide data on how widely this exemption is used. Address the provision of recycling series to multifamily units, including trailer parks, homeowners association and condominiums. Response: The purpose if Section 4.1.1 is to provide an overview if the collection program; action 1.A in Table 9-1 addresses the need to evaluate the exemption program. MultifamilY residential rerycling is discussed in Section 4.2.2.

2. Table 4-1, Accepted Curbside Materials by Bin: Please add "phone books" under "Scrap Paper," perhaps in the "Mail, magazines, catalogs" Bullet. Consider adding "steel" cans to the "Tin cans" bullet and perhaps specifying that empty aerosol cans are included. Response: "Phone books" are alreac!J listed under the second bullet associated with Scrap Paper; fourth bullet associated with Containers will be revised to indicate 'Tin/ steel cans."

3. In the Point Roberts paragraph, please clarify how "seasonal vacation" and "weekend homes" are serviced (one assumes through drop-off service). Response: Curbside reryclingpick ttp is not required if residences meeting these definitions; therefore, rerycling particzpation is left to the discretion of the resident.

4. Under "in-house recycling," please indicate the level of diversion the County is achieving through this program, as a baseline. This is an excellent place to record the County's efforts to procure recycled-content products and compost as well as any waste-prevention measures such as banning of single-use water bottles at County events.

Response to Comments 21 Whatcom County CSHWMP,July 16,2015 Revision Response: The Counry has not conducted an assessment rif the diversion level associated with in-house rerycling. A1?)' efforts that Counry mqy be pursuing associated with rerycled-content and compost procurement is not applicable to discussion specific to "in-house rerycling".

5. Electronics Recycling: Opportunities for diversion of small electronics that do not fall under theE-Cycle Washington definition should be clarified here. "Consumer Products" represent 10% of the County's discarded waste: Is there need for more diversion of small electronics? Response: A l!Jperlink to the specified RCW sections, in addition to theE-Cycle webpage will be provided .for the reader to access more specific information relative to small electronics diversion opportunities.

6. Along those same lines lie opportunities to divert additional hard-to-recycle materials for which markets are developed or developing. These include Christmas lights, ftlm plastic, rigid plastics, paint and, perhaps, carpet. Response: Comment noted.

7. Diversion of Construction and Demolition materials should be addressed in this section. Response: Construction and demolition waste is considered a special waste; therefore it is discussed in Section 8, Special Waste.

8. 4.1.2, Facilities: These should be mapped in this section in a more specific fashion than in Figure 1-1. Response: Comment noted.

9. I would be interested in knowing the number of hours these facilities are open each week, the number and type of users (residents vs. businesses vs. apartment/ trailer park dwellers) and any change in use over time. Response: This information is not available.

10. More information in this section could appropriately include details about the markets for Whatcom-County-generated recyclables and compost (domestic or international? Washington or west coast?), contracts, responsibilities and residuals. Response: Comment noted.

11. I would be interested in knowing the number of hours these facilities are open each week, the number and type of users (residents vs. businesses vs. apartment/ trailer park dwellers) and any change in use over time. Response: This information is not available.

12. I suggest sections 4.2.3 "Commercial Recycling" with a similar level of detail and 4.2.4 "Construction and Demolition Recycling." Response: Please reftr to response to Diana Wadlry Comment No. 21 (Other Specific Comments ry Section); construction and demolition debris is discussed in Section 8.

13. Table 4-2, Goals and Actions: Incorporate section on Commercial diversion and C/D. Explain how local government will improve efforts towards "Beyond Waste" Strategy 4: "Lead by example in government, especially through ... purchasing power... "

Response to Comments 22 Whatcom County CSHWMP,July 16,2015 Revision Response: Goals and associated actions provided in the Goals and Actions table were the outcome if significant deliberation if the SWAC subcommittee relative to tangible results and cariful consideration if available County resources for action implementation.

Organics Material Management 1. This section should address health and environmental concerns about micro-plastics in compost and steps to keep these materials out of the Whatcom County organics stream. Currently, materials are collected that do not meet the "Biodegradable Products Institute" standards for compostability nor equivalent ASTM standards. Response: Comment noted.

2. In addition, the residents of Lummi Island are interested in regular residential compost collection service: this need should be addressed in this section. Response: The collection service provider will be notified if this perceived need.

3. In the first paragraph, the parenthetical definition of "organic materials" could include compostable paper. Response: Comment will be incorporated as suggested.

4. 5.1.1, Programs: How are food scraps handled in Point Roberts? Are they accepted in the "green waste" drop box at Cando? Response: Food scraps are managed as municipal solid waste in this area.

5. Under "Educational Programming," provide data about the effectiveness of existing outreach programs and how continuous improvement can be gained. Response: Requested data is not available.

6. 5.1.2, Facilities: Indicate the costs to the consumer for use of these programs and usage trends over time, particularly given recent increases in charges at the City of Bellingham Clean Green facility. Under "Digesters," please indicate the percentage of County waste currently directed to these facilities, vs. other organic management options. Response: Most recent annual tonnage processed (and percentage if which was manure) f:y anaerobic digesters located in the counry will be added to Section 5. 1.2.

7. 5.2.1, Programs: The adjective "backyard" should be added to "composting," to differentiate that term other organics management options listed in the first sentence. Response: The word "on-site" has been added prior to "composting" to provide the differentiation (see response to Diana Wadlry Comment No. 30- Other Specific Comments f:y Section).

8. Purchase and use of finished compost should be addressed in this section. Response: Poliry associated with purchase and use iffinished compost should be considered f:y the Counry department using compost operationai!J, not as a poliry defined the solid waste management plan.

9. Table 5-1, Goals and Actions: Perhaps add 1B- "Evaluate effectiveness of current backyard composting programs and seek continuous improvement."

Response to Comments 23 Whatcom County CSHWMP,July 16,2015 Revision In element 2 C, clarify that only BPI- or ASTM-certified compostable containers should be required. In addition to requiring the use of these materials, purchase of organics receptacles and collection service should likewise be mandated. Add a third goal to encourage government/institutional purchase of use of finished compost Response: Comment noted. Goals and associated actions provided in the Goals and Actions table were the outcome rif signijicant deliberation rif the SWAC subcommittee relative to tangible results and carifu/ consideration rif available County resources for action implementation.

Solid Waste Collection 1. In this section, it would be appropriate to address litter data over the past decade (how much is collected, from what regions, etc.) and the exemption of solid waste collection, how many exemptions exist, estimate of gaps, and the enforcement of the exemption. Response: Action 1.A in Table 9-1 addresses the need to evaluate the exemption program.

2. The management of industrial quantities of solid waste, though not MSW, should be addressed in some portion of the plan: What is done with wastes from Alcoa, refineries, etc.? Response: Industria/ generators utilize existing services rif the county solid waste management .rystem. A/though Alcoa and BP additiona/fy operate permitted /an 4ft/Is for certain approved wastes generated onfy from on-site operations, thry are not within the scope rif the plan.

3. Enforcement of the collection exemption and mapping of its use can be included under "Goals and Actions." Funding is likely available to the county for this type of analysis, and it should not be overlooked simply because of fears that analysis is not within the budget. Response: Action 1.A in Table 9-1 addresses the need to evaluate the exemption program.

Transfer and Disposal 1. Section 7.1.1, Transfer Stations: Separate the third and fourth bullets in the paragraph beginning "These transfer stations are open to the public," as the Bellingham Vactor Waste Facility is closed to the public. Response: Text will be revised to read "These tran.ifer stations, with exception to the Bellingham Vactor Waste Facility, are open to the public."

2. Section 7.1.1, Transfer Stations: Separate the third and fourth bullets in the paragraph beginning "These transfer stations are open to the public," as the Bellingham Vactor Waste Facility is closed to the public. Also in the f111al paragraph, add a reference to Section 8.1.8. Response: Text will be revised to read 'These tran.ifer stations, with exception to the Bellingham Vactor Waste Facility, are open to thepub/ic." Reference to Section 8.1.8, Vactor Waste, is a/reac!J provided in the bullet associated with the Bellingham Vactor Waste Facility.

3. Table 7-1: For clarity, be sure the footnote "*Gate fee, regardless of weight or materials," appears on the same page as the "RDC" section. Response: The suf:ject footnote is applicable to anywhere in the table an asterisk (*)is presented, regardless rif what page rif the table the notation is presented.

4. Section 7 .1.3, Landfills: Please reference the closed "County Construction Recycling/Muenscher Landfill" site, which was operations at the time of the previous Plan

Response to Comments 24 Whatcom County CSHWMP,July 16, 2015 Revision update: It's closure should be documented in this plan, along with the fate of the "Foothills Recycling Landfill," referenced in Section 8.1. 9. The fate of the Olivine incinerator, which at one time accepted materials from the public and local haulers, should also be addressed in this section. Response: There are matry closed private lan4ftlls in the counry that are no longer a component of the solid waste .rystem, and not within the scope of the plan. Lan4ftlls that are operational and part of the .rystem, or public[y owned and maintained in post-closure status utilizing solid waste excise tax revenues, are within the scope of the plan.

5. Section 7.2, Needs and Opportunities: In light of continuing litter issues on county roadsides, the potential for siting of another drop box in the County should be addressed here. This topic is more fully addressed in section 9 but also deserves mention in this section. Response: Do not concur. Access and capaciry are mere[y one component of the litter and illegal dumping issue, which is a compliance management task appropriate[y and adequate[y discussed on[y in Section 9.

Special Waste 1. The inclusion of plant and soil residuals from marijuana-growing operations should be addressed in this section, including pertinent state regulations that affect this new industry. Response: Text will be added to Section 8.1. 1 to indicate that handling and disposal of marijuana industry crop residues will be completed in accordance with the most current state regulations.

2. Section 8.1.5, Disaster Debris: A separate disaster management plant should be developed by the County and referenced in this section. Include "woody debris" under both "flood" and "earthquakes" and include "vehicles" under "flre." Make note of FEMA guidance on the development of such plans and note that federal funding might be available for plan creation. Contingency contractors with debris management companies and site should be in place in advance of any disaster. Response: The Health Department is current[y supporting the Whatcom Counry Sheriffs Office Division of Emergenry Management in the development of a separate disaster debris management plan, which will be riferenced in this section. Suggested materials will be added to the applicable events.

3. Section 8.1.7, Biomedical Waste and Pharmaceuticals: In the bulleted section listing "Participating pharmacies," consider the fate of the Haggen chain. Also, clarify whether the MRW facility accepts controlled substances from households, though not from businesses: I found the acceptance of controlled substances from households surprising. Additional detail is not clear on the phone line nor the County Hazardous web site. Response: Agree that the future ofpharmary acceptance unused medications at the current Haggen pharmacies remains uncertain; however, all are current[y still operating. The plan is accurate as stated that the MRWfaciliry "accepts unused pharmaceuticals from households (t"ncluding controlled substances), and from small-quantiry generator businesses (not inclttding controlled sttbstances)."

4. Section 8.1.9: Tires: Please provide data and trends for used tire diversion in the county, including the number/weight of tires found as litter or in cleanup piles: The Ecology website indicates that tons of tires cleaned up are going down statewide; does the same hold true in Whatcom County? Response: The Counry has not tracked tire diversion data.

Response to Comments 25 Whatcom County CSHWMP,July 16,2015 Revision 5. Section 8.2.1, Construction and Demolition Debris Recycling: Because C&D materials represent such a significant portion of the local waste stream, any data on the tonnage of these materials being diverted from Whatcom County should be reported in this section. Data about the success of marketing sorted materials from in-county processors and, if possible, out-of-county processors, would be appropriate before proposing any flow control changes. Also in this section, the "Goals and Actions" recommend controlling "sham recycling." This topic is not addressed in the narrative; this section seems the appropriate place for clear introduction of the "sham recycling" topic and its place in the state "Beyond Waste" plan. Response: As stated above, potential flow control and sham rerycling issues will be investigated, reviewed and responded to in the planningperiod.

6. Section 8.3, Goals and Actions: Under goal number 1, include bullet "D" to encourage pilot program for use of recycled asphalt shingles in County parking lot paving or road applications. Response: The Health Department is current!J providing support to a private sector paving compatry to implement permitted asphalt shingle rerycling operations.

7. Under "Priorities of Plan," is the wording "Enforce compliance, technical assistance and enforcement"? This terminology seems self-reflective and can be, therefore, confusing to the lay reader. Response: The correct terminology, per the Bryond Waste Plan, is "Focus on facility compliance, technical assistance, and enforcement. " Text wzll be revised accordinglY.

Administration and Enforcement 1. Section 9.1.1, Agency Roles and Responsibilities: Perhaps introduce the "Solid Waste Division" of the Whatcom County Health Department in the first sentence, for clarity. Response: Clarity specijj;ing the Solid Waste Division of the Health Department wzll be added.

2. Insert information about the county's management of the annual Solid Waste budget into this section with a reference to Section 10.3. Response: Comment will be incorporated as suggested.

3. Under "Cities," please address the absence of a municipal contract for commercial solid waste collection in the City of Bellingham and the reason the City does not contract for this service. Response: Text will be added specifying that commercial collection in the City of Bellingham is governed fry WUTC regulations.

4. Under "Washington State Department of Ecology," please address the availability of grant funding from the state for local solid waste programs. Response: Comment will be incorporated as suggested.

5. Under "Washington Utilities and Transportation Commission," please clarify whether the certificated areas are for residential collection only and, if so, the legal structure(s) under which commercial garbage, recycling and organics collection take place. Clarify whether Whatcom County Ordinance No. 90-95 was restricted to residential services or whether commercial collection was also addressed.

Response to Comments 26 Whatcom County CSHWMP,July 16,2015 Revision Response: Do not concur. Sufficient level of detail relative to the WUTC's role as it pertains to a solid waste management plan is provided.

6. Section 9 .1.3, Financing: The history of the Maple Falls drop-box site should be addressed here or in Chapter 7. Response: Do not concur. Maple Falls drop-box facility is no longer active and, therifore, not relative to the current plan update.

7. At the end of this section, indicate how often payments are made to the County and whether there has ever been any issue regarding the amount/ timeliness of such payments. A 10-year summary of payments might be helpful. Response: Do not concur. Request is not relevant to the level of detail of a solid waste management plan.

8. This is also a good place to indicate the county's plans for continued financial support of essential solid waste services, education, and program evaluation if waste reduction and recycling result in a decline in fee payments/smaller budget. It would not be appropriate for readers of this plan to come away with the idea that waste reduction and recycling would be given reduced priority if- by their success - the solid waste budget could suffer. Response: Comment noted.

9. Section 9.1.4, Administration: The County's role in procuring state and local grants for solid waste operations should be mentioned here, as should the role of the health department in facilitating the SWAC and SWEC meetings. Response: Comment wz!l be incorporated as suggested.

10. Section 9.1.5, Enforcement and Compliance: Data about the county's garbage collection exemption structure should be included here. Also, the duplicate labeling of Section 9 .2.1 as "Enforcement and Compliance" is confusing. Perhaps consider additional distinction between the two section and their titles. Response: Specijic data requested are not available and, as stated above, the exemption program will be reviewed duting the planning period as a recommended action item. Section 9.1.5 describes the existing conditions associated enforcement and compliance, while Section 9.2.1 identijies corresponding needs and opportunities.

11. Section 9.2, Needs and Opportunities: The opportunity for the County to apply for and benefit from USDA Rural Development Solid Waste grants should be detailed here, especially as these grants could provide additional solid waste services to the Kendall-Maple Valley and Point Roberts areas listed here .. Response: Do not concur. The solid waste budget includes signijicant revenue from numerous grant sources, and it is not within the scope of the plan to call out each grant opportunity separate!J as an action item.

Implementation Schedule 1. Section 10.1, Implementation Responsibility: Under "Waste Reduction and Recycling," consider adding: "The County should lead by example by buying recycled products and finished compost and by promoting a model in-house diversion program." Response: Comment noted.

Response to Comments 27 Whatcom County CSHWMP,July 16,2015 Revision 2. Section 10.1, Implementation Responsibility: Under "Solid Waste Management Planning," the provision of data on diversion successes should be emphasized, as should financing for effective programs. Response: Comment noted.

3. Table 10-1, Implementation Schedule: The phrase "Track efflcacy and fine-tune" would be appropriate in nearly every section, including: "Education and Community Outreach" elements 1, 2, and 3; Multifamily Recycling elements 2 and 3; and the initial occurrence of "Compliance Management and Enforcement" 2.a (Provide programing support ... ) The Education and Community Outreach element could use a bullet 4.C to consider use of the Re-TRAC software. 4.A should include litter reduction measures. The "Residuals Recycling" section needs a second element that would read: "Monitor residuals and markets" to insure that locally generate materials are sent to end-use markets with a 12% or lower residual rate (to combat or deflne "sham recycling"). New sections need to be created for Commercial Recycling and C&D Diversion. The Multi-Family Recycling section would benefit from "Track efflcacy and fine-tune" phrases for elements 2 and 3. Under "Organics Management," please include the term "data-based" before "impact." Include the "Food, Too Good to Waste" program and also use the term "BPI-Certified compostables" in section C. If both the "Compliance Management and Enforcement" and "Administration and Enforcement" sections are maintained, the checkmarks in both timelines should match. Bullets "A" should include "Track efficacy and fine-tune." In the "Special Waste Programs" section, address data-based evaluation of current diversion programs and goals for the future in element 1, "Increase CID ~material recycling." Under sub-topic "C," add the use of recycled-asphalt-shingle paving material. If data will not soon be available for adequate comparisons between in-county and out-of­ county CID processing options, considered delaying element 2.B, "Evaluate changes in the Flow Control exemption ... " to 2017 or later. Under element 4, regarding pharmaceuticals, incorporate an action that reads: "Develop extended producer management policy at the state level." Consider an element 5: Investigate extended producer management options for paint. Response: The implementation schedule reflects the timeline for completing goals and associated actions identijied associated with each plan element. Those goals and associated actions were the outcome of signijicant deliberation of the SWAC subcommittee relative to tangible results and careful consideration of avatfable Counry resources for action implementation.

4. Section 10.3, Budget: Provide detail on the Disposal ofToxics budget, which represents a quarter of the annual solid waste budget: How has this budget changed in the past decade. What percentage is dedicated to the management of paint? Provide additional data on the success of community eclncation and outreach programs and the amount of money spent on litter control programs year over yare I ton by ton. Detail a budgetary goal: Lower expenditures and increase the effectiveness of outreach I program spending. Response: The purpose of Section 10.3 is to provide an overview of the solid waste budget, not specijic detail relative to program components or budgetary goals.

Local Hazardous Waste Management Plan

Response to Comments 28 Whatcom County CSHWMP,July 16,2015 Revision 1. Section 11.1.2.1, Hazardous Waste Inventory: Please provide detail on the hours per week the MRW site is open and also the hours per week the drop-off sites are open. Detail the percentage of collected material that comes from the MRW site vs. the drop-offs and, if possible, the amount collected at each drop-off site per year. Include the volumes of oil collected in the residential recycling collection program and the volumes of oil and antifreeze collected by the CESQG service. If possible, make a note on Figure 11-2 explaining the jump in customers in 2007. Provide a break and new title after the bullet that begins "Twenty-four ... " to indicate a change in subject to contaminated sites. A similar break and new title should precede the final paragraph in this section, which again changes subjects to address service providers. Response: Operational hours if each faciliry will be added The detailed data requested is not within the scope ifthe plan. Section titles will be added to delineate discussion relative to Dangerous Waste Generators, Remedia!Action Sites, and Hazardous Waste Services.

2. Section 11.1.2.2, Public Education: Please add wording that will direct the County to track efficacy of these outreach programs and fine-tune services for greater impact. Response: Comment noted. Due to resource constraints, measurement ifprogram e.fficary is not a prion.tized goal.

3. Section 11.1.2.3, Technical Assistance: Include data about the number of calls received, the topics that represent the most common inquiries, and the number of individuals and businesses served each year. Response: The number if businesses and households served each year is depicted graphicallY in Figure 11-2. Technical assistance inquiries ry rype are not tracked

4. Section 11.1.2.4, Service Improvement ... : Provide data on cost savings and public service improvements realized through the state's fluorescent lighting take-back program and extrapolate to the potential for service improvements through a paint take-back program for Whatcom County. Response: Do not concur. Although the DOTprogram supports participates in established stewardship programs, such programs are not managed at the local/eve!.

5. Section 11.1.4, Financing the Program: Discuss options for manufacturer funding of paint and pharmaceuticals management through Extended Producer Responsibility programs. Similar programs are already helping fund the take-back of electronics and fluorescent lights in Whatcom County, and those fmancial contributions/savings should be acknowledged in this section. Response: Do not concur. Although the DOTprogram participates in established stewardship programs, such programs are not managed at the local/eve!.

6. Section 11. 7.1, Household Collection: Please provide data on the amount of each of these materials managed by the county on an annual basis over the past decade; perhaps in an appendix. Under "Annual Collection Events," indicate the geographic location of these collections over the past decade.

Response to Comments 29 Whatcom County CSHWMP,July 16,2015 Revision Under "Household Waste Pharmaceuticals Collection," indicate the volumes of these materials collected through the MRW each year. If possible, incorporate data from local pharmacy and law enforcement take-back programs, as well. Response: Figure 11-1 graphicallY depicts the total annual quantities ifMRW collected~ source. It is not within the scope if this plan to provide detail on quantities ~ waste type.

7. Section 11.1. 7.2 and 11.1.7.3: Provide data on the effectiveness of each program either here or in Section 11.1.2.2. Response: Comment noted Due to resource constraints, measurement ifprogram dficary is not a prioritized goal.

8. Section 11.1.7.6, Used-Oil Education and Collection: Provide data on the percent of used oil re-processed for re-use as an oil-product versus the percent that is used for fuel. Substitute the phrase "taken to" (the MRW facility) for "disposed of at." Indicate the amount of used oil that comes to the facility from residents vs. through the CESQG program. Response: All if the used oil is delivered to the refiner for reprocessing, with different fractions being used for different purposes (light ends become fuel product): it is not within the scope if this plan to ana/yze this product ratio. "Disposed ifat" will be replaced with "delivered to. "

9. Section 11.2.1, Guiding Principles: Incorporate a new bullet early in the strategies that allows for Extended Producer Responsibility for management of materials. This will be congruent with item #8 in this section: " ... foster an ethic of responsibility among those who produce, sell, and use hazardous products." And with item #10.a. Response: The DOT program current/y does participate in established stewardship programs, as applicable.

10. Section 11.2.2.1, Household Collection: Under "Action," specify the hours per week the MRW facility and satellite collection sites are to be open. Under HC Goal2, Collection Event, "Action," include the phrase "in addition to every­ other-year collections in Point Roberts." Under "Funding Source(s)" include the potential for USDA rural development funding for rural collection events. Incorporate a new HC Goal: "Explore Extended Producer Responsibility for painting, pharmaceuticals and other priority materials, as determined by the county or state." This can also be the text of"Action," with the timeframe to begin in 2016 and the implementing agency to be the County. Appropriate funding source(s) would be the excise tax on solid waste hauled by certified haulers and, possibly, affected manufacturers. Response: Do not concur.

11. Section 11.2.2.2, Household and Public Education: Incorporate "Test efficacy and fine-tune" under each action. Re.rpon.re: Comment noted. Due to re.rource con.rtraints, measurement ifprogram dficar:y is not prioritized goal.

12. Section 11.2.2.3, Small Business Technical Assistance: Incorporate "Test efficacy and fine­ tune" under each action. Response: Comment noted. Due to resource constraints, measurement ifprogram dficary is not prioritized goal.

Response to Comments 30 Whatcom County CSHWMP,July 16,2015 Revision 13. Section 11.2.2.4, Small business Collection Assistance: Add "fees" to the Funding Sources under SBCA Goal 1. Response: Comment will be incorporated as suggested

14. Section 11.2.2.5, Enforcement: Incorporate "Test efficacy and fine-tune" under E Goal1. Response: Comment noted Due to resource constraints, measurement ofprogram iflicary is not prioritized goal.

15. Section 11.2.2.6, Used-Oil Education and Collection: Incorporate "Test efficacy and ftne­ tune" under each action. Add "fees" to the Funding Sources under USEC Goal 2. As appropriate, add another element for the collection of used oil by curbside recycling service providers. Response: Comment noted Due to resource constraints, measurement ofprogram ifficary is not prioritized goal. Whatcom County solid waste collection providers current!J accept used oil via curbside pick-up.

Response to Comments 31 Whatcom County CSHWMP,July 16,2015 Revision COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN

WHATCOM COUNTY, WASHINGTON

June 14, 2016 ACKNOWLEDGEMENTS

The Whatcom County Comprehensive Solid and Hazardous Waste Management Plan was prepared by a team consisting of Whatcom County Solid Waste Division staff, the Whatcom County Solid Waste Advisory Committee, and the Maul Foster & Alongi, Inc. consultant team. Throughout development of this document, the individuals involved dedicated an extensive amount of time and energy in formulating recommendations, discussing approaches, and reviewing the document. In particular, the team wishes to acknowledge, with great appreciation, the solid waste industry service providers in our community, and their employees, who work hard to effectively manage our solid and hazardous wastes.

Maul Foster & Alongi, Inc. Justin Clary ErikBakkom Jacqueline Gruber

Whatcom County Staff Jeff Hegedus, Health Department Debbie Bailey, Public Works Department Gary Stoyka, Public Works Department

Solid Waste Advisory Committee Barbara Brenner, Whatcom County Council representative Greg Young, City of Ferndale, small cities representative Eric Johnston, City of Bellingham representative Casey Heinle, citizen representative Ed Nikula, citizen representative Mark Peterson, public interest group representative Marjorie Ann Leone, public interest group representative Amber Jones, business/industry representative Calvin DenHartog, waste collection industry representative (term expired 12/31/2014) Troy Lautenbach, waste collection industry representative (term began 1/1/2015) Martin Kuljis, Jr., waste recycling industry representative Pete Edwards, solid waste facility representative

Washington State Department of Ecology Diana Wadley Peter Christiansen

Contact Information Whatcom County Health Department 509 Girard Street Bellingham, Washington 98225 360.778.6000 CONTENTS

1 INTRODUCTION 1.1 PURPOSE 1.2 SOLID WASTE SYSTEM OVERVIEW 1.3 PARTICIPATING JURISDICTIONS 4 1.4 REQUIRED CONTENTS 4 1.5 RELATIONSHIP TO OTHER PLANS 5 1.6 THE SOLID WASTE ADVISORY COMMITTEE AND SOLID WASTE EXECUTIVE COMMITTEE 6 1.7 MISSION 7 1.8 PROCESS OF UPDATING THE PLAN 7 1.9 ORGANIZATION OF THE PLAN 9 2 PLANNING AREA 10 2.1 DESCRIPTION OF THE PLANNING AREA 10 2.2 HISTORY OF SOLID WASTE SYSTEM 16 2.3 QUANTITY AND CHARACTERIZATION OF SOLID WASTE 17 3 WASTE REDUCTION AND PUBLIC EDUCATION 27 3.1 EXISTING CONDITIONS 27 3.2 NEEDS AND OPPORTUNITIES 33 3.3 GOALS AND ACTIONS 35 4 RECYCLING 37 4.1 EXISTING CONDITIONS 37 4.2 NEEDS AND OPPORTUNITIES 42 4.3 GOALS AND ACTIONS 44 5 ORGANIC MATERIAL MANAGEMENT 45 5.1 EXISTING CONDITIONS 45 5.2 NEEDS AND OPPORTUNITIES 47 5.3 GOALS AND ACTIONS 49 6 SOLID WASTE COLLECTION 50 6.1 EXISTING CONDITIONS 50 6.2 NEEDS AND OPPORTUNITIES 53 6.3 GOALS AND ACTIONS 54

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGEl 7 TRANSFER AND DISPOSAL 55 7.1 EXISTING CONDITIONS 55 7.2 NEEDS AND OPPORTUNITIES 62 7.3 GOALS AND ACTIONS 63 8 SPECIAL WASTE 64 8.1 EXISTING CONDITIONS 64 8.2 NEEDS AND OPPORTUNITIES 69 8.3 GOALS AND ACTIONS 71 9 ADMINISTRATION AND ENFORCEMENT 72 9.1 EXISTING CONDITIONS 72 9.2 NEEDS AND OPPORTUNITIES 76 9.3 GOALS AND ACTIONS 78 10 IMPLEMENTATION SCHEDULE 79 10.1 IMPLEMENTATION RESPONSIBILITY 79

10.2 SUMMARY OF GOALS AND ACTIONS 80 10.3 BUDGET 84 11 LOCAL HAZARDOUS WASTE MANAGEMENT PLAN 85 11.1 MASTER SECTION 85 11.2 IMPLEMENTATION 92 GLOSSARY REFERENCES APPENDICES A-SOLID WASTE HANDLING FACILITIES LIST

B-COMPLIANCE CHECKLIST C-RESOLUTION OF ADOPTION AND INTERLOCAL AGREEMENTS D-SEPA DOCUMENTS

E-WUTC COST ASSESSMENT QUESTIONNAIRE

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE II ACRONYMS AND ABBREVIATIONS

Beyond Waste State Solid and Hazardous Waste Plan; Moving Washington Beyond Waste and Toxics C/D Construction and Demolition Cando Cando Recycling and Disposal CESQG Conditionally Exempt Small-quantity Generator County Whatcom County CPG Coordinated Prevention Grant Ecology Washington State Department .of Ecology E-waste Electronic Waste FCO Flow Control Ordinance HHW Household Hazardous Waste LAMIRD Limited Area of More Intense Rural Development MFS Minimal Functional Standards (refer to WAC 173-304 and 173-350) MRF Material Recovery Facility MRW Moderate-risk Wastes MSW Municipal Solid Waste MTCA Model Toxics Control Act NVD Nooksack Valley Disposal NWCAA Northwest Clean Air Agency OFM Washington State Office of Financial Management Plan Comprehensive Solid and Hazardous Waste Management Plan PPG Ecology Public Participation Grant RCRA Resource Conservation and Recovery Act RCW Revised Code of Washington RDC Regional Disposal Company RDS Recycling and Disposal Services SEPA State Environmental Policy Act sse Sanitary Service Company SWAC Solid Waste Advisory Committee SWEC Solid Waste Executive Committee TZW Toward Zero Waste TZWI Toward Zero Waste Initiative UGA Urban Growth Area USEPA U.S. Environmental Protection Agency USGS U.S. Geological Survey WAC Washington Administrative Code wee Whatcom County Code WDFW Washington Department of Fish and Wildlife WSDOT Washington State Department of Transportation wsu Washington State University WUTC Washington Utilities and Transportation Commission

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE Ill 1 INTRODUCTION

1.1 PURPOSE

The State of Washington enacted legislation through adoption and subsequent, periodic amendments to Revised Code of Washington (RCW) Chapter 70.95 establishing comprehensive statewide programs for solid waste handling and solid waste recovery and recycling. The purpose of these requirements is to prevent land, air, and water pollution, and to conserve the natural, economic, and energy resources of the state. Each county in the state is required by RCW 70.95.080 to prepare a solid waste management plan. Washington Administrative Code (WAC) Section 173-304-011 states that "the overall purpose of local comprehensive solid waste planning is to determine the nature and extent of the various solid waste categories and to establish management concepts for their handling, utilization, and disposal consistent with the priorities established in RCW 70.95.010 for waste reduction, waste recycling, energy recovery and incineration, and landfill." To address state requirements, Whatcom County (the County) originally developed and adopted the first revision of the Comprehensive Solid and Hazardous Waste Management Plan (the Plan) in 197 4. This 2016 revision represents the sixth iteration of the Plan, which was most recently revised in 1999 and 2008. RCW 70.95.110 requires that each plan be reviewed and revised, if necessary, at least every five years. Chapters 1 through 10 of this Plan are specific to solid waste management planning, and Chapter 11 is specific to hazardous waste management planning.

1.2 SOLID WASTE SYSTEM OVERVIEW

The waste management system in the County, illustrated in Figure 1-1, consists of approximately 35 permitted and exempt solid waste handling facilities, as regulated by WAC 173-350, Solid Waste Handling Facilities. These facilities consist of private sector landfills, landfills managed in post-closure, transfer stations, drop box collection sites, moderate risk waste (MRW) fixed facilities, composting facilities, anaerobic digesters, biosolids facilities, and recycling operations. The solid waste system is largely privatized, and except for the MRW facility (Disposal ofToxics Program), the County neither owns nor operates collection, treatment or disposal facilities. An overview of the County's solid waste system is provided below. Specific details on the system components are located in the corresponding sections.

1.2.1 WASTE REDUCTION AND PUBLIC EDUCATION

The first step in the waste management hierarchy is reducing waste generated. The County's waste reduction efforts use public education and technical assistance for businesses to educate the public on the importance of and methods for reducing waste generated to the extent possible. In addition, there is a wide variety of material reuse opportunities provided by private sector and nonprofit entities, consisting of consignment stores, donation centers, and construction material reuse centers. More detail is provided in Section 3.1.

WHATCOM COUNrY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGEl .____,..,.,..______, Comprehensive Solid and BLAINE i Hazardous Waste :r~·--·-·--· .. ·--·-·--·- ...... -... i Management Plan Update

Figure 1-1 Handling Facilities Map ..!\s, 0 Whatcom County Washington

NO FACILITEIS IN EAST COUNTY

0 Legend J'"'' 0 [._.J City Boundary CJ Planning Area ~ Handling Facilities * Drop Box Facility r.;-·- .. ·-·- 8 Hazardous Waste ··-·--·-·-~ \ £::,. Organics Drop Box L_r·-·-, \ Iii Organics Drop-off ) fffJ Reuse Drop-off Location 0 Recycling Drop-off Location '-·-·'"t ... _., • Transfer Facilities }'7;\ ~ r"~ . Q Vactor Waste h 6,000 12,000 il""'iiiiiiii r; Feet ~ Source: City Boundary & Planning Area from Whatcom County. Roads from WSDOT.

Point Roberts NTS ' JUNE 14,2016

1.2.2 RECYCLING

Recyclable materials are collected in the system through curbside collection, drop-box facilities, and transfer station drop-off locations and are delivered to the appropriate facilities. Most household recyclable materials go to Northwest Recycling. Other recycling services are also available to the public and are described in more detail in Section 4.1.

1.2.3 ORGANIC MATERIALS MANAGEMENT

Curbside and self-haul organic materials (yard and food waste) are collected and delivered to Green Earth Technology Composting Facility. Materials are processed on site. More detail is described in Section 5.1.2.

1.2.4 SOLID WASTE COLLECTION

Solid waste in the county is collected primarily by three private haulers, covering distinct service areas: Sanitary Service Company (SSC), Nooksack Valley Disposal (NVD), and Cando Recycling and Disposal (Cando). The far eastern portion ofWhatcom County is served by the Skagit County waste hauler, currently Waste Management. All cities in Whatcom County use traditional bag or customer­ owned, 32-gallon can residential collection systems, or collector provided containers or totes. Customers of SSC and NVD also have the option of using collection-company-owned wheeled carts. Residential recycling is collected on a weekly basis in Bellingham and biweekly elsewhere in the county, and organic materials (yard waste and food waste) are picked up on a biweekly basis throughout the year. Commercial recycling collection frequency and services vary based on customer need. More detail is provided in Section 6.1.

1.2.5 TRANSFER AND DISPOSAL

Curbside waste, recycling, and organic materials collected by the private haulers are transported to one of three transfer stations, which also receive waste from public self-haulers. Municipal solid waste (MSW) is consolidated into transfer trucks or railcars for landfill disposal outside the county. The three transfer stations include the Recycling and Disposal Services (RDS) Transfer Station, Regional Disposal Company (RDC) Transfer Station, and Cando Recycling Transfer Station. MSW collected by Waste Management from the communities Diablo and Newhalem (eastern Whatcom County) is transported to the Skagit County Recycling and Transfer Station and ultimately disposed of at the Roosevelt Landfill in Roosevelt, Washington. The County system also includes four drop-box facilities available to public self-haulers: NVD Drop Box Facility, SSC Roeder Avenue Drop Box Facility, SSC Birch Bay-Lynden Drop Box Facility, and SSC Cedarville Drop Box Facility. Waste collected in these drop boxes is hauled to the transfer stations in Whatcom County. Waste for disposal is transferred by truck or rail to the Columbia Ridge Landfill in Arlington, Oregon (RDS), the Roosevelt Landfill in Roosevelt, Washington (RDC), or the Cowlitz County landfill (Cando). While there are no active landfills, there are five closed county landfills maintained under permit in post closure status in the county. Other closed landfills, such as the Y Road landfills, are regulated as MTCA sites (see Section 7.1.3). Other system facilities include the City of Bellingham Vactor Waste Transfer Station, the Whatcom County MRW Facility (Disposal of Taxies Program), and a variety of private recycling and reuse services.

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More detail is provided in Section 7 .1. A list of public and private solid-waste-handling facilities is provided in Appendix A.

1.2.6 SPECIAL WASTE

Special wastes are materials that require special or separate handling because of their unique characteristics, such as bulk, water content, or dangerous constituents. Special wastes include agricultural waste, contaminated soils, vactor waste, tires, and construction and demolition (C/D) waste, to name a few. Special waste is handled through material-specific programs. Details on these programs are provided in Section 8.1.

1.3 PARTICIPATING JURISDICTIONS

Pursuant to interlocal agreements, the Plan defines the solid waste management policy ofWhatcom County and all incorporated cities in the county, including Bellingham, Blaine, Everson, Ferndale, Lynden, Nooksack, and Sumas. These jurisdictions have worked with the County to plan for solid­ waste-related needs since the 1970s and originally entered into formal inter-local agreements regarding solid waste management in 1989. The agreements have been amended over the years. Current interlocal agreements were reviewed as part of the planning process and are consistent with the Plan. These agreements are presented in Appendix C. Each participating jurisdiction, as represented by the Solid Waste Executive Committee (SWEC) through interlocal agreement, adopted this revision to the Plan prior to its approval by Ecology. The Plan encompasses both the incorporated and unincorporated areas of the county, with the exception of the Lummi and Nooksack reservations. In addition, the far eastern portion of Whatcom County (including Newhalem and Diablo) is serviced by the Skagit County waste hauler, currently Waste Management.

1.4 REQUIRED CONTENTS

RCW 70.95.090 mandates the required contents for solid waste management plans in Washington State, including: • A detailed inventory and description of all existing solid waste handling facilities, including an inventory of any deficiencies in meeting current solid waste handling needs. • The estimated long-range needs for solid waste handling facilities projected 20 years into the future. • A program for the orderly development of solid waste handling facilities in a manner consistent with the plans for the entire county that shall: Meet the Minimum Functional Standards (MFS) for solid waste handling adopted by the County and all laws and regulations relating to air and water pollution, fire prevention, flood control, and protection of public health Take into account the comprehensive land use plan of each jurisdiction Contain a six-year construction and capital acquisition program for solid waste handling facilities

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE4 JUNE 14,2016

Contain a plan for financing both capital costs and operational expenditures of the proposed solid waste management system • A program for surveillance and control. • A current inventory and description of solid waste collection needs and operations within each respective jurisdiction that shall include: Any certificate for solid waste collection granted by the Washington Utilities and Transportation Commission (WUTC) in the respective jurisdictions Any city solid waste operation in the county and the boundaries of such operation The population density of each area serviced by a city operation. or by a certificated operation within the respective jurisdictions The projected solid waste collection needs for the respective jurisdictions for the next six years • A comprehensive waste reduction and recycling element that, in accordance with the priorities established in RCW 70.95.010, provides programs that reduce waste, provides incentives and mechanisms for source separation, and establishes recycling opportunities for the source-separated waste. RCW 70.95.090(6) and (7) list detailed program and strategy requirements. • An assessment of the plan's impact on the costs of solid waste collection. The assessment must conform to guidelines established by the WUTC. • A review of potential areas that meet the solid waste disposal facility siting criteria outlined in RCW 70.95.165. A compliance checklist has been provided that clearly articulates requirements specified by state code and illustrates how the revised plan formally achieves each standard on a case-by-case basis (Appendix B). The compliance checklist cites each regulatory requirement and the section in the Plan report that satisfies each criterion. Planning specific to hazardous waste management, as required by RCW 70.105, is presented in Chapter 11.

1.5 RELATIONSHIP TO OTHER PLANS

The 2016 Plan builds on previous solid waste plans, namely the 1999 Comprehensive Solid Waste Management Plan, the 2008 Plan Update, and the 1991 Hazardous Waste Management Plan. These documents provide a useful baseline for the 2016 planning process, but in many cases do not reflect the County's current practices and administrative structure. In addition, this 2016 Plan builds on the foundation of the County's comprehensive plan, which provides framework for growth in the county over the 20-year planning horizon in accordance with the Growth Management Act (RCW 36.7QA). The 2014 Comprehensive Plan is the current, adopted County plan; however, County planning staff are currently in the process of the comprehensive plan update, which is scheduled for adoption in 2016. To ensure consistency between plans, this Plan has been developed using the latest demographic data for population and employment projections provided by County Planning and Development Services. Although the comprehensive plan update

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE5 JUNE 14,2016

will not be complete for another year, these demographic figures have received preliminary approval from the County Council through Ordinance 2014-013 and represent the best data available. Further, this 2016 Plan complies with the land use policies set forth in the 2014 Comprehensive Plan. In addition, the following plans provided a foundation for development of this 2016 Plan and were reviewed for consistency: • Whatcom County Code (WCC), Title 20-Zoning (updated November 2014) • Washington State Growth Management Act, RCW 36. 70A • Washington State Office of Financial Management (OFM) County Growth Management Population Projections by Age and Sex: 2010-2040 • Washington State Department of Ecology (Ecology) 2015 State Solid and Hazardous Waste Plan; Moving Washington Beyond Waste and Toxics (Beyond Waste Plan) • Supporting comprehensive and land use plans for the jurisdictions of Bellingham, Blaine, Everson, Ferndale, Lynden, Nooksack, and Sumas.

1.6 THE SOLID WASTE ADVISORY COMMITIEE AND SOLID WASTE EXECUTIVE COMMITIEE

The Solid Waste Advisory Committee (SWA C) provides ongoing public input and advice to the County on solid waste management issues and played a critical role in overseeing the creation of this Plan. The SWAC consists of 11 committee members: eight Council-appointed members and three designees from the County and municipal jurisdictions. Members are appointed for three-year terms, with a two-term limit. Returning members are required to have a one-year separation between terms, and that position is filled by another individual for the entire term. The SWAC meets on a quarterly basis to discuss current solid waste issues. To facilitate the development of the Plan, a SWAC subcommittee was formed to provide frequent direction to the planning team on an as-needed basis. The SWAC includes the following members, with SWAC subcommittee members designated: • County Council Representative • City of Bellingham Representative (SWAC subcommittee) • Small Cities Representative • Citizen Representative I • Citizen Representative II • Public Interest Group Representative I (SWAC subcommittee) • Public lnterest Group Representative II • Business/Industry Representative (SWAC subcommittee) • Waste Collection Industry Representative • Waste Recycling Industry Representative (SWAC subcommittee) • Solid Waste Disposal Facility Representative The SWEC consists of the County Executive and Mayor of each city, and was established in 1991 by interlocal agreement. SWEC meets at least annually as may be necessary to approve the Plan or

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE6 JUNE 14,2016

amendments to the Plan, review and approve budget proposals, flow control ordinance revisions, and other solid waste system policy considerations.

1.7 MISSION

The County's mission through implementation of the Plan is to facilitate an economically efficient waste prevention, recycling, and disposal system that protects human health and the environment. The County provides for appropriate and economical utilization of natural resources for the citizens of Whatcom County by managing a privatized solid waste system. The Plan works to develop, monitor, educate and enforce various federal, state, and local government plans, laws, regulations, and grants. The County achieves this mission through the following objectives: • Reduce or prevent, where possible, the generation of solid waste and MRW and their associated issues through service-oriented, cost-effective actions in which prevention or reduction will protect human health, safety, and environmental quality. • Solve issues related to solid waste and MRW through service-oriented actions that protect human health and safety and environmental quality. • Maintain a balance with the privatized solid waste system while ensuring that user needs are satisfied. • Provide necessary support for the preceding goals, using service-oriented, cost-effective actions.

1.8 PROCESS OF UPDATING THE PLAN

This Plan was developed by the County through direct input from staff, the public, SWAC, SWEC, WUTC, Ecology, and industry stakeholders.

1.8.1 DEVELOPMENT OF SOLID WASTE PLAN

The preparation of the 2016 Plan began in July 2014. At the start of plan development, background information available in the previous plan was reviewed, and informational interviews with County staff and service providers were conducted to update the description of the overall County solid waste system. These interviews provided insight into the effectiveness of programs and system capacity from a service-provider perspective, with interviewees providing feedback on potential system gaps for further evaluation by the SWAC. This description was used as the basis for the data gathering analysis and reporting process for the plan update. An updated description of the current solid waste system was prepared so that all members of the SWAC had an accurate basis for evaluating the path forward. An evaluation of the system's past performance was conducted using data from Ecology's annual waste disposal and recycling summary for the County. Data from the past ten years were compiled and analyzed to understand total tonnage of waste recycled, diverted, and disposed of, as well as the breakdown by type of the county's recycled and diverted materials. This analysis resulted in a detailed understanding of the historical waste profile critical to understanding the value of specific waste management programs.

WHAT COM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE? JUNE 14,2016

A demographic analysis was conducted to understand historical population trends. Future population projections were also considered and the anticipated growth rate was applied to estimate future waste disposal and recycling trends. When considered with the waste generation information, changes in individual waste generation and recycling habits could then be analyzed. An updated understanding of the current system was developed with support from the SWAC subcommittee. County staff worked with the SWAC subcommittee and consultant team to identify 15 goals in these primary areas to address the needs identified through the planning effort. Forty­ three supporting actions were developed by the County and its partners, providing a road map for strategic implementation of each goal.

1.8.2 IMPLEMENTATION PLAN

The implementation plan described in Chapter 10 was developed to assist the County in the systematic achievement of each goal defined in this Plan through specific, measurable actions, Each of these actions is described in detail in the corresponding sections. Actions were prioritized over the six-year planning horizon, from year 2016 through 2021. The implementation plan is designed to assist the County with decision-making associated with new or expanded programming, as funding becomes available.

1.8.3 PUBLIC PARTICIPATION

The SWAC meets on a quarterly basis to provide public input and advice to the County on a variety of solid waste management issues. To assist with the development of this Plan, the County SWAC formed a subcommittee of members who agreed to meet on a more frequent basis to facilitate the rapid development and evaluation of information and strategy. The subcommittee met periodically, between September 2014 and February 2015, and went through a process of evaluating the existing system, identifying needs, setting goals, and determining future action items. The progress of the plan development was reviewed with the SWAC during their regular quarterly meetings, with ultimate approval of all recommendations coming from the full SWAC. All draft chapters and subsequent revisions of the 2016 Plan have been reviewed by the SWAC. SWAC meetings were open to the public and provided opportunities for public input. Planning materials and periodic updates were posted on the County's solid waste web site to ensure inclusivity in the process. Following the development of the draft Plan, the Plan was presented to the full SWAC and then released for a 30-day public review and comment period. Toward the end of the review period, the County Council held a public hearing to consider public comments on the draft Plan, After revision to incorporate public and Ecology comments, and SWEC review and approval, the Council formally adopted the final Plan and submitted it to Ecology for approval. The final resolution for adoption and accompanying interlocal agreements are located in Appendix C, as are copies of SWAC and SWEC meeting minutes recommending Plan approval.

1.8.4 PUBLIC AGENCY REVIEW

A State Environmental Policy Act (SEPA) checklist was prepared in conjunction with the Plan update. The submittals and meetings required for SEPA checklist review and approval were timed to facilitate the incorporation of the SEPA checklist (Appendix D) into the final revision of the Plan submitted to Ecology.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGES JUNE 14,2016

The WUTC reviewed the draft Plan, as well as the WUTC Cost Assessment Questionnaire (Appendix E), during the approval process. The WUTC regulates solid waste companies and reviews solid waste plans to evaluate probable financial impacts to ratepayers. More information regarding their authority is provided in Section 9.1.1. The WUTC issued a letter dated September 10,2015 indicating it had no comments on the revised Plan (Appendix E). The draft Plan was also reviewed by all participating local jurisdictions represented in the Plan. To ensure consistency with prior efforts, the Plan was also reviewed by the County Public Works Department, the previous County authority for solid waste management (effective January 1, 2015 the County Solid Waste Division was transferred from the Public Works Department to the Health Department). The County Health Department revised the Plan to address comments received from all parties. The revised draft was submitted to Ecology for its 120-day review and comment. Once the County incorporated Ecology's comments, the County carried out the local adoption process, including revisiting interlocal agreements with participating municipalities to ensure accordance with the terms. Following adoption, the final Plan was submitted to Ecology for final approval. Implementation of the 2016 Plan began following Ecology approval.

1.9 ORGANIZATION OF THE PLAN

This Plan provides an overview of existing conditions, needs, and opportunities, as well as defining system-wide solid waste management goals. Action items supporting each of these goals are embedded in the corresponding chapter. The format of this Plan was drafted to correspond with the Plan Organization Table provided in the Ecology Guidelines for Development of Local Comprehensive Solid Waste Management Plans and Plan Revisions (Publication No. 10-07-005). However, the plan outline was modified following discussion with Ecology staff to meet the unique needs of the County, which operates as an administrative and educational agency overseeing a privatized solid waste system. The resulting plan framework focuses on system-wide goals and actions for implementing new programs and services, rather than evaluating alternatives for future specific facility or infrastructure improvements, which will be determined by the private waste collection and disposal providers. This Plan includes ten subsequent sections relating to: • Waste reduction • Public education • Recycling • Organics • Waste collection • Transfer and disposal • Special waste • Administration and enforcement • Implementation • Hazardous waste management

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2 PLANNING AREA

2.1 DESCRIPTION OF THE PLANNING AREA

Whatcom County is the northernmost county in western Washington. The county, depicted in Figure 2-1, covers an area of 2,182 square miles and extends from the Strait of Georgia eastward to the crest of the Cascade Mountain Range. Whatcom County is bounded on the north by Canada, Okanogan County to the east, and Skagit County to the south. Nearly two-thirds of the county's total land area lies in the mountainous region of the Mt. Baker National Forest, with most of the population residing in the western portion of the county. The solid waste management planning area encompasses the entire county, including the incorporated municipalities of Bellingham, Blaine, Everson, Ferndale, Lynden, Nooksack, and Sumas, but excepting tribal lands. Figure 2-2 shows this area in greater detail, including city limits, urban growth areas, and tribal lands.

2.1.1 NATURAL ENVIRONMENT

Topography Northwestern Whatcom County is relatively flat terrain, with elevations ranging from sea level to a few hundred feet above mean sea level. Rolling hills characterize the bottom southwestern portion of the county. The eastern portion of the county is typically mountainous. Mt. Baker, the most notable landmark of the North Cascade range, reaches an elevation of 10,781 feet (USGS, 2015). Climate The county's position between western ocean salt water and eastern mountains gives it a maritime climate. Winters are generally moist, with temperatures dropping into the 30 degrees Fahrenheit range; summers are generally dry, with temperatures in the 70 degrees Fahrenheit range. Precipitation falls mostly as rain in the lowlands and snow in the mountains, and varies from 30 inches per year near Puget Sound to as much as 200 inches annually in the Cascades. Hydrology Three main river systems, the Nooksack, Sumas, and Skagit, help to drain the lowlands, foothills, and western mountains. The largest body of water in the western part of the county is Lake Whatcom (4,924 acres) and is the main source of drinking water for Bellingham. Other sizable lakes include Lake Samish (809 acres), Lake Terrell (321 acres), Silver Lake (157 acres), Lake Padden (14 7 acres), and Wiser Lake (116 acres) (WDFW, 2015). Because of the county's hydrological features, the area available for the development of any future solid waste disposal landfill sites has proven to be extremely limited. Therefore, all solid waste generated in the county is transported to permitted sites outside the county.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 10 Comprehensive Solid and Hazardous Waste Management Plan Update

Figure 2-1 Whatcom County 8 Base Map Whatcom County Washington

Project Location

BRITISH COLUMBIA, CANADA

WHATCOM COUNTY

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FEDERAL LAND

Legend CJ Planning Area ,-'j City Boundary WHATCOM COUNTY Urban Growth Area County Boundary Washington Boundary Federal Land Uf.ill! Tribal Lands

4.5

Miles COUNTY ~ CHELAN COUNTY Source: Modeled terrain from EsriArcGIS Online City Boundary, County Boundary, Federal Lands, Railroad, & Roads from Whatcom County. SKAGIT COUNTY

SNOHOMISH COUNTY BRITISH COLUMBIA, CANADA Comprehensive Solid and Hazardous Waste Management Plan Update

Figure 2-2 Land Uses Map

Whatcom County Washington

Legend County Boundary Comprehensive Plan Designation Urban Designations [~=-j Incorporated City Limits Small Town Urban Growth Area Urban Growth Area Reserve

Agriculture lfll Commercial Forestry Federal Land m Major/Port Industrial UGA ~ Mineral Resource Lands Public Recreation Rural Forestry Rural 1111 Rural Business Rural Community

- Rural Neighborhood Ill Rural Tourism

Note: 1. Urban and rural designations are consistent with Revised Code of Washington 70.95.090(7)(b).

9,000 18,000 l"iiiiiiiiiiii Feet ~ Source: City Boundary, National Forest Area, Planning Area Designations, Waterbodies. Zoning Designations from Whatcom County. JUNE 14,2016

Soils and Geology There are a wide variety of soil types in the lowland portions of the county, including sandstone, shales, conglomerates, and coal, all of which are underlain by sedimentary bedrock. The lowland consists of alluvial bottomlands, broad fluvial and glacial terraces, and several large moraines of bedded glacial till clays and gravels. The low-permeability cemented hardpan or clay soils provide protection of the underlying groundwater, but can also create constraints associated with construction of solid waste disposal facilities. A very compact or firmly cemented and comparatively impervious hardpan could result in a perched water table and make excavation difficult. From a solid waste management standpoint, the area's most important physical feature is the alluvial plain of the Nooksack River, which extends more than 20 miles inland and is a center for population and economic activity. The terrain is relatively flat, with a few low, poorly drained sections oflakes and marshes. The Nooksack River meanders slightly above sea level and periodically floods areas between Lynden and Ferndale. Just east of the alluvial plain, the north, middle, and south forks of the Nooksack River have formed narrow valleys as they flow out of the Cascade foothills. In southwestern Whatcom County, glaciers of the Pleistocene epoch (about 10,000 to 15,000 years ago) carried uplifted and eroded rocks to the sea, forming Lake Whatcom and Lake Samish, and affecting the Chuckanut Mountain Range. The southern edge of Bellingham is situated on the lower, primarily sandstone slopes of the Chuckanut Mountains. Potential land disposal sites can be found in the unconsolidated deposits of the lowland portion ofWhatcom County. These deposits consist of two distinct types, characterized by whether they were formed by glaciers or water movement. Glacial movement formed marine and till deposits around King Mountain, Lummi Peninsula, the northern half of Lummi Island, Mountain View, Birch Point, and Point Roberts. Glacial deposits are essentially an impervious, blue-gray, compacted mixture of clay, silt, sand, and gravel up to 50 feet thick. Deposits from water movement associated with glacial outwash and recent alluvium also contain clay, sand, silt, and gravel, but are not as impervious as the more compact glacial deposits. Such sedimentary deposits are located along the Nooksack lowland, Custer Trough, Lynden Terrace, and Sumas Trough. The detailed soils maps produced by the Soil Conservation Service and the U.S. Geological Survey should be consulted for site-specific information.

2.1.2 COUNTY DEMOGRAPHICS

Population Waste generation, recycling, and disposal rates of an area are a function of the county's population and projected growth. The 2010 U.S. Census estimated the total county population as 201,140. The population of the incorporated areas was 114,061, while the population of unincorporated areas was 87,079. The U.S. Census defines urban areas as census-designated places that contain 2,500 residents or more. By this definition, 94.3 percent of the total county population resided in urban areas. Table 2-1 provides a more detailed breakdown of different areas in the county from the federal census data.

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Table 2-1 Whatcom County Population

PLACE 2000a 2010a 2013 Urban Areas Bellingham 67,171 80,885 82,759b Blaine 3,770 4,684 4,793b Ferndale 8,758 11,415 11 ,679b

Lynden 9,020 11,951 12,228b Unincorporated Urban 66,117 80,789 82,661b Urban Subtotal 154,836 189,724 194,120b Rural Areas Everson 2,035 2,481 2,538b Nooksack 851 1,338 1,369b Sumas 960 1,307 1,337b Unincorporated Rural 8,132 6,290 6,436b Rural Subtotal 11,978 11,416 11 ,680b TOTAL POPULATION 166,814 201,140 205,800c Source: aData for 2000 and 2010 was provided by the U.S. Census Bureau. bThe breakdown of population estimated for each jurisdiction in 2013 was calculated by assuming the same population share for each jurisdiction in 2010. crotal population for 2013 is projected data prepared by OFM.

Between 2000 and 2010, the growth rate of county population varied between 0.6 percent and 2.6 percent per year, with an average annual growth of 1. 8 percent. Employment The U.S. Census 2013 American Community Survey reports that approximately 96,145 individuals above the age of 16 are employed in Whatcom County. The current employment rate is approximately 46.7 percent. This employment rate is comparable to the future statewide employment rates projected by OFM. To support the ongoing comprehensive planning update effort, the County also conducted analysis of employment in the county. The study utilizes county population and statewide employment forecasts, provided by OFM, to estimate an annual employment growth rate of approximately 1.1 percent through 2036. Overall, 64 percent of employment growth is expected to occur in the City of Bellingham Urban Growth Area (UGA), with additional growth occurring in the cities of Ferndale and Lynden (6.6 percent and 6.1 percent, respectively). The major growth sectors for the county as a whole are commercial (59 percent of total anticipated growth), industrial (26 percent), and retail (15 percent) (BERK, 2013). Table 2-2 illustrates historical employment rates in Whatcom County compared to Washington State.

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Table 2-2 Employment Rates

Whatcom County Washington State Historical Estimates 1990 50.6% 49.4% 2000 50.1% 49.2% 2010 48.0% 47.1% Projections 2020 - 46.6% 2030 - 44.8% 2040 - 44.4% Source: BERK, Whatcom County Population and Employment Projections and Urban Growth Area Allocations, 2013. (References: OFM Long-term Forecast of the Washington Labor Force, March 2012-2013, Employment Security Department Local Employment Statistics.)

Employment opportunities in the county are diversified; however, health care and social assistance, retail trade, manufacturing, and education services provide the largest shares of employment. Table 2-3 provides more detail on the county's most substantial industry sectors. According to the U.S. Census Survey of business owners, conducted in 2007, there are nearly 20,000 companies in Whatcom County, Table 2-3 Whatcom County Employment Sectors, 2013

Industry % ofTotal Population Median Annual Income Health care and social assistance 13% $29,541 Retail trade 13% $21,231 Manufacturing 11% $40,737 Educational services 11% $26,687 Professional, scientific, management, and 10% $33,640 administrative Accommodations and food service 7% $13,393 Construction 6% $36,317 Financing, insurance, and real estate 5% $39,106 Public administration 5% 56,606 Transportation, warehousing, and utilities 4% $48,957 Other services 4% $21,014 Agriculture, forestry, fishing, hunting, and mining 4% $22,536 Arts, entertainment, and recreation 3% $21,821 Wholes ale trade 3% $37,170 Information 2% $32,739 Source: 2013, U.S. Census American Community Survey

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2.1.3 LAND USE

Whatcom Courity covers approximately 2,152 square miles, with the majority (nearly three-quarters) of nonfederalland use distribution in unincorporated Whatcom County dedicated to forestry and agriculture. Residential lands make up approximately 11 percent of the county's unincorporated areas. The Washington State Growth Management Act requires that counties designate UGAs based on the 20-year population projections developed by OFM. By definition, these areas must contain enough space and density to accommodate the projected growth. Counties then allocate data­ gathering tasks for more specific forecasts, which are essential for planning by cities, towns, and rural areas. Whatcom County's process involves all jurisdictions and the County's Planning Department. The Whatcom County Comprehensive Plan, most recently updated in 2014, sets policies for land use, community services, transportation, and environmental management.

2.2 HISTORY OF SOLID WASTE SYSTEM

The 2016 Plan represents the sixth iteration of the Plan. Each planning period represents a chapter in the history of solid waste management in Whatcom County, and each has contributed to where we are today. Until the early 1970s, the County was involved in relatively unsophisticated solid waste disposal, the management of four dumps: Birch Bay-Lynden, Cedarville, Point Roberts, andY-Road. In addition, two incinerators were privately operated by Recomp of Washington, Inc. and Olivine Corporation (the last incinerator, operated by Recomp of Washington, Inc., ceased operation prior to 1996). In the early 1970s, the County acquired minimal solid waste management planning responsibilities as a result of a new state law, and produced its first plan in 197 4. The Plan was developed in conjunction with the cities and towns in the county, and recognized that open dumps were no longer an acceptable solid waste disposal method, and that public health and environmental concerns warranted a more rigorous approach. This is when "the system" was formed, and the County set up a separate Solid Waste Management Division within its Department of Public Works. At that time, state grants helped finance capital costs, while disposal or tipping fees financed operational costs. In the early 1980s, the system began closing its dumps to all municipal solid waste (MSW), and three of the four accepted only C/D waste until the late 1980s. During the late 1980s, the County relied on private disposal companies and Cedarville Landfill to provide for the county's waste disposal needs. The system also began environmental compliance at the closed landfill sites and developed the second iteration of the Plan. The 19R0s saw the system expand its solid waste management activities to include more than disposal, at least partially as a result of increased state and federal requirements. During this period, the system closed most of its existing dumps, examined the feasibility of waste export versus finding a site for a new landfill, and began the development of the third iteration of the Plan. Most importantly, from a functional viewpoint, the system designed and implemented its initial recycling and MRW programs. Trends in federal and state environmental regulation had increased the emphasis on multimedia approaches to environmental problems. Activities such as solid waste management were seen as capable of contributing to the resolution of problems such as resource depletion and air and water pollution. For the first time, the system formally acknowledged that its

WHAT COM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 16 JUNE 14,2016

waste responsibilities extended beyond solid waste and beyond disposal-related activities. One component of this acknowledgment was the adoption, in the 1990 plan, of a 41 percent recycling goal by 1994. Since the 1990 plan was adopted, the system made the decision to abandon efforts to site a County­ owned landfill, and expanded the recycling and MRW programs into the area of waste and pollution prevention, with an increased emphasis on recycling and MRW-related activities. In addition, environmental compliance responsibilities increased as a result of additional mandates and closure of the Cedarville Landfill. Since this time, the private sector has played an increasing role in the County's solid waste system, providing not only for disposal, but also for handling of solid waste. While the system owns the MRW Facility (Disposal ofToxics Program), the operation of the facility is contracted out. Later iterations of the Plan, in 1999 and 2008, stressed the importance of diverting waste from landfill through reducing, reusing, recycling, and composting. The primary roles of the County in the current system revolve around in-house waste prevention, public education and outreach, in-house recycling, MRW disposal, monitoring and compliance at closed landfills, enforcement, and administration.

2.3 QUANTITY AND CHARACTERIZATION OF SOLID WASTE

This section identifies and characterizes the county's waste stream, which provides the information necessary for evaluation of existing programs, development of new strategies, and implementation of new or revised planning measures.

2.3.1 SOLID WASTE DEFINITIONS

The following definitions describe general categories of waste discussed throughout this Plan. A more comprehensive glossary of definitions is provided immediately following the main body of this document. Solid Waste: All putrescible and non-putrescible solid and semisolid wastes, including, but not limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, C/D wastes, abandoned vehicles or parts thereof, contaminated soils and contaminated dredged material, and recyclable materials. MSW: A subset of solid waste that includes unsegregated garbage, refuse, and similar solid waste material discarded from residential, commercial, institutional, and industrial sources and community activities, including residue left after recyclables have been separated. Industrial Waste: Industrial waste includes by-products from manufacturing operations, food processing, and other industrial processes, such as scraps, trimmings, packaging, boiler ash, wood­ product residuals, and other discarded materials not otherwise designated as a dangerous waste under WAC Chapter 173-303. Recycling: Transforming or remanufacturing waste materials into usable or marketable materials for use other than landfill disposal or incineration. Recycling does not include collection, compacting, repackaging, and sorting for the purpose of transport.

WHAT COM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 17 JUNE 14,2016

Diversion: Any method of recycling, energy production, or beneficial use that prevents disposition of material in landfills or incinerators. This definition includes all materials that are reported as recyclable. Waste Reduction: Also sometimes referred to as "waste prevention" or "precycling." Waste reduction is the practice of minimizing waste through responsible purchasing and consumerism. It is, essentially, removing waste from the waste stream by not creating it in the first place. Waste reduction is typically achieved through better product or packaging design, by improved efficiency of use by the end user, and/ or by process management.

2.3.2 WASTE DISPOSAL

The discussion presented below is based mainly on data that were collected by Ecology and provided to Whatcom County. 1 A total of 311,842 tons of solid waste was generated in Whatcom County in 2013 (this is inclusive of recycled, diverted, MSW, and industrial and inert wastes). Most of the total solid waste generated in the county is MSW, with roughly 56 percent of total county wastes disposed of at Columbia Ridge landfill in Arlington, Oregon (RDS), roughly 36 percent disposed of at the Roosevelt Landfill in Roosevelt, Washington (RDC), and a very small amount disposed of at the Headquarters Landfill in Cowlitz County, Washington. The remaining 8 percent of waste was disposed of at the BP Cherry Point landfill in Blaine, Washington, the Cemex waste landfill in Everett, Washington, the greater Wenatchee regional landfill in East Wenatchee, Washington, and Graham Road Recycling and Disposal in Medical Lake, Washington.

2.3.3 POPULATION PROJECTIONS

OFM's population estimates for 2013 are used as a basis for the discussion below (OFM, 2014). OFM provides population forecasts for each county in Washington State. OFM has prepared high-, medium-, and low-series population projections for Washington counties through 2040. ~ 43.62.035 provides that counties may, for purposes of growth management planning, use values between the high and low projections. As shown in Table 2-4, the intermediate series population projection predicts a county population of 284,901 in 2040. These populations would be attained with an average annual growth rate of approximately 1.4 percent over the planning period. The OFM low- and high-series projections have average annual growth rates of approximately 0.8 percent to 2.1 percent, respectively.

1 http: I I www.ecy. wa.gov /programs I swfa/ solidwastedata/ disposal /Landfil!Reports2013.pdf

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Table 2-4 OFM Population Projections

Year Low Series Medium Series High Series 2015- estimated 192,540 210,050 231,274 current 2020 202,407 225,307 255,019 2025 210,985 241,138 287,764 2030 217,628 256,643 302,509 2035 224,268 271,142 326,254 2040 230,908 284,901 350,000 Av.erage Annual 0.8% 1.4% 2.1% Percent Growth Note: All projections based on 2010 base year population of 201,140.

Figure 2-2 OFM Population Growth Trajectory for Whatcom County-Low, Medium, High 400,000 ,-;:======:;------, -Census f OFM Estimate 350,000 .. · • • •• • • • 2012 GMA High .... ···· 300,000 .. .. · ...... , 2012 GMA Medium ,• .. ·.. ·· .·· 250,000 • • •• • • • 2012 GMA Low .. ·

200,000

150,000

100,000

50,000 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040

Continued increases in population and households likely will result in increased overall solid waste generation, which will increase the need for continued emphasis on waste reduction and recycling.

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2.3.4 SOLID WASTE PER CAPITA

In 2013, 311,842 tons ofMSW (including recycled and diverted material) was generated in Whatcom County (see Table 2-5). Of that total amount generated, 135,134 tons were transported to and disposed of at an MSW landfill. With an estimated population of205,800 in 2013 (OFM, 2014), the county's municipal disposal rate was 1,313 pounds per person per year, or 3.60 pounds per person per day. Table 2-5 summarizes the county's total waste and diversion rates per capita over the last ten years. Table 2-5 Whatcom County Municipal Solid Waste Summary-Total and Per Capita 2003-2013

Year

2003 2004 983 2005 107,677 142,324 1,013 1'164 1,539 2006 109,583 105,430 152,664 1,153 1'109 1,606 2007 132,007 88,602 156,043 1,349 906 1,595 2008 121,917 28,232 149,751 1,234 286 1,515 2009 92,358 75,300 138,623 925 754 1.388 2010 103,385 88,194 133,943 1,028 877 1,332 2011 129,553 55,679 130,171 1,282 551 1,288 2012 120,215 88,347 132,539 1,181 868 1,303 2013 114,055 62,653 135,134 1,108 609 1,313 NOTES: Tons landfilled data for 2003-2013 are taken from annual Ecology records. Recycled tons are taken from annual Ecology Recycling Survey.

2.3.5

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2.3.6 DISPOSED-OF MUNICIPAL SOLID WASTE STREAM COMPOSITION

In 2009, Ecology conducted a four-season MSW characterization study that identified major waste stream compositions for specific counties in Washington State. 2 The study included wastes generated from four major sectors: commercial waste sector, residential waste sector, self-hauled C/D waste sector, and self-hauled other waste sector. Figure 2-3 below shows the disposed-of waste stream composition for the county from all waste sectors averaged over the four seasons. Figure 2-3 Whatcom County Waste Stream Composition 2009 Seasonal Study (All Seasons)*

Construction, 30%

' 11%

Consumer Products, 10%

*Ecology seasonal percentages have been averaged among the four seasons.

The annual disposed-of waste stream composition for Whatcom County is nearly identical to the waste stream composition for Washington State as a whole.

2 http://www.es;J!.Wa.gov/pubs/1007023.pdf

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2.3.7 OTHER DISPOSED-OF SOLID WASTE

Table 2-6 shows the other major waste streams generated in Whatcom County in addition to MSW. Table 2-6 Whatcom County Total Tonnage of Waste Disposal 2003-2013 Asbestos- Municipal Industrial Petroleum- Year C/D Waste Containing Waste Waste Contaminated Soil Materials 2003 135,114 2,663 1,808 17,019 294 2004 140,913 16,827 9,765 24,312 473 2005 375,284 176,816 18,106 15,483 413 2006 152,664 4,556 5,665 16,727 381 2007 156,043 29,503 11,299 815 6,214 2008 149,751 3,447 10,901 3,034 1,004 2009 138,623 1,511 12,197 460 67 2010 133,943 4,109 10,485 2,938 236 2011 130,171 7,893 16,332 440 227 2012 132,539 13,380 8,062 2,270 115 2013 135,134 3,407 6,027 4,541 93

Percent of Total 79% 12% 5% 4% <1% Waste Stream

2.3.8 DIVERSION AND RECYCLING RATES

Diverted waste is the prevention of landfill disposal of generated waste though source reduction, reuse, recycling, energy recovery, or composting. The waste diversion rate for the county over the most recent five-year period (2009 to 2013) has fluctuated between 52 and 58 percent. The rate of recycled MSW over the same period has been between 40 and 50 percent. Major diversion streams for the county include C/D-related waste, metals, paper, and organics. Major recycled streams for the county include metals, paper, and organics. Figure 2-4 illustrates the major recycle stream compositions.

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Figure 2-4 Whatcom County Recycled Stream Composition 2007-2013

Other, 3%

Electronics, 1%

Vehicle, 3%

Plastic, 2%

A summary of the overall diversion and recycling rates for 2013 are summarized in Table 2-7.

Table 2-7 Total Tonnage of Waste Generation, Diversion, and Recycling Whatcom County 2013 Total Tonnage of Waste Generation and Diversion (2013) MSW Disposed Of 135,134 Other Waste Types Disposed Of 26,551 Recycled MSW 114,055 Diverted MSW 62,653 TOTAL MSW GENERATED 249,189 TOTAL RECOVERED 176,708 TOTAL WASTE GENERA TED 338,393 OVERALL RECYCLING RATE 46% OVERALL DIVERSION RATE 52%

2.3.9 WASTE PROJECTIONS

Per Capita Waste Projections The per capita MSW generation chart is shown in Figure 2-5, highlighting two drastically different trends. Between 2000 and 2008, per capita waste generation rates ranged between 2,300 and 2,600 pounds per person. However, starting in 2009, the per capita waste generation rate fell to a very

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE23 JUNE 14,2016

consistent level of between 2,000 and 2,100 pounds per person. A large part of the change in the annual per capita waste generation rate likely is due to the significant financial recession that began in 2008. This change in the per capita trend is a phenomenon has been observed at a state and national level. A portion of the drop in the per capita waste generation likely is also a result of increasing public awareness of the negative economic and environmental impact, which resulted in improved efficiency (reducing management costs) and/or community motivation to prevent the generation of solid waste. Table 2-8 illustrates the pattern of waste generation trends in the county since 2003. Table 2-8 Waste Summary-Change Over Time 2003-2013

Tons MSW Annual Percent Annual Percent Change in Year Tons Recycled Landfilled Change Tons Recycled 2003 135,114 68,327 2004 140,913 4.1% 80,447 15.1% 2005 142,324 1.0% 93,643 14.1% 2006 152,664 6.8% 109,583 14.5% 2007 156,043 2.2% 132,007 17.0% 2008 149,751 -4.2% 121,917 -8.3% 2009 138,623 -8.0% 92,358 -32.0% 2010 133,943 -3.5% 103,385 10.7% 2011 130,171 -2.9% 129,553 20.2% 2012 132,539 1.8% 120,215 -7.8% 2013 135,134 1.9% 114,055 -5.4% NOTES: Tons landfilled data for 2003-2013 are taken from annual Ecology records. Recycled tons are taken from annual Ecology Recycling Survey.

There are very few data to support the full development of a predictable trend at this lower rate of change in the per capita waste generation rate. Additionally, at the writing of this Plan (2015), the market conditions that were seen during the recession have largely reversed. Therefore, a projection of the per capita MSW generation in Whatcom County has been developed for both of the trends that are shown in Figure 2-5: a high projection assumes the gradual return to the generation rates and annual growth that were observed prior to the recession; and a low projection that assumes maintaining current waste-generation habits. The per capita low projection of waste generation decreases at a rate of 5 pounds per person per year, while the high rate increases at 52 pounds per person per year. The per capita low projection of recycling increases at 10 pounds per person per year, while the high rate increases at 22 pounds per person per year.

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Figure 2-5 Whatcom County Waste Projection, Per Capita

PER CAPITA WASTE PROJECTIONS

4,500

--MSVV Generated Per Capita --MSW DisposNJ Per Capita

High MSW Generation Projection High MSW Disposed Projection 4,000 '"'·~~~=Medium MSW Generdtion Projection "'~ - -.~ Mt:,diurTl MSW Disposed Projection

- · -1 ow MSW Generation Projection - , ,... LovJ MSW Disposed Projection

MSVI/ P(-"f Capita .,, LovJ MSVV f{ecyc!ed Projection 3,500 f\r:~cyded

Medium MSW R{.;.cydEO>d Projection M' "'~ High MSVv' Recycled Projection

3,000

z 2,500 :;ss: ·-·-·-·­·-·-·-·- :;;-Q. "'~ 2,000

1,500

~. -·­ 1,000 ·-·- ·-·-.

500

0 1990 1995 2000 2005 2010 2015 2020 2025 2030 2035 2040 2045 YEAH

Total County Waste Projections Estimates for future waste generation, recycling, and disposal are generated by multiplying the population projections with the per capita waste generation projections. The medium series population projection is shown in Figure 2-6, reflecting the high and low per capita as shown in Figure 2-5. The middle per capita number combined with the medium series population growth for the county identifies a 20-yearwaste potential of 350,000 tons generated, 200,000 tons disposed of, and 150,000 tons recycled. Solid waste service providers were apprised of these waste projections throughout development of this revision of the Plan and have ensured the County that they will continue to plan for and constmct sufficient system capacity in advance of need. The County will continue to work with the private solid waste service providers to ensure that facility capacity is constmcted in advance of need.

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Figure 2-6 Whatcom County Waste Projection, Total

COUNTY TOTAl PROJECTIONS

640,000

--County Total MSW Genet ation --·County Total MSW Disposed

540,000 =- , - High MS\rV Generation Projection - , """ High MSW Disposed Projection -----Medium MS\A/ Generation Projection ..... - -Median MS\AJ Disposed Projection

, =Low MS\,V ,Generation Projection · ,,.. LovJ M~W Disposed Projection

--County Total MSW Recyci<'d , ~ Low MSW Recycled Projection Median MSW Recyled Projection - High MSW Recyled Projection 440,000

zVl ~ 340,000

240,000

'#'

140,0(YJ

40,000 1990 1995 2000 2005 2010 2015 2070 2025 .:?030 2035 2040 2045 YEAR

2.3.10 MODERATE-RISK WASTE MANAGEMENT

MRW is regulated as solid waste, and is defined as hazardous waste (waste chemicals) generated from households and qualified CESQG businesses (conditionally exempt small quantity generators). The State of Washington's 22nd Annual Status Report on Solid Waste, published by Ecology in December 2013, provides a summary of the statewide solid waste activities, including MRW activities. The report states that Whatcom County was one of the five counties that publicly collected the most CESQG waste per capita. The County collected 92,365 pounds of CESQG waste in2012.

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3 WASTE REDUCTION AND PUBLIC EDUCATION

The State of Washington identifies source reduction of waste as a fundamental strategy and a top priority for solid waste management (RCW 70.95). As a result, waste reduction is a critical element of all local solid waste management plans. Waste reduction is defined in RCW 70.95.030 as "reducing the amount or toxicity of waste generated or reusing materials." Recycling is defined in RCW 70.95.030 as "transforming or remanufacturing waste materials into usable or marketable materials for use other than landfill disposal or incineration." There are two primary reasons for promoting waste reduction. One is to reduce the risks associated with all solid waste management methods by reducing toxicity, Reducing the toxicity of solid waste makes all solid waste management methods safer and helps develop public confidence in waste management methods. The other reason is to reduce the quantity of discarded materials. This extends the useful life of existing and future facilities and conserves natural resources; there is also significant economic value to the avoided cost of disposal. Waste prevention and pollution prevention are the most environmentally beneficial waste management strategies. There has been a recent trend in increased focus and support for waste and pollution prevention, including the most recent revision to the Beyond Waste Plan. An obstacle that remains, however, is that while individual companies can achieve considerable economic benefits through waste and pollution prevention, no other company, such as a hauler or processor of recyclables, will gain from another party reducing their generation of waste. This is contrary to the situation of recyclables, where certain companies earn money by helping others to recycle. Since no such profits exist in the case of waste or pollution prevention, the marketing of these strategies is left largely to the public sector and nonprofits, with some exceptions. In Whatcom County, County programming and work conducted by Sustainable Connections, RE Sources, WSU and others attempt to fill this void. In a few cases, private haulers have demonstrated a balanced approach by pursuing community outreach efforts and providing technical assistance to businesses with reduction and recycling. For example, sse currently provides waste audits to businesses in order to increase efficiency in their customers' system and to help save money and gain efficiencies. The objective of this chapter is to identify waste reduction actions that are reasonable for implementation in the county.

3.1 EXISTING CONDITIONS

3.1.1 PUBLIC SECTOR ACTIVITIES

Whatcom County In a privatized solid waste system, a primary County role in solid waste management is public outreach and education, as well as overall program assessment. The County conducts, sponsors and/ or contracts for several waste prevention and public outreach programs, including in-class education, green classroom certification programs, business outreach through the Local Source Control and EnviroStars programs, and volunteer training through the Washington State University

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(WSU) Extension Master Recycler & Composter Program. The County also serves as a resource for members of the public who may have questions regarding the solid waste program. Classroom Education and Programming are provided by the County through contracts with third-party entities, currently RE Sources. County contractors provide in-classroom education to educate students on responsible waste management, including ways to minimize waste and disposal. Green classroom certifications and waste audits are also provided as a means to measure classroom and cafeteria waste and educate students. More details are provided in Section 3.1.3. Local Source Control is a program funded through grants from Ecology to both the County and the City of Bellingham that provides business assistance for hazardous materials management, stormwater protection, and other resource management issues. The grant focuses on "source control" and the process of identifying pollution sources and preventing them from entering the· environment. Included in these activities is providing technical assistance to businesses to reduce pollution through site visits to businesses. County staff help businesses identify and mange dangerous waste, prepare for spills, and reduce stormwater pollution. The grant also funds the EnviroStars Program (below). The EnviroStars Program profiles sustainable businesses and provides a rating system that helps businesses communicate to the public their commitment to environmental protection. The program provides technical assistance with: • Waste storage • Disposal and recycling • Spill management and prevention • Stormwater protection • Washwater practices • Recordkeeping ENVIROSTARS"' • Processes that generate wastewater • Outdoor storage of products and waste To qualify as an EnviroStar, businesses must not generate large quantities of hazardous waste and must set goals to reduce hazardous materials and improve handling practices. Businesses are rated on a scale of two to five stars based on their ability to reduce waste, protect water quality, conserve energy, and educate the public on green practices. EnviroStar businesses are listed in the annual EnviroStars directory and receive a window decal advertising their participation in the program. Businesses are also recognized through radio, print, and online advertisements and through award nominations. The program is a joint effort between the Whatcom County Health Department and the regional EnviroStars Cooperative. Assistance is provided in conjunction with the County's Local Source Control program. City of Bellingham A Single-Use Carry-Out Bag Ordinance, commonly referred to as the "plastic bag ban," was instituted in the City of Bellingham through Ordinance 2011-07-034. The ordinance prohibited the

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use of single-use, plastic, carry-out bags less than 2.25 mils 3 thick, like those typically provided by retailers at the point of sale. Thick plastic bags, thicker than 2.25 mils, are deemed reusable and may be with or without a charge, at the store's discretion. Large paper bags require a S-cent charge and must be a minimum of 40 percent post-consumer recycled fiber. Fiber content is required to be marked on the outside of the bag. The ordinance represents a big step forward in reducing litter and unnecessary waste, protecting water and wildlife, and saving money by reducing the use of plastic bags in the community. The ordinance was approved in July 2011 and took effect in August 2012.

3.1.2 PRIVATE SECTOR ACTIVITIES

Repair and reuse of durable products represent the most traditional forms of waste reduction and are well established in the county. There are various nonprofit and for-profit ventures in the county that accept or purchase used goods and resell them through local storefronts and other outlets. Online material exchanges such as Craigslist (http://www.craigslist.org/) and Industrial Materials Waste Exchange (IMEX; http: //www.lhwmp.org/home/BHW/index.aspx) are additional resources available for material exchange and resale. Reuse of goods is a significant contributor to the success of waste-prevention activities but is also extremely hard to measure because these businesses do not track and report their data in a measure that is comparable to waste (i.e., weight in tons). The following organizations accept used goods from the public in the county. This list of organizations should not be considered inclusive of all organizations that accept used goods. Appliance Depot offers free curbside pickup of large household appliances in the City of Bellingham. Pickup service in other areas of the county is also available. Appliance Depot reconditions and then sells these appliances. ARC of Washington State offers curbside pickup of bedding, small appliances, videos, small children's items, clothing/ shoes, craft items, furniture, kitchen equipment, home goods, musical instruments, records, tapes, CDs, camping equipment, and VCRs. Donated materials are sold to the public. Goodwill Bellingham accepts reusable clothing, household items, and electronics, including televisions, computer monitors, desktop computers, and laptops. Donated materials are sold to the public. Habitat for Humanity accepts donations of surplus building materials, furniture, and appliances. Materials are sold to the public at discounted rates. Northwest Center's Big Blue Truck offers curbside pickup of bedding, small appliances, books, videos, clothing/ shoes, craft items, small furniture, kitchen equipment, records, tapes, CDs, toys, bikes, camping equipment, VCRs. Donated materials are sold to the public. TheRE Store is a program of RESources for Sustainable Communities. Staff and volunteers work to divert more than 4 million pounds of C/D waste annually by deconstructing small homes and outbuilding, salvaging usable building materials and furnishings from residential and commercial

3 A mil is equivalent to one thousandth of an inch.

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buildings, offering free pickup of usable building materials and usable manufacturing by-products, and accepting material donations at their facility. The RE Store operates a retail store that sells affordable building materials and furnishings as a quality alternative to new products; locally manufactures fine, handcrafted furniture and furnishings created from repurposed building materials; offers educational opportunities to the community throughout North Puget Sound; and has an extensive community jobs training program with more than 225 work trainees and volunteers, totaling more than 5,100 hours annually. Salvation Army Bellingham accepts clothing, furniture, electronics, and household goods, including pots, pans, and blankets. Donated materials are sold to the public. Value Village Bellingham accepts reusable clothing, household items, and electronics, including televisions, computer monitors, desktop computers, and laptops. Donated materials are sold to the public.

Education programming and public outreach efforts are also provided by the private sector and nonprofit entities. SSC has provided over 2,000 free commercial waste evaluations since 1996. Evaluations are provided to local businesses, government agencies, and institutions such as school districts, St. Joseph's Hospital, and local colleges and universities. These on-site evaluations continue to be provided on request, and through SSC's participation as a Pioneer Business Partner in the Toward Zero Waste Program organized by Sustainable Connections in concert with the City of Bellingham and Whatcom County. Participating entities receive a written report outlining current activities and additional opportunities in waste reduction, reuse, and recycling, as well as links to resources in similar community efforts for water, energy, and traffic. Aggregate recycling savings to the community at large totals in the tens of millions of dollars. Since 1994, the SSC Recycling Manager has reviewed all new commercial and multifamily construction in the City of Bellingham (Ferndale and Blaine applications since roughly 2004) to help design safe and effective enclosures for recycling, composting, and refuse collection, thus adding to the permanent infrastructure in the community, making waste diversion easier and more cost effective. sse also consults regularly with local processors, agency staff and elected officials on new opportunities in public area recycling, event recycling, and possible program expansions. Free recycling and waste prevention consultations have been provided to local event managers for twenty years, helping create an even stronger climate of resource conservation and community support for the curbside program serving all residents. NVD also provides educational materials at their facility and online to educate customers on proper waste-disposal practices, as well as recycling and composting. Sustainable Connections is a nonprofit membership organization that provides educational programming and technical services for reducing waste, increasing reuse and recycling, and increasing the purchasing of recycled and environmentally preferable products. Sustainable Connections provides waste audits, trainings, and education toolkits, and promotes companies committed to reducing waste in the community on a limited basis, determined by funding levels. Sustainable Connections is currently conducting business outreach through funding provided by the Alcoa Foundation. The program actively engages 50 businesses per year over a two-year period, helping participants implement individual Toward Zero Waste (TZW) plans. Of these businesses, 30 to 35 typically are existing participants who need supplemental hands-on assistance to successfully

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implement TZW, and ten to 15 are new partlclpants interested in establishing TZW in their businesses. By September 30, 2014, a total of 365 participating businesses showed improvement in at least two of the following areas: • Reducing solid waste generated by 50 percent compared to pre-TZI participation • Increasing recycling and composting by 50 percent • Reducing their largest solid waste stream • Participating in additional sustainable business practices

3.1.3 NONPROFIT AND INSTITUTIONAL ACTIVITIES

RE Sources is a nonprofit environmental education organization that provides technical assistance for clean energy, water, carbon emissions, and school education programs. RESources also operates The RE Store reuse facility. Currently the Sustainable Schools team offers two types of programming on behalf of the Whatcom County Solid Waste Division's traditional in-class presentations on solid waste, paper-making, and household hazardous waste; and a Green Classroom Certification program for elementary schools. The Green Certification builds on the introductory presentations to create a structured way for classrooms to implement behavior change in the classroom and beyond. In 2014, RESources conducted programming in 81 classrooms, made contact with 1,685 students, and certified seven Green Classrooms. Outreach took place in 15 different schools in six school districts throughout Whatcom County. The 1999 Plan states that, before County funding was reduced, RE Sources conducted outreach to 331 classrooms in the 1995 annual budget cycle. RE Sources is seeking additional funding to expand and extend waste prevention education programming to the middle school level in 2015 and explore the potential for programs at the high school level in 2016. In addition, RE Sources will continue to develop relationships with district­ level staff, starting with Mt. Baker School District. In addition to local efforts led by RE Sources, a handful of schools also participate in the Washington Green Schools program, which provides support and resources provide resource conservation education. County funding for solid waste education is supplemented by funding provided by private foundations and a Washington Service Corps AmeriCorps service member placement. These additional funding sources support education for clean energy, clean water, and low-carbon-living programs. The RE Store provides manufacturing businesses with a waste or by-product audit to identify usable materials and an end use through repurposing as a means for increased diversion and cost savings to those businesses. WSU, Whatcom County Extension hosts a Master Composting & Recycling Program. The effort is a volunteer service program in which volunteers are trained in methods for reducing wasle and increasing public awareness of opportunities to prevent waste, recycle, and compost in Whatcom County. Course participants work with local organizations, community members, neighborhoods, schools, and workplaces, or at special events encouraging waste prevention, recycling, and composting. Scheduled programming for 2015 includes a four-week course with an emphasis on composting and soil building. Enrollment is anticipated at 12 to 15 students.

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3.1.4 FORMER EDUCATION EFFORTS (COUNTY, PRIVATE, AND NONPROFIT)

Although current programming is viewed as an effective mechanism for maintaining current waste­ reduction levels, funding for such programs is scarce and many previous programs were discontinued during the economic recession. The County has a long history of public education and outreach regarding solid waste best management practices. Although these programs have been successful, the County was forced to reduce funding allocated toward public education during the Great Recession. As funding levels return to pre-recession levels, the County may look toward the success of former programs, either reinstating them or preparing new programs. Examples of programs that were previously funded by the County, or that could potentially be funded by the County in the future, are listed below. The Toward Zero Waste (TZW) Initiative is an ongoing effort to reduce waste, increase reuse and recycling rates, and increase purchases of environmentally friendly products by businesses in the county. The program, led by Sustainable Connections, receives funding from multiple public and private sources to promote the TZW in person to a list of nearly 700 business leaders and participants. Outreach staff attend local conferences and events to promote sustainable waste management practices. In addition, the initiative funds the update of the Construction Waste Recycling Toolkit and Service Provider Directory, which is widely distributed both in print and online. Despite the lack of County funding, the program has been highly successful. As of the end of 2014, 379 businesses were participating in the TZW program. Eighty-two percent of respondents have reduced, reused, or recycled their largest waste stream, 54 percent of participants reduced the size of their garbage dumpster, 34 percent of participants reduced the frequency of waste hauler pickup, and 49 percent of TZW participants have instituted at least one additional sustainable business practice. This effort, originally launched in 2009, received funding from Whatcom County in 2009 and 2011, but has not received additional County funding since. Most current program funding comes from private foundations and grants. An Ecology Public Participation Grant (PPG) formerly provided for technical business assistance that was contracted to Sustainable Connections. The program provided technical assistance and educational outreach to commercial entities over a 15-month period in order to promote Green Building and TZW practices. Outreach was conducted to building professionals, business owners, and individuals interested in environmental friendly and energy saving practices. Technical workshops and green building tours were conducted for designers, developers, media, and business entities. Funding was also used to coordinate with waste service providers to measure monthly volumes of generated waste, recycled materials, and costs to business owners for committing to TZW and green building practices. The quantitative data were intended to measure the effectiveness of these methods; however, the PPG was awarded in 2009, but was pulled early because of shortfalls in the Washington State budget. Sustainable Connections has been able to pursue similar work, in smaller amounts, through a Sustainable Path Toward Zero Waste Grant, awarded for 2011-2012. As part of this work, Sustainable Connections conducted a waste audit for the Whatcom County Library System central services, illustrating that waste streams could be reduced by 70 percent by separating materials disposed of. This recommendation has now been effectively implemented in nine other County library locations.

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A formal Recycling Hotline was operated by the County, and previous to that, by RESources, to answer questions regarding waste reduction, recycling, composting, and household hazardous waste. Callers were served by a recorded message and were referred to the County's solid waste Web site, or were able to leave a message. Messages left on the hotline were returned by solid waste staff multiple times per week. Calls made to the hotline are now redirected to the County Health Department receptionist and calls are referred to relevant staff. Additional resources are available online through the state https://www.facebook.com/1800recycle.wa.gov and http: //1800recycle.wa.gov, and via live phone assistance during the week (9:00a.m.- 3:00p.m.) at 1- 800-RECYCLE (1-800-732-9253) Diaper Education Programs were formerly provided in cooperation with Bellingham Technical College; these provided diaper use alternative information through teacher training, student brochures, and an instructional video. Teachers use this information in prenatal and parenting classes. The County also cooperated with the Health Department to distribute this information to daycare providers in hopes of influencing diaper use decisions at daycare facilities. Cloth diaper use increased dramatically (285 percent) as a result of the program. The Paper Tiger Program used posters and brochures to emphasize ways to reduce the amount of waste paper produced in government and business offices. Paper Tiger materials were distributed to businesses and institutions throughout Whatcom County. "Absolutely Free" Listings were free advertisements for free items that ran in four newspapers, the Bellingham Herald, Lynden Tribune, Ferndale Record Journal and the Echo, as well as KGMI radio station and TCI cable station. Permanent Information Centers were installed in 1992 to provide solid waste information on brochure racks throughout the county. Locations include libraries, city halls, post offices, malls, recreation centers, senior centers, Western Washington University and Whatcom Community College. Event Recycling was provided by RESources with funding from the County (and is now required by law). RESources developed an event recycling guide that detailed how to host large, waste-free events (i.e., soccer tournaments, fundraisers, concerts) and then managed a crew of volunteers who staffed the garbage cans at several County events, including Ski to Sea, directing people how to dispose of their waste. Dish Rental service was provided by RE Sources with funding from the County. RE Sources maintained a set of 100 dishes, flatware, and glasses and made them available to the public free of charge. RE Sources still receives inquiries about borrowing flatware. Electronics Recycling assistance was provided by RE Sources in partnership with Ecology and local retailers. Information was provided at stores selling computers, TVs, and other electronics to educate the public on the importance of recycling electronic waste (e-waste) and the programs available to do so. In addition, certain electronics can be recycled for free through a product stewardship program call E-Cycle Washington launched in 2009.

3.2 NEEDS AND OPPORTUNITIES

The State has identified citizen participation as a critical element in decreasing the per capita waste­ generation rate. County residents currently generate approximately 2,422 pounds of waste per person per year, compared to the state rate of 2,552 pounds per person per year. After accounting

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for waste reduction and recycling, county residents dispose of 1,313 pounds per person per year compared to the state rate of 1,303 pounds per person per year. In summary, the average resident is generating less waste than the state as a whole, but somewhat less material is being recovered from the waste stream prior to disposal. As presented in Section 2.3.8, based on the historical trends and existing waste reduction programs, the county per capita waste-generation rate is expected to stay level or increase at up to 2 percent per year over the next twenty years. The goal of successfully implementing the goals and actions of this Plan is to keep per capita generation to the mean 2016 level (or below 2,500 pounds of waste per person per year) and up to a 2 percent decrease in per capita waste generation annually after 2016 (50 pounds per person per year decrease). Keeping per capita waste generation levels steady as the state economy improves is a significant challenge that should be considered to be an indicator of a successful effort. Given the significant volumes of material that require disposal and the projections for continued population growth, there is a need for the County to maintain and strategically improve, as appropriate, its formal waste-reduction programs. It should be noted that with contamination losses of less than 1 percent, the county's effective recycling diversion per capita is significantly higher than the state average, where contamination and processing losses from single stream recycling approach 25 percent by weight. Waste reduction is the state's highest waste management priority. The Solid Waste Management Planning Guidelines recommend that local jurisdictions, such as the County, set specific waste­ reduction goals and implement programs to reduce waste. The County may consider not only development of waste-reduction programs, but also a mechanism for tracking subsequent results. Initial recommendations highlight the need to track county waste trends. Voluntary waste reduction can only be achieved through inclusion of public education, media campaigns, waste audits, classroom education and other outreach activities that promote the economics, necessity, and purpose of waste reduction. If the public does not understand these values, waste reduction efforts are not likely to succeed. If necessary, waste reduction goals may also be supported by regulatory requirements. Easily accessible information is critical to raising public awareness of County- and non-County­ funded waste programs and encouraging public engagement in the waste management dialogue. To heighten public awareness, a rebranding effort may be undertaken to reenergize the community's efforts and increase program recognition. Residents who understand that the County has a role in management of the solid waste system may use the County as a resource when looking for information about management and disposal options. The County can play a significant role in providing easy access to waste management information that is spread to various Web sites, such as those maintained by the private haulers and transfer facilities, composting facilities, the master gardener program, and other municipal entities. Public education and awareness efforts may also be expanded to include preparation of educalional materials that advertise the solid waste services available through the County, haulers, facilities, community partners, and Ecology. Outreach efforts could be enhanced to include a greater presence at public events or by posting the County web site address prominently in public places (e.g., libraries and municipal buildings). The County may also partner with haulers to distribute informational material through billing systems.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE34 3.3 GOALS AND ACTIONS

Education programming and waste reduction are two areas in which the County is most active in improving the solid waste system. As County funding levels for solid waste management improve, the County will prioritize their resources based on the goals and actions outlined in Table 3-1 below. TABLE 3-1 GOALS AND ACTIONS FOR EDUCATION AND COMMUNITY OUTREACH

CONNECTING TO GOALS ACTIONS BEYOND WASTE* 1. Increase community A. Increase current youth and primary school education programming. Priorities of Plan knowledge and expertise of ~~s.~~Tx~pan~crsC:-ilooreauC:-afi'onpro-9r-ammin9foinC:1ucremraaTe~anC:rflT9Fl~scfioor~ • Move upstream by increasing waste reduction methods by levels with age-appropriate projects, information, and messaging. focus on manufacturing and providing educational -~e,~~~supporfanCTtunCTcommercrareau-catfOntFiro~u~9f11al-9mefea-outreacil,~®----- use, not just on end-of-life opportunities to targeted commercial waste audits, and technical assistance. issues. populations using existing -Ts~--rro¥raewas1e~au-aYfsana~pro¥Tae-reC:'hn'iC:-arassisfanC:-eTo_m_cwna-mTiv--~-.~--·· - Enable more reuse of public and private residential tenants and property managers. materials and products. resources. [-~E".~--Inc-reasesupportana-c;crverf1Srri91o'r1FleeX.T5tir19-v:rso-comp-os~tlr19---~-----~- . Mitigate climate change . ------~9Y~S9!~~~P!9_~~~~!~l~Y-~~!~-~~9~!:!_~~~P-~~~~9-~-~:_s~~~~~-~l~~!2-~~-- - Increase reuse, recycling, F. Sponsor community events and promote a theme of zero waste to and waste reduction. educate participants. Make arrangement for waste management and - Prevent food waste. describe the decisions that were made to accommodate the choice. ~-c;~--rubTisl1-ecru-catfonalma1erTars-ab-oufff1e-s-ona-v::,a-s1e-svsTemrn-respons-eto--~- community requests. 2. Utilize appropriate and A. Continue distribution of educational materials digitally and make available K~::: Prin!;;iQI~~ gnd Strat~gi~~ relevant tools for mass in paper form, as requested. • Build on what's already communication and ·~~'B'.~~~Inte-9rcifee-xisfin9pul)ITc~ciria~r;rr~tare~social~m~earaP'rofTI"es-anCJa~5fru-cfur-e--·· working, such as maximizing outreach to further promote for effective advertisement and information sharing. the use of existing implementation of waste --c-~oevelop~acolle-sT¥e-6ranCTin97ortfle-solicf.;7cisfesvsfem,-reco9r1i2:in9-PubTic-,. reduction methods, using an infrastructure. and private roles, and analyze the effectiveness of and develop a relevant Take advantage of integrated public/private • and attention-getting advertising campaign that creates a vision in the momentum and approach. collective public mind and appeals to the senses of the public. complementary actions. --6~-®co~nslae-r-ae-,7elopme-rifo7o1'h-eraf9~altoofSTor~communTca1Ton-ofwasfe-~-- • Create collaborative management information (e.g., mobile Web site, phone app, QR codes on partnerships with a variety of advertising). partners. -~E'.~--c.o-ris1aer·a-markefin9C:-ampaT9n-filatmeefs-rile-publfCwtiel-eTt1eY.~aire~aav- • Strive for continuous are (e.g., on public transit, at events, or in movie theaters). improvement.

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CONNECTING TO GOALS ACTIONS BEYOND WASTE* 3. Develop relevant A. Educate on waste generation habits/trends. educational materials for ~~B'.~~~gaGe:-are-on-wa51e-red'u-cfio-nan-dhome-was1emana9eme-r1f7maTerfal ______residential, commercial, and reuse opportunities, purchasing products with less packaging, purchasing institutional consumers. more durable goods, home composting, and food waste prevention). ~-c_:·--gaiJC:-afeonTt1eenvfronmentaTrm-P'aC:1-ofwasfea-na-.wasfeman-a9e-menr.---

0 --o~~-rromoFeth-etfle-me-oTierowaste~-----"------, ______~- 4. Review solid waste data on A. Review annual solid waste data provided by Ecology and track an annual basis to effectiveness of County programming. understand ongoing solid _T___ Req-uesfmore-ae1ailea-aara:as-ne-eae-a.-rrom-materrartiand"lers1o-6eTte-r--"· waste trends and prioritize understand the effectiveness of County programming. County solid waste initiatives. .This column refers to the 2015 Beyond Waste Plan. The numbering system for key goals and strategies 1s intended to reflect the number system in the Beyond Waste document.

WHAT COM COUNTY COMPRErENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE36 4 RECYCLING

Recycling is defined by the State's Guidelines for Development of Local Comprehensive Solid Waste Management Plans and Plan Revisions as "transforming or remanufacturing waste materials into usable marketable materials for use other than landfill disposal or incineration. Recycling does not include "collection, compacting, repackaging, and sorting for the purpose of transport" (WAC 173-350-100, as adopted by reference in WCC 24.06, Solid Waste Rules and Regulations).

4.1 EXISTING CONDITIONS

Recyclable materials are currently collected in the county according to their potential for waste stream diversion, collection efficiency, processing requirements and market demand. The list of materials that the County Council has designated as "recyclable" is located in WCC 8.1 0.050, Section C. Items are added to or deleted from the list, depending on these very conditions, and as described in Section 4.1.3.

4.1.1 PROGRAMS

Collection Services Residential Curbside Recyclable Collection is legally established and defined under WCC 8.1 0.050, which requires that source-separated recyclables be collected from all residences in unincorporated portions of the county that receive regularly scheduled garbage collection. In accordance with existing solid waste interlocal agreements (Appendix C), each county municipality requires that the County-designated recyclable materials be collected by the contracted waste hauler (SSC, NVD, or Cando, depending on service area) with regularly scheduled solid waste collection. Each private waste hauler offers residential collection services under the conditions of a WUTC permit (G-Permit) in unincorporated areas or through a contract directly with a municipality. Recycling is collected through a three-bin system consisting of bins for newspaper; scrap paper, including cardboard and other wood-fiber materials; and containers, including plastics, glass, aluminum, and tin cans. All single-family residences are provided recycling collection service at least every other week on the same day of the week as garbage collection. Residents in unincorporated areas have the option of applying for a garbage collection exemption if they certify that they self­ haul their waste and recyclables to local transfer or drop-box facilities. Residents claiming the exemption also have the opportunity to subscribe to recycling-only collection. Collection companies provide recycling containers to each residence at the customer's request. The following recyclable materials are collected: newspaper, mixed paper, cardboard, aluminum, tin, glass, plastic bottles, scrap metal, vehicle batteries, and motor oil. Recyclable materials are source­ separated using a stackable, three-bin recycling system for newspaper, scrap paper, and containers.

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Table 4-1 Accepted Curbside Materials by Bin Bin Acceptable Materials Newspaper • Newspaper (Red Bin) • Inserts • Ads Scrap Paper • Mail, magazines, catalogs (White Bin) • Envelopes, stationery, labels, paper sacks, phone books, paperback books, manuals, textbooks, and guides. Note: remove and discard covers and bindings of hardback books. • Computer, copy/office paper (all colors), carbonless paper, file folders, poster paper. • Paperboard cartons (e.g., cereal boxes, mac n' cheese boxes, shoe boxes, gift boxes, egg cartons). Discard liners/packing material. Flatten. • Staples, paper clips, file folder clips OK . Containers • Glass bottles (Blue Bin) • Jars • Aluminum cans • Tin/steel cans • Plastic containers (i.e., bottles, jugs, caps and rings, tubs, pails, buckets, and lids)

Point Roberts, serviced by Cando and presenting special challenges due to geographical constraints, is an unincorporated community on the Tsawwassen Peninsula. Point Roberts is unique because of the seasonality of residents and because it's physical isolation requires two trips across the Canadian border in order for residents to connect to the rest of the county. In Point Roberts, single-family residences are defined as permanent, year-round-occupied homes. Recycling collection in this community is provided every other week, but is not required to take place on the same day as garbage pickup. All Point Roberts single-family residents meeting the WCC 8.1 0.030(H) definition of "seasonal vacation" or "weekend home" are exempt from curbside recycling collection requirements. The unincorporated Newhalem/Diablo area is serviced by Waste Management and has an exclusion from mandatory curbside recycling service per WCC 8.10.010. However, this area meets the minimum program requirements for collection of source separated materials as described in RCW 70.95.090(7)(b)(i) through recycling depots to which residents may self-haul their recyclables. Commercial Recyclable Collection is provided directly to businesses by the private sector in an unregulated system. Recycling collectors include waste haulers, buyback centers, private collection firms, and small "mosquito fleet" operators (often consisting of a single pickup truck and driver). Most commercial MSW customers also subscribe to source-separated collected from the G­ certificated haulers for various materials, depending upon their economic sector. These services are almost universally less costly than disposal, thus exiting rate structures incentivize diversion to recycling and composting, and in some cases, reuse. Commercial recyclables are generally collected in the same material streams as residential (newspaper, scrap paper, and containers). Depending

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upon business size, they may request curbside bins, carts, various dumpsters, drop box, and/ or compactor service. Businesses may also subscribe to source-separated collection of plastic film, scrap metal, drywall, specific industrial plastics, wood, and other source-separated materials (e.g., concrete, pallets, and horse manure). Business participation has been steadily growing since the early 1990s to today, where nearly every local business participates in recycling or waste reduction to one extent or another. Part of this success is due to the rate structure, which makes recycling the more cost effective alternative to solid waste disposal. SSC and NVD also provide technical assistance to businesses requesting information, or that need support in setting up commercial composting services. In-House Recycling The County manages an internal recycling program consisting of the collection of bottles, cans, and paper at all County facilities. The program provides recycling containers at all locations with trash containers in public areas. Recycling is emphasized in office areas by providing a small, deskside trash container and a larger recycling container. These measures have contributed to the County's successful LEED (Leadership in Energy and Environment Design) certification of the Courthouse as an existing building. Electronics Recycling RCW 70.95N.030 requires that manufacturers participate in an independent or standard plan that finances an electronics collection, transportation, and recycling program in Washington State. Products covered under the law include TVs, computers, and monitors (RCW 70.95N.020 6) from "covered entities" defined as any household, charity, school district, small business, or small government. The County and private haulers inform residents, small businesses, and schools about this program through currently existing community outreach and education methods. Electronics can be dropped off at facilities in Whatcom County that are registered withE-Cycle Washington. The web site for this program is www,ecyclewashington.org. Light bulb Recycling As of January 1, 2015, Washington State residents and businesses are able to recycle mercury­ containing lights at no charge, by dropping them off at authorized collection sites throughout Washington State, including the County's MRW Facility (Disposal ofToxics Program). Categories of acceptable lights include fluorescent tubes, compact fluorescent lights, and high-intensity-discharge lights. Recycling mercury-containing lights protects the environment and human health by reducing the release of mercury, a potent neurotoxin. Collection sites are listed on the program web site at http:// www.lightrecyclewa. org/. Tire Recycling Used tires are accepted at transfer stations in the system and at Beacon Battery and Tires. In recent years, the County has been the recipient of multiple tire pile cleanup grants funded by Ecology. These programs are described in further detail in Section 8.1. 9.

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4.1.2 FACILITIES

The following list includes, but is not limited to, facilities that accept recyclable materials from the public: • Alrite Recycling Bellingham-Accepts metals and electronics. • Beacon Battery & Tires-Accepts recyclable scrap lead acid batteries of all sizes, as well as tires ranging in size from wheelbarrow to semi-trailer truck. • SSC Birch Bay-Lynden Drop Box Facility-Accepts metal, antifreeze, oil, cardboard, glass, paper, plastic, cans. • Cando Recycling Transfer Station-Accepts metal, oil, cardboard, glass, paper, plastic, cans, electronics, tires, yard waste, construction debris, wood, and motor oil. • SSC Cedarville Drop Box Facility-Accepts metal, antifreeze, oil, cardboard, glass, paper, plastic, cans. • Granite Construction Company-Recycles rubber, asphalt, and concrete into finished construction materials, including asphalt concrete and road base for local roadways. • Heni:fin Recycling Facility-Accepts clean concrete, concrete rebar, and asphalt . • Lynden Christian School Recycling Center-Accepts cardboard, mixed paper, and aluminum. • NVD Drop Box Facility-Accepts metal, antifreeze, oil, cardboard, glass, paper, plastic, cans, tires, yard waste, and electronics. • Northwest Recycling and Northwest Recycling Warehouse-Accepts metals, appliances, paper, cardboard, automobile bodies, electric motors, radiators, car batteries, and plastics. Provides drop boxes upon request for residential, commercial, and industrial accounts. • Safe and Easy Recycling-Recycles e-waste, including all computers and computer accessories, as well as monitors, televisions, liquid crystal displays, plasma TVs, servers, laptops, cables, cords, cell phones, CD players, DVD players, and many other types of electronics. • SSC Roeder Avenue Drop Box Facility-Accepts recycling of household materials, including metals, plastics, plastic film and miscellaneous plastics, and paper. Also accepts yard waste. • Scrap-It Recycling-Provides free disposal of uncontaminated recyclable materials and buys scrap metal. Also provides demolition services for metal structures and removal of obsolete equipment. • RDC Transfer Station-Accepts scrap metal, vehicle batteries, cardboard, scrap paper, and newspaper. • RDS Transfer Station-Accepts aluminum, vehicle batteries, appliances, cardboard, glass, electronics, paper, tires, plastic, scrap metal, cans, porcelain, sheetrock, wood, and yard debris.

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• Whatcom Builders-Accepts asphalt. • Z Recyclers-Metal recycling center and scrap metal facility that accepts all types of metal. A Material Recovery Facility (MRF) is located at the RDS Transfer Station in Ferndale. Potentially recoverable materials (recycling or diversion) are high-graded out of the transfer station tipping floor and sent to the MRF portion of the site. Construction material haulers may be directed to dump their loads directly at the MRF. The conveyor brings materials past a manual pickline where various construction materials may be sorted, including aluminum, vehicle batteries, appliances, cardboard, glass, electronics, paper, tires, plastic, scrap metal, cans, porcelain, sheetrock, and wood. This facility guarantees a diversion rate of 20 percent for the overall waste stream being processed by the transfer station as a result of the MRF capability.

4.1.3 DESIGNATED RECYCLABLE MATERIALS LIST

Recyclable materials are currently being collected in the county because of their potential for waste stream diversion, collection efficiency, processing requirements, and market demand. The list of materials that the County Council has designated as "recyclable" can be found in WCC 8.1 0.050, Section C. Changes in technology, political climate, and markets may necessitate changes in the designated recyclables. Items are reviewed for addition to or deletion from the designated recyclables list based on the following criteria: • The market price for an existing material becomes so low that it is no longer feasible to collect, process, and/ or ship to markets. • Local markets and/ or brokers expand their list of acceptable items based on new uses for materials or technologies that increase demand. • New local or regional processing or demand for a particular material develops. • No market can be found for an existing recyclable material, causing the material to be stockpiled with no apparent solution in the near future. • The potential for increased or decreased amounts of diversion . • New technologies and innovative program approaches. • Legislative mandate . For instance, for several years, only plastic bottles with necks were accepted for recycling because of available markets for processing. However, in 2009, plastic tubs, such as yogurt and margarine containers, were added to the list as markets became available and processing these items because economically feasible for local haulers. Any proposed changes to the designated recyclables list must be made to the Solid Waste Division and taken to the SWAC for review. The SWAC will make a recommendation to the County executive for review/ approval on whether to add or remove the material from the designated recyclables list. If approved, the designated recyclables list is updated and submitted to Ecology.

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4.2 NEEDS AND OPPORTUNITIES

4.2.1 RESIDENTIAL RECYCLING

Residential recycling programs in the county currently operate under a three-bin collection system. As stated in Ecology reports provided annually to the County, the County system has relatively high recycling rates (40 to 50 percent) and diversion rates (52 to 58 percent) when compared to the state and other Washington counties. Service providers and County staff generally agree that the community, specifically single-family residential users, has a strong understanding of the existing source-separated, three-bin system. The County reports some of the lowest contamination rates in the state, which is commonly attributed to the curbside source separation. Contamination results when customers improperly sort recyclable materials, and results in higher customer costs and additional materials going to landfill. Despite this, the Plan update process considered the benefits of alternative collection methods under a commingled (single-stream) system for recyclables, including the potential for even higher participation rates and improved compliance. However, stakeholders noted the significant challenges associated with conversion to a commingled recycling system, which would require the construction of high-end sorting facilities, a new truck fleet, and access to markets accepting degraded products. In addition, the value of recyclable commodities could decline as a result of increased contamination and increased competition from the many other communities that have already converted to commingled recyclables collection. Given the strong support for the existing three-bin system of collecting recyclables, other collection opportunities were not evaluated in the development of this Plan. Ecology supports the collection of source-separated materials through RCW 70.95.090 (7)(b). Some providers reported issues of improper recycling of materials, including materials being placed in the wrong bins or experiencing overflow of the bins. These issues may be addressed through additional public education programs and advertising. Haulers may also provide notice to customers who repeatedly ignore recycling instructions. In cases where a customer may have a higher volume of recyclable materials than the associated bin's capacity, haulers also typically accept materials, as long as they are appropriately separated, in alternative containers. There is also an opportunity to consider if the materials separated into the three bins are making the best use of the available space. Review of bin-specific materials should be undertaken, as warranted, by the County, haulers, and recyclers to potentially identify a more efficient use of bin space by combining lower-priority, lower-volume materials and identifying new materials for bins that are growing in quantity and volume. Recyclable material reconfiguration could reduce curbside overflow. An example of the evaluation might consider the continued value of dedicating one bin solely to newspaper as that material stream decreases because of consumer trends and the availability of news in digital formats, or collection of plastic bags and films or glass in order to reduce contamination in the paper and container recycling bins.

4.2.2 MULTIFAMILY RESIDENTIAL RECYCLING

Approximately 44 percent of the county's population resides in multifamily residential units, representing a large share of the customer base (U.S. Census, 2009-2013). There is a general perception that recycling rates for multifamily residential are low relative to single-family residential rates. This is commonly attributed to the lack of understanding of the system by multifamily

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE42 JUNE 14,2016

residential subscribers, limited or non-user-friendly recycling infrastructure at multifamily housing units, and a lack of outreach and education to multifamily residents. According to stakeholders interviewed during the Plan update, some building managers have suggested removing recycling bins altogether due to the inappropriate recycling of materials. Some service providers also indicated that the higher levels of contamination found in multifamily recycling bins and lower participation rates are a significant weakness of the existing system The Washington State Recycling Association (WSRA) recognized multifamily recycling as an issue for communities across the state in its 2014 report, "Sorting It Out: That State of Multifamily Recycling in Washington State." Multifamily recycling issues pertain to low participation rates and higher contamination rates than single-family residential. The report notes the lack of targeted focus on multifamily recycling as a primary cause of relatively low multifamily recycling rates, and that an approach with three prongs can help boost rates. The three components are: 1) collection statistics; 2) policies and regulations; and 3) education and outreach. While additional outreach will be helpful, it should be noted that the local multifamily program is now, and has been very successful since 1992. Over 9 5 percent of all multifamily complexes participate, with an average recycling rate of 30 percent, and a contamination rate of below 5 percent.

WHAT COM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE43 4.3 GOALS AND ACTIONS

Recycling and diversion in the county is already highly successful when compared to the state goal of achieving waste stream reduction of 50 percent. In 2013, approximately 46 percent of the county's waste stream was recycled and 52 percent was recycled or diverted, as reported by Ecology. The County recognizes that while recycling remains relatively stable, diversion rates vary and can be easily skewed by one-time events, misrepresenting the success of the County's educational programs. Goals and actions related to recycling focus on maximizing the benefits of the three-bin system; increasing public outreach, including a focus on multifamily residential recycling; and developing a better understanding of how users interact with the overall system. TABLE 4-2 GOALS AND ACTIONS FOR RECYCLING GOALS I ACTIONS CONNECTING TO BEYOND WASTE* Residential Recyc6ng PriQritie~ Qf Elgo l. Enhance residential A. Assess materials currently collected through the three-bin system, focusing on . Move upstream by increasing focus on manufactumg recycling. their relevance to ov era II solid waste system goals and commonly disposed-of and use phases, not just on end-of-life issues. recyclable materials. - Enable more reuse of materials and products. ~K~~'Evaru~ate=ccrrenra~liemaferr1aferralsco11eC:teC:rc:urt3side=ar;e:rc:onsrcrer~t"h=e===~~- . Increase efficiency of recycling (including organic potential to add orremov e materials. processing) systems, and maximize effectiveness of =c:.~='E<:ruca1e1lie=pu151iC:-ari1F1e=purposea~riatierieTits-ofa1firee~t3in=svstem.=asw=e~r~= existing solid and hazardous waste infrastructure. as the success of the local program. - Address curbside recycling contamination and M RF system loss. Multifarrily Recycling - Provide enforcement to reduce sham recycling. l. Gatherinformation on A. Conduct a waste audit to understand the recycling habits of multifamily - Ensure clean and marketableend-productsfrom multifamily disposal and customers. Findings could drive future action. organics and recyclables. recycling habits. . Mitigate climate change . 2. Encourage A. Education outreach to building/facility management. Suggest training of - Increase reuse, recycling, and waste reduction. manager/owner residents for facility waste bin system at move-in and require compliance in Ke~ Prin!:;;iQiesang ~trgtegi~~ responsibility. lease. . Build on what's already working, such as maximizing 3. Increase multifamily A. Provide educational information to be distributed to multifamily residents, such the use of existing infrastructure. residential outreach. as information on how to accommodate recycling bins. . Takeadvantageofmomentumand complementary mK=~cre-ateorexpancfprogramstoproviae-waste=auaitsfoS=uiiding=ma=nagers=ancr= actions. provide support for follow-on education. . Createcollaborativepartnershipswith a variety of players. =c:.==rr-oviae=clea-r1aFelin-9olaccepiaSiemarerra~wrlfiP'iCiures~foreachc=orirainer-~ Lead by example in government, especially through to address potential language barriers. . research, purchasing power, and model D. Ensure that the frequency of curbside service to multifamily buildings provides demonstration projects. adequate co pacity in each recycling bin at any time, minimizing potential for Strive for continuous improvement . unnecessary disposal or contamination. . _,_ ____ .1_ ,r. __ , _ >I

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE44 5 ORGANIC MATERIAL MANAGEMENT

Significant diversion of waste is commonly accomplished through composting of organic materials. Organic materials (green waste, food waste, and compos table paper) are a significant component of the County's solid waste stream. In 2013, recycling and diversion efforts accounted for the diversion of nearly 40,000 tons of organic materials (including 12,000 tons of food) from landfill disposal, which equated to about 29% percent of the total waste stream. In 2009-2010, Ecology conducted a four-season MSW characterization study in select counties across the state, one of which was the County. The study found that organic material made up approximately 25 percent of the total MSW stream. More than half of the organic materials were attributed to residential and commercial food waste. Using the Ecology waste sort study information and the Ecology diversion reports, the organic material generation for the 2009 waste stream was approximately 62,000 tons of organic materials, with about 17,000 tons of food waste (food scraps) and wasted food (food allowed to spoil) disposed of at a landfill. These data suggest that more than half of the organic material generated in the county is ultimately disposed of at a landfill.

5.1 EXISTING CONDITIONS

5.1.1 PROGRAMS

Curbside Collection Residential food and yard waste collection services are provided by SSC and NVD on an every­ other-week basis; commercial collection frequency varies dependent upon customer need. 4 Curbside collection is not available in some of the rural areas of eastern Whatcom County. • SSC-Provides residential curbside and commercial collection of yard waste, food waste, and compostable papers through the SSC Food Plus program. Materials are collected together in the same container. The service is provided throughout the SSC service area, with the exception of Lummi Island and the Lummi peninsula south of Cagey. • NVD-Provides residential curbside and commercial collection of yard waste, food waste, and compostable papers within the city limits of Lynden, Nooksack, Everson and Sumas. Household waste and yard waste can also be disposed of at the NVD Drop Box Facility.

Cando does not provide curbside collection of organics. However, green waste is accepted at the Cando drop-box facility in Point Roberts.

4http://www.whatmmmunty.us/722/Recyding-Trash

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE45 JUNE14,2016

Educational Programming The WSU Master Composting & Recycling Program and the County Solid Waste Division provide a substantial amount of composting information on their web sites. These programs assist residents with the management of food waste scraps so that these scraps never enter the solid waste system but instead provide a beneficial product for use around the home. The SSC Food to Flowers! is a school service available to elementary schools and other educational institutions. The program promotes student engagement in composting practices while they learn about the associated environmental benefits. The County currently provides no outreach program to assist commercial entities in managing their organic material. Because the County cannot mandate commercial recycling or composting services, the SSC Food to Flowers! program is supported through a means of advertising and education during facility audits to enhance participation. SSC and NVD also provide technical assistance to businesses requesting information, or that need support in setting up commercial composting services.

5.1.2 FACILITIES

Public Drop-off Locations The following drop-box facilities accept organic materials from the public: • SSC Roeder Avenue Drop Box Facility-Accepts yard waste only. Materials are transported to the Green Earth Technology Composting Facility. • RDS Transfer Station-Accepts yard waste and food waste. Materials are transported to the Green Earth Technology Composting Facility. • Cando Recycling Transfer Station-Accepts yard waste only. Materials are transported to the Green Earth Technology Composting Facility. • NVD Drop Box Facility-Accepts yard waste only. Materials are transported to the Green Earth Technology Composting Facility. • Green Earth Technology Composting Facility-Accepts residential and commercial yard waste and food waste. A description of the composting process is provided below.

Composting Facilities Organic materials collected at curbside or at drop-box locations are transported to the privately operated Green Earth Technology facility in Lynden. Materials are composted using a Gore-based aeraleu pile syslem, which is capable of con1.posting a green waste stream with a lighter amount of food waste mixed in through an eight-week production cycle. The facility currently manages 14,000 to 16,000 tons per year, with the capacity to manage up to 20,000 tons per year under its current configuration. The facility's existing infrastructure would require relatively few improvements to double the capacity to 40,000 tons per year, if a sustained need is foreseen. The facility cautiously accepts additional food waste from commercial sources, primarily because a more wet/putrescible food waste might overwhelm the system and result in the generation of significant odors.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE46 JUNE 14,2016

Digesters In addition to the composting facility, four anaerobic digesters are operated in the county. Digesters can be used to generate renewable energy biogas using various organic feedstocks, such as pre­ consumer food waste, manure, sewage, grease trap waste, and agricultural waste. Biogas, biologically produced by an anaerobic digestion process, can be used to fuel combined heat and power engines that generate utility-scale electricity, and heat for use internally or by neighboring facilities. Liquid fertilizer, digestate fiber, and water are secondary by-products that potentially can be used in agricultural applications. The anaerobic digestion process begins with bacterial hydrolysis of the input materials in order to break down insoluble organic polymers such as carbohydrates and make them available for other bacteria. Acidogenic bacteria then convert the sugars and amino acids into carbon dioxide, hydrogen, ammonia, and organic acids. Acetogenic bacteria then convert these resulting organic acids into acetic acid, along with additional ammonia, hydrogen, and carbon dioxide. Finally, methanogens convert these products to methane and carbon dioxide. The methane gas can then be combusted and turned into energy as described above. An anaerobic digestion facility typically includes a receiving building for feedstock, anaerobic digestion tanks, digestate treatment facilities, and gas conditioning and power-generation equipment. The four digesters in the county are: • Edaleen Cow Power LLC • Vander Haak Dairy • Farm Power • VanDyke Dairy

A total of 13 million gallons of pre-consumer food waste and 78 million gallons of livestock manure were treated by anaerobic digestion in 2014, and 14 million kilowatt-hours of generator power was produced.

5.2 NEEDS AND OPPORTUNITIES

5.2.1 PROGRAMS

Organic materials in the county are managed through residential and commercial collection, local drop-off facilities, and on-site composting. The existing program elements for collection or drop-off are accessible to all residents of the county. The residential curbside organic materials collection (yard waste plus food waste) is offered every other week; commercial collection is offered on a more frequent basis dependent upon customer needs. Commercial subscribers consist primarily of food processors and manufacturers, grocery stores, school districts, colleges and universities, and governmental entities, as well as retail and office users. Commercial subscribers also include some restaurants; however, only one restaurant chain restaurant participates (both SSC and NVD provide curbside collection services to this chain). sse personnel indicate that commercial food waste is collected on the residential routes so that there is substantial mixing of food waste with yard waste prior to delivery to the composting facility. Food waste prevention outreach is currently a significant topic discussed by the U.S. Environmental Protection Agency (USEP A) and by Washington jurisdictions. Educational materials

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE47 JUNE 14,2016

are readily available to solid waste program managers through the "Food: Too Good to Waste" campaign, which is focusing on consumer education to avoid waste by consuming what is purchased. Some counties are researching partnerships with community health groups to increase food security as a means of reducing wasted food, including subsidizing the purchase of refrigerated trucks to collect and transport perishable food to community kitchens and shelters.

5.2.2 FACILITIES

Commercial businesses account for a large percentage of the organic waste generation in the county, although a substantial portion of that material may be less preferred by the composting facility because of the material's overly wet or dense characteristics. The County has several food processors that may be able to divert their waste materials, including seafood, berries, and vegetables. An additional composting opportunity may include identification of a process to reliably compost heavy, wet food generated by restaurants, institutional cafeterias, and other food providers. Identifying additional organics processing techniques in the future may allow more of the County's organic waste stream to be diverted from disposal and processed for a higher use (such as biogas generation). There are no issues regarding current composting facilities. The Green Earth Technologies Facility is able to rapidly double its operational capacity in order to meet the future needs of the public.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE48 5.3 GOALS AND ACTIONS

Curbside composting has proven to be an effective program in the county, given its high participation rates. However, both prevention and recovery levels should be increased. To complement this success, future County programming will focus on the expansion of services and outreach to commercial business. TABLE 5-1 GOALS AND ACTIONS FOR ORGANICS MANAGEMENT GOALS ACTIONS CONNECTING TO BEYOND WASTE* 1. Consider accessibility of A. Evaluate flexibility of collection (frequency, container size, cost, etc.) Priorities of Plan organic materials collection and impact to the existing system. • Increase efficiency of recycling and management. (including organic processing) systems, 2. Increase recovery of organic A. Target outreach to the lo-OdTndustry with the goal ofseparating more and maximize effectiveness of existing materials from commercial material appropriate for organics composting, or other organics solid and hazardous waste infrastructure. and industrial generators. management approaches as they become available. - Ensure clean and marketable end- products from organics and "1r~·'o8¥~efor31ooawasfe~m~ana9~emenrpro~;rra-m5~rr;c:rcarr;9~P'oten1Tar~m~~ recyclables. programs that connect restaurants with farmers who would use food - Focus on facility compliance, waste as livestock feed. technical assistance, and ~c.~~RequTrec~ompo~sia~t51e~.sTn9Te=servin9confainers~atc-ommercial-~----- enforcement. locations-stadiums and fast-food venues. • Mitigate climate change. - Increase use of processed organics -o.--s-ur)poriinCfustryoppo~rtunifiesTousean-aeroblc-afQesfersfordTve-rslO-n to sequester carbon. of preconsumer food waste. - Increase reuse, recycling, and waste reduction. - Prevent food waste. Key Principles and Strategies • Build on what's already working, such as maximizing the use of existing infrastructure. • Focus solutions on designing sustainable products and processes. • Take advantage of momentum and complementary actions. • Create collaborative partnerships with a variety of players. • Strive for continuous improvement. *This column refers-to-the 2J15 Beyond Waste Plan. The numbering system for key goals and strategies is intended to reflect the number system in the Beyond Waste document.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE49 6 SOLID WASTE COLLECTION

6.1 EXISTING CONDITIONS

wee 8.10.040 and wee 8.10.060 require that certificated solid waste companies collect solid waste from residential and nonresidential entities. Only companies holding G-certificates or operating under municipal contract for that area may collect solid waste for a fee. Weekly, every other week, and monthly curbside garbage and every other week recycling collection service in the county is provided through three private collection companies, each providing service to a different region of the county and regulated by the WUTC and municipal contracts. In addition to garbage and recycling, and with the exception of Point Roberts, Lummi Island, and certain areas east of Cedarville Road, all SSC subscribers have the option to pay for curbside collection of organic materials. Organic materials (yard waste, food-soiled paper, and food waste) are picked up on an every other week basis. NVD also offers organics collection in its cities (weekly in Lynden, and every other week in Nooksack, Everson, and Sumas). NVD does not offer organics collection in unincorporated areas. No collection is completed in eastern Whatcom County due to this area almost wholly being federal forest land, with exception to Newhalem and Diablo, which are serviced by the Skagit County waste hauler, currently Waste Management. All cities in the county use traditional bag or customer-owned, 32-gallon can residential collection systems, or collector provided containers or totes. Customers of SSC and NVD also have the option of using collection-company-owned wheeled carts. The four G-certificated haulers are: • NVD (Permit G-000166)-Located at 250 Birch Bay-Lynden Road in Lynden. Serves northern Whatcom County, including the cities of Lynden, Everson, Nooksack, and Sumas, and unincorporated portions of the county in that region. • SSC (Permit G-000014)-Located at 1001 Roeder Avenue in Bellingham. Serves the cities of Bellingham and Ferndale, the Lummi and parts of the Nooksack reservations, and the areas of unincorporated Whatcom County not served by NVD or Cando. • Cando (Permit G-063819)-Located at 2005 Johnson Road in Point Roberts. Serves the unincorporated area of Point Roberts. • Waste Management (Permit G-00237)-Serves the Newhalem and Diablo unincorporated areas in eastern Whatcom County. G-certificated hauler territories are depicted in Figure 6-1. Figure 6-2 shows the population density per square mile in relationship to each hauler territory. Incorporated cities in the county obtain their own solid waste collection services through independent contracts. Contracted services, by way of interlocal agreements, must meet the County's standards for curbside collection. Collected waste is delivered to County-designated transfer facilities, as described in Section 7 .1. As an alternative to curbside collection, there are a number of facilities available for public drop-off. These facilities are discussed in Chapter 7.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 50 ' Comprehensive Solid and BRITISH COLUMBIA, CANADA I Hazardous Waste Management Plan Update

Figure 6-1 Hauler Territory Map

Whatcom County Washington

Legend City Boundary Small Town Boundary County Boundary Certified Waste Hauler Territory Freedom 2000 LLC, dba Cando (G063819) Nooksack Valley Disposal, Inc. (G00166) Sanitary Service Co., Inc. (G00014) Waste Management, Inc. (G00237)

9,000 18,000 ~ WHATCOM COUNTY Feet ~ SKAGIT COUNTY

Source: City Boundary, Waterbodies, National Forest Area, Planning Area from Whatcom County. County Boundary from WSOOT Waste Hauler Territory from Ut!ities and Transportation Commission. BRITISH COLUMBIA, CANADA Comprehensive Solid and Hazardous Waste Management Plan Update

Figure 6-2 Population Density Map

Whatcom County Washington

Legend City Boundary

Planning Area National Forest

Freedom 2000 LLC, dba Cando Nooksack Valley Disposal, Inc. Sanitary Service Co., Inc. Waste Management, Inc. Population Density (per square mile) Ill 100,001 or more people Ill 25,001 to 100,000 people R 10,001 to 25,000 people filii 1,001 to 10,000 people 101 to 1,000 people 100 or less people No population

~ - 9_!00 18,~00 ~ M M \]7 Feet : Source: City and County Boundaries from Whatcom County. Population Density from Esri ArcGIS Online. Waste Hauler Territory from Washinton Utilities & Transportation Commission

Point Roberts. AUL FOSTER ALONGI NTS JUNE 14,2016

6.2 NEEDS AND OPPORTUNITIES

Curbside solid waste collection is an entirely privatized system, with each collector responsive to market demands and customer requests. Collectors adjust the size and routing of their fleet as necessary to provide the services required by the County and cities. Additional services requested by customers are considered by each collector and responded to directly. Existing solid waste collection services adequately meet the current waste disposal needs of the community, and no significant issues were reported. At this time, the private service providers have not identified any needs requiring expanded capacity or infrastructure.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 53 6.3 GOALS AND ACTIONS

This existing collection system meets the needs of the county customer base through market demands placed on the private collectors. The County will continue to monitor the program and engage the public to ensure continued functionality of the system. TABLE 6-1 GOALS AND ACTIONS FOR COLLECTION CONNECTING TO GOALS ACTIONS BEYOND WASTE* l. Ensure that collectors are A. Investigate complaints regarding collection services and correct Priorities of Plan providing the required deficiencies. . _ ...... minimum service to all ....s:----concfuct"c.ommunTiy.involvement and engagement process in . Increase efficiency of recycling (including organic processing) systems, and maximize subscribers as outlined in Point Roberts to identify potential adjustments to collection effectiveness of existing solid and the WhatcomCounty system infrastructure and regulatory requirements to improve hazardous waste infrastructure. Code and interlocal level of service and cost structure, and implement adjustments as - Focus on facility compliance, technical agreements between the appropriate. assistance, and enforcement. County and municipalities. Ke:x: Prin~igles ang StrgtSlQiSl~ • Build on what's already working, such as maximizing the use of existing infrastructure. .lhisC::olurnn refers to the 2015 3eyond Waste PIOn: The numbering system for key goalsand-sfrategies is intended to reflect the number system in the Beyond Waste document.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 54 7 TRANSFER AND DISPOSAL

Transfer systems consist of fixed facilities with drop boxes and/ or transfer stations that receive waste from public and commercial sources. The purpose of a transfer system is to provide a centralized location for consolidation of numerous small waste loads, loading the waste into larger transfer containers, and transporting it to an appropriately permitted disposal site. Consolidation improves the economics of waste transport and reduces traffic impacts at land disposal sites. In addition to the consolidation of waste materials, transfer stations can serve as a location for the processing of recyclable materials. Material-processing activities include the separation, preparation, and consolidation of recyclable material collected through curbside programs or removed from incoming loads. • Transfer Station-A transfer station is a facility that receives compact and loose waste from both residential and commercial sources. Transfer stations may use a dumping pit or tipping floor to consolidate waste material before transferring it into a trailer or compactor. In transfer stations with a dumping pit, a tractor typically crushes and compacts the waste before the waste is loaded into the trailer or compactor. Trailer loading usually requires the use of a knuckle-boom crane to evenly distribute and compact the waste in the trailer. Alternatively, a transfer station with a tipping floor may use a dozer to push the materials against a wall for crushing, followed by lifting into a trailer or pushing into a subfloor stationary compactor. Once the trailer is loaded, the load is secured and then the container is hauled to the landfill by truck or by rail. • Drop-Box Facility-A drop-box facility is simply a solid waste facility where the public can directly deposit their own waste materials into a drop-box container. When the drop box is full, it is loaded onto a roll-off truck and transported to a transfer station where the waste is then transferred to disposal containers for transport to the landfill. Drop-box facilities are often provided in various urban and rural areas to reduce the distance that the public must travel to reach a transfer facility or to provide an option where there might be less congestion. In general, drop-box facilities are less expensive to operate because of reduced costs for structures, equipment, and, potentially, land. Drop-box facilities can also provide opportunities for recycling and for the separate collection of yard debris, woodwaste, and/ or C/D waste.

7.1 EXISTING CONDITIONS

The County solid waste system is a transfer-based system consisting of several transfer stations and drop-box facilities that direct waste to two primary out-of-county landfills. There are no operational landfills in the county, although the County owns several closed landfills.

7.1.1 TRANSFER STATIONS

The county is served by three privately operated transfer stations, one of which is located on County-owned land leased to the operator (located in Point Roberts).

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 55 JUNE 14,2016

• RDS Transfer Station-The RDS Transfer Station is one of the two primary transfer stations in the county and accepts self-haul waste and waste collected by SSC and NVD. The RDS Transfer Station includes an MRF, one inbound scale, two outbound scales, and two truck bays. There is a self-service recycling center prior to the scales that accepts cardboard, newspaper, mixed paper, glass, tin cans, and aluminum. Waste for disposal is transported by truck to the Columbia Ridge Landfill in Arlington, Oregon. Recyclable materials are sold to the appropriate processing facilities, including Northwest Recycling. Wood is chipped and shipped to burners in Washington State and Canada. In 2013, RDS processed 105,788 tons of solid waste materials. • RDC Transfer Station-The RDC Transfer Station is the other primary transfer station in the. county and accepts self-haul waste and waste collected by SSC in the City of Bellingham. The facility includes one scale for inbound and outbound traffic. The tipping floor is contained entirely indoors and provides space for six vehicle hand unloaders and one tip truck. Waste for disposal is transported by rail to the Roosevelt Regional Landfill in Roosevelt, Washington. Recyclable materials, including cardboard, newspaper, and steel, are collected at the front of the facility (prior to the scales). In 2013, RDC processed 50,422 tons of solid waste materials. • Cando Recycling Transfer Station-The Cando Recycling Transfer Station is on County­ owned land, but is privately operated via a lease with the County. Curbside and self-haul waste and recycling are collected and sorted. Waste for disposal is transported by truck to the Cowlitz County Headquarters Landfill in Castle Rock, Washington. Recyclable materials are sold to various entities through British Columbia, Canada. In 2013, Cando processed 1,020 tons of solid waste materials. • Bellingham Vactor Waste Facility-The City of Bellingham owns, operates, and maintains a vactor waste transfer station for the purpose of processing street sweepings and vactor waste materials. The facility accepts street waste from the City of Bellingham, Whatcom County, the Washington Department of Transportation (WSDOT), and several private operators. The City currently contracts with a private party to transport the material to the Waste Management Greater Wenatchee Solid Waste Landfill. This facility is discussed in more detail in Section 8.1.8.

These transfer stations, with exception to the Bellingham Vactor Waste Facility, are open to the public. Current disposal rates for the transfer stations are provided in Table 7-1. Private operators adjust their rates as necessary to efficiently maintain their services. Private transfer stations are in direct competition with each other. Customers should contact the service providers directly for accurate and up-to-date information.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 56 TABLE 7-1 CURRENT DISPOSAL RATES FOR TRANSFER STATIONS (APRIL 2015)

•>::,•''• · · -·-····. ·· ··.,. ·· - ? .--_-.·.. ~->,))c;~~·;:~.j.l ~~·~-.~!,~Ji~• '''"'''' .., :c~_;.d,; .•• •• ~;• .;~--'.sf..'~ ...... :.i'·····~--1!·~-·~··\ ·• -.·.. ' ·Minimum···· · ··· · .. ---··-.: _·.·. .-. ' ·.• - .;\ ;.. '-'< •>:>·(;•'.; :;:•:.'·i~;!?1 ·~·~·-~·.:""·'~ .·: i,f·'···i:·.; ...... _.,:.:·.;-: ..• RDS Garbage Weight $0.050 $100 Contractors (Accounts Only) Weight $0.045 $90 Wood Weight $0.050 $100 Yard Waste Weight $0.033 $66 Dirt and Sod Weight $0.025 $50 Metal Weight $0.020 $40 Concrete Weight $0.020 $40 All Passenger Tires Flat Fee $5/each Semi Tires Flat Fee $20/each TractorTires Flat Fee $50/each Loader Tires Flat Fee $1 00/each Propane Tanks Flat Fee $5/each

Hot W aterTanks, Dishwasher, Flat Fee $5/each Stoves, Washers, Dryers Refrig.e.rators, F:eezers, Air Flat Fee $35/each Conditioner Un1ts Porcelain Toilets and Sinks Flat Fee $3/each

Mobile Homes (Manager Volume $1.25 per $1 000 Approval) square foot ' ROC Garbage Weight $6* $0.048 $95 $6.00 C/D waste Weight $6* $0.048 $95 $6.00 Yard Waste Weight $6* $0.048 $95 $6.00 Asbestos Weight $6* $0.125 $250 $81.50 Paper Free

WHATCOM COUNlY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 57 JUNE14,2016

Garbage Weight I $0.141 $28o 1 I $5.50 Recycling Weight I $0.051 $1oo 1 I $3.00 Appliances Flat Fee $20/each Fridge/Freezer Flat Fee $50/each Tirew/ Rim Flat Fee $5/each Tire no Rim Flat Fee $4/each Propane Tank Flat Fee $1 /each Battery Flat Fee $1 /each Computer Monitor Flat Fee $10/each Flat plus TV ... . $1 le?~~ 1 $0.14 - Microwave ''""'' !"-'' ...... "f" ...... / ...... $0.14 weight plus weight Electronics Flat Fee

Notes: Private operators adjusttheir rates as necessary to efficienHymaintain their services. Customers should contactthe service providers diredlyfor accur,ate and up­ to-date information. *Gate fee, reqardlessof weiqht or materials

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 58 In addition, the City of Bellingham maintains a vactor waste transfer station, which is not open to the public, but does receive vactor and street wastes from countywide commercial and municipal operators for a fee.

7.1.2 DROP-BOX FACILITIES

In addition to the transfer stations, county residents and businesses may dispose of waste at any of the drop-box facilities listed below. • SSC Birch Bay-Lynden Drop Box Facility-The SSC Birch Bay-Lynden Drop Box Facility is County-owned and is operated by SSC via a lease with the County. Waste is transported to the RDS Transfer Station. Recyclable materials are brought to the RDS Transfer Station and Recycling Northwest for sorting and shipment to the appropriate entities. • SSC Cedarville Drop Box Facility-The SSC Cedarville Drop Box Facility is County­ owned and operated by SSC via a lease with the County. Waste is transported to the RDS Transfer Station. Recyclable materials are delivered to the RDS Transfer Station and Recycling Northwest for sorting and shipment to the appropriate entities. • SSC Roeder Avenue Drop Box Facility-The SSC Roeder Avenue Drop Box Facility is located in downtown Bellingham on Roeder Avenue. Waste and recyclable materials are transported to the RDS Transfer Station or the RDC Transfer Station. • NVD Drop Box Facility-Waste collected at the NVD Drop Box Facility is transported to the RDS Transfer Station for sorting. Recyclable materials are collected and shipped to the appropriate entities.

These drop-box facilities are open to the public. Current disposal rates for the drop-box facilities are provided in Table 7-2. Private operators adjust their rates as necessary to efficiently maintain their services. Private drop-off facilities are in direct competition with each other. Customers should contact the service providers directly for accurate and up-to-date information.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE 59 TABLE 7-2 CURRENT DISPOSAL RATES FOR DROP-BOX FACILITIES (APRIL 2015)

. .... ·...... w2<4~ -r•~--.~ \ . < i~ " ~: .. ~2 ir;;,• ; I .c~.:.~;.:.,.{~;i.~:;;••. : •.:\'·;: .• ~?'!:~·"~~~ , •, ... ,,. ·• · r(i)\:.~r;··~I !:.. ··· .....·~·~ . ~:~~;~~~z;.\;:· ;'!1' ~~ ·> t ··. .;<.: ' ,. ·.·.·.•.. ·.·.······· ..··.·. . . . :·· .....•··•··• .~;~~.;.;... :Jj.,~f·?)·;'.:~~~~.r:.. ~Fi'z~;n .... ·.;{:,:~~~·" ~i:·:f ...;··. ;· ' ·~·· "''·r .. i •• .:.. .. ·• •.t·',~ ;,.·; ..• ~:;i~·~. NVD Garbage Weight $0.10 $200 Recycling Volume** $5.00 Paper, Cardboard, Tin Weight $0.02 $40 Plastics Volume $1.00 per 32 gallon Glass Weight $0.05 $100 Scrap Metal, Aluminum Free Free Wood weight $0.07 $140 Yard Waste Weight $0.04 $80 sse Cedarville Garbage Weight $0.1 5 $300 $5.00 Recycling Weight $0.05 $100 sse Birch Bay Garbage Weight $0.15 $300 $5.00 Recycling Weight $0.05 $100 SSC Roeder Garbage Volume $300*** $30.90 per cubic yard $5.85 Recycling Volume $0.05 $100 $5 per 30 gallon bag $5.00

Notes: Private operators adjusttheir rates as necessary to efficiently maintain their services. Customers should contactthe service providers diredlyfor accur,ate and up-to-date information. **Volume defined as "normal residential amounts." ***Garbage disposalrateperton is estimated from thevolumerate based on a loose density of 190 to 2201b/cubicyard. 1

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE60 7.1.3 LANDFILLS

MSW generated in the county is primarily disposed of at one of the following landfills:

ii Coiumbia Ridge Landfill, Arlington, Oregon-The Columbia Ridge Landfill, operated by Waste Management, is a modem Resource and Conservation Action (RCRA) Subtitle D­ permitted landfill that accepts primarily MSW, as well as industrial and special wastes. It does not accept hazardous waste. Columbia Ridge is the final destination of waste originating from the RDS Transfer Station. • Roosevelt Regional Landfill, Roosevelt, Washington-The Roosevelt Regional Landfill, operated by Republic Services, accepts MSW and specific types of special waste. Roosevelt Regional Landfill is the final destination of waste originating from the RDC Transfer Station and MSW collected by Waste Management from Newhalem and Diablo in eastern Whatcom County. • Headquarters Landfill, Castle Rock, Washington-Cowlitz County operates the Headquarters landfill in Castle Rock, Washington. The landfill is the final destination of waste collected by Cando. Other facilities accepting waste generated in the county, as reported by Ecology, include: • Cemex Inert Waste Landfill, Everett, Washington-The Cemex Inert Waste Landfill accepts materials that are neither chemically nor biologically reactive, such as petroleum contaminated soils generated from cleanup sites, and will not decompose. The contaminated soils are treated with a thermal desorption process before they are landfilled. • Graham Road Recycling & Disposal, Medical Lake, Washington-Graham Road Recycling & Disposal, operated by Waste Management, is a "limited purpose" facility that accepts primarily C/D debris, industrial waste, and special waste; it does not accept MSW or hazardous waste. • Greater Wenatchee Regional Landfill, East Wenatchee, Washington-The Greater Wenatchee Regional Landfill, operated by Waste Management, accepts primarily MSW, C/D debris, and industrial waste. It does not accept hazardous waste.

The County owns and maintains five closed landfills: • Cedarville Landfill-The 9-acre landfill opened in 1980 and was closed in 1990. The landfill is estimated to contain 400,000 cubic yards of refuse underlying the cover soil. The facility is monitored under permit during post-closure consistent with WAC 173-304. The facility has a system in place that controls landfill gas migration and odors; it also has a leachate collection system. The leachate collected is treated and discharged under an NPDES permit issued by Ecology. • Birch Bay Landfill-The 5-acre landfill was a County-operated landfill purchased in 19 51 and closed in 1983. • Point Roberts Landfill-The landfill accepted MSW from 1982 until1985, when operation ceased because of the potential costs associated with meeting the then-new MFS. At the time of closure, the landfill was slightly less than 1 acre in size. The landfill area was then used solely for C/D waste until a separate area was designated for disposal of this waste type

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE61 JUNE 14,2016

in 1988. In 1990, the landfill was closed in accordance with WAC 173-304. This is the current location of the Cando Recycling Transfer Station. • Y Road Landfill 1-The Y Road Landfill consists of two distinct landfills, Y Road I andY Road II, located along opposite sides of the same road. Y Road Landfill I was acquired in 1995 from the Georgia Pacific Corporation for public safety reasons. Records indicate that it was used between 1967 and 1970. It is monitored and regulated as a MTCA cleanup site. • Y Road Landfill 11-Y Road Landfill II was closed to MSW in 1984 because of water quality concerns. The landfill was reopened as a limited-purpose landfill, which accepted only C/D waste. The landfill was closed to all waste types in 1989. Closure improvements were completed in 1991 and included installation of monitoring wells for gas and water. The MSW cells were closed to WAC 173-301 standards in 1984 and the C/D waste later placed on both the MSW cell footprint and the separate cell was later covered and closed to WAC 173-304 standards, and is monitored and regulated as a MTCA cleanup site.

7.2 NEEDS AND OPPORTUNITIES

The existing transfer and drop-box facilities adequately meet the current waste-disposal needs of the community. These facilities are privately owned by entities that consistently evaluate the respective facilities from an efficiency standpoint. At this time, the private entities have not identified any needs that require expanded capacity, but have expressed the ability to expand their own operations under short timeframes. The County will continue to work with the service providers to ensure each provider is adequately planning for and constructing additional capacity in advance of need.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE62 7.3 GOALS AND ACTIONS

Transfer and disposal of solid waste are managed through the private sector. The County will continue to monitor compliance of private-sector activities, as well as maintaining and monitoring the County's closed landfills. TABLE 7-3 GOALS AND ACTIONS FOR TRANSFER AND DISPOSAL CONNECTING TO GOALS ACTIONS BEYOND WASTE* 1. Continue to maintain A. Provide ongoing post closure monitoring and maintenance of Priorities of Plao and support transfer closed landfills. Increase efficiency of recycling (including organic and disposal system . . ~1f~~w~orFW1ft1exisfi'n9p~rivate1rcin~s1erstatfOr15'fo~ensurecompnance~~ processing) systems, and maximize effectiveness facilities. with solid waste handling facility permits. of existing solid and hazardous waste ·~c.-·"w~orFwift15e~r¥lceproviaer-51o~ens'Ure~aaequa1esvs'femcapac~itv~ infrastructure. is constructed in advance of need. - Focus on facility compliance, technical ~o.~~·con'duct~communTfvfnvolve-menfcin~ae~r19a9ement~proce_s_s-in--~ assistance, and enforcement. Point Roberts to identify potential adjustments to transfer and Kex: Princigi!2S gng Strat!2gi!2S disposal system infrastructure and regulatory requirements to improve level of service and cost structure, and implement • Build on what's already working, such as adjustments as appropriate. maximizing the use of existin~J infrastructure. ...,.------x This column refers to the 2015 Beyond Waste Plan. The numbering system for key goals and strategies is intended to reflect the number system in the B€Norid Wasfe document.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE63 8 SPECIAL WASTE

Special wastes are materials that require special or separate handling because of their unique characteristics, such as bulk, water content, or dangerous constituents. Special wastes discussed in this chapter include: • Agricultural waste • Asbestos • Biosolids (sewage and septage) • Contaminated soils and dredged materials • Disaster debris • Food-related, grease not containing petroleum • Biomedical waste and pharmaceuticals • Vactor waste • Waste tires • C/D waste This chapter discusses the current management practices for special waste and establishes goals and actions for encouraging recovery and reducing environmental impacts.

8.1 EXISTING CONDITIONS

8.1.1 AGRICULTURAL WASTE

Agricultural waste, such as manure and crop residues, is typically returned to the land as soil conditioners. Annual volumes and seasonal variation differ by agricultural sector. Guidelines for the proper handling of livestock waste in western Washington have been published by the WSU Agricultural Extension Service and codified under WCC 16.28, Manure and Agricultural Nutrient Management. Deceased animals and animal parts can be disposed of by Tri-County Dead Stock, Inc. Allowances can also be made by the Health Department for animal burials and composting. The recent legalization of recreational marijuana production and sales has resulted in regulations specific to the handling and disposal of crop residues. As the industry matures and regulations evolve, the County will rely on the most current regulations for addressing this waste.

8.1.2 ASBESTOS

The term "asbestos" represents a group of naturally occurring minerals that historically were used in building products such as cement siding, sprayed-on ceiling texture, and the paper backing of vinyl floor coverings. Asbestos is not considered a hazardous waste under either federal or state regulations, but is regulated under the federal Toxic Substances Control Act. Asbestos is also regulated under the federal Clean Air Act as an air pollutant that poses human health hazards. Local regulation is provided by the Northwest Clean Air Agency (NWCAA), Regulation Section 570. Properly packaged and labeled asbestos waste is collected at the RDS and RDC transfer stations, placed in special containers or bags, and transferred to out-of-county landfills for proper disposal as

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE64 JUNE 14,2016

asbestos-containing material. The final disposal sites require that a copy of the NWCAA's asbestos abatement or demolition permit accompany asbestos waste deliveries.

8.1.3 BIOSOLIDS (SEWAGE SLUDGE AND SEPT AGE)

Sewage sludge that has been treated to meet standards for beneficial use (such as in land application) is called "biosolids." This type of material is specifically excluded from the definition of solid waste, although other wastes from the wastewater treatment process are classified as solid wastes. Biosolids are defined by WAC 173-308-080 as: Municipal sewage sludge that is a primarily organic, semisolid product resulting from the wastewater treatment process that can be beneficially recycled and meets all applicable requirements under this chapter. Biosolids includes a material derived from biosolids, and septic tank sludge, also known as septage, that can be beneficially recycled and meets all applicable requirements. Biosolids are further categorized by federal regulations into Class A and Class B, based on pathogen­ reduction measures and metals contamination levels. The federal and state regulations are self­ implementing, which means that the requirements must be met regardless of the permit status of a facility. There are three biosolids land application facilities in the county: • Shannon Tjoelker Biosolids Facility • Lil John Biosolids Facility • Tjoelker Enterprises Biosolids Facility

8.1.4 PETROLEUM-CONTAMINATED SOIL AND DREDGED MATERIAL

Contaminated soil is soil removed during the cleanup of a MTCA site, during a dangerous waste facility closure, or from corrective actions or other cleanup activities, and which contains harmful substances but is not designated as dangerous waste. Contaminated dredge materials come from the dredging of waterways where contaminants are present at concentrations not suitable for open water disposal, but not designated as dangerous waste. The primary statute governing cleanup of petroleum-contaminated soil in Washington State is the Model Taxies Control Act (MTCA), RCW 70.1 05D. WAC 173-340 contains regulations to implement MTCA, including sections on corrective action requirements for leaking underground storage tanks and on cleanup standards. Materials that also contain lead, benzene, polycyclic aromatic hydrocarbons, or polychlorinated biphenyls may trigger a designation as dangerous waste. Treatment, transportation, and disposal of dangerous wastes are subject to the state dangerous waste regulations, WAC 173-303. Dangerous wastes can be transported only to specifically permitted facilities for treatment, storage, or disposal. Disposal of petroleum-contaminated materials is subject to the requirements of WAC 173-350; these materials must be disposed of at a permitted solid waste handling facility such as a landfill or incinerator. No landfills in the county are currently permitted to accept contaminated soil. Generators of contaminated dredged materials who wish to dispose of the materials must either construct and permit a limited-purpose landfill (.WAC 173-350-400), or use an approved solid waste landfill site or incinerator (CEMEX) located outside the county. Use of the County waste management system for disposal of contaminated dredged materials typically is conducted only for small projects (i.e., less than 10 cubic yards). Small project contaminated dredged materials will be

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE65 JUNE 14,2016

accepted into the County system, provided that they have been adequately characterized and have been dewatered adequately to meet criteria specified under the USEPA paint filter test (see Federal Register, Vol. 50, No. 83, Tuesday, April30, 1985).

8.1.5 DISASTER DEBRIS

Whatcom County could be impacted by a number of natural disasters, including floods, earthquakes, volcanos, windstorms, and landslides, all of which can create an enormous quantity of material requiring management and/ or disposal. According to the Federal Emergency Management Agency, natural disasters generally create the following types of debris: • Windstorms may leave behind waste consisting primarily of trees and other vegetation, construction materials from damaged or destroyed structures, and personal property. • Flood debris consists of sediment, wreckage, personal belongings, and sometimes hazardous materials deposited on public and private property. Additionally, heavy rains and floods may produce landslides, the debris consisting primarily of soil, gravel, rock, woody debris, and some construction materials. • Earthquakes generate damaged building materials, personal property, woody debris, and sediment caused by landslides. • Ice storm or snowstorm debris consists of significant amounts of woody debris from broken tree limbs and branches. • Fire debris consists of burned-out structures, metal objects, vehicles, ash, and charred woodwaste. Oil spills or other disasters associated with large industry or refineries are generally addressed by plans already put in place by the appropriate industries and agencies. The Whatcom County Sheriffs Office Division of Emergency Management is responsible for developing and maintaining a community infrastructure for emergency and disaster mitigation, planning, response and recovery. The Health Department plays an active role in supporting emergency planning efforts, as well as serving on the incident command team during response to any natural disasters. Disaster debris will be managed through the appropriate existing facilities, including transfer facilities, permitted inert waste landfills, building materials recovery centers, and composting facilities, as feasible. The County may also designate certain locations and facilities for accumulating large volumes of disaster debris. In the future, the County may need to designate certain locations and facilities for accumulating large volumes of disaster debris, as needed, specifically drop-box and transfer station locations.

8.1.6 FOOD-RELATED, NONPETROLEUM GREASE

Grease is generated primarily by restaurants, cafeterias, and other food services. Because it is semiliquid, it should not be disposed of into a sewer or on-site sewage system, and is not easily handled as solid waste. County residents can properly dispose of cooking oil by taking it to the MRW Facility (Disposal of Toxics). Rendering companies usually handle the collection of grease from businesses, recycling it into such products as an animal feed supplement or biodiesel fuel. If grease is improperly disposed of, several different agencies or companies may deal with it. Grease dumped into sewers is addressed by municipal wastewater agencies, while grease improperly

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE66 JUNE 14,2016

disposed of in the garbage is addressed by the private MSW collectors. Improper handling of grease by restaurants is addressed by the County Health Department.

8.1.7 BIOMEDICAL WASTE AND PHARMACEUTICALS

In the medical industry, a number of definitions exist for biomedical waste because of overlapping and inconsistent local, state, and federal regulations governing its management. This has a critical impact on the management of material, since each generator's quantity ofbiomedical waste is greatly influenced by how inclusive the definition may be. In response, the State of Washington has developed a statewide definition of biomedical waste to simplifY compliance with local regulations while preserving local control of biomedical waste management (RCW 70. 95). Furthermore, biomedical waste is regulated by WCC 24.06.040. The state definition of biomedical waste is to be the sole definition for biomedical waste in the state, and will preempt biomedical waste definitions established by local health departments or local governments. Biomedical waste is defined and limited to the following types of waste: Animal Waste is waste animal carcasses, body parts, and bedding of animals that are known to be infected with, or that have been inoculated with, pathogenic microorganisms infectious to humans. Biosafety Level 4 Disease Waste is waste contaminated with blood, excretions, exudates, or secretions from humans or animals that are isolated to protect others from highly communicable infectious diseases that are identified as pathogenic organisms assigned to biosafety level 4 by the current edition of the Centers for Disease Control manual Biosafery in Microbiological and Biomedical Laboratories. Cultures and Stocks are wastes infectious to humans, and include specimen cultures, cultures and stocks of etiologic agents, wastes from production of biologicals and serums, discarded live and attenuated vaccines, and laboratory waste that has come into contact with cultures and stocks of etiologic agents or blood specimens. Such waste includes but is not limited to culture dishes; blood specimen tubes; and devices used to transfer, inoculate, and mix cultures. Human Blood and Blood Products are discarded waste human blood and blood components, and materials containing free-flowing blood and blood products. Pathological Waste is waste human-source biopsy materials, tissues, and anatomical parts that are derived from surgery, obstetrical procedures, and autopsy. Pathological waste does not include teeth, human corpses, remains, and anatomical parts that are intended for interment or cremation. Sharps Waste is all hypodermic needles, syringes with needles attached, IV tubing with needles attached, scalpel blades, and lancets that have been removed from the original sterile package. The major sources of biomedical waste include hospitals, medical laboratories, research laboratories, commercial diagnostic laboratories, outpatient medical clinics, dental clinics, nursing homes, and veterinary hospitals and schools. Transportation of biomedical waste requires a solid waste certificate from the WUTC. Stericycle Environmental Solutions and Waste Management Healthcare Solutions are the two collection companies in the state. In general, biomedical wastes must be categorized, segregated, and packaged separately from other waste in containers that are clearly labeled "biohazard" or "biomedical waste." Sharp objects, such as needles and blades, must be packaged in rigid, impervious, properly labeled

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE67 JUNE 14,2016

containers designed for this purpose. With prior approval of the Health Department, disposal of treated infectious solid waste in the solid waste stream is allowed. The City of Bellingham began collecting unused household medications in April 2010. Since that date, over 7,000 pounds of phartP...aceutical \Vaste has been securely collected and safely transported to a hazardous waste incinerator for destruction. This waste is kept out of the waste stream, protecting surface water, groundwater, and . Properly collecting and destroying unwanted medications keeps them out of the wrong hands and reduces the potential for poisoning and unintended overdose. Expired and unwanted medications may be dropped off in original packaging at participating pharmacies. Examples of accepted items include household prescriptions and samples, over-the­ counter medications, medicine for pets, medicated ointments and lotions, vitamins, inhalers, and unopened EpiPens. Narcotic pain relievers and prescribed controlled substances, such as codeine, hydrocodone, OxyContin, Percocet, Ritalin, Vicodin, and Xanax, are not accepted at pharmacies and must be taken to the Bellingham Police Department. There is no fee for this service. The program is funded by the City of Bellingham through a combination of Ecology grants and Solid Waste Tax revenues. Participating pharmacies in Bellingham include: • Haggen Pharmacy-Fairhaven Market, 1401 12th Street • Haggen Pharmacy-Meridian, 2814 Meridian Street • Haggen Pharmacy-Barkley, 2900 Woburn Street • Hoagland Pharmacy, 2330 Yew Street • Interfaith Pharmacy, 218 Unity Street Since the success of the City of Bellingham's program, additional entities throughout the county have begun receiving similar items. Examples of this include the Haggen Pharmacy in Ferndale, which collects household prescriptions and over-the-counter medications, and the Ferndale Police Station, which accepts controlled substances. The MRW Facility (Disposal ofToxics Program) accepts unused pharmaceuticals from households (including controlled substances) at no charge, and from small-quantity generator businesses (not including controlled substances).

8.1.8 VACTOR WASTE

The City of Bellingham owns, operates, and maintains a vactor waste transfer station in the Irongate Industrial Area for the purpose of processing street sweepings and vactor waste materials in accordance with regulatory guidelines. The County pays a proportionate share of operations and maintenance cost for its use. The facility also accepts street waste from other municipal jurisdictions and private parties for a fee on a per-ton basis. Customers include the City of Bellingham, Whatcom County, the WSDOT, and several private operators. The smaller cities of the county either dispose of their street sweepings and vactor waste at a permitted disposal facility, or process it at a wastewater treatment plant. Wet material is stockpiled and allowed to passively drain or decant under a covered structure. Decanted wastewater is collected and discharged to the municipal sewer system for treatment at the wastewater treatment plant.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE68 JUNE 14,2016

Material is received at the vactor waste transfer station as low- to moderate-risk solid waste. Due to the classification of the material, vactor waste recycling or reuse options are limited. Since the facility is permitted as a transfer station, the City of Bellingham currently legally contracts with a private hauler to transport the material to the Waste Management Greater Wenatchee Solid Waste Landfill for reuse as alternative daily landfill cover. The City of Bellingham continues to pursue avenues to reuse and recycle vactor waste and street sweepings. The City of Bellingham is also exploring options to encourage the development of additional privately operated vactor waste and street sweeping transfer stations.

8.1.9 WASTE TIRES

Used tires generated in the county are generally handled by the retail tire industry. Usable tire casings are either shipped directly to retreading plants or combined with unusable casings for later sorting at processing sites. Unusable tires are shipped by state-permitted tire haulers to approved processing, storage, or disposal sites. Tires disposed of in the MSW stream by individuals and businesses are handled at local transfer stations, Cando Recycling Transfer Station, the NVD Drop Box Facility, or Beacon Battery and Tires. In addition, Ecology maintains a Waste Tire Removal Account to fund tire pile cleanups. This account is funded with a $1 fee collected for each new vehicle tire sold in Washington. The account funds waste tire efforts identified by local governments and other public entities for waste tire pile prevention, cleanup, and education. Whatcom County was a recipient of funds in FY2009-201 0 for tire pile cleanup on four properties and in FY2012-2013 for tire pile prevention activities, such as the cleanup of 80,000 tires at the Foothills Recycling landfill and the Upriver Tire Amnesty Collection Event. More information can be found on the program's web page: http://www.ecy.wa.gov/programs/swfa/tires/cleanup.html.

8.1.10 CONSTRUCTION AND DEMOLITION WASTE

There are several private for-profit and not-for-profit facilities that accept construction waste throughout the county. These facilities are described in more detail in Sections 3.1 and 4.1. • REStore • RDS Transfer Station • sse facilities • Cando Recycling Transfer Station • Northwest Recycling • Granite Construction Company • Whatcom Builders • Henifin Recycling Facility 8.2 NEEDS AND OPPORTUNITIES

The purpose of the solid waste system is to protect public health and environmental quality. Unfortunately, if generators do not have a convenient means of disposing of their waste, some generators will be more likely to dispose of their waste illegally. Others may store the waste while they seek disposal. Such storage or dumping is illegal and often creates environmental and/ or human health risks.

WHATCOM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE69 JUNE 14,2016

Managing these risks and ensuring that there are disposal opportunities for special waste is a critical role of the county. Although special wastes represent only a relatively small proportion of the total solid waste generated, the Health Department receives a significant number of inquiries about a variety of unusual and new wastes. It is the County's responsibility to ensure that a safe and reasonable disposal option exists. All special waste types are being handled consistent with the description in Section 8.1. The County will continue to remain active with all identified special waste handlers to ensure compliant disposal practices. In certain cases, such as with C/D debris and vactor waste, special waste may be repurposed.

8.2.1 CONSTRUCTION AND DEMOLITION DEBRIS RECYCLING

C/D waste comprises a significant portion of the waste stream. The 2009 waste sort study conducted by Ecology found that approximately 30 percent of all solid waste consisted of C/D debris. Of this, approximately 50 percent consisted of wood, 16 percent asphalt paving and roofing, 7.5 percent drywall, 6 percent ceramics and bricks, 5 percent carpeting, 4 percent insulation, and 11 percent residual materials. Based on these data, C/D waste represents a significant portion of the waste stream and recovery efforts may effectively increase county diversion rates. Since completion of the study, RDS installed and has been operating an MRF to recover C/D­ related materials, which are dropped off in a designated area or manually sorted from the transfer station tipping floor. Therefore, a significant amount of diversion is now occurring that was not accounted for in the Ecology study. The County's Flow Control Ordinance (FCO) (Ordinance No. 91-041) requires that solid waste generated in the county be processed or disposed of at a designated waste facility. The ordinance also establishes priority levels for waste disposal sites that favor recycling or other means of diversion over landfilling of unseparated solid waste. However, the ordinance exempts C/D debris. A subsequent ordinance (Ordinance No. 96-037) further exempts C/D waste from the FCO. This amendment allows disposal of C/D waste at undesignated disposal sites, including sites located outside the county. It is difficult for the County to determine the current recycling levels of these materials, given their out-of-county disposal location. More investigation would be required to better understand the situation. Alternatively, revising the current exemption may encourage better management at existing in-county facilities to ensure material recovery prior to disposal.

8.2.2 VACTOR WASTE

Materials from the City of Bellingham's vactor waste facility are sent to a landfill to be used as landfill cover. Since much of the material contains some level of contamination, reuse of the material requires careful consideration. However, some opportunities may exist to repurpose the material as fill for road projects where the fill will then be capped with asphalt and isolated from any potential exposure pathways. The City of Bellingham and the County should work with regulatory agencies to identify appropriate and safe beneficial reuse alternatives.

WHAT COM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE70 8.3 GOALS AND ACTIONS

The County will continue to evaluate the potential for disposal, recycling, and reuse of special waste sources. Programs for special waste will focus on the evaluation of alternatives for management of construction demolition, street sweepings, and pharmaceutical waste. TABLE 8-1 GOALS AND ACTIONS FOR SPECIAL WASTE GOALS ACTIONS CONNECTING TO BEYOND WASTE* l. Increase C/D waste recycling. A. Conduct outreach to building associations and other Priorities of Plan construction-related entities to educate contractors about Increase efficiency of recycling the benefits of a self-regulating industry. • (including organic processing) systems, ~s~~~1:\7aluafe~poten1Taiforins1TfutTri9recvciin9~requirements1or ___ and maximize effectiveness of existing construction sites through the building permit program. solid and hazardous waste ~c.~~lmplemenf'ProvisTons1or~9ov~ernmenfaico~ns1ruc1fon'PrOle~c'tS- infrastructure. to require recycling of waste and a preference to use - Focus on facility compliance, recycled building products. technical assistance, ond 2. Control sham recycling, if it is A. Investigate service provider compliance with applicable enforcement. taking place. requirements to determine if there is an issue of illegally . Mitigate climate change . hauling solid waste under the guise of recycling, and - Increase reuse, recycling, and waste enforce requirements as applicable. reduction. -K~~1:\7alu0fe~cflan~9es1offle~F"fc>'W~c'Onrroiexemption1o·r-c7o_____ Key Principles and Strategies waste. 3. work Within state regulatory A. Evaluate grow1ng need to manage street sweepmgs and . Focus solutions on designing structure to effectively manage regulatory barriers to beneficial reuse and/or management sustainable products and processes. street sweepings and of street sweepings. • Create collaborative partnerships with cont aminated soil. a variety of players. 4. Provide effective management A. Continue to support and/or enhance existing programs for • Lead by example in government, options for pharmaceutical pharmaceutical take-back. especially through research, waste. purchasing power, and model 5. Be prepared for management A. Coordinate with theW hat com County Sheriff's Office demonstration projects. of special waste generated Division of Emergency Management for integration of waste • Strive for continuous improvement . though response to natural or handling/disposal into emergency planning documents. __,., man-caused disasters. This column refers tothe2015 Beyond Waste Plan. The numbering system for key goalsandstrategiesis intended toreflecHhe number system in the BeyonaWaste document.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE71 9 ADMINISTRATION AND ENFORCEMENT

Administration and enforcement of solid waste regulations in Whatcom County are carried out by various agencies in the county. Administration of solid waste regulations is the joint responsibility of Ecology, the Health Department, and the incorporated cities in the county. Responsibilities for the enforcement of solid waste regulations are distributed between Ecology and the Health Department. This chapter identifies the statutes and regulations that form the basis for solid waste administration and enforcement and the agencies responsible for implementing them, discusses their effectiveness, and offers recommendations for improvements.

9.1 EXISTING CONDITIONS

9.1.1 AGENCY ROLES AND RESPONSIBILITIES

What com County Health Department The solid waste system is managed by the Solid Waste Division of the Whatcom County Health Department, which includes the following responsibilities: solid waste enforcement; solid waste facility permitting; education and outreach for waste prevention and recycling; ensuring economically efficient recycling and disposal systems; litter control; hazardous waste education and disposal; and monitoring of the County's closed landfills. They also facilitate SWAC committee meetings. Funding for the Solid Waste Division is allocated through the County's annual budget process (see Section 10.3) with most revenues provided by the collection of an excise tax on garbage hauled by certificated haulers, as well as by multiple Ecology Coordinated Prevention Grants. The Health Department administers several contracts to provide solid waste education and outreach services to enhance County programs. The Solid Waste Division was transferred to the Health Department from the County's Public Works Department on January 1, 2015. What com County Public Works Department As the agency formerly overseeing the Solid Waste Division, the Public Works Department was responsible for drafting previous solid waste plans, including the 2008 Comprehensive Solid and Hazardous Waste Management Plan and the 1991 Hazardous Waste Plan. The Public Works Department has remained engaged in the planning process of the current Plan, although they no longer hold any responsibility for solid waste activities in the county. Solid Waste Advisory Committee The Whatcom County SWAC was established in 1985 to provide input and review for the Plan that was under development at that time. The SWAC has continued to meet to review and update solid and hazardous waste management plans, County policies and ordinances, and other issues related to local solid waste management. SWAC meetings are open to the public and are recorded with written minutes. All documents and meeting minutes are distributed to the mayors of the cities, affected agencies and organizations, and interested individuals.

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Solid Waste Executive Committee The SWEC is responsible for estimating quarterly and annual revenues, recommending annual budgets to the County Council, and monitoring expenses to ensure budget compliance. The SWEC is composed of the mayors representing each city within the county, as well as the County Executive. The SWEC is responsible for reviewing the Plan and providing recommendations to County Council. Cities Pursuant to interlocal agreements with the County, all cities have instituted mandatory garbage and recycling collection. Cities in the WUTC-regulated areas have the option of providing for solid waste collection either through municipal crews or through contracted services. If cities do not elect to exert local authority over collection, collection services will be provided by the collection company with the underlying certificate for the geographical area that includes the city. The cities of Everson, Ferndale, Lynden, Nooksack, and Sumas have municipal contracts for both residential and commercial solid waste collection. The City of Bellingham has a municipal contract with SSC for residential collection and commercial collection remains governed by WUTC regulations; disposal is managed through an independent contract. No other cities in Whatcom County currently have independent disposal agreements, although the City of Ferndale previously had separate disposal contracts. The City of Blaine has asserted no local authority and consequently is fully serviced under WUTC authority. Coincidentally, all cities that contract for collection services at this time have contracted with a collection company that holds the underlying WUTC certificate covering that city. With the exception of Blaine, cities in the county undertake solid waste collection and determine collection rates, frequency of service, billing, and recordkeeping systems through ordinances and contracts with private collection companies. City-contracted collection companies provide direct billing services. No city in Whatcom County has a municipally operated collection system The City of Bellingham also has a formal, staffed, litter-control program. A deputized city staff member performs all litter and illegal dumping control activities, including investigating litter and illegal dumping complaints, providing enforcement, and cleaning up dumping sites. Other cities also have litter-control programs, although litter-control activities are often informal and are generally performed by public works or parks crews, as needed. Native American Tribes Lummi and Nooksack tribal lands are not subject to this Plan. However, non-tribal residents living within reservation boundaries are subject to provisions of County solid waste ordinances. Both the Lummi and Nooksack Tribes contract with private WUTC certificated haulers for garbage collection. Washington State Department of Ecology Ecology is responsible for promulgating and enforcing state regulations associated with solid waste disposal, air emissions, and wastewater and leachate discharges. The state solid waste regulations that Ecology enforces result from state legislation (including RCW 70.9 5) and in response to federal law such as RCRA. Ecology reviews and approves local solid waste management plans, works with local health departments to enforce the state's MFS (WAC 173-304), and permits incinerator ash disposal as

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authorized by RCW 70.138. Ecology may periodically revise facility standards for demolition landfills, compost facilities, and MRW facilities as part of the MFS revisions. Ecology also provides grant funding to local governments that assists in solid waste program operations. l'brthwest C!ean ;<\ir ,a,gency The NWCAA has regional responsibility for regulating and enforcing air quality. Solid waste management activities that impact air quality fall under NWCAA jurisdiction. NWCAA regulatory activities in local solid waste management historically have been focused on the regulation of emissions for solid waste incinerators; the permitting of controlled burns of woody debris, including burns at landfills and transfer sites; and enforcement related to the use of burn barrels to burn solid waste. NWCAA is also responsible for regulation of any construction that may result in handling and/ or disposal of asbestos containing materials. There are no active incinerators in the county. Washington Utilities and Transportation Commission The WUTC regulates solid waste collection companies under the authority ofRCW 81.77. In brief, the law provides for regulated garbage collection companies with monopolies in specified geographical (certificated) areas. The WUTC regulates collection fees and operating standards, as well as requiring annual revenue and expense reports for certificated collection companies. Collectors charge uniform rates subject to WUTC approval across each certificated area. Collection companies must provide collection services at the specified tariffs to all customers in their certificated area. The original certificates were awarded in 1961. These certificates are perpetual unless a collection company fails to offer adequate service, or cedes or sells all or part of their certificated area to another collection company. In the event that a collection company decides to cease business, their certificate could be sold to a competing entity, under review of the WUTC, which would then provide collection services to the same jurisdiction. The WUTC provides temporary authorization during the review period to ensure uninterrupted service to customers. With the passage of the County's 1990 Service Level Ordinance (Ordinance No. 90-95), the County took an active role in defining local solid waste collection services. Through the Ordinance and successive amendments, the County defined minimum garbage and recycling collection services and set collection charge rate policies. The WUTC is responsible for regulating the certificated services within the framework of the County's Service Level Ordinance. The WUTC also reviews the Plan during the approval process and evaluates probable financial impacts to county rate-payers.

9.1.2 FLOW CONTROL ORDINANCE

Flow controls are legal provisions that allow state and local governments to designate the places where MSW is taken for processing, treatment, or disposal. County Ordinance 91-041, adopted June 25, 1991 and codified as WCC 8.15.030, establishes County control over the disposal of solid waste in the county and requires designated disposal sites to have disposal agreements with the County. The FCO establishes priorities for the flow of materials through the county solid waste system, prioritizing recycling as the primary means of solid waste handling. In September 1996, the County Council passed an ordinance (No. 96-03 7) to exempt C/D waste from the flow-control requirements.

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9.1.3 FINANCING

Until 1990, the County financed solid waste activities from disposal revenues received at County disposal facilities. These activities included landfill operations, transfer operations (e.g., subsidizing the Maple Falls and Point Roberts drop-box sites), the closure and maintenance of old landfill sites, and planning and administration. With the establishment of the FCO and the temporary disposal site agreement with the former Recomp facility (now RDC) in 1990, the County funded its solid waste activities with the $9-per-ton surcharge collected by Recomp. These surcharge funds allowed the County to formally close past County landfills, enhance waste reduction and recycling program design and implementation, and address other County solid waste funding obligations. When FCO­ based disposal site agreements became unenforceable in early 1997, disposal sites ceased to collect and remit the disposal surcharge ahd the County lost its solid waste revenue source. The County then reviewed a number of financing options, including "no funding" (i.e., ceasing any solid waste functions); reactivating a 1987 county ordinance [No. 87-1 7] authorizing the collection of pass-through fees at private disposal facilities; implementing a percentage collection excise tax through the disposal district; implementing a per-container collection excise tax through the disposal district; and shifting to general tax funding through the County's "current expense" fund. The "no funding" option was rejected because of the County's need to meet statutory obligations, including planning, ordinance enforcement, and postclosure responsibilities for closed County landfills. The implementation of the 1987 "pass-through" ordinance was deemed inadvisable, since many of the same flow-control legal issues that challenged the disposal site agreements would apply to the earlier pass-through ordinance. The percentage excise tax through a disposal district was considered feasible, but potentially inequitable, since customers paid varying amounts to different haulers for the same level of service, and would thus pay varying amounts of excise tax while receiving the same service. The shifting to general tax funding was rejected because of the limited availability and competition for current expense funds. The County determined that a weight-based excise tax based on disposal district taxing authority would be the best funding mechanism. This approach would avoid the perceived inequity of a percentage tax and would link tax payments to container size and anticipated container weight. The County's disposal district (WCC 8.13) was revised to reflect this excise tax approach and others updated through Ordinance 97-041, adopted July 29, 1997. The collection of the excise tax began in October 1997. According to WCC 8.13.030, the excise tax is levied on all solid waste collection at each residence, business, and institution at the rate of $8.50 per ton. The County levies this tax to administer solid waste management planning and a portion of the education and community outreach in the county. This excise fee is collected by the collection companies.

9.1.4 ADMINISTRATION

The Health Department provides staff to administer the contracts for solid waste education and outreach programs, procure state and local grants supporting solid waste operations, and support the SWAC and SWEC. In addition to contract administration, County staff respond to public questions and serve as a resource to the community. Except for defining the terms of the Service Level Ordinance, the County does not take an active role in administering the collection, transfer, or disposal of solid waste generated in the county. These actions are managed through municipal contracts, WUTC G-Perrnits, and private contract mechanisms between service providers.

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9.1.5 ENFORCEMENT AND COMPLIANCE

The Health Department maintains responsibility for permit compliance and solid waste enforcement activities in the county and the solid waste system. Health Department staff routinely administer solid waste permits to facilities in the county and periodically assess compliance. Staff, along with the sheriff's office, address the need to periodically enforce solid waste ordinances, including instances of illegal dumping. Although disposal rates have been stable or have moderately increased for years, illegal disposal continues to be a problem in rural county areas. Given the size of the county, the possibility of multiple sites scattered throughout the county, and the difficulty of gathering sufficient evidence, enforcement activities related to illegal disposal are very time-consuming. Staff only responds to complaints, and does not actively patrol the county looking for illegal disposal sites. On average, there are 11 0 complaints per year. The Health Department's complaint tracking consists of an initial site visit for documentation and verification of illegal dumping; research of ownership, property owner, etc.; outreach to the property owner and enforcement letters; follow-up public contacts, correspondence, and inspections; and court preparation and appearances, if needed. It is Health Department policy to encourage voluntary compliance and avoid the use oflaw enforcement agencies. If there is a lack of progress, the sheriffs department becomes involved, which may result in a civil action and subsequent court date. In addition to the general problem of adequately responding to complaints of illegal disposal, bringing charges against violators is further complicated by the evidence requirements for prosecution based on state law. The current system can consume numerous man-hours to gather sufficient evidence, conduct repeated inspections/investigations, and possibly bring court action.

9.2 NEEDS AND OPPORTUNITIES

Financing for the solid waste system is provided through the County excise tax collected by collection companies, various Ecology grants (as made available), and revenues resulting from leases with private sector solid waste providers (refer to Sections 7.1.1 and 7.1.2) . Current funding levels are enough to support minimum programming, but more funding may be needed to expand the County's education, outreach, and business technical assistance. The County should periodically assess programs in development and the funds available and reallocate funds on an as-needed basis in order to meet the implementation priorities for waste reduction, recycling, and composting.

9.2.1 ENFORCEMENT AND COMPLIANCE

Enforcement of solid waste disposal provisions is a critical component of the County's solid waste management program. While the community as a whole prides itself on disposal compliance and a relatively high rate of diversion, specific challenges exist in two somewhat more rural portions of the county. In particular, the Point Roberts area is geographically separated by Canada, and the Kendall­ Maple Valley Area requires urban levels of service even though it is located in a more rural area. The Kendall-Maple Valley Area The Kendall-Maple Valley area is located in unincorporated Whatcom County, but requires near urban area levels of service because of its relatively high residential development density. In addition to demographic factors, the area is challenged by its distance to typical urban services. As a result,

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there is frequent illegal dumping of solid waste on vacant lots, off logging roads, and in culverts. Health Department staff implement a compliance and enforcement program, but because of limited resources and countywide demands, additional infrastructure may be necessary to better serve this area. In the past, the Health Department has worked with community groups, including Kendall Kleen, to provide special attention to these issues and has facilitated various cleanup activities. Point Roberts There is also a new compliance issue being investigated in Point Roberts, which may be exacerbated by international travel restrictions that are enforced on the only road leading from this isolated community, which happens to be the point of entry into Canada. Point Roberts is located just south of the United States-Canadian border and is isolated from the mainland United States. The community includes a large number of seasonal residents who must travel into Canada to return to their primary place of residence, whether in the United States or Canada. Providing urban services in this area is a challenge for a number of reasons. For example, the area's relatively small population makes it difficult to provide waste management services on economies of scale. Also, whereas residents and visitors in other seasonal communities around the United States would be permitted to transport household solid waste to dispose of at their primary place of residence, international border regulations prohibit the importation of solid waste into Canada. As a result, residents must dispose of garbage before leaving Point Roberts. Other factors include the fact that some seasonal residents use their Point Roberts address to receive packages and must dispose of the packaging before leaving the area. In some cases, garbage is disposed of illegally at public parks and facilities. County staff have undertaken steps to curb illegal disposal through the Health Department enforcement program. The issue, which has only recently been brought to County enforcement staff, is currently being examined in greater detail.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE77 9.3 GOALS AND ACTIONS

Beyond educational programming, administrative and enforcement activities represent a significant role for the County in the largely privatized system. As funding for these roles expands, the County will consider alternatives to increasing compliance and participation in the appropriate recycling and waste management programs. TABLE 9-1 GOALS AND ACTIONS FOR ADMINISTRATION AND ENFORCEMENT GOALS ACTIONS CONNECTING TO BEYOND WASTE* 1. tva1uate regulatory A. Ev6Tudfe the ex1stmg exemption program for solid waste Priorities of Plan changes to increase collection effectiveness. • Increase efficiency of recycling (including organic efficiency and -~~f~~'Ev~aluafe1'h-eex1sfin9C:T¥TI'Penalfvsfrucfure7orwasfe¥fola1fciri5,- processing) systems, and maximize effectiveness of management. with consideration to develop alternative structures to existing solid and hazardous waste infrastructure. incentivize compliance. - Provide enforcement to reduce sham recycling. ~c.--'Ev~aluafe-ancrcreaTee1f8C:1i¥e-cou-nTi5oncrwas1e------m-- - Focus on facility compliance, technical enforcement tools countywide, with emphasis on highly assistance, and enforcement. developed, unincorporated areas (such as Limited Area of - Increase capacity and diversity of recycling More Intense Rural Development [LAMIRD]). (including organics processing) infrastructure. m15.--conduct7e'vfSTon~aswarranted,Towliatcommmco-unfycoC:fe·--~ • Mitigate climate change. 8.15.030.E to reflect current disposal sites. - Increase reuse, recycling, ond waste reduction. -'E:-mrmur5uea-riTnferlocaia-9r-eemen1-wTfh'si

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE78 10 IMPLEMENTATION SCHEDULE

The purpose of this section is to outline the planning process followed in the development of this Plan, and identify implementation responsibilities, actions, and an overall implementation schedule.

10.1 IMPLEMENTATION RESPONSIBILITY

Solid waste management is governed by the laws and regulations of federal, state, and local governments. These laws and regulations create the legal framework defining roles and responsibilities. The following section discusses the roles and responsibilities of local government in the management of solid waste in the county. Waste Reduction and Recycling Waste reduction and recycling is a fundamental strategy and top priority for solid waste management in the county, and is a critical element of the Plan. The County is responsible for implementing education and recycling programs countywide, with its partners, to reduce waste disposal. Private solid waste companies will continue to support recycling education and enforcement as a basic part of their customer services efforts. Collection With the exception of the City of Blaine, the cities in the county manage the solid waste collection system, including the establishment of rates to pay for the service. Cities are responsible for ensuring that their solid waste collection systems, albeit privately owned, are in compliance with the Plan. The WUTC is responsible for ensuring that the services provided and the rates charged by the regulated haulers are in compliance with the Plan. Disposal It is the responsibility of the County to ensure that a long-term disposal system is available for MSW. Private entities operating transfer stations in the county use their operating contracts to ensure that properly permitted disposal facilities are utilized for the disposal of county-generated waste. The Plan is required to describe existing solid waste disposal handling facilities, which, in Whatcom County, are all privately owned. The County is responsible for assessing the need for additional solid waste handling facilities over the 20-year planning horizon. Education and Public Involvement Comprehensive education is to be conducted throughout the county so that people are informed of the need to reduce, source separate, and recycle solid waste. Development of educational programs is required as part of the Plan (RCW 70.95). The County is responsible for ensuring that the public has a chance to participate in the decision­ making process. This has been accomplished by holding public meetings on the Plan and other solid waste issues, providing adequate public notice of SWAC meetings, establishing a comment period during which citizens submitted written comments on the proposed plan, distributing informational brochures, and soliciting ideas from citizens.

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Solid Waste Permits As described in Sections 9.1.1 and 9.1.5, the Health Department is responsible for permitting solid waste facilities. The department issues permits for transfer stations, drop boxes, biosolid facilities, vactor waste facilities, recycling facilities, digesters, and MRW facilities. Applicants must also apply for permit approval from the County Department of Planning & Development Services. The Department of Planning & Development Services reviews proposal to make sure they are consistent with County land use codes, zoning, and the County's comprehensive plan. Potential approvals required include building permits, grade/fill permits, and conditional use permits. Solid Waste Management Planning The County is responsible for solid waste planning and management. The County, in cooperation with the cities, is required to prepare a coordinated, comprehensive plan, which must comply with RCW 70.95, Ecology's Guidelines for the Development of Local Solid Waste Management Plans and Revisions, and the Cost Assessment Guidelines published by WUTC in accordance with RCW 70.9 5.090(8). Implementation It is the responsibility of the County and cities to implement programs following the adoption and approval of the 2016 Plan. The County and the cities are required to adopt regulations ordinances governing solid waste handling to implement the 2016 Plan (RCW 70.95). Reporting Municipalities that provide their own solid waste disposal are required to report annual tonnage information to Ecology. Solid Waste Advisory Committee The County is required to establish a local SWAC to assist in the development of programs and policies concerning solid waste management. The SWAC also reviews and comments on proposed rules, policies, and ordinances before their adoption. The SWAC is advisory only, making recommendations to the County Council, which makes final decisions after considering SWAC recommendations and other available information. The County SWAC elects its own chairperson, adopts its own bylaws, and conducts its own meetings in accordance with the Ecology Solid Waste Planning Guidelines. County staff provide information to the SWAC and facilitate meetings.

10.2 SUMMARY OF GOALS AND ACTIONS

The following table provides a list of implementation actions for the County, cities, private haulers, private businesses, and institutions in the county. The list is derived from the goals and actions section of each chapter contained in this Plan.

WHAT COM COUNTY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE SO Table 10·1 IMPLEMENTATION SCHEDULE

GOALS ACTIONS 2019 2020 2021 I Future

Education and Community Outreach I. Increase community knowledge and expertise of waste A. Increase current youth and primary school education programming. .F .F .F .F ...... ,., reduction methods by providing educational opportunities -il~--E:x-,;c,·rict5e:ti00r;;;:r.:;;:;Q'ii0"ri",;;c,g-;"n:;n:;T;;9·ic,·i.:;e:icC:ie·,:;;;-crar;;·c;;;c:r,;iQF15C:tiCiCiii8¥-;;is·w-iilia·9e:a·,;p-r';;;;;rc;r;;;;;;c,j;;c-t5:···· .F to targeted populations using existing public and private information, and messaging. .F .F .F :~d:~·:: ...... ,..., .... ,...... ,. .. ~ ...... resources. ·c:~·s'U",;p-;;;t();;Cir~-;,·a·e:c,·,;;;;:;;;;e:T;;r;;c:;u-c:;;iTCi';;'i'h";;;c9·hi'Or98i;;a·c;~i;;;Cie:h~-e:;;r;;;n;;;a;r;;::;;;i.;;·c;~d'~;:-a;;Cir;,·a;;:;i;;Cil""""" .F .F .F .F assistance. ·o~·l-c,~g-;:,;-c,;~;;r;p-;n;;-n-r;T;.;:rce:Cin<;;;;;r;n;;!;riaTs-;;;·,;:;c~TiamiiY."C:G51C:;r1:;.;;;-s~---········------············· .. ·······---- ·------·------·-·-;;-···r ··-;;--··r-·-;;---·r·., ··:;---- ·r··;;;<;;;,·c;;;:,·;u'Pi'Ciri"O"ri<:'O;;;;;;~;;;;t;:requ-esrs~------··------·-· ···,?--r·-;;-··r-;;-···r-·".i·--r·".i·--r···:;···· 2. Utilize appropriate and relevant tools for mass A. Continue distribution of educational materials digitally and make available in paper form, as requested.

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Multifamily Recycling 1. Gather information on multifamily disposal and recycling A. Conduct a waste audit to understand the recycling habits of multifamily customers. Findings could drive future habits. action. ./ 2. Encourage manager/owner responsibility. A. Education outreach to building/facility management. Suggest training of residents for facility waste bin system at move-in and require compliance in lease. ./ 3. Increase multifamily residential outreach. A. Provide educational information to be distributed to multifamily residents, such as information on how to ./ ./ ./ ./ accommodate recycling bins. [~~~~~~;~~~;:~~~~~~::=~~~:~~~~~:::~~~~=~~~~:~~~~:~:~:~:~i:~:~~:::::~~:::~~:~~:~:~~~:s:~::~~:~~::f:~~:~~~:~::~::::: ./ ./ ./ C. Provide clear labeling of acceptable materials with pictures for each container to address potential language ./ ./ ./ barriers. ·o~·'E·;;c;~-~h;rn:;;;rreCi~·~;;<:;,··c;r;:u;t;-;rc;;;;,~;~-;;r;·,;;·c-iiif-;;;;.;ii7ti~Tid'i-;,-9;'P;,;¥;0rtina·c;r,:;;<;ii'PorfCniii65-i0"C56"oliaeratiiC:-Cli9esiers·rc;;:d'iv·~;s;;·;c;rp-,:e..c:,;;;s7.J-;;.;6n0c;·d-;;7a-5i~~------Solid Waste Collection 1. Ensure that collectors are providing the required minimum A. Investigate complaints regarding collection services and correct deficiencies. service to all subscribers as outlined in Whatcom County ./ ./ ./ ./ ./ ./ Code and interlocal agreements between the County and municipalities. Transfer and Disposal 1. Continue to maintain and support transfer and disposal A. Provide ongoing post-closure monitoring and maintenance of closed landfills. system facilities. ··cwc;;·k''Wiit1"8xi5iin9·;;;:iVc;;;,·i;a-~;r~;-siaii0~;;c;;,·;;c;-~-c:0·,:n;;iiance-;;;.ii'il"50~

·s~·-'E.:Ciica-iechon9esi0iii';;"Fia-;;;.·c;c;-;,Tr~;r~;;,·,;;·pric;;;·fO'rcii)w0sie.·------·-··········--···------· ./ ./ 3. Work within state regulatory structure to effectively manage A. Evaluate growing need to manage street sweepings and regulatory barriers to beneficial reuse and/or street sweepings and contaminated soil. management of street sweepings. ./ ./ 4. Provide effective management options for pharmaceutical A. Continue to support and/or enhance existing programs for pharmaceutical take-back. ./ ./ ./ waste.

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5. Be prepared for management of special wastegenerated A. Coordinate with theW hat com County Sheriff's Office Division of Emergency Management for integration of waste through response to natural or man-caused disasters. handling/disposal into emergency planning documents. ~ ~ ~

AdminislraHon and Enforcement 1 Evaluate regulatory changes to increase efficie-ncy and A-:-Ev<:lll!ate the existmg-exemption program-fOr solid waste cOTiecfion effectiveness. ~ management. ·K··r;~i~a-ieiii"eexi;ir,;-9-;T~irpe-;~iiv"si~~d-;7r";;i'O"r·~~;i:;~rc;ic;i;;;~;7~iit1'C0nsicferaii0~Ta·a;,~·eia;:i;;iier~ati¥";;~i;~a;:;;e;·· to incentivizecompliance. ~ ·c:~·'E-;;~i~a·ie-a~cr;;e-~ie--;;ii;,C"n:;-;;·c;-;;~~i"Y"50iid'~a-;ie-·e-~'1;;:;-;;;n;,ni·i;;·a~·;;a-c~i~rae~-~itii·;,n;·pha;;;-;;~·hT9h'ly··········· developed, unincorporated areas (such as Limited Area of More Intense Rural Development [LAMIRD]). ~

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WHATCOM COUNlY COMPREHENSIVE SOUD AND HAZARDOUS WASTE MANAGEMENT PLAN PAGE83 10.3 BUDGET

The County maintains an annual solid waste budget of approximately $1,260,000. More than half of the solid waste budget is funded t.b.rough the County solid waste excise tax. Tl-Js tax is collected by private haulers through curbside collection fees. There is no self-haul disposal tax collected at the current time. The balance of funding is secured through Ecology grants, which has recently been reduced by $125,000 per year through reductions in the State 2015-2017 biennial capital budget. County solid waste handling facilities and collection services are largely privatized and do not require direct County investment. Two of the three transfer facilities in the County, RDC and RDS, are privately owned and operated. The Cando transfer facility is County-owned, but leased to a private party for operation. Drop-box facilities in the County include both publically and privately owried drop boxes; however, public drop-box facilities (Cedarville and Birch Bay) are also leased to private entities and require only periodic maintenance. As a result, expenditures for solid waste infrastructure development, maintenance, and operation represent very little of the County's overall solid waste budget. Exceptions to this are the five closed, County-owned landfills and the Whatcom County MRW Facility (Disposal of Taxies Program). Approximately five percent of the solid waste budget is expended for post-closure maintenance and monitoring associated with the Cedarville, Birch Bay, Point Roberts, and Y Road Landfills (Y Road I and II). The Whatcom County MRW Facility (Disposal of Taxies Program) represents a much larger portion of the budget, at approximately 25 percent. Funding for community education and outreach programs are critical to achieving waste reduction goals. In the 2015 fiscal year, funding will be enhanced to increase composting and recycling education and education programming in schools. Additional programming will be added for commercial technical assistance programs pertaining to organics management, construction and demolition debris recycling, and single and multifamily residential recycling. The County also plays a significant role in litter control and illegal-disposal enforcement. Approximately 20 percent of the budget is allocated to enforcement programs, addressing reports of illegal disposal and contracting with the Sheriff's office for jail litter crews.

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11 LOCAL HAZARDOUS WASTE MANAGEMENT PLAN

11.1 MASTER SECTION

This section provides the framework of the County's existing hazardous waste management system, current program services associated with hazardous waste collection, public education, and technical assistance, and identifies opportunities and constraints for improving those services. This section also serves as a foundation for program goals that are presented in Section 11.2, Implementation.

11.1.1 INTRODUCTION

As an overall component of the County's solid and hazardous waste management system, this section is specific to hazardous waste management system components and is intended to demonstrate compliance with RCW 70.105, the Hazardous Waste Management Act. The format of this section follows the Ecology-recommended outline provided in Guidelines for Developing and Updating Local Hazardous Waste Plans (Ecology, 2010). The County adopted its initial hazardous waste management plan in 1991 to comply with requirements stipulated under RCW 70.105. Since then, updates to the Plan (most recently completed in 2008) have included reference to the 1991 Hazardous Waste Management Plan, with no substantial revisions to that plan completed.

11.1.2 ANALYSIS OF CURRENT CONDITIONS

This section provides information on the current quantities, types, and management of hazardous waste generated by households and businesses in the county.

11.1.2.1 Hazardous Waste Inventory

MRW is regulated as solid waste, and is defined as hazardous waste (waste chemicals) generated from households and qualified CESQG businesses. The County owns the Whatcom County Moderate Risk Waste Facility, also known as the Disposal ofToxics Program facility, located at 3505 Airport Drive in Bellingham (Figure 1-1), which accepts MRW from county households and qualifying small businesses (9:00 a.m. -4:00p.m., Monday through Friday and the first Saturday of each month). The facility is operated under contract by Stericycle Environmental Solutions. Automobile-related MRW (motor oil, antifreeze, and oil filters) are also accepted at satellite facilities (Cedarville Road transfer station [9:00 a.m. - 5:00 p.m., Saturday], Birch Bay transfer station [9:00 a.m.-5:00p.m., Sunday], and NVD Lynden transfer station [8:00a.m.- 4:00p.m., Monday through Friday, and 9:00 a.m. - 12:00 p.m., Saturday). The County collected 408,629 pounds of MRW in 2014 (105,260 pounds from CESQGs and 303,369 pounds from county residents). Figure 11-1 presents the annual MRW received over the past ten years.

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Figure 11-1 Annual Moderate Risk Waste Received

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The County served 8,63 7 customers at the l'v1RW facilities in 2014 (861 visits by CESQGs and 7, 77 6 visits by county residents), Figure 11-2 presents the annual number of users of the County's l'v1RW facilities over the past ten years, Figure 11-2 Annual Customers-Moderate Risk Waste Facilities

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Dangerous Waste Generators. Ecology's records indicate how many of the following numbers of businesses and institutions in the county were registered as hazardous waste generators as of June 2014: • 1_'.-Jineteen large-quantity generators • Eighteen medium-quantity generators • Forty-three small-quantity generators (includes only those small-quantity generators that have chosen to obtain a USEPA identification number [which is not required for CESQGs]; the actual number of CESQGs may be higher) • Twenty-four nongenerating sites and transporters that have active USEPA or state identification numbers but that did not generate waste in the most recent year, Remedial Action Sites. Ecology's list of confirmed and suspected contaminated sites in the county can be found at https: //fortress. wa.gov /ecy/tcpwebreporting/Default.aspx. The sites are listed in five categories (figures shown are current as of October 2014): 1. Brownfield Sites-ten sites. Brownfield sites are abandoned or underutilized properties where potential liability due to environmental contamination and cleanup costs complicates redevelopment. 2. Environmental Covenants Register-nine sites. This registry is a list of sites that have residual contamination after the cleanup has been completed. These sites have environmental covenants or deed restrictions limiting the types of uses on the property. 3. Leaking Underground Storage Tanks-119 (active) sites. This report contains information on underground storage tank facilities that require cleanup, as well as their cleanup history. 4. State Cleanup Sites: a. Confirmed and Contaminated Sites Report-220 records. This report contains information about sites that are undergoing cleanup and sites that are awaiting further investigation and/ or cleanup. b. No Further Action Sites-204 records. This data set contains information about sites previously on the Confirmed and Suspected Contaminated Site list (above) that have received a No Further Action decision. These sites may have deed restrictions or environmental covenants. 5. Regulated Underground Storage Tanks-136 (active) sites with 360 tanks. Washington State regulates active storage tanks on different properties, including gas stations, industries, commercial properties, and government entities. Hazardous Waste Services (Transporters and Facilities). Transporters and facilities in the county that provide transportation and disposal services are listed on Ecology's Hazardous Waste and Taxies Reduction Services Directory at http://www.ecy.wa.gov/programs/hwtr!index.htmL

11.1.2.2 Public Education

The County is dedicated to educating the public about hazardous waste issues. Educational programs are designed to increase awareness and to reduce use, misuse, improper storage and disposal, and risks to human health and the environment related to hazardous products. The County

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prionuzes specific topics, audiences, and education methods according to hazards, community needs, and outreach effectiveness, so specific campaign elements change over time. The County also strategically teams with community partners to cost-effectively reach a wider range of the public in its educational messaging. The County identifies and implements effective means of connecting hazardous materials education to related environmental, health, and resource concerns, such as restoring Puget Sound, protecting indoor air quality, protecting drinking water, preventing chronic disease, and broader community health improvement. In addition to educational materials on the County's Web site specific to hazardous material management (http://www.co.whatcom.wa.us/674/Solid-Waste-Management), the County maintains printed brochures and posters for distribution at the public's request. Tours of the MRW facility are provided to various community groups, as well as to middle-school-age students, and Stericycle Environmental Solutions and County staff are available to speak at various public meetings (e.g., small business associations, neighborhood associations, real estate professional associations).

11.1.2.3 Technical Assistance

The County is committed to assisting the public in safely storing and using hazardous chemicals, as well as appropriately disposing ofMRW. In additional to information provided on its Web site (see Section 11.1.2.2) relative to appropriate disposal options, the County, through Stericycle Environmental Solutions, maintains a telephone hotline (360-384-4640) for additional technical assistance. Assistance is typically provided in the form of over-the-phone technical advice and referrals to information available on the Internet. In cases where additional, on-site technical assistance is warranted for small businesses, County staff source control specialists are available to conduct business tours and consultations. In addition, the EnviroStars program (see Section 3.1.1) is another resource for businesses.

11.1.2.4 Service Improvement Opportunities and Constraints

In light of budgetary constraints created through significant reductions in state funding levels beginning with the 2015-2017 biennial budget, the County plans to focus its limited available funding on program maintenance, and if necessary, strategic service reductions. Partnerships with both the private sector and nonprofit organizations will be explored to an even greater level than in the past to identify potential means of cost-effective service enhancement.

11.1.3 LEGAL AUTHORITY FOR THE PROGRAM

The 1976 RCRA addresses the management of solid and hazardous waste at the federal level. RCRA exempts small-quantity generators and household hazardous waste from hazardous waste regulation at the federal level to allow greater focus on large-quantity generators of hazardous waste. At the state level, the management of solid and hazardous waste is delegated to Ecology by the USEPA through the RCRA State Authorization rulemaking process. The RCRA program is administered by Ecology through the Washington State Dangerous Waste Regulations in WAC Chapter 173-303, Solid Waste Handling Standards in WAC Chapter 173-350 (which includes moderate risk waste), and Criteria for Municipal Solid Waste in Landfills in .\lQ:AC Chapter 173-351. Relevant federal laws and regulations include the following:

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• RCRA • Universal Waste Rule • Mercury-containing and Rechargeable Battery Management legislation • Comprehensive Environmental Response, Compensation and Liability Act (CERCLA/Superfund) • Emergency Planning and Community Right-to-Know Act (which establishes the Toxics Release Inventory program) Solid and hazardous wastes are regulated in the state through multiple statutes and regulations: • Hazardous Waste Management Act (RCW 70.105) • Solid Waste Management Act (RCW 70.95) • MTCA • Pollution Prevention Planning Act • Used Oil Recycling Act Under RCW 70.105, local governments are assigned the responsibility to develop and implement plans for managing MRW. The County's Department of Health is the lead agency for implementation and enforcement of local hazardous waste regulations, which include: • WCC 24.06, Solid Waste Rules and Regulations-Standards and Permits

11.1.4 FINANCING THE PROGRAM

The County's programs to address MRW are funded primarily through: • Excise tax on solid waste hauled by certificated haulers • Ecology grants (primarily Coordinated Prevention Grant funds)

11.1.5 GOVERNANCE STRUCTURE

As presented in Section 11.1.3, local governments are delegated the responsibility by the state to prepare and carry out comprehensive management plans for small quantities of hazardous waste through adoption of the Hazardous Waste Management Act in 1985. The County, through the Health Department's Disposal of Toxics Program, is assigned the lead responsibility for operating and maintaining the hazardous waste management system. Consistent with the solid waste management governance structure, the County has adopted interlocal agreements with the cities of Bellingham, Blaine, Everson, Ferndale, Lynden, Nooksack, and Sumas for the County's management of hazardous waste (Appendix C).

11.1.6 PROGRAM PHILOSOPHY

The primary objective of the hazardous waste management program is to protect the health and safety of the public and the environment from the potential adverse effects of exposure to hazardous waste.

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11.1.7 PROGRAM SERVICES

The County provides services in the following six required elements associated with hazardous waste management: • Household hazardous waste collection • Household and public education • Small business technical assistance • Small business collection assistance • Enforcement • Used-oil collection and public education Goals associated with maintenance of existing services, as well as strategic expansion of services, as warranted, specific to each of these elements are discussed in Section 11.2.2.

11.1.7.1 Household Collection

The County currently accepts hazardous waste at its MRW facility located at 3505 Airport Drive in Bellingham (Figure 1-1 ). The facility accepts the following hazardous waste substances from county residents: • Automotive products • Cleaners • Fluorescent lamps • Good, usable latex-based paint (1 /2+ full cans) • Lawn and garden chemicals • Mercury thermometers • Oil-based paint and associated products • Solvents • Use oil and fuels Annual Collection Events. In an effort to promote appropriate disposal of MRW in underserved areas of the county, up to two collection events have been held annually at locations that are geographically removed from the MRW facilities. Because of international transport challenges, one MRW collection event is held in the Point Roberts area at least once every two years. Household Waste Pharmaceuticals Collection. Waste pharmaceuticals disposal services are provided to county residents at the MRW facility. Residents wishing to dispose of waste pharmaceuticals are encouraged to call the telephone hotline (360-676-6724) before transporting the substance(s) to the facility. MRW Re-Use Program. To reduce MRW disposal rates, reuse of appropriate materials is provided at the MRW facility. For example, latex-based paint that is received by the facility is made available to the public for reuse. This program annually reduces the amount ofMRW requiring disposal by 10 to 15 percent.

11.1.7.2 Household and Public Education

Section 11.1.2.2 provides a description of current household and public education services provided by the County specific to hazardous waste management.

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11.1.7.3 Small Business Technical Assistance

In additional to information provided on its Web site relative to appropriate disposal options (see Section 11.1.2.2), the County, through Stericycle Environmental Solutions, maintains a telephone hotline (360-676-6724) for additional technical assistance. Assistance is typically provided in the form of over-the-phone technical advice and referrals to information available on the Internet. In cases where additional, on-site technical assistance is warranted for small businesses, County staff source control specialists are available to conduct business tours and consultations. In addition, the EnviroStars program (see Section 3.1.1) is another resource for businesses.

11.1.7.4 Small Business Collection Assistance

CESQGs may dispose of hazardous wastes at the MRW facility and must pay for hazardous waste disposal in accordance with the fee structure defined in the Disposal ofToxics Program operations plan. Wastes accepted from CESQGs at the facility are consistent with those identified in Section 11. 1. 7. 1 for household collection. The County, as well as the cities of Bellingham and Ferndale, also provides pharmaceutical collection services to CESQGs through a specific program. Participating small businesses must be precertified to participate in the disposal program.

11.1.7.5 Enforcement

The County's Health Department leads enforcement of local hazardous waste regulations for CESQGs and households, and investigates approximately 250 complaints per year. When appropriate, the County coordinates with Ecology and other agencies on enforcement, inspections, and technical assistance. The three main activities of the local enforcement program are: • Complaint response and enforcement • Regulatory coordination • Site investigation

11.1.7.6 Used-Oil Education and Collection

Used motor oil is currently collected curbside by MSW collectors for appropriate disposal. As an alternative, used oil may also be delivered to the MRW facility, as well as at satellite sites (SSC Cedarville Road and Birch Bay transfer stations, and NVD Lynden transfer station). The County relies primarily on service description content on its Web site in public education specific to used-oil collection services. In addition, the County has collaborated with the to provide handling and disposal of used watercraft motor oil. Efforts have resulted in EnviroStars status through by educating the public on proper watercraft motor oil disposal through signage at port­ operated facilities.

11.1.8 PROCESS FOR UPDATING THE HAZARDOUS WASTE SECTION

With inclusion of this hazardous waste management section in the Plan, the process for completing revisions to this section specific to the hazardous waste system components is described in Section 1.8.

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11.2 IMPLEMENTATION

This section describes programs to help the County achieve the goals related to its hazardous waste management program for the 2016-2021 planning period.

11.2.1 GUIDING PRINCIPLES

The County will: 1. In priority order, promote the following hazardous waste management strategies: a. Waste prevention b. Waste reduction c. Reuse d. Recycling e. Physical, chemical, and biological treatment f. Incineration g. Solidification or stabilization h. Landfill 2. Establish program priorities, target resources, and focus efforts accordingly. 3. Ensure that program services are available to and easily accessed by all residents and businesses regardless of income levels or where they reside. 4. Use emerging information technologies to the program's advantage. At the same time, use alternative communication methods to ensure that no group or community is excluded from program information or services. 5. Be adaptive to changing conditions, such as: a. Community values b. Environmental and health indicators c. Political priorities 6. Be responsive and accountable to ratepayers. 7. Continually improve the program efficiency and effectiveness by measuring performance. 8. To minimize risks to human health and the environment, foster an ethic of responsibility among those who produce, sell, and use hazardous products. 9. Be strategic in developing partnerships that advance the program's rmss1on, including nontraditional partnerships. 10. Work "upstream" to reduce human and environmental exposure to hazardous material and products and reliance on publicly funded services. Examples include: a. Promoting greater producer responsibility b. Encouraging businesses to use existing and emerging "green" technologies 11. Encourage greater coordination of effort by government and nongovernmental organizations, businesses, and residents. 12. Facilitate interagency coordination and cooperation to:

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a. Improve regulatory oversight and enforcement b. Minimize regulator gaps c. Reduce duplication of effort

11.2.2 STRATEGIC GOALS

There are six elements specific to the County's local hazardous waste system under which future system preferred programs and alternatives are categorized. The following subsections present the County's goals specific to each element.

11.2.2.1 Household Collection

Household Collection (HC) element objective: Provide or facilitate convenient collection services for household hazardous waste and key special wastes.

HC Goal 1: Disposal Facility Operation Action Operate MRW facility and associated satellite collection facilities for residents. Time frame Ongoing, 2016-2021. Implementing Agency County (through contract with contractor such as Stericycle Environmental Solutions). Funding Source(s) Excise tax on solid waste hauled by certificated haulers. HC Goal2: Collection Event Action Host at least one annual mobile collection event for residents in underserved areas of the county. Time frame Ongoing, 2016-2021 Implementing Agency County (through contract with contractor such as Stericycle Environmental Solutions.) Funding Source(s) Excise tax on solid waste hauled by certificated haulers. HC Goal 3: Waste Pharmaceuticals Disposal Program Action Operate waste pharmaceuticals collection and disposal program. Timeframe Ongoing, 2016-2021. Implementing Agency County (through contract with contractor such as Stericycle Environmental Solutions). Funding Source(s) Excise tax on solid waste hauled by certificated haulers; Coordinated Prevention Grant (CPG) funds.

11.2.2.2 Household and Public Education

Household and Public Education (HPE) element objective: Educate and motivate residents to understand the environmental risks posed by hazardous products, reduce purchase and use of hazardous products, and properly use, store, and dispose of hazardous products.

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HPE Goall: MRW Reduction Education and Outreach Action Deliver household hazardous materials education programs designed to increase awareness and reduce use, misuse, improper storage and disposal, and risks to human health and the environment. Time frame Ongoing, 2016-2021 . Implementing Agency County. Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds. HPE Goal 2: Environmental Health Hotline Action Operate a hot line (360-380-4640) for residents to provide information about environmental health, including hazardous materials prevention, use, storage, disposal, and cleanup. Time frame Ongoing, 2016-2021. Implementing Agency County (through contract with contractor such as Stericycle Environmental Solutions). Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds.

11.2.2.3 Small Business Technical Assistance

Small Business Technical Assistance (SBT A) element objective: Educate and motivate small businesses to understand the environmental risks posed by hazardous products, reduce purchase and use of hazardous products, and properly use, store, and dispose of hazardous products. SBTA Goall: MRW Reduction Education and Outreach Action Deliver technical assistance services that result in measurable changes in waste management, compliance, and best management practice implementation. Timeframe Ongoing, 2016-2021. Implementing Agency County. Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds.

SBTA Goal2: Environmental Health Hotline Action Operate a hot line (360-380-4640) for small businesses to provide information about environmental health, including hazardous materials prevention, use, storage, disposal, and cleanup. Time frame Ongoing, 2016-2021. Implementing Agency County (through contract with contractor such as Stericycle Environmental Solutions). Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds.

11.2.2.4 Small Business Collection Assistance

Small Business Collection Assistance (SBCA) element objective: Provide or facilitate collection services to small-quantity generators for business hazardous waste and key special wastes. SBCA Go all: MRW Collection Action Accept business hazardous waste from small-quantity generators for a fee at the existing MRW facility. Time frame Ongoing, 2016-2021.

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Implementing Agency County. Funding Source(s) Excise tax on solid waste hauled by certificated haulers; disposal fees.

1 1.2.2.5 Enforcement

Enforcement (E) element objective: Provide protection of human health and the environment for all residents and workers.

E Go all: Complaint Response and Enforcement Action Respond to hazardous- and solid-waste-related complaints, and conduct enforcement activities, as warranted. Timeframe Ongoing, 2016-2021. Implementing Agency County. Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds. E Goal2: Regulatory Coordination Action Coordinate with Ecology, other agencies, and County departments involved in hazardous materials regulations that relate to prevention and proper use, storage, and disposal of hazardous materials. Time frame Ongoing, 2016-2021. Implementing Agency County. Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds.

11.2.2.6 Used-Oil Education and Collection

Used-oil education and collection (USEC) element objective: For residents and small-quantity generators, provide and facilitate collection of used oil and related automotive wastes.

USEC Goall: Used Oil Collection Sites Action Operate the MRW facility and associated satellite facilities. Time frame Ongoing, 2016-2021. Implementing Agency County (through contract with contractor such as Stericycle Environmental Solutions). Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds; disposal fees. USEC Goal2: Oil Filter and Antifreeze Collection Action Operate the MRW facility and associated satellite facilities. Time frame Ongoing, 2016-2021. Implementing Agency County (through contract with contractor such as Stericycle Environmental Solutions). Funding Source(s) Excise tax on solid waste hauled by certificated haulers; CPG funds.

11.2.3 PROGRAMS AND MIL EST ONES

All program goals presented in Section 11.2.2 are intended to be ongoing efforts during the planning horizon, with no specific milestone-associated dates.

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Anaerobic Digestion: The process by wf-Jch organic trillterial is broken down by microorgar1isms in the absence of oxygen. This process results in emission of a carbon dioxide- and methane-rich biogas that can be collected and used as an energy source. The digestate can then be landfilled or compos ted. Advantages of this process include volume reduction of landfilled organic waste, as well as decreased landfill gas production. Beyond Waste: The ultimate message behind the state Solid Waste Management Plan. Beyond Waste focuses on achieving a state where waste is viewed as inefficient and toxic substances have been eliminated. The Bryond Waste Plan lays out key initiatives to address as the state moves in the direction of Bryond Waste. Biosolids: Municipal sewage sludge that is a primarily organic, semisolid product resulting from the wastewater treatment process and that can be beneficially recycled. Commingled Recycling: A method of recovery and/ or collection where recyclable commodities are mixed together and sorted at a material recovery facility (MRF). Composting: The biological degradation and transformation of organic solid waste under controlled conditions designed to promote aerobic decomposition. Natural decay of organic solid waste under uncontrolled conditions is not composting. Construction and Demolition (C/D) Waste: Those wastes that are typically associated with the construction industry; these can include stone, concrete, brick, metal, lumber, and shingles. Designated Recyclables: Wastes separated for recycling or reuse, such as paper, metals, and plastics that are identified as recyclable material pursuant to a local comprehensive solid waste plan. Prior to the adoption of the local comprehensive solid waste plan, adopted pursuant to ~ 70.9 5.110(2), local governments may identify recyclable materials by ordinance from July 23, 1989. Disposal: The discharge, deposit, injection, dumping, leaking, or placing of any solid waste into or on any land or water. Diversion: Any method of recycling, energy production, or beneficial use that prevents disposal of material in landfills or incinerators. This definition includes all materials that are reported as recyclable. Drop Box: A "drop box" facility means a facility used for the placement of a detachable solid waste container, such as a drop box, including the area adjacent for necessary entrance and exit roads, and unloading and turnaround areas. A drop-box facility normally serves self-haulers with loose loads and receives waste from off site. A drop-box facility may also include containers for separated recyclable materials.

5 Source: Appendix A (Glossary of Terms and List of Acronyms), Guidelines for Development of Loml Comprehensive Solid Waste Management Plans and Plan Revisions, Washington State Department ofEmlogy Publimtion No. 10-07-005.

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN E-Cycle Washington: Washington's producer-funded recycling program for computers, monitors, laptops and televisions. www.ecy. wa.gov /programs /swfa /eproductrecycle /index.html Food Waste: Organic waste derived from food products. G-Certificate: A certificate of public convenience and necessity issued by the WUTC under the provisions of RCW 81.77 for the operation of solid waste collection. This certificate defines the territory and level of service required for solid waste collection in unincorporated areas of Washington State. Garbage: General unsorted household waste that goes to a landfill. Garbage may include scrap paper, food, metal, plastic, wood, glass, dirt, fabric, and other materials that are considered not recoverable because of the size of the material, presence of contamination, lack of a market, or lack of separation effort by the generator. Green Building: Design or construction practices that significantly reduce or eliminate the negative impact of buildings on the environment and occupants in the areas of site selection, and promote conservation of materials and resources, energy efficiency, water efficiency, and indoor environmental quality. Green Waste: Biodegradable waste typically consisting of garden or park waste, such as grass or flower cuttings and hedge trimmings, and contain relatively high nitrogen concentrations. Hazardous Substance: Any liquid, solid, gas, or sludge, including any material, substance, product, commodity or waste, regardless of quantity, that exhibits any of the characteristics or criteria of hazardous waste as described in rules adopted under RCW 70.105. Hazardous Waste: All dangerous and extremely hazardous waste, including substances composed of both radioactive and hazardous components. Household Hazardous Waste (HHW): Those substances identified by Ecology as hazardous household substances in the guidelines developed under RCW 70.105.220 (Local Hazardous Waste Management Program Guidelines). HHW is any waste that exhibits the properties of dangerous wastes but is exempt from the Dangerous Waste Regulations solely because it is generated by households. Hog Fuel: Wood chips ranging in size between 2 and 5 inches that are used as a fuel source in a combustion process, such as firing a boiler. Incineration: Reducing the volume of solid wastes by use of an enclosed device using controlled flame combustion. Industrial Waste: Industrial waste includes by-products from manufacturing operations, food processing, and other industrial processes, such as scraps, trimmings, packaging, boiler ash, wood­ product residuals, and other discarded materials not otherwise designated as a dangerous waste under WAC Chapter 173-303. Interlocal Agreement: An interlocal agreement is a formal agreement between any two or more public agencies to work cooperatively. In the world of solid waste planning, this usually refers to an agreement where the county and participating cities enter into an interlocal agreement to designate the county as the solid waste planning authority. Landfill: A disposal facility or part of a facility at which solid waste is permanently placed in or on land, including facilities that use solid waste as a component of fill. Material Recovery Facility (MRF): Any facility that collects, compacts, repackages, sorts, or processes for transport source-separated solid waste for recycling.

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN Model Toxics Control Act (MTCA): MTCA is the legislation that created the taxies accounts that now fund a significant portion of solid waste management at the state and local levels. More detail on the act can be found in RCW 70.1 OSD. Moderate-Risk Wastes (MRW): MRW are composed of chemical materials that are poisonous, toxic, flammable, reactive, or corrosive. These products include but are not limited to pesticides, herbicides, mercury and mercwy thermometers, some types of batteries, gasoline, kerosene, motor oil, antifreeze, oil-based paint, paint thinner, turpentine, pool chemicals, and drain cleaners. MRW are divided into two categories: household hazardous waste and small-quantity generator hazardous waste. Municipal Solid Waste (MSW): A subset of solid waste that includes unsegregated garbage, refuse and similar solid waste material discarded from residential, commercial, institutional, and industrial sources and community activities, including residue left after recyclables have been separated. Organics (organic materials): Substances and products of biological origin that have the potential to be returned to the soil or turned into biofuels, bioenergy, or other products. Organic materials include landscaping and yard waste, food waste, manures, crop residues, wood, soiled/low-grade paper, and biosolids. Per capita waste generation: The average amount of waste generated by a single person in a year. The per capita waste generation rate is calculated by dividing the total waste generation in an area by the total population of that area. Planning Area: The geographical boundaries in which a solid waste plan will be implemented. Recovery: Material removed from the waste stream for the purpose of recycling and/ or composting. Recyclable Materials: Solid wastes that are separated for recycling or reuse, including, but not limited to, papers, metals, and glass that are identified as recyclable material pursuant to a local comprehensive solid waste plan. Recycling: Transforming or remanufacturing waste materials into usable or marketable materials for use other than landfill disposal or incineration. Recycling does not include collection, compacting, repackaging, and sorting for the purpose of transport. Resolution of Adoption: In solid waste planning, a resolution passed by the local executive or legislative authority to adopt the local solid waste management plan. A combination of an interlocal agreement and a resolution of adoption is generally required for all participating jurisdictions in order for a solid waste management plan to be approved by Ecology. Revised Code of Washington (RCW): A compilation of all Washington State laws now in force, created and modified through bills passed by the Legislature. Solid Waste Advisory Committee (SWAC): An advisory committee established at the local level in each planning jurisdiction. The local SWAC should assist in development of programs and policies concerning solid waste handling and disposal and should review and comment on proposed rules, policies, or ordinances prior to their adoption. Solid Waste: All putrescible and nonputrescible solid and semisolid wastes, including, but not limited to, garbage, rubbish, ashes, industrial wastes, swill, sewage sludge, C/D wastes, abandoned vehicles or parts thereof, contaminated soils and contaminated dredged material, and recyclable materials.

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN Source Separation: The separation of different kinds of solid waste at the place where the waste originates. State Environmental Policy Act (SEPA): A way to identify possible environmental impacts that may result from governmental decisions. These decisions may be related to issuing permits for private projects; constructing public facilities; or adopting regulations, policies, or plans. Transfer Station: A facility where wastes are transferred from smaller vehicles (cars, pickup trucks, contractor trucks, and collection vehicles) into larger transport trailers prior to transport to the landfill for disposal. Toxics or Toxic Substances: A general term that refers to hazardous substances and hazardous wastes that have properties that may cause or significantly contribute to death, injury, or illness of humans, animals, or other living things. USEPA: The U.S. Environmental Protection Agency is a federal agency that leads the nation's environmental science, research, education, and assessment efforts. Created in 1970, the USEPA's mission is to protect human health and the environment. Vactor Waste: A common term used to describe street waste. "Vactor" is a brand name for a vacuum truck that is capable of picking up many types of waste. Currently, a wide variety of wastes are collected by Vactor trucks and treated as street wastes. However, not all wastes picked up by Vactor truck qualify as street waste. Washington Administrative Code (WAC): Regulations of executive branch agencies are issued by authority of statutes. Like legislation and the Constitution, regulations are a source of primary law in Washington State. Waste Characterization: The composition and ratio of materials in the total waste stream. Also sometimes referred to as a "waste audit." Waste Reduction: Also sometimes referred to as "waste prevention" or "precycling." Waste reduction is the practice of minimizing waste through responsible purchasing and consumerism It is, essentially, removing waste from the waste stream by not creating it in the first place. Waste reduction is typically achieved through better product or packaging design, by improved efficiency of use by the end user, and/ or by process management. Woodwaste: Solid waste consisting of wood pieces or particles generated as a by-product or waste from the manufacturing of wood products, construction, demolition, and handling and storage of raw materials. This includes, but is not limited to, sawdust, chips, shavings, bark, pulp, hogged fuel, and log sort yard waste, but does not include wood pieces or particles containing paint, laminates, bonding agents, or chemical preservatives such as creosote, pentachlorophenol or copper-chrome­ arsenate. Yard Waste/Debris: Plant material commonly created in the course of maintaining yards and gardens and through horticulture, gardening, landscaping, or similar activities. Yard debris includes, but is not limited to, grass clippings, leaves, branches, brush, weeds, flowers, roots, windfall fruit, and vegetable garden debris.

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN REFERENCES

BERK. 2013. Whatcom County population and employment projections and urban growth area allocations. Phase I technical report. November 1. Ecology. 2010. Guidelines for development of local comprehensive solid waste management plans and plan revisions. Publication No. 10-07-005. Washington State Department of Ecology. February. Ecology. 2013. Waste 2 Resources Program. Solid waste in Washington State, 22nd annual status report. Publication No. 13-07-070. Washington State Department of Ecology. https://fortress.wa.gov/ecy/publications/publications/1307070.pdf. December. Ecology. 2015. State solid and hazardous waste plan, moving Washington beyond waste and toxics. June 2Q.l2.. OFM. 2012. County growth management population projections by age and sex, 2010-2040. Washington State Office of Financial Management. August. OFM. 2014. April1, 2015 population of cities, towns, and counties used for allocation of selected state revenues. Washington State Office of Financial Management. April. http://www.ofm.wa.gov/pop/april1/ofin april1 population final.pdf U.S. Census Bureau. 2013. American community survey 5-year estimates, 2009-2013. http: //factfinder.census.gov /faces /nav /j sf/pages /searchresults.xhtml?refresh=t. Whatcom County. 1991. Hazardous waste management plan. May. Whatcom County. 1999. Comprehensive solid waste management plan. November. Whatcom County. 2008. Comprehensive solid waste management plan. Whatcom County. 2013. Whatcom County comprehensive plan. February. WSRA and Washington Multifamily Recycling Study Group. 2014. Sorting it out: the state of multifamily recycling in Washington State. July 3.

WHATCOM COUNTY COMPREHENSIVE SOLID AND HAZARDOUS WASTE MANAGEMENT PLAN APPENDIX A WHATCOM COUNTY SOLID WASTE HANDLING FACILITIES Whatcom County Solid Waste Handing Facilities Whatcom County

Facility I Materials Type I Materials Accepted* I Permitted I Reuse I Recycling J Organics I Waste J I Reuse Drop-off Locations Appliance Depot small and large household appliances made of metal "' household items and appliances, clothing, furniture, functioning ARC of Washington State electronics Goodwill Bellingham "' clothing, household items, electronics Habitat for Humanity "' building materials, furniture, appliances Northwest Center's Big Blue Truck )in-home pick up) "' small appliances, household items, small furniture, electronics TheRE Store "' building materials Salvation Army Bellingham Corps Community Center "' clothing, household items, electronics, furniture Salvation Army Family Store "' clothing, household items, electronics, furniture Value Village Bellingham "' clothing, household items, electronics -- "' ...... -----

R:\0744.02 Whatcom County\Report\01_2016.06.14 Solid & Hazardous Waste Management Plan\Appendix A_Facilities Chort\Appendix A_WC SW Handling Facilities.xlsx\Facility Chart for Report Doc Page 1 of 2 Whatcom County Solid Waste Handing Facilities Whatcom County

Facility I Materials Type J Materials Accepted* Permitted Reuse I Recycling I Organics Waste I Recycling Drop-off Locations Alrite Recycling Center ., scrap metal, electronics, batteries, electric motors, appliances Beacon Battery & Tires (21ocohons) ., batteries, tires of a II size Granite Construction Company (21ocatians) ., rubber, asphalt, concrete Henifin Construction ., concrete, rebar, asphalt ., Lynden Christian School Recycling Center ., cardboard, mixed paper, aluminum Northwest Recycling & Northwest Recycling scrap metal, appliances, paper, cardboard, automotive bodies, electric Warehouse (21ocationsJ ., motors, radiators, car batteries, plastics Safe and Easy Recycling (2 locations) ., electronics ., Scrap-It Recycling ., scrap metal, obsolete equipment Whatcom Builders ., asphalt Z Recyclers ., scrap metal Drop Box Facilities (recycling, waste, organics) scrap metal. antifreeze, oil, yard waste, cardboard, glass, paper, plastic, NVD Drop Box Facility ., ., ., cans, tires, electrorlics, yard waste ., SSC Birch Bay- Lynden Drop Box Facility ., ., scrap metal, antifreeze, oil, cardboard, glass, paper, plastic, cans ., SSC Cedarville Drop Box Facility ., ., scrap metal. antifreeze, oil, cardboard, glass, paper, plastic, cans .,

SSC Roeder Ave Drop Box Facility ., ., ., scrap metal, building materials, plsatics, plastic film, paper, yard waste ., Organics Drop-off Locations Green Earth Technology I I I ., lyard waste and food scraps ., Transfer Stations (with public drop-off) Cando Recycling Transfer Station ., ., yard waste ., RDC Transfer Station ., ., scrap metal, batteries ., RDS Transfer Station ., ., ., scrap metal, batteries, electronics, yard waste, food scraps ., Hazardous Waste Facility azarous neuse 010 was e, me uatng mo or au, an 1 reeze, coo mg otiS, Disposal of Toxics ., ., and other chemicals ., Vactor Waste Facility City of Bellingham Vactor Waste Facility- not open to the public ., vactor waste only, not open to public ., ' Contact the facility for a full list of materials accepted

R:\0744.02 Whatcom County\Report\01_2016.06.14 Solid & Hazardous Waste Management Plan\Appendix A_facilities Chart\Appendix A_WC SW Handling Facilifies.xlsx\Facility Chart for Report Doc Page 2 of 2 APPENDIX B

COMPLIANCE CHECKLIST Plan Requirements Plan Location 1) A detailed inventory and description of all existing solid-waste- Sections 3.1- Waste Reduction and Public handling facilities, including an inventory of any deficiencies in Education, Existing Conditions meeting current solid-waste-handling needs. Section 3.2- Waste Reduction and Public Education, Needs and Opportunities Section 4.1 -Recycling, Existing Conditions Section 4.2- Recycling, Needs and Opportunities Section 5.1 -Organic Material Management, Existing Conditions SeCtion 5.2- Organic Material Management, Needs and Opportunities Section 7.1 -Transfer and Disposal, Existing Conditions Section 7.2- Transfer and Disposal, Needs and · Opportunities 2) The estimated long-range needs for solid-waste-handling facilities Section 2.3.8- Planning Area, Quantity and projected 20 years into the future. ·Characterization of Solid Waste, Waste Projections Section 3.2- Waste Reduction and Public Education, Needs and Opportunities Section 4.2 -Recycling, Needs and Opportunities Section 5.2- Organic Material Management, Needs and Opportunities Section 6.2 -Solid Waste Collection, Needs and Opportunities Section 7.2- Transfer and Disposal, Needs and Opportunities Section 8.2- Special Waste, Needs and Opportunities 3) A program for the orderly development of solid-waste-handling The county solid waste facilities are privately facilities in a manner consistent with the plans for the entire county, owned and operated, and will be permitted which shall: on an as-needed basis. This is addressed (a) Meet the minimum functional standards for solid-waste throughout the entirety of the Plan. handling adopted by the department and all laws and regulations relating to air and water pollution, fire prevention, flood control, and protection of public health; (b) Take into account the comprehensive land use plan of each jurisdiction; (c) Contain a six-year construction and capital acquisition program for solid-waste-handling facilities; and (d) Contain a plan for financing both capital costs and operational expenditures of the proposed solid-waste management system. 4) A program for surveillance and control. Section 9 .1.5- Administration and Enforcement, Existing Conditions, Enforcemen and Compliance 5) A current inventory and description of solid-waste collection needs Section 6.1 -Solid Waste and operations within each respective jurisdiction, which shall Collection, Existing Conditions include: Section 6.2- Solid Waste Collection, (a) Any franchise for solid-waste collection granted by the Needs and Opportunities WUTC in the respective jurisdictions, including the name of the holder of the franchise and the address of his or her place of business and the area covered by the franchise; (b) Any city solid-waste operation within the county and the boundaries of such operation; (c) The population density of each area serviced by a city operation or by a franchised operation within the respective jurisdictions; (d) The projected solid-waste collection needs for the respective jurisdictions for the next six years. 6) A comprehensive waste-reduction and recycling element that, in Section 3- Waste Reduction and Public accordance with the priorities (listed in next cell) established in Education Revised Code of Washington (RCW) 70.95.010, provides programs Section 4- Recycling that (a) reduce the amount of waste generated, (b) provide incentives and mechanisms for source separation, and (c) establish recycling opportunities for the source-separated waste. Plan Requirements Plan Location 7) The waste-reduction and recycling element shall include the following: Section 3- Waste Reduction and Public Education {a) Waste-reduction strategies; Section 4- Recycling

(b) Source-separation strategies, including: {i) Programs for the collection of source-separated materials from residences in urban and rural areas. In urban areas, these programs shall include collection of source-separated recyclable materials from single and multiple family residences, unless the department approves an alternative program, according to the criteria in the planning guidelines. Such criteria shall include: Anticipated recovery rates and levels of public participation, availability of environmentally sound disposal capacity, access to markets for recyclable materials, unreasonable cost impacts on the ratepayer over the six-year planning period, utilization of environmentally sound waste-reduction and recycling technologies, and other factors as appropriate. In rural areas, these programs shall include but not be limited to drop-off boxes, buy-back centers, or a combination of both, at each solid-waste transfer, processing, or disposal site, or at locations convenient to the residents of the county. The drop-off boxes and buy-back centers may be owned or operated by public, nonprofit, or private persons; {ii) Programs to monitor the collection of source-separated waste at nonresidential sites where there is sufficient density to sustain a program; {iii) Programs to collect yard waste, if the county or city submitting the plan finds that there are adequate markets or capacity for composted yard waste within or near the service area to consume the majority of the material collected; and {iv) Programs to educate and promote the concepts of waste reduction and recycling; {c) Recycling strategies, including a description of markets for recyclables, a review of waste-generation trends, a description of waste composition, a discussion and description of existing programs and any additional programs needed to assist public and private sector recycling, and an implementation schedule for the designation of specific materials to be collected for recycling, and for the provision of recycling collection services. {d) Other information the county or city submitting the plan None determines is necessary. 8) An assessment of the plan's impact on the costs of solid waste WUTC Cost Assessment collection. The assessment shall be prepared in conformance with Questionnaire guidelines established by the WUTC. The commission shall cooperate with the Washington State association of counties and the association of Washington cities in establishing such guidelines. 9) A review of potential areas that meet the criteria as outlined in RCW This information will be prepared 70.95.165. {Disposal Facility Siting) during the facility site selection process when a new facility is sited. Existing facilities are permitted and therefore meet the criteria of RCW 70.95.165. APPENDIX C

RESOLUTIONOF ADOPTION AND INTERLOCAL AGREEMENTS The adopting resolution to be included following approval if the Comprehensive Solid and Hazardous Waste Management Plan i!y Whatcom Counry Council. WHATCON, COUNTY~~:~ C,t :v 1- .... CONTRACT NO. ;s .... ,. , U q; /OrJo I 'd1' .. 21199;

;:)).- This agreement is executed by and betweeh what~om County

("County") and the city of i)v.,rnQ...... ';2 _ ("City") (hereinafter jointly referred to as "the parties") for the purposes of establishing an integrated and coordinated Solid waste management program for Whatcom County; fulfilling the City's and county's obligations under Chapter 70.95 RCW, and other state and federal laws and regulations governing solid waste managementi and contributing to the health and Safety of all lvhatc:om _County residents. The parties make and enter into this First Amended Inter local Agreement ("Agreement") effecL.ive as amended the /5r- day of @dz;/IJ!u 1991 for the purposes and under the terms contained herein. This Agreement supersedes .. _the Interlocal

Agreement between the parties bearing an effective date of July 25 1

1989, and the Addendum of Clarificq,tion and Second AddenqtJ.lh of

Clarification thereto.

Definitions

For the purposes of this Agreement and any related agreements, contracts, and documents executed, adopted, or approved .pursuant to this Agreement, the parties shall use the definitions found in

1 Ed. June 27, 1991

--:" ---=., ---::~ ~---~~-.~· :-1le t·4o: 921--31:311--:::124 ''

RCW 70.95.030; 70.138.020, and WAC 173-304-100, unless the context indicates otherwise.

Recitals

WHEREAS, the parties recognize the need and obligation to meet f.ederal and state mandates for solid waste planning and management; and

WHEREAS, the parties believe that the comprehehsive solid waste management plan ("Plan") can best be accompl.i;shed under the leadership of Whatcom County in cooperation with the Cityi and

WHEREAS, the City agrees that to implement the County's Plan the County must control the flow and disposal of all solid wastes originating within the City; anci

WHEREAS, programs of solid waste reduction and recycling can be most effective when carried out pursuant to a coordinated Plan; and

WHEREAS, the County must have adequate fmiding to support its solid waste management activities and meet its financial

2 Ed •. June 27, 1991

\/ol ~ ~2=~~::::; P-::t9e: 27 File No: 9 2 0 1 :::::;: 1 i-3 2 4 ''

obligations for solid waste planning and management as required by

law; and

WHEREAS, the parties are atJ.thorized and empowered to enter

into this Agreement pursuant to Chapter 39.34 RCW.

THEREFORE, in consideration of mutual promises and covenants herein, it is hereby agreed:

1. Authoritv and Resnonsibilit.ies cf the County: The City hereby delegates and grants to the County the following authorities and obligations to be exercised and assumed by the County on behalf of the City with only such limits as are herein specifically enumerated or provided by law. The County shall:

.A. Prepare and submit for approval on behalf o:t; the

City and County a comprehensive solid waste management plan as provided in RCW 70.95. 080 and related provisions of law. Such plan as finally prepared, amended, or modified shall, following referral to the Executive committee as provided in Section 7 of this

Agreement, be binding upon the City in its solid waste man9,gementi

3 Ed. June 27, 1991

~~~~~~~~M~, ~--=~~ M~::~ ~·. 1 ;-- 1 .~. e No; 9~20 l ::=: 11-::::i24 B. Include within the Plan the official position of the County and signatory cities on the disposal of special

incinerator ash in the County. The County Executive shall be the

sole spokesman of participating local governments for th.e purpose of commenting to the Department of Ecology on ash management plans prepared pursuant to RCW 70.138.030(1), and disposal permit applications prepared pursuant to RCW 70.138.030(4). Notwithstanding the foregoing, the County recognizes that final determination of special incinerator ash disposal resides within

the jurisdiction of the Department of Ecology;

c. Implement, in cooperation with the City, waste reduction and recycling programs within such city, as well as in unincorporated areas, all as enumerated in the Plan. Where appropriate and agreed, the County may provide funding to the City

to implement such waste reduction and recycling program;

D. Include the City in a solid waste disposal district if such district is formed under the provisions of RCW 36.58.100 - . 150. Any excise tax levied under the provisions of. RCW 36.58

~--shall be a uniform percentage for all parti~s within th_e Distric-t;:. In the event that no such tax is imposed, the county may instead

impose a fee upon disposal of waste from incorporated and

4 Ed. June 27, 1991

Fi ie No: 9201:31024 unincorporated areas through agreements with owners or operators of disposal facilities. The city is permitted to use County-:- approved disposal sites which have negotiated an agreement with the

County. Said agreement may provide for a surcharge to be collected and paid to the County;

E. Acquire, construct, and operate within the corporate limits of the City, where provided for in Plan implementation, solid waste facilities including, but not limited to, transfer stations and recycling facilities, subject, however, to City zoning, building codes, and related land use ordinances.

2. Responsibilities of the city: The City hereby agrees:

A. That its cooperation with the County shall include, where appropriate, provisions in its franchise agreements with. waste haulers to implement curbside recycling or other . waste reduction and recycling programs of the adopted Plan;

B. To provide for mandatory solid waste collection within such city during the term of the Agreementi

c. Pursuant to the County flow control ordinance, the city agrees that commencing upon the effective date of such

5 Ed. June 27, 1991

~-:~~ --=c --::~: Vol: ~--..r:: ..,_ .. File No: 9201 :::=: 1 (:i24 ordinance, all solid waste generated within the City sha.ll be

processed or disposed of only as provided in such ordinance;

0, That, subject to law, the city grants to the County

exclusive and complete jurisdiction over any solid waste

originating outside of the County and imported into the City for disposal, or originating in the City and exported for disposal outside the County. such jurisdiction is granted commencing upon the effective date of such ordinance. Any such import or export of solid waste shall only be on terms and conditions approved by the County; and

E. To cooperate in implementing Plan elements, particularly those related to solid waste reduction and recycling.

3. Financing: The County shall finance the programs provided for in the Plan by a combination of "tipping" fees, · transfer station charges, taxes authorized by law (including

RCW 36.58.140), and such other revenues, fees imposed pursuant to flow control ordinance, and charges as the County Council may authorize from time to time to fund its solid wast_e utility. If any excise tax as authorized by RCW 36. 58 .. 140 or fee as authorized_ by flow control ordinance is levied, it shall be calculated and utilized to pay costs related to:

6 Ed. June 27, 1991

~~/o 1. : 2:~::~: P.:J9e: ::=! 1 File No: 9~20 1 ~31 t-324 ~-:~ ---:=-.: ~-=~ '·/o l ~ ~--D'--"

A. construction, operation, maintenance and closure of

any landfill that may be developed in the future;

B. Funding of approved wq.ste reduction and recycling

programs when recommended by the · Executive Conuni ttee or. when

adopted to implement the approved Comprehensive Solid Waste

Management Plan;

c. Funding of moderate risk waste programs when

:::-eco:mmended by the E:cecuti ve Coir.mi -::-cee or \·lhen adopted to implement the approved Hazardous Waste Management Plan;

D. Public educational programs related to the management of solid waste;

E. Construction, maintenan.ce and operation of transfer stations;

F. Landfill closure and post closure improvements when recommended by the Exeoutive CQmmittee;

G. Administration and overhead expenses;

7 Ed. June 27, 1991 ~-:f: ·::~: ~-:a C-.--::~_c:

H. Such other programs as the Executive Committee may

recommend pursuant to the approved Solid Waste Management Plan.

4. county Flow Control: The County shall control by county flow control ordinance all solid waste originating within the

unincorporated areas of the courity.

5. Universal Garbage Collection: The County shall establish universal garbage collection in unincorporated areas of Whatcom County if a solid waste disposal district is formed under the

provisions of RCW 36.58.100-.150 which includes the City.

6. Termination of Aareement: The City or County may

terminate this Agreement after June 1, 1991 by giving written notice no less than six ( 6) months prior to the last day of the County's budget year. Under current state law the last day of the County's budget year is December 31. The parties agree: (1) that.

termination will not absolve them of responsibility for ~~~ting financial and other obligations outst.anding at the time of __ termination and through the current County budget year; and

------(2) that prior -to te-rmination, a withdrawing city will prepare and

receive Ecology approval of its own solid waste management plan.

8 Ed. Auqust 2, ~991 ;,lol: 2:::;::;:: P.~ge; ::=:4 File No: :9201 :::::1024

7. Formation of Executive Committee; The parties agree to

form an Executive committee to consider various matters in ,the management of the Plan that require the cooperation and joint action of each signatory to an interlocal agreement. The members of the Executive Committee shall be the County Executive and the mayor or mayor's representative from each city executing an interlocal agreement. The Executive Committee shall:

A. Meet at least annually, and more oft2n as necessary, at the call of the County Executive or a majority of the mayors;

B. Approve the Plan or revisions or amendments thereto by majority vote for submission to the County Council; provided, that any member may file a minority report with the County <::ouncil or the Department of Ecology; provided further, that if a majority of members cannot agree on a plan revision or update, the county

Executive may submit the Plan with the alternatives or objections of the mayors noted on the record;

Consid.e.r the dirE?cct implE;;ffi§J1t<:!tion st:rateg;Les for the Plan, including funding allocations as may be recommended to the County Council;

9 Ed. June 27, 1991 D. Revietv and recommend annually to the county Council

whether there should be any revision to either (i) the tax rate

assessed by the Solid Waste Disposal District, it being specifically agreed that the tax rate shall not exceed ten percent

(10%) of any collection charge or (ii) the fee established pursuant

to the flow control ordinance, it being specifically agreed that

the rate shall not exceed nine dollars ($9.00) per ton of mixed solid waste disposed of or ten percent (10%) of the basic fee for disposal of demolition and construction waste.

E. Prior to October 1 of each year, review and approve

each program item in that portion of the County Executive's

proposed solid waste budget which will be financed by revenues from either method referenced in section 7(0) of this Agreement. The program items so approved shall be contained in the budget which

the County Executive recommends to the county Council. In the

event that the County Council adopts a budget in excess of the

recommended amount for any such approved program items, the Council

and the Executive Committee shall submit to binding arbitration to

·---determine· t·he amounts -t-ha-t -sllall be financed sy revenues .from either method referenced in section 7(0) of this Agreement. The arbitration shall be conducted by a panel of three arbitrators, one

10 Ed. June 27, 1991 selected by the County Council, one selected by the Executive

Committee, and the third selected by the other two. At the direction of the Executive Committee, the County shall remit any revenues in excess of the amount required to fund the approved portion of the County's solid waste budget, including any reserve accounts, to the cities to finance city solid waste programs. In

any remittance, priority shall be given to city p~ograms that provide County-wide benefits.

F. Review and approve any proposed revisions or

amendments to the county 1 s flow control ordinance. The County Executive sha,ll propose to the County Council only those revisions or amendments that the Executive Committee has approved.

The County Council will issue a letter of intent to each city

executing an inter.iocal agreement indicating its willingness to negotiate in good faith issues brought to the Council by the

Executive Committee and to give good faith consideration/weight to

the Executive Committee's recommendations.

8. Asse:ts ...and __ .... LLahi_liJ;ies: On terrninati9n of this ·Agreement, any assets owned separately by a party shall remain the

property of that party. In entering into this Agreement, neither

il Ed. June 27, 1991

M-:~ ~-::1' ~-::· ==-~-"--' File No: 9:::;:-~o 1:::::1024 party assumes liability for the actions or activities of the other,

except as provided by law or as may be agreed by the parties from

time to time.

9. Implementing Agreements: The parties agree that routine

operating agreements may be required from time to time to

accomplish the purpose of this Agreement and the Plan. Any such operating agreement or understanding executed to implement this Agreement or the Plan which is signed by the county Executive and the Mayor shall be presumed to be binding on the parties unless

WHATCOM.COUNTY

SHIRLEfVAiiANTEN./lirh L~ ~ county Executive

Randall J. Watts, ~Civil Deputy Prosecuting Attorney

ATTEST:

12 Ed. June 27, 1991

il/o 1 = ;;:.: :::=; ==: P-:3 9e : :~; 7 File No: 9;;::1-:::::t 1 ::;::; 1024 ). 1J-UJc~~ \ AT~OM COUNTY CONTRACT NO. Cf II d-O <.f 3

FIRST AMENDED INTERLOCAL AGREEMENT

This agreement is executed by and between Whatcom County ("County") and the City of Beliingham ("City") (hereinafter jointly referred to as "the parties") for the purposes of establishing c:;.n integrated and coordinated solid waste management program for Whatcom County; fulfilling the city's and County's obligations under Chapter 70.95 RCW, and other state and federal ·laws and regulations governing solid waste management; and contributing to · the health and safety of all Whatcom County residents. The parties make and enter into this First Amended Interlocal Agreement

11 ( Agreement") effective as amended the '3 o "t1l day of r>s~. 1991 for the purposes and under the terms contained herein. This Agreement supersedes the Interlocal Agreement between the parties bearing an effective date of July 25, 1989, and the Addendum of Clarif.ication and Second Addendum of Clarification thereto.

Definitions

For the purposes of this Agreement and any related agreements, contracts, and documents executed, adopted, or approved pursuant to this Agreement, the parties shall use the definitions found in RCW 70.95.030; 70.138.020, and WAC 173-304-100, unless the context indicates otherwise.

Recitals

WHEREAS, the parties recognize the need and obligation to meet federal and state mandates for solid waste planning and management; and

FIRST AMENDED INTERLOCAL AGREEMENT- PAGEl 9. Impleme.nting Agreements: The part'ies agree that routine operating agreements may be required from time to time to accomplish the purpose of this Agreement and the Plan. Any such operating agreement or understanding executed to implement this Agreement or the Plan which is signed by the County Executive and the Mayor shall be presumed to be bind,ing on the parties unless contrary to law. a IN WITNESS HEREOF 1 ·this Agreement is executed this :36 day of

:5) e..c 1 1991.

Subscribed and swo~. ~o me this~y of ~tW. 199L ~... ) i~ /A-/:-·, residing SHIRLEY VAN Z TEN ~ County Executive {_

AS TO FORM:

a. s 1 Chief Civil cuting Attorney CITY OF BELLINGHAM ATTEST: ~Q () By__ ~~~--~~~~~·~~------Tim Dougl~yor

FIRST AMENDED INTERLOCAL AGREEMENT - PAGE 8 \2- .. ,, ',:..,.. "11.

WHA"f CQt·A COUt~TY CO~·~TRACT NO. Cj ra Gf a a.,:;;;_:__ ~"':'r.-1!<····

FIRST AMENDED INTERLOCAL AGREEMENT

This agreement is executed by and between Whatcom County

("County") and the City of ~ ("City") (hereinafter

11 11 jointly referred to as the parties ) for the purposes of

establishing an integrated and coordinated solid waste•management

program for W.hatcom County; fulfilling the City's and Count;.y•_s

obligations under Chapter 70.95 RCW, and other state and federal

laws and regulations governing solid waste management; and

contributing to the health and safety of all Whatcom County

residents. The parties make and enter into this First Amended

Inter local Agreement ("Agreement") effective as amended the 3M_ day of 4r0. , 1991 for the purposes and under the terms contained herein. This Agreement supersedes the Interlocal

Agreement between the parties bearing an effective date of July 25,

1989, and the Addendum of Clarification and Second Addendum of

Clarification thereto.

Definitions

For the purposes of this Agreement and any related agreements,

contracts, and documents executed, adopted, or approved pursuant

to this Agreement, the parties shall use the definitions found in

1 Ed. June 27, 1991

2::=~2 Page: 19~:::4 No:. 9 2 0 1 :3 1 1-3 1' :3 party assumes liability for the actions or activities of the other,

except as provided by law or as may be agreed by the parties from

time to time.

9. Implementing Agreements: The parties agree that ro).ltine

operating agreements may be required from time to time to

accomplish the purpose of this Agreement and the Plan. Any such.

operating agreement or understanding executed to implement this

Agreement or the Plan which is signed by the county Executive and

the Mayor shall be presumed to be binding on the parties unless

contrary to law. ,;._/_ IN WITNESS HEREOF, this Agreement is executed this J-----a·ay of •.. WHATCOM COUN.TY 9; . M. ,t/~,/ &i." d f; SHIRLEYVAirANTEN ~ rlj County Executive

tts, Chief civil uting Attorney

ATTEST:

12 Ed. June 27, 1991

'·/ol: :::.::~~2 Pase ~ 19S:a5 Fi l e No : 9 0 1 :::::; 1 0 1 :::;: \'2-

'vV .. /\fC(),,,, COUNTY COl'ffRt\CT NO. __'7 1a cro ;;zo

FIRST AMENDED INTERLOCAL AGREEMENT

This agreement is executed by and between Whatcom County

11 ( "County ) and the City of Everson ( "Ci ty•i) (hereinafter jointly referred to as "the parties") for the purposes of establishing an integrated and coordinated solid waste management program for Whatcom County; fulfillil).g the city's and County~s· obligations under chapter 70.95 RCW, and other state and federal laws and regulations governing solid waste managem~nt; and contributing to the health and safety of all Whatcom County residents. 'fhe parties make and enter into this First Amended

Interlocal Agreement ("Agreement") effective as amended the ~ day of ;)f~ 1991 for the purposes and under the terms contained herein. This Agreement supersedes the Interlocal

Agreement between the parties bearing an effective date of J_uly 25 1 1989, and the Addendum· of Clarification and Second Addendum of

Clarification thereto.

Definitions

For the purposes of this Agreement and any related agreements, contracts, and document:s executed, adopted, or approved pursuant to this Agreement, the parties shall use the definitions found in

. I

1 Ed. June 27, 1991 *·lol ;. 2:::::2 File No: 9201:3.., i I ,/' . ' ' i-. ~;I\• :· / >

party assumes liability for the actions or activities of the other,

except as provided by law or as may be agreed by the parties from

time to time.

9. Implementing Agreements: The parties agree that routine operating agreements may be required from time to time to

accomplish the purpose of this Agre~ment and the Plan. Any such

operating agreement or understanding executed to implement this Agreement or the Plan which is signed by the County Executive and the Mayor shall be presumed to be binding on the parties· unless contrary to law.

WHATCOM COUNTY

~ v~,/ &L91,! SHIRLEYVA:Nz:NTEN ~ · /9/. County Executlve .

tts, Chief CivJ.l uting Attorney

ATTEST: '~1}~~4W1)0essl cfJJ J:\et\25552-89.001\2fa.21v

12 Ed. June 27, 1991 ,, l' .-..-- p \' o II -==- ...=:::::: 'a se: 1 9 :=:1-:=t .F i 1e No: 9 2 0 1 :31 0 :l i Wh'ATCOM COUNTY ' CONTRACT NO. 1/09023

.. FIRST AMENDED INTERLOCAL AGREEMENT

This agreement is executed by and between Whatcom County

11 ("County") and the City of T;:;t.A//l/ft!£ ( City") (hereinafter

11 jointly referred to as "the parties ) for the purposes of establishing an integrated and coordinated solid waste management program for Whatcom County; fulfilling the City's and County's obligations under Chapter 70.95 RCW, and other state and federal laws and regulations governing solid waste management; and contributing to the health and safety of all Wha tcom County residents. The parties make and enter into this First Amended Interlocal Agreement ("Agreement") effective as amended the / 7 day of 5JSeT , 1991 for the purposes and under the terms contained herein. This Agreement supersedes the Interlocal Agreement between the parties bearing an effective date of July 25,

1989, and the Addendum of Clarification and Second Addendum of

Clarification thereto.

Definitions

For the purposes of this Agreement and any related agreements, contracts, and documents executed, adopted, or approved pursuant to this Agreement, the parties shall use the definitions found in

1 Ed. June 27, 1991

\iol : 2::=:2 Pa9e: 1577 File party assumes liability for the actions or activities of the other,

except.as provided by law or as may be agreed by the parties from

time to time.

9. Implementing Agreements: The parties agree that routine

operating agreements may be ·required from time to time to

accomplish the purpose of this Agreement and the Plan. Any such

operating agreement or understanding executed to implement this

Agreement or the Plan which is signed by the County Executive and the Mayor shall be presumed to be binding on the parties unless

contrary to law. this Agreement is executed this J'Jflday of

WHATCOM COUNTY Jtb ,/ g Jo••" . ~~- ~-- SHIRLEY VAN'ZTEN . ~ · · county Executive

APPROVED AS TO FORM:

ATTEST: /dZ--4}!~ J:\et\25552-B9.001\2fa.2lv

12 Ed. June 27, 1991

Vol: 2::=:2 P.39e: 1 5~::=.: ( 7' \ATCOM COUNTY ~.·:r:.!VED

.... l-' v .. ,ONTRACT NO, S p, 2 l 1991 . 9/)tJ tJ()2 ' . . J

FIRST AMENDED INTERLOCAL AGREEMENT

This agreement is executed by and between Whatcom County

11 11 ( County ) and the C~ ty of ("City") (hereinafter

jointly referred to as "the parties") for the pu..rpo.;:;es of

~ptablis:tl:i,ng an .:Lnteg;r;ated and cqo:r;din<;ted solid waste management

p,rogram for Whatcom County; fulfilling the City's and County's obligations under chapter 70.95 RCW, and other state and federal

laws and regulations governing solid waste management; and

contributing to the health and safety of all Whatcom County

residents. The parties make and enter into this First Amended

11 Inter local Agreement ("Agreement ) . effective as amended the / .S ,- day of CD-t.±-~1991 for the purposes and under the terms contained herein. This Agreement supersedes the Interlocal

Agreement between the parties bearing an effective date of July 25,

1989, and the Addendum of Clarification and Second Addendum of

Clarification thereto.

Definitions

For the purposes of this Agreement and any related agreements,

contracts, and documents executed, adopted, or approved pursuant

to this Agreement, the parties shall use the definitions found in

1 Ed. June 27, 1991 party assumes liability for the actions or activities of the other, except as provided by law or as may be agreed by the parties from time to time.

9. Implementing Agreements: The parties agree that routine operating agreements may be required from time to time to accomplish the purpose of this Agreement and the Plan. Any such operating agreement or· understanding executed to implement this

Agreement or the Plan which is signed by the county Executive and the Mayor shall be presumed to be binding on the parties unless contrary to law.

IN WITNESS HEREOF, this Agreement is executed this /~day of

_ __;o~J:=-. __ , 1991. Subscribed and sworn to me thi; / ~ of {!)(!_;:/:: . 1991. WHATCOM COUNTY

;P/ED AS. :ro FORM: .Xih~~ /Ji li~ .-:~~ Randall J. Watts, Ch~ef C~v~l Deputy Prosecuting Attorney

ATTEST: CITY OF _51~ By~-- J:\et\25552-89.001\2fa.21v

12 Ed. June 27, 1991 )2--

~·' · '' ._Jivi COUNTY (Ot

This agreement is executed by and between Whatcom County

11 ( "County") and the City of NOOKSACK ("City ) (hereinafter . ,. ~.: ... : i. jointly ret'~rred to as "the parties") for the purposes of establishing an integrated and coordinated solid waste management program for Whatcom County; fulfilling the City • s and County's obligations under Chapter 70.95 RCW, and other state and federal laws and. regulations governing solid waste management; and contributing to the health and safety of ·all Whatcom County residents. The parties make and enter into this First Amended

Interlocal Agreement ("Agreement") effective as amended the 7 ~.

day of ~ 1991 for the purposes and under the terms contained herein. This Agreement supersedes the Interlocal Agreement between the parties bearing an effective dat.e of July 25;

1989, and the Addendum of Clarification and Second Addendum of

Clarification thereto.

. ~-' pe.finit-ions- ..

For the purposes of this Agreement and any related agreements, contracts, and documents executed, adopted, or approved pursuant to this Agreement, the parties shall use the definitions found in

1 Ed. June 27, 1991 party assumes liability for the actions or activities of the other, except as provided by law or as may be agreed by the parties from time to time.

9. Implementing Agreements: The parties agree that routine operating agr~ements may be required from time to tim.e .to accomplish the purpose of this Agreement and the Plan. Any such operating agreement or understanding executed to implement this

Agreement or the Plan which is signed by the County Executive and the Mayor shall be presumed to be binding on the parties unless contrary to law.

WHATCOM COUNTY

~it· ~ Ji;/1.. ·· 7Lv

CITY OF NOOKSACK

Byfluy_~~Mayor I /

12 Ed. June 27, 1991

\"ol: 2:=:::::=: P.::tse: 49 Fi It:· No: 9201 ::;:: 1 025 WHATCOM COUNTY SOLID WASTE ADVISORY COMMITTEE MINUTES April 23, 2015

Members Present: Barbara Brenner, Pete Edwards, Casey Heinie, Eric Johnston, Amber Jones, Marty Kuljis, Marjorie Leone, Troy Lautenbach, and Mark Peterson

Members Absent: Greg Young and Ed Nikula

Staff Present: Jeff Hegedus and Janice Deptuch

Others Present: John Wolpers - Whatcom County Health Department, EH Manager; Justin Clary & Jacqueline Grinder- Maul Foster & Alongi; and Diane Mace a volunteer with City of Bellingham

Call to Order The regular meeting of the Whatcom County Solid Waste Advisory Committee was called to order on Thursday, April 23rd, 2015 at 5:33p.m. in Garden Level Meeting Room by Vice Chair, Mark Peterson.

• Introductions Troy Lautenbach, the new committee member of SWAC. Troy took over a transfer station in San Juan Island County. He was also a member of SWAC in 2000 and a member of the State Resource Board.

• Reading, Correction and Approval of Minutes The minutes of the, January 22nd, 2015 SWAC meeting were not approved as written. Barbara Brenner had some corrections and clarifications. Janice will amend and send back out to the group.

• Communications None

Agenda Items: 1. Review of Draft Comprehensive Solid and Hazardous Waste Management Plan The Solid and Hazardous Waste Management Plan has changed a bit from 2008, the plan follows the Department of Ecology template. The Hazardous Waste section is still outstanding. Eric asked where we were at with the process, and Jeff commented for the SWAC committee to review and make comment of the plan. Eric asked about the order of approval; it goes through SWAC, then SWEC, and then CIPA. Mark felt we were 80% to 90% complete with the plan. Mark asked if there were any comments. Eric said no comments, but felt we needed a more complete document. Justin asked that comments be sent to him so he could update the document. Troy stated that the SWAC committee is mandated to be in compliance with the Solid Waste Comprehensive Plan. He felt we need a vaguer list of recyclables under section 4.1.3; he felt the current list of recyclables could be considered too restrictive. Mark advised that section 4.1.3, page 42, talks about how to make changes to the recyclables list. Troy shared his issues in Skagit County with the recyclable list. There was discussion on having an interim for adding to the recycling list. Troy felt that the item they wanted added to the recycling list would have to go to the Health Department first before going to SWAC. Eric stated that Justin could look into the Whatcom County Code about how to add to the recycling list, and check on limitations. Justin felt it would be an amendment to the Whatcom County code. Justin will also clarify code referring to residential items. Mark said maybe we should ask the Solid Waste collectors what they feel needs to be added to the recycling list. Barbara said maybe we should put language in the Solid and Hazardous Waste Management Plan about an interim for adding to the recycling list. Jeff stated we will bring answers to the next meeting. Eric asked if there are recyclables that are not on the list that we want to have picked up at curbside. He also asked if there were any other comments, he thought it looked great and liked the goal and action statement. Mark asked if there is a list of facilities accepting batteries. Amber said there were some inconsistences in section 1.2.4, she said the County only collects every other week, not weekly. Amber will work with Justin to make comments on hauling. She asked that Justin send her a word document to be able to track changes. Troy wants it on record that he felt there were issues with flow control, collection and disposal leaving the County. Marjorie said maybe we should add "Including, but not limited to" to sections 3.1.2 and 4.1.2. Amber said section 8.3 -#2 doesn't talk about hauling of garbage out of County. She also thinks SHAM recycling needs further defining. Troy asked if #2A under section 8.3 Goals and Action if it should be limited to just construction sites? Mark said that SHAM is the only reference on special waste. Amber said some issues with the frequency of service on page 17 #2.2, the solid waste fee is not mentioned, and when the ordinance was in acted or the date. Jeff will make changes and incorporate. Jeff appreciated Amber's comments.

Open Session None

Announcements, Agenda Items Announcements none Agenda Items- Review changes and minutes review.

Adjournment Meeting adjourned at 7:00 p.m. Troy 1st and 2nd by Eric

CERTIFICATION I hereby certify this to be a true and correct copy of the minutes of the Whatcom County Solid Waste Advisory Committee meeting held April 23 2015.

Attest: ______Janice Deptuch Clerk III Ed Nikula, Chair Whatcom County Health Department Whatcom County Solid Waste Advisory Committee WHATCOM COUNTY SOLID WASTE EXECUTIVE COMMITTEE

!SEPTEMBER 2, 2015 MEETING MINUTES!

Committee Members Present Jack Louws, Whatcom County Executive Scott Korthuis, Mayor, City of Lynden John Perry, Mayor, City of Everson

Committee Members Absent Kelli Linville, Mayor, City of Bellingham Gary Jensen, Mayor, City of Ferndale Harry Robinson, Mayor, City of Blaine Bob Bromley, Mayor, City of Sumas James Ackerman, Mayor, City of Nooksack

Staff Present Jeff Hegedus, Environmental Health Supervisor, Solid Waste Division Janice Deptuch, Clerk Ill, Whatcom County Health Department John Wolpers, Environmental Health Manager, Whatcom County Health Department Patty Proctor, Accounting Supervisor, Whatcom County Health Department

AGENDA Call to Order The meeting of the Solid Waste Executive Committee was called to order by County Executive Jack Louws on Wednesday, September 2, 2015 at 1 :03 p.m. at Lynden City Hall.

Introductions We went around the room and everyone introduced themselves.

Solid Waste Division Transfer and Operations Jack Louws, County Executive was very pleased on how the Whatcom County Health Department took on the Solid Waste Division and how smoothly the transition went from the Public Works Division to the Whatcom County Health Department, Solid Waste Division.

Jeff Hegedus gave an update on the Solid Waste Division transfer. Effective January 1, 2015 the Whatcom County Solid Waste Division was transferred from the Public Works Department to the Health Department. All business functions, records and institutional knowledge are essentially transferred and working smoothly. Grants, contracts, lease agreements and interlocal agreements have been reviewed, updated, and renewed. The draft comprehensive solid waste plan is completed, and the new county web site now includes information regarding SWEC agendas and minutes on the solid waste page.

The Litter and Adopt-a-Road programs are functioning well, and the Birch Bay seasonal solid waste system, including the collection of 6 tons of waste fireworks debris from the July 4th celebration, was implemented, with help from the Blaine Chamber of Commerce, 150 volunteers, and Adopt-a-Road program. Sanitary Service Company donated haul services to the effort, and was thanked for their work ..

Significant capital improvements were implemented at the Disposal of Toxics facility. Excess grant funds from Ecology that were slated for deobligation were instead targeted for necessary and overdue facility upgrades and maintenance. The facility gravel driveway, parking lot and work area was paved; the building exterior was pressure washed and cleaned, and the interior was cleaned from over a decade of waste chemical processing. Three waste oil and antifreeze collection tanks, which were leaking into their secondary containment chambers, were replaced. New signs, storage units, carts and tables were purchased, and previously unmanaged problem waste was disposed of. The overall program continues to operate exceptionally well.

Cando Recycling and Disposal in Pt. Roberts recently entered into receivership, but emerged intact. We have more of a presence and are in Point Roberts more, and will soon increase attention to service provision.. The Health Department did meet with legal counsel to discuss the issue. Jack Louws asked if they go out of business, can the County take over at our expense.

Scott Korthuis asked can we get Sanitary Service Company (SSC)?

Jack Louws stated we should have an interim plan as we move forward. Maybe have language in plan regarding financial crisis.

Jeff Hegedus stated that an upcoming issue with County Construction Recycling (CCR) Landfill post-closure care funds will expire soon, and contingency planning is in progress. The county is not obligated according to the RCW, if they go through foreclosure, and we pick it up we are not responsible. Scott asked who is. John Wolpers said that it should have been closed early with the intent that CCR could build up funds, which there they looked at equipment and economy.

Jeff Hegedus talked about the tire amnesty event, utilizing Ecology funding that was implemented, and resulted in 3,400 waste tires from backyard residential sources being properly collected and disposed at no cost to residents. Jack Louws asked if certain areas of the county were highlighted and Jeff said yes, Deming area.

Jack asked if anyone had any questions. No one had any questions.

Disposal of Toxics Program Fee Schedule for Non-Profit Organizations

At the Disposal of Toxics Facility, small business and households can dispose of their waste. In 2007, SWEC moved to allow non-profit organizations to dispose of universal and moderate risk wastes at no charge; costs have increased significantly (estimated at $12,000 for 2015), are not grant eligible, and the allowance is unique. Additionally, current legal counsel is that the existing policy constitutes a potential gifting of public funds. SWAC has recommended that non-profit organizations now be subject to the Disposal of Toxics program fee schedule for small quantity generators, equivalent to other businesses. The County should start charging non-profits for disposal, households are still free. The Disposal of Toxics does not reimburse us. Jack Louws said that the household waste was not a make or break deal. A motion was made for SWEC to reconsider the 2007 non-profit policy and move to adopt the SWAC recommendation to charge non-profit organizations, subject to the Disposal of Toxics program fee schedule, for universal and moderate risk waste disposal. It was made by Scott Korthuis and 2nct by John Perry. We will poll other members by email .. NOTE: Polling resulted in 6 yea's and 0 nays, with Bellingham and Ferndale abstaining.

Draft 2015 Comprehensive Solid and Hazardous Waste Management Plan

Jeff Hegedus stated that the law requires that the Comprehensive Solid and Hazardous Waste Management Plan be reviewed and updated every five years.

The draft update of the existing 2008 plan, as required by RCW 70.95, describes the current solid and hazardous waste management system and makes recommendations for potential future implementation. The draft update proposes no structural changes to the existing solid waste system; primary recommendations include an increase of waste reduction and recycling community education and outreach activities, in order to continue to increase waste recycling and diversion rates.

How can we support people? We can do waste audit and assessments, and going out to schools and commercial sites for education training. Jack Louws asked what it will take to move forward. Jeff said that the draft 2015 Comprehensive Solid and Hazardous Waste Management Plan is completed and SWAC has been substantially involved in the planning process, and has approved moving the plan forward to Ecology for preliminary review. The plan has been submitted to Ecology, and will soon enter into the SEPA public review and comment phase.

Concurrent with the 120 day Ecology preliminary draft review period, the plan will 1) be reviewed by the Washington Utilities and Transportation Commission (WUTC), and 2) enter into a SEPA public comment period. SWAC will conduct a final review, and the plan will be submitted for SWEC review, comment and approval. Following this, the plan will be submitted to County Council and Ecology for final approval. Jack Louws asked if there were any other questions. No other questions. Mid-Cycle Budget Adjustment

Patty Proctor, Accounting Supervisor for the Whatcom County Health Department presented the mid-cycle budget adjustment information.

There will be a reduction of an annual $11 0,444 in revenue from the Ecology Coordinated Prevention Grant (CPG), which is about a 50% reduction. The county did get an increase in the litter grant. These are the recommendations:

Maintain the existing Youth Waste Reduction and Recycling Education Program (ReSources) at the budgeted $35,000 per year.

Increase the existing Master Compost and Recycler Program (WSU) by $10,000 per year from the current $25,000 to $35,000. Budget an additional $35,000 per year to implement a Commercial Waste Reduction and Recycling Program. The objective of the program would be to provide commercial waste audits and business specific detailed waste assessments and action plans for waste reduction and recycling opportunities in the construction, food service and residential multi-family property management sectors. Jack asked how much longer on the ReSources Contract? Jeff Hegedus said we held onto the contract just not signed yet.

Jack asked out of the $25,000 to $35,000 what the deliverables are? Jeff Hegedus said the extra $10,000 was for adding middle and high schools. Jack Louws asked about the $10,000 for the WSU program and Jeff sated it is the same work for the adult students in their programs, with a proportional increase in outcomes.

Jack Louws asked that next time we document number of how many contacts, kids, etc ... , to give a sense of how many people. Jeff will send information to members about the deliverables.

A motion was made that the county stay consistent with the current adopted interlocal agreements between the cities and the county, staff requests that SWEC review and approve the mid-cycle budget adjustment as presented in the meeting materials. The motion was made 1st by John Perry and 2nd by Scott Korthuis. They will poll other members by email. . NOTE: Polling resulted in 6 yea's and 0 nays, with Bellingham and Ferndale abstaining.

Open Session

Jack Louws is trying to get more information on the County website, contracts, deliverables, etc ...

John Perry gave the Health Department praise on getting the OSS and Drinking Water documents online.

Jeff mentioned that the Solid Waste Executive Committee and Solid Waste Advisory Committee minutes and agendas are now online.

Jack Louws stated that he is looking forward to working with the Whatcom Health Department on solid waste issues.

Jack Louws also mentioned that it might be easier to more of the mayors to attend if we had the meetings before or after the Small Cities Caucus, which meets the 3rd Tuesday of every month or the Whatcom Council of Government meeting that meets once a month at 3 p.m. on Wednesday,

Adjournment

The meeting was adjourned at 1:54 p.m. by Jack Louws. APPENDIX D SEPA CHECKLIST WHATCOM COUNTY J.E. "Sam" Ryan Planning & Development Services Director 5280 Northwest Drive, Bellingham, WA 98226-9097 360-676-6907, TIY 800-833-6384 360-738-2525 Fax SEP ___

SEPA Environmental Checklist

Purpose of Checklist:

Governmental agencies use this checklist to help determine whether the environmental impacts of your proposal are significant. This information is also helpful to determine if available avoidance, minimization or compensatory mitigation measures will address the probable significant impacts or if an environmental impact statement will be prepared to further analyze the proposal.

Instructions for Applicants:

This environmental checklist asks you to describe some basic information about your proposal. Please answer each question accurately and carefully, to the best of your knowledge. You may need to consult with an agency specialist or private consultant for some questions. You may use "not applicable" or "does not apply" only when you can explain why it does not apply and not when the answer is unknown. You may also attach or incorporate by reference additional studies reports. Complete and accurate answers to these questions often avoid delays with the SEPA process as well as later in the decision-making process.

The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to determining if there may be significant adverse impact.

Use of Checklist for Non-Project Proposals:

For non-project proposals (such as ordinances, regulations, plans and programs), complete the applicable parts of sections A and B plus the Supplemental Sheet for Non-project Actions (Part C). Please completely answer all questions that apply and note that the words "project", "applicant", and "property or site" should be read as "proposal", "proponent" and "affected geographic area", respectively. The lead agency may exclude (for non-projects) questions in Part B - Environmental Elements that do not contribute meaningfully to the analysis of the proposal.

SEPA Environmental Checklist Page 1 of 19 Form PL4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

A Background

1 Name of proposed project, if applicable: Whatcom County 2015 Comprehensive Solid and Hazardous Waste Management Plan (SHWMP) Update

2 Name of applicant: Jeff Hegedus, RS, Environmental Health Supervisor Applicant phone number: (360) 778-6044 Applicant address: Whatcom County Health Department City, State, Zip or Postal Code: 509 Girard St., Bellingham, WA 98225

3 Contact name: Jeff Hegedus, RS, Environmental Health Supervisor Contact phone number: (360) 778-6044

Contact address: Whatcom County Health Department City, State, Zip or Postal Code: 509 Girard St., Bellingham, WA 98225

4 Date checklist prepared: August 31, 2015

5 Agency requesting checklist: Whatcom County Planning & Development Services

6 Proposed timing or schedule (including phasing, if applicable): Proposed implementation of the Whatcom County SHWMP Update will begin upon adoption and proceed tl1rough plan revision in 202 L

7 Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? Yes 11'1 No D If yes, explain: Yes, the SHWMP will be reviewed every two years after its implementation and updated as necessary, as required by state law (WAC 173-304-011).

8 List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal: Whatcom County Comprehensive Solid and Hazardous Waste Management Plan 2008 Update and Whatcom County 1991 Hazardous Waste Management Plan.

9 Do you know whether applications are pending for governmental approvals of othMroposals directly affecting the property covered by your proposal? Yes U No [l] If yes, explain.

SEPA Environmental Checklist Page 2 of 19 Form PL4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

10 List any government approvals or permits that will be needed for your proposal, if known. In order to participate in the SHWMP, each local jurisidiction will need to approve and adopt the SHWMP. These jurisidictions include the Washington State Department of Ecology; Whatcom County Council; Washington Utilities and Transportation Commission; and the cities of Bellingham, Blaine, Everson, Ferndale, Lynden, Nooksack, and Sumas.

11 Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask vou to describe certain aspects of vour proposal. You do_no.t need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information on project description.) The Whatcom County SHWMP defines goals and action items for the management and disposal of municipal solid waste and hazardous waste produced by households and commercial generators.

12 Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range, if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist. The jurisdiction of the SHWMP will include all incorporated and unincorporated areas in Whatcom County, Washington, with the exception of the Lummi and Nooksack reservations, which are excluded from the planning area, and the far eastern portion of Whatcom County, which is serviced by the Skagit County waste hauler. Certain plan action items are intended for specific areas within the County.

B Environmental Elements

1 Earth

a. General description of the site:

Flat Rolling Hilly Steep Slopes Mountainous Other

SEPA Environmental Checklist Page 3 of 19 Form PL4·83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

b. What is the steepest slope on the site (approximate percent slope)? Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be required to evaluate slope as part of SEPA documentation. c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any agricultural land of long-term commercial significance and whether the proposal results in removing any of these soils. Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be required to evaluate soils as part of SEPA documentation.

d. Are there surface indications or history of unstable soils in the immediate vicinity? Yes D No D If so, describe. Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be required to evaluate soils as part of SEPA documentation.

e. Describe the purpose, type, total area, approximate quantities and total affected area of any filling excavation or grading proposed. Does not: apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be evaluated as a separate SEPA review process. Indicate source of fill. Does not apply. There are no site--specific recommendations in the plan.

f. Could erosion occur as a result of clearing, construction, or use? Yes 0 NoD If so, generally describe. Does not apply. There are no site--specific recommendations in the plan. Future solid waste facilities or programs will be evaluated as a separate SEPA review process.

g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)? Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be evaluated as a separate SEPA review process. h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be evaluated as a separate SEPA review process. SEPA Environmental Checklist Page 4 of 19 Form PL4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

2. Air

a. What types of emissions to the air would result from the proposal during construction, operation and maintenance when the project is completed (i.e., dust, automobile, odors, or industrial wood smoke)?

Does not apply. There are no site··specific recommendations in the plan.

If any, generally describe and give approximate quantities if known. No significant amounts of emissions to the air are anticipated as a result of any recommendations made by the SHWMP. Actions in the plan are oriented towards reduction of solid waste disposal, thus a reduction in the transportation of solid waste and greenhouse gas emissions.

b. Are there any off-site sources of emissions or odor that may affect your proposal? YesO No

If so, generally describe. Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be required to evaluate soils as part of SEPA documentation.

c. Proposed measures to reduce or control emissions or other impacts to air, if any:

Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be required to evaluate soils as part of SEPA documentation.

3. Water

a. Surface:

(1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? Yes D No D If yes, describe type and provide names. If appropriate, state what stream or river it flows into. Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be required to evaluate surface water as part of SEPA review. (2) Will the project require any work ovhin, or adjacent to (within 200 feet) the described waters? Yes LJ No D If yes, please describe and attach available plans. Does not apply. There are no site-specific recommendations in the plan.

SEPA Environmental Checklist Page 5 of 19 Form PL4·83·005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

(3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected.

Indicate the source of fill material. Does not apply. There are no site-specific recommendations in the plan.

(4) Will the proposal rrm\ire surface water withdrawals or diversions? Yes D No U Does not apply. There are no site-specific recommendations in the plan.

Give general description, purpose, and approximate quantities if known. Does not apply. There are no site--specific recommendations in the plan.

Does the proposal lie within a 100-year floodplain? Yes D NoD If so, note location on the site pian. Does not apply. There are no site-specific recommendations in the plan.

(5) Does the proposal involve any discharges of waste materials to surface waters? Yes D No [Z] If so, describe the type of waste and anticipated volume of discharge

b. Ground Water:

( 1) Will ground water be withdrawn from a well for drinking water or other purposes? Yes D No 11'1

If so, give a general description of the well, proposed uses and approximate quantities withdrawn from the well. Will water be discharged to groundwater? Give general description, purpose, and approximate quantities if known. Neither groundwater withdrawal for use as drinking water or other purposes, nor discharge of water to groundwater is contemplated as part of the SHWMP. Future solid waste facilities or programs will be required to evaluate ground water as part of SEPA documentation.

SEPA Environmental Checklist Page 6 of 19 Form PL4-83 .. QOSA Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

(2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: Domestic sewage; industrial, containing the following chemicals ..... ; agricultural; etc.). Describe the general size of the system, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve. Does not apply. There are no site-specific recommendations in the plan.

c. Water runoff (including stormwater):

(1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (include quantities, if known). Does not apply. Future solid waste facilities or programs will be required to evaluate water runoff as part of SEPA documentation.

Where will this water flow?

Will this water flow into other waters? Yes D

If so, describe. Does not apply. There are no site-specific recommendations in the plan.

(2) Could waste materials enter ground or surface waters? Yes D NoD

If so, generally describe. Does not apply. There are no site-specific recommendations in the plan. Future solid waste facilities or programs will be required to evaluate waste containment as part of SEPA documentation.

(3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site: YesD NoD

If so, describe.

Does not apply. There are no site-specific recommendations in the plan.

d. Proposed measures to reduce or control surface, ground, and runoff water impacts, if any: Does not apply. There are no site-specific recommendations in the plan.

SEPA Environmental Checklist Page 7 of 19 Form PL4 ·83 -OOSA Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

4 Plants

a. Check types of vegetation found on the site: D Deciduous tree: alder, maple, aspen, other D Evergreen tree: fir, cedar, pine, other D Shrubs D Grass D Pasture 0 Crop or grain D Orchards, vineyards or other permanent crops 0 Wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other D Water plants: water lily, eelgrass, milfoil, other D Other types of vegetation b. What kind and amount of vegetation will be removed or altered? Does not apply. There are no site-specific recommendations in the plan.

c. List threatened or endangered species known to be on or near the site. Does not apply. There are no site-specific recommendations in the plan.

d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any: Does not apply. There are no site-specific recommendations in the plan.

e. List all noxious weeds and invasive species known to be on or near the site. Does not apply. There are no site-specific recommendations in the plan.

5. Animals

a. Check any birds and animals, which have been observed on or near the site or are known to be on or near the site:

Birds: 0 Hawk, D Heron, D Eagle, D Songbirds; 0 Other:

SEPA Environmental Checklist Page 8 of 19 Form PL4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

Mammals: Deer, Bear, Elk, BBeaver; § Other:

Fish:

Bass, Salmon 1 Trout, Herring, § Shellfish; Other:

b. List any threatened or endangered species known to be on or near the site. Does not apply. There are no site-specific recommendations in the plan.

c. Is the site part of a migration route? Yes D If so, explain. Does not apply. There are no site-specific recommendations in the plan.

d. Proposed measures to preserve or enhance wildlife, if any: Does not apply. There are no site-specific recommendations in the plan.

e. List any invasive species known to be on or near site. Does not apply. There are no site-specific recommendations in the plan.

6. Energy and Natural Resources a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc. Does not apply. There are no site-specific recommendations in the plan.

b. Would your project affect the ~entia! use of solar energy by adjacent properties? Yes 0 No U If so, generally describe. Does not apply. There are no site-specific recommendations in the plan.

SEPA Environmental Checklist Page 9 of 19 Form Pl4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any: The SHWMP emphasizes waste reduction and recycling, which results in the conservation of energy and natural resources.

7. Environmental Health

a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste that could occur as a result of this proposal? Yes D No 1"'1 If so, describe. No environmental risks are anticipated as a result of new or additional programs proposed by the SHWMP. Future solid waste facilities or programs will be required as necessary to evaluate potenttal environmental health hazards as part of SEPA documentation. (1) Describe any known or possible contamination at the site from present or past uses. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

(2) Describe existing hazardous chemicals/conditions that might affect project development and design. This includes underground hazardous liquid and gas transmission pipelines located within the project area and in the vicinity. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

(3) Describe any toxic or hazardous chemicals that might be stored, used, or produced during the projects development or construction, or at any time during the operating life of the project. There are no facility construction projects proposed as part of the SHWMP. Storage of hazardous materials at the third-party facilities are managed through individual health and safety plans.

( 4) Describe special emergency services that might be required. Additional emergency services are not required by any of the SHWMP recommendations.

(5) Proposed measure to reduce or control environmental health hazards, if any: There are no net increases in risk caused by the SHWMP recommendations. Existing facility site-specific emergency procedures are addressed by the individual facilities as part of the sites' safety plans.

SEPA Environrnental Checklist Page lO of 19 Form PL4-83··005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

b. Noise

(1) What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other)? There are no facilities proposed as part of the SHWMP. Any future solid waste facilities or programs will be required to evaluate noise as part of SEPA documentation.

(2) What types and levels of noise would be created by or associated with the project on a short-term or a long-term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site. Does not apply. There are no site-specific recommendations in the plan.·

(3) Proposed measures to reduce or control noise impacts, if any: Does not apply. There are no site-specific recommendations in the plan.

8 Land and Shoreline Use

a. What is the current use of the site and adjacent properties? Does not apply. Future solid waste facilities or programs will be required to evaluate land use as part of SEPA documentation. Will the proposal affect current land uses on nearby or adjacent properties? Yes D No 0 If so, describe. Does not apply. Future solid waste facilities or programs will be required to evaluate land use as part of SEPA documentation.

b. Has the proliecf site been used as working farmlands or working forest lands? Yes No D If so, descrioe. Does not apply. There are no site .. specific recommendations in the plan.

How much agriculture or forest land of long-term commercial significance will be converted to other uses as a result of the proposal, if any? Does not apply. There are no site-specific recommendations in the plan.

If resource lands have not been designated, how many acres in farmland or forest land tax status will be converted to non-farm or non-forest use? Does not apply. There are no site-specific recommendations in the plan.

SEPA Environmental Checklist Page 11 of 19 Form PL4-83·005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

(1) Will the proposal affect or be affected by surrounding working farm or forest land normal business operations, such as oversize equipment access, the application of pesticides, tilling and harvesting? Yes D No D If so, how: Does not apply. There are no site-specific recommendations in the plan.

c. Describe any structures on the site. Does not apply. There are no site-specific recommendations in the plan.

d. Will any structures be demolished? YesO If so, what? Does not apply. There are no site-specific recommendations in the plan.

e. What is the current zoning classification of the site? Does not apply. There are no site-specific recommendations in the plan.

f. What is the current comprehensive plan designation of the site? Does not apply. There are no site-specific recommendations in the plan.

g. If applicable, what is the current shoreline master program designation of the site? Does not apply. There are no site-specific recommendations in the plan.

h. Has any part of the site been classified as a critical area by the city or county? Yes D No D If so, specify. Does not apply. There are no site··specific recommendations in the plan.

i. Approximately how many people would reside or work in the completed project? Does not apply. There are no site-specific recommendations in the plan.

j. Approximately how many people would the completed project displace? Does not apply. There are no site-specific recommendations in the plan.

SEPA Environmental Checklist Page 12 of 19 Form PL4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

k. Proposed measures to avoid or reduce displacement impacts, if any: Does not apply. There are no site--specific recommendations in the plan.

I. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any: Does not apply. There are no site-specific recommendations in the plan.

m. Proposed measures to ensure the proposal is compatible with nearby agricultural and forest lands of long-term commercial significance, if any? Does not apply. There are no site-specific recommendations _in the plan.

9 Housing

a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income housing.

D High D Middle D Low-income

b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income housing.

D High Middle B Low-income c. Proposed measures to reduce or control housing impacts, if any: Does not apply. There are no site-specific recomrnendations in the plan.

10 Aesthetics

a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building material(s) proposed? Does not apply. No structures are being proposed as part of the SHWMP. Future solid waste facilities or programs will be required to evaluate height as part of the SEPA review. b. What views in the immediate vicinity would be altered or obstructed? Does not apply. No structures are being proposed as part of the SHWMP.

SEPA Environmental Checklist Page 13 of 19 Form PL4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

c. Proposed measures to reduce or control aesthetic impacts, if any: Does not apply. No structures are being proposed as part of the SHWMP. Future solid waste facilities or programs will be required to evaluate aesthetics as part of the SEPA review. 11 Light and Glare

a. What type of light or glare will the proposal produce? What time of day would it mainly occur? Does not apply. No actions are being proposed that would create light or glare impacts. Future solid waste facilities or programs will be required to evaluate light and glare as per SEPA. b. Could light or glare from the finished project be a safety hazard or interfere with views? Does not apply. There are no site-specific actions recommended as part of the SHWMP.

c. What existing off-site sources of light or glare may affect your proposal? Does not apply. There are no site-specific actions recommended as part of the SHWMP.

d. Proposed measures to reduce or control light and glare impacts, if any: Does not apply. There are no site-specific actions recommended as part of the SHWMP.

12 Recreation

a. What designated and informal recreational opportunities are in the immediate vicinity? Does not apply. There are no site-specific actions recommended as part of the SHWMP. Future solid waste facilities or programs will be required to evaluate recreation as per SEPA. b. Would the proposed project displace any existing recreational uses? If so, describe. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any: Does not apply. There are no site-specific actions recommended as part of the SHWMP.

13 Historic and Cultural Preservation

a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed in or eligible for listing in national, state or local preservation registers located on or near the site? Yes D No D If so, specifically describe. Does not apply. There are no site-specific actions recommended as part of the SHWMP. Future solid waste facilities or programs will be required to evaluate historic and cultural preservation.

SEPA Environmental Checklist Page 14 of 19 Form PL4-83··005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

b. Are there any landmarks, features, or other evidence of Indian, historic use or occupation, this may include human burials or old cemeteries? Yes 0 NoD Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Yes D No D Please list any professional studies conducted at the site to identify such resources. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

c. Describe the methods used to assess the potential impacts to cultural and historic resources on or near the project site. Examples: Include consultation with tribes and the Department of Archeology and Historic Preservation, archaeological surveys, historic maps, GIS data, etc.

Does not apply. There are no site~specific actions recommended as part of the SHWMP.

d. Proposed measures to avoid, m1n1m1ze, or compensate for loss, changes to, and disturbance to resources. Please include plans for the above and any permits that may be required. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

14 Transportation a. Identify public streets and highways serving the site or affected geographic area and describe proposed access to the existing street system. Show on site plan, if any.

Does not apply. There are no site~specific actions recommended as part of the SHWMP. Future solid waste facilities or programs will be required to evaluate transportation as per SEPA. b. Is site or geog~hic area currently served by public transit? Yes D No U If not, what is the approximate distance to the nearest transit stop? Does not apply. There are no site-specific actions recommended as part of the SHWMP.

c. How many parking spaces would the completed project have? How many would the project eliminate? Does not apply. There are no site-specific actions recommended as part of the SHWMP.

SEPA Environmental Checklist Page 15 of 19 Form Pl4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

d. Will the proposal require any new or improvements to existing roads, streets, pedestriap.t,bicycle or state transportation facilities, not including driveways? Yes LJ No D If so, generally describe (indicate whether public or private). Does not apply. There are no site-specific actions recommended as part of the SHWMP.

e. Will the project use (or occur in the immediate vicinity of) D Water, D Rail, or D Air transportation? If so, generally describe. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

f. How many vehicular trips per day would be generated by the completed project or proposal? If known, indicate when peak volumes would occur and what percentage of the volume would be trucks (such as commercial and non-passenger vehicles). What data or transportation models were used to make these estimates? Does not apply. There are no site-specific actions recommended as part of the SHWMP.

g. Proposed measures to reduce or control transportation impacts, if any: Does not apply. There are no site-specific actions recommended as part of the SHWMP.

15 Public Services

a. Would the project result in an increased need for public services (for examRie: fire protection, police protection, health care, schools, other)? Yes D No D If so, generally describe. Does not apply. There are no site--specific actions recommended as part of the SHWMP. Future solid waste facilities or programs will be required to evaluate public services as part of the SEPA review process.

b. Proposed measures to reduce or control direct impacts on public services, if any. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

SEPA Environmental Checklist Page 16 of 19 Form PL4·83·005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

16 Utilities

a. Check utilities currently available at the site:

Electricity, Natural gas, B Water, B Refuse service, Telephone, Sanitary sewer, BSeptic system, B Other

b. Describe the utilities that are proposed for the project, the utility providing the service, and the general construction activities on the site or in the immediate vicinity which might be needed. Does not apply. There are no site-specific actions recommended as part of the SHWMP.

Signature

The above answers are true and complete to the best of my knowledge. I understand that the lead ag.em::y s relying on them to make its decision. / ~~

Date Submitted:

SEPA Environmental Checklist Page 17 of 19 Form PL4·83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

C Supplemental Sheet for Non-project Actions

(It is not necessary to use this sheet for project actions)

Because these questions are very general, it may be helpful to read them in conjunction with the list of the elements of the environment. When answering these questions, be aware of the extent the proposal or the types of activities likely to result from the proposal, would affect the item at a greater intensity or at a faster rate than if the proposal were not implemented. Respond briefly and in general terms.

1 How would the proposal be likely to increase discharge to water; emissions to air; production, storage, or release of toxic or hazardous substances; or production of noise? Implementation of the proposed SHWMP should result in an overall decrease in discharges to the environment as a result of management strategies developed to prevent or minimize problems associated with solid waste and hazardous waste.

Proposed measures to avoid or reduce such increases are: Goals and actions established during the planning process will reduce impacts to water, air, and noise by properly managing wastes, and will minimize the potential release of toxic or hazardous substances into the environment.

2. How would the proposal be likely to affect plants, animals, fish, or marine life? Implementation of the proposed SHWMP should result in an improved quality of habitat for plant and animal species in the county by reducing pollution.

Proposed measures to protect or conserve plants, animals, fish, or marine life are: Does not apply.

3. How would the proposal be likely to deplete energy or natural resources? Implementation of the SHWMP's strategies for recycling and waste reduction will result in conservation of energy and natural resources.

Proposed measures to protect or conserve energy and natural resources are: The proposal will conserve energy and natural resources.

SEPA Environmental Checklist Page 18 of 19 Form PL4-83-005A Rev May 2014 To Be Completed Evaluation For By Applicant Agency Use Only

4. How would the proposal be likely to use or affect environmentally sensitive areas or areas designated (or eligible or under study) for governmental protection; such as parks, wilderness, wild and scenic rivers, threatened or endangered species habitat, historic or cultural sites, wetlands, floodplains, or prime farmlands? The SHWMP recommendations will enhance environmentally sensitive areas by improving water quality through the education of the public to properly manage and dispose of solid and hazardous waste.

Proposed measures to protect such resources or to avoid or reduce impacts are: No impacts are anticipated.

5. How would the proposal be likely to affect land and shoreline use, including whether it would allow or encourage land or shoreline uses incompatible with existing plans? The SHWMP does not make any recommendations for land and shoreline use that are incompatible with existing plans or regulations.

Proposed measures to avoid or reduce shoreline and land use impacts are: Does not apply.

6. How would the proposal be likely to increase demands on transportation or public services and utilities? No impacts are anticipated.

Proposed measures to reduce or respond to such demand(s) are: Does not apply.

7. Identify, if possible, whether the proposal may conflict with local, state, or federal laws or requirements for the protection of the environment. The SHWMP was prepared in response to state requirements for the proper management of solid and hazardous waste, and complies with all applicable local, state, and federal laws and requirements.

SEPA Environmental Checklist Page 19 of 19 Form PL4-83 005A Rev May 2014 APPENDIX E COST ASSESSMENT QUESTIONNAIRE COST ASSESSMENT QUESTIONNAIRE

Please provide the information requested below:

PLAN PREPARED FOR THE COUNTY OF: Whatcom

PLAN PREPARED FOR THE CITY OF: ______

PREPARED BY: Erik Bakkom PE

CONTACT TELEPHONE: _....;::;5..;;;;03::;..-....3=12=--0=0=9...:.4 _____ DATE: July 15, 2015

DEFINITIONS

Please provide these definitions as used in the Solid Waste Management Plan and the Cost Assessment Questionnaire.

Throughout this document: YR.1 shall refer to 2015. YR.3shallreferto 2017. YR.6 shall refer to 2020.

Year refers to (circle one) calendar (Jan 01 - Dec 31) ~01-Jun30) 1. DEMOGRAPHICS: To assess the generation, recycling and disposal rates ofan area, it is necessary to have population data. This information is available from many sources (e.g., the State Data Book, County Business Patterns, or the State Office of Finance and Management)

1.1 Population

1.1.1 What is the total population ofyour County/City?

YR.l 210,050 YR.3 216,228 YR.6 225,307

1.1.2 For counties, what is the population ofthe area under your jurisdiction? (Exclude cities choosing to develop their own solid waste management system.)

YR.l 206,543 YR.3 212,678 YR.6 221,545

Note that the population under jurisdiction of the plan does not include East Whatcom County, which is covered under the Skagit County solid waste management plan.

1.2 References and Assumptions

Population projections have been provided from the OFM 2012 County Growth Management Projections 2010-2040 report.

2. WASTE STREAM GENERATION: The following questions ask for total tons recycled and total tons disposed. Total tons disposed are those tons disposed of at a landfill, incinerator, transfer station or any other form of disposal you may be using. .if other please identify.

2.1 Tonnage Recycled

2.1.1 Please provide the total tonnage recycled in the base year, and projections for years three and six.

YR.l 1 140 YR.3 1 172 YR.6 1,220

2.2 Tonnage Disposed

2.2.1 Please provide the total tonnage disposed in the base year, and projections for years three and six.

YR.l 1,328 YR.3 1 343 YR.6 1 366

2.3 References and Assumptions Recycling is based on the medium projection [Total Waste Generation]­ [Total MSW Disposed] and represents materials that are considered recycled and diverted by the Department of Ecology.

3. SYSTEM COMPONENT COSTS: This section asks questions specifically related to the types of programs currently in use and those recommended to be started. For each component (i.e., waste reduction, landfill, composting, etc.) please describe the anticipated costs of the program(s), the assumptions used in estimating the costs and the funding mechanisms to be used to pay for it. The heart of deriving a rate impact is to know what programs will be passed through to the collection rates, as opposed to being paid for through grants, bonds, taxes and the like.

3.1 Waste Reduction Programs

3 .1.1 Please list the solid waste programs which have been implemented and those programs which are proposed. lf these programs are defined in the SWM plan please provide the page number. (Attach additional sheets as necessary.)

IMPLEMENTED • Waste Reduction & Recycling Education - School and Community (Contract with ReSources) • WSU Extension Compost Program (through lnterlocal Agreement)

PROPOSED • Increased Educational Programming (Through Professional Services Contract) • Increased Support to WSU Extension Compost Program (increase funding)

3.1.2 What are the costs, capital costs and operating costs for waste reduction programs implemented and proposed?

See attached budget summary and projected budget (Question 3.8).

3.1.3 Please describe the funding mechanism(s) that will pay the cost of the programs in 3.1.2.

Whatcom County provides all external services through outside parties - through contract with private companies, through lnterlocal Agreement with WSU, or through services provided by solid waste providers. The funding for all County led efforts (primarily contract or lnterlocal Agreement) are derived from the excise tax that is assessed on solid waste collected within the county.

3.2 Recycling Programs 3.2.1 Please list the proposed or implemented recycling program(s) and, their costs, and proposed funding mechanism or provide the page number in the draft plan on which it is discussed. (Attach additional sheets as necessary.)

All Whatcom County recycling programs are education and outreach based and are administered through the same contracts that are described in Section 3.1.

See attached budget summary and projected budget (Question 3.8).

3.3 Solid Waste Collection Programs -SSC, NVD and Cando

3.3.1 Regulated Solid Waste Collection Programs Fill in the table below for each WUTC regulated solid waste collection entity in your jurisdiction. (Make additional copies of this section as necessary to record all such entities in your jurisdiction.)

• Customer annual growth rate at 1 .2% is based on Whatcom County Comprehensive Plan (Berk, pending). • Waste annual growth rate is estimated at 0.98% per waste projections. • Residential and commercial accounts are reported together since materials are collected on shared routes.

WUTC Regulated Hauler Name Sanitary Service Company, Inc. G-permit #GOOOO 14

2015 2017 2020 Residential Customers 20,784 21,286 22,062 Commercial Customers 4,507 4,616 4,784 Total Tons Collected 68,054 69,395 71,455 WUTC Regulated Hauler Name Freedom 2000, LLC G-permit #G063819

2015 2017 2020 Residential Customers 533 546 566 Commercial Customers 35 36 38 Total Tons Collected 598 610 628

WUTC Regulated Hauler Name Nooksack Valley Disposal, Inc. G-Permit #G000166 2015 2017 2020 Residential Customers 2,302 2,358 2,444 Commercial Customers 693 2,002 10,223 Total Tons Collected 4,515 4,604 4,740

3.3.2 Other (non-regulated) Solid Waste Collection Programs Fill in the table below for other solid waste collection entities in your jurisdiction. (Make additional copies of this section as necessary to record all such entities in your jurisdiction.)

Hauler Name Sanitary Services Company, Inc- Contract to City of Bellingham

2015 2017 2020 Residential Customers 18,913 19,370 20,076 Total Tons Collected 10,806 11,019 11,346

Hauler Name Sanitary Services Company, Inc- Contract to City of Ferndale

2015 2017 2020 Residential Customers 3,177 3,253 3,372 Commercial Customers 346 354 367 Total Tons Collected 4,299 4,383 4,514 Hauler Name Nooksack Valley Disposal- Contract to City of Lynden

2015 2017 2020 Residential Customers 3,532 3,617 3,749 Commercial Customers 699 2,873 25,261 Total Tons Collected 6,019 6,138 6,320

Hauler Name Nooksack Valley Disposal- Contract to City ofEverson

2015 2017 2020 Residential Customers 510 522 541 Commercial Customers 79 93 120 Total Tons Collected 698 712 733

Hauler Name Nooksack Valley Disposal- Contract to City ofNooksack

2015 2017 2020 Residential Customers 347 355 368 Commercial Customers 18 20 24 Total Tons Collected 483 492 507

Hauler Name Nooksack Valley Disposal- Contract to City of Sumas

2015 2017 2020 Residential Customers 302 309 320 Commercial Customers 76 114 212 Total Tons Collected 1,727 1,761 1,813 3.4 Energy Recovery & Incineration (ER&I) Programs (Ifyou have more than one facility ofthis type, please copy this section to report them.)

There are no ER&I facilities in Whatcom County

3.5 Land Disposal Program

There are no operational landfills or other land disposal facilities in Whatcom County. Maintenance of close landfills is presented in Question 3.7.

3.6 Administration Program

3.6.1 What is the budgeted cost for administering the solid waste and recycling programs and what are the major funding sources.

Budgeted Cost

See attached budget summary and projected budget (Question 3.8).

Funding Source

Solid waste collections excise tax

3.6.2 Which cost components are included in these estimates?

Labor and benefits, facility expenses, staff training, vehicle and insurance, solid waste management plan

3.6.3 Please describe the funding mechanism(s) that will recover the cost ofeach component.

Solid waste collections excise tax 3. 7 Other Programs

For each program in effect or planned which does not readily fall into one of the previously described categories please answer the following questions. (Make additional copies ofthis section as necessary.)

3.7.1 Describe the program, or provide a page number reference to the plan.

Landfill Post-Closure (Section 7.1.3)

3.7.2 Owner/Operator: Whatcom County

3. 7.3 Is WUTC Regulation Involved? If so, please explain the extent of involvement in section 3.8.

No

3.7.4 Please estimate the anticipated costs for this program, including capital and operating expenses.

See attached budget summary and projected budget (Question 3.8).

3.7.5 Please describe the funding mechanism(s) that will recover the cost ofthis component.

Solid waste collections excise tax 3.7 Other Programs

For each program in effect or planned which does not readily fall into one of the previously described categories please answer the following questions. (Make additional copies ofthis section as necessary.)

3. 7.1 Describe the program, or provide a page number reference to the plan.

Disposal of Toxics (Section 11)

3.7.2 Owner/Operator: Whatcom County

3. 7.3 Is WUTC Regulation Involved? If so, please explain the extent of involvement in section 3.8.

No

3. 7.4 Please estimate the anticipated costs for this program, including capital and operating expenses.

See attached budget summary and projected budget (Question 3.8).

3.7.5 Please describe the funding mechanism(s) that will recover the cost ofthis component.

Solid waste collections excise tax State coordinated prevention grant 3.7 Other Programs

For each program in effect or planned which does not readily fall into one of the previously described categories please answer the following questions. (Make additional copies ofthis section as necessary.)

3. 7.1 Describe the program, or provide a page number reference to the plan.

Litter Control (Section 9.1.1)

3. 7.2 Owner/Operator: Whatcom County

3. 7.3 Is WUTC Regulation Involved? If so, please explain the extent of involvement in section 3.8.

No

3.7.4 Please estimate the anticipated costs for this program, including capital and operating expenses.

See attached budget summary and projected budget (Question 3.8).

3.7.5 Please describe the funding mechanism(s) that will recover the cost ofthis component.

Solid waste collections excise tax State coordinated prevention grant

3.8 References and Assumptions (attach additional sheets as necessary)

See attached budget summary and projection. 4. FUNDING MECHANISMS: This section relates specifically to the funding mechanisms currently in use and the ones which will be implemented to incorporate the recommended programs in the draft plan. Because the way a program is funded directly relates to the costs a resident or commercial customer will have to pay, this section is crucial to the cost assessment process. Please fill in each ofthe following tables as completely as possible.

Table 4.1.1 Facility Inventory I Facility Name Type of Tip Fee Transfer Transfer Station Final Disposal Total Tons Total Revenue Generated Facility per Ton CostA Location Location Disposed (Tip Fee x Tons)

Recyclin~ and Disposal Columbia Ridge Private Services $100 Ferndale, WA Landfill, Arlington, 92,597 $ 9,259,700 Transfer OR Regional Disposal Roosevelt Regional Private Company $82.50 Ferndale, WA Landfill, Roosevelt, 11,663.25 $962,200 Transfer WA - Freedom 2000, LLC Headquarters Private (Cando) $280 Pt. Roberts, WA Landfill, Castle 979.42 $ 274,237.60 Transfer Rock, WA Sanitary Service Company Birch Bay- Private Recycling and $300 Lynden, WA 64.90 $ 19,470.00 Lynden Drop Box Dropbox Disposal Services Facility Sanitary Service Private Recycling and Company Cedarville $300 Blaine, WA 81.91 $24,573.00 Drop box Disposal Services Drop Box Facility ! Sanitary Service Private Recycling and Company Roeder Ave $300 Bellingham, WA 115.37 $ 34,611.00 Drop box Disposal Services DrOQ_ Box Facility Nooksack Valley Private Recycling and Disposal Drop Box $200 Lynden, WA 745 $149,000 Drop box Disposal Services Facility Notes A Where there is no additional transfer cost between the drop box facilities and the transfer stations because this service is included in the base cost of the Transfer Station Operation Agreement (i.e. no additional charge). All transfer costs represent the agreed to rate within the Long Haul and Disposal Agreement. 8 RDS Tip Fee is "weighted" with Recyclables Received or Recovered but not Landfilled. "Total Landfilled, Total Revenue and Total Costs" are accurate and inclusive of all activities. RDS Recycled over 20% of all materials accepted. RDS received 116,700 tons but only landfilled 92,597 tons.

11 Table 4.1.2 Tip Fee Components

Tip Fee by Facility Surcharge City Tax County TaxA Transportation Operational Cost 8 Administration Cost c Closure Costs Cost Recycling and Disposal NA 12.5% NA ND ND ND NA Services Regional Disposal NA 12.5% NA ND ND ND NA Company Freedom 2000, LLC NA NA NA ND ND ND NA (Cando) Sanitary Service NA NA NA 0 $78.40 0 NA Company Birch Bay- Lynden Drop Box Facility Sanitary Service NA NA NA 0 $78.40 0 NA Company Cedarville Drop Box Facility Sanitary Service NA NA NA 0 $78.40 0 NA Company Roeder Ave Drop Box Facility Nooksack Valley NA NA NA 0 $89 0 NA Disposal Drop Box Facility Notes ND- Not Disclosed by private solid waste company. NA- Not Applicable A The County solid waste excise tax is paid through solid waste collection fees and is not represented in the table above. 8 Drop Box Facilities have listed transfer station disposal fees in the operations costs column c Providers do not track operational and administrative costs per ton separately unless listed. These items are reported together in the Operational Costs Column.

12 Table 4.1.3 Funding Mechanism

Name of Program Bond Total Bond Bond Due Grant Name Grant Amount Tip Fee Taxes Other Surcharge Funding Mechanism Name Bond Rate Date will defray costs Debt

Waste $ 80,000 Reduction/Recycling Solid Waste $435,000 Administration Landfill Post-Closure $ 77,600 Disposal ofToxics Ecology CPG $281,000 $145,000 Facility Litter Control Ecology CPG $ 18,500 $ 4,500

13 Table 4.1.4 Tip Fee Forecast

Tip Fee per Ton by Year One Year Two Year Three Year Four Year Five Year Six Facility Recycling and Disposal $100 $100 $100 $100 $100 $100 Services Regional Disposal $82.50 $82.50 $82.50 $82.50 $82.50 $82.50 Company Freedom 2000, LLC $280 $280 $280 $280 $280 $280 ,(Cando) Sanitary Service Company Birch Bay- $300 $300 $300 $300 $300 $300 Lynden Drop Box Facility Sanitary Service Company Cedarville $300 $300 $300 $300 $300 $300 Drop Box Facility Sanitary Service Company Roeder Ave $300 $300 $300 $300 $300 $300 Drop Box Facility Nooksack Valley Disposal Drop Box $200 $200 $200 $200 $200 $200 Facility

Notes • Tip fees for private waste management facilities have been level for the past 10 years and rate increases are not currently anticipated by the facility operators. • Private operators of the facilities respond to market conditions and may change tip fees at any time.

14 4.2 Funding Mechanisms summary by percentage: In the following tables, please summarize the way programs will be funded in the key years. For each component, provide the expected percentage ofthe total cost met by each funding mechanism. (e.g. Waste Reduction may rely on tip fees, grants, and collection rates for funding). You would provide the estimated responsibility in the table as follows: Tipfees=IO%; Grants=50%; Collection Rates=40%. The mechanisms must totallOO%. Ifcomponents can be classified as "other, "please note the programs and their appropriate mechanisms. Provide attachments as necessary.

Table 4.2.1 Funding Mechanism by Percentage Year One Component Tip Fee% Grant% Bond% Collection Tax Other% Total Rates%

Waste Reduction/ 0% 100% 100% RecyclinQ Administration 0% 100% 100% Landfill Post-Closure 0% 100% 100% Disposal of Taxies 65% 35% 100% Litter Control 80% 20% 100% Notes • Collection Tax Rates is the Excise Tax collected by Whatcom from permitted haulers. • Waste Reduction/Recycling includes county administered contracts for solid waste education and community outreach. • Administration includes County solid waste staff, solid waste planning, and general county solid waste program administration.

15 Table 4.2.2 Funding Mechanism by Percentage Year Three Component Tip Fee% Grant% Bond% Collection Tax Other% Total Rates% Waste Reduction/ 0% 100% 100% Recycling Administration 0% 100% 100% Landfill Post-Closure 0% 100% 100% Disposal of Toxics 65% 35% 100% Litter Control 80% 20% 100%

Table 4.2.3 Funding Mechanism by Percentage Year Six Component Tip Fee% Grant% Bond% Collection Tax Other% Total Rates% Waste Reduction/ 0% 100% 100% Recycling Administration 0% 100% 100% Landfill Post-Closure 0% 100% 100% Disposal of Toxics 65% 35% 100% Litter Control 80% 20% 100%

16 4.3 References and Assumptions Please provide any support for the information you have provided. An annual budget or similar document would be helpful.

See attached budget summary and projection.

4.4 Surplus Funds Please provide information about any surplus or saved funds that may support your operations.

Surplus funds within the County Solid Waste program are managed appropriately to their funding source. Grant funds that are not spent are returned to the grantor. County General Fund dollars are not used to fund solid waste operations. Excess solid waste excise taxes ($6/ton) that are unspent are transferred to a solid waste reserve account that has been established to fund future landfill post-closure costs or to support programs that are recommended within the solid waste management plan.

17 ATTACHMENT

Whatcom County Solid Waste Program Budget Summary & Projection

18 Solid Waste Program Summary

1. Maintain 25% of existing vehicle in budget: allocate 75% to enforcement and 25% to operations 2. Budget 0.5 FTE EHS Supervisor and 0.25 EHS II to operations 3. No need to increase travel and training budget 4. Existing fund balance to be held in reserve for potential landfill post-closure contingency, or as identified in 5 year plan update

Total Budget= $1,049,804 Solid Waste Tax $740,000 Grants $299,604 Other $ 10,200

1. Solid Waste Operations- $435,000 • Solid Waste Coordinator • Update of Comprehensive Solid and Hazardous Waste Management Plan- rnid-2014 through 2015 • Leases for operation of SW drop box facilities- o Sanitary Services: Cedarville, Birch Bay o Cando Recycling: Point Roberts o Periodic maintenance required • Office Space Rental/Overhead • Training • Office Supplies/Printing/Postage/Telephone • Insurance Premiums • Vehicle • Payment to Health Department 2. Landfill Post-Closure- $77,600 • Cedarville and Y Road Landfills o Leachate Collection System/NPDES Permit-Cedarville o Groundwater/Surface Water/Leachate/LFG monitoring/reporting • Currently contracted to Bennett Engineering- contract ends on 12/31/14 • Birch Bay/Point Roberts • Interdepartmental Agreement with Sheriff's Office for site maintenance 3. Disposal ofToxics Facility- $410,000 • Contracted to PSE Services through 2018 • Mostly paid for by Ecology CPG 4. Litter Control- $23,000 • Interdepartmental Agreement with Sheriff's Office for jail litter crew- paid for by Ecology grant • Contract with Sanitary Services for seasonal trash cans in Birch Bay- no grant funding 5. Waste Reduction/Recycling- $80,000 • Education- Contract with RESources for school recycling education- contract ends on 12/31/14 • WSU Extension Compost Program- part of comprehensive interlocal agreement between WSU/County • Clean Green contribution to City of Bellingham- ends in 2014 Whatcom County Solid Waste Program Budget Summary & Projection

2015 (Year 1) 2017 (Year 3) 2020 (Year 6) SW Operations $435,000 $435,000 $435,000 LF Post- $78,000 $78,000 $78,000 Closure DOT Facility $410,000 $410,000 $410,000 Litter Control $23,000 $23,000 $23,000 Waste $105,000 $105,000 $105,000 Red/Recyc Total $1,051,000 $1,051,000 $1,051,000

Due to pending budget cuts at the state level, budget projections for the Whatcom County solid waste programs are very uncertain. The current state issued CPG accounts for approximately 30% of the County budget. The state legislature is currently considering an across the board cut of state funds of between 25% and 50%, which translates to up to $160,000 over the 2015-2016 biennium or approximately $80,000 per year. These budget cuts are likely to carry into the 2017 calendar year. The loss of state funding will be managed through the elimination of low-priority actions or use of excess solid waste funds that have accumulated from the solid waste collection excise tax. The budget projections identified above are maintained at a fixed level for the years requested by UTC in this questionnaire.

As a result of Whatcom County's privatized solid waste system, budgetary demands for County infrastructure are essentially fixed in the administration and operation of the DOT Facility, Litter Control, and maintenance of Closed Landfills. The second priority for County staff is to preserve the existing Waste Reduction and Recycling programs that are currently provided though WSU Extension (via lnterlocal Agreement) or through ReSources (via public contract). New solid waste activities addressing the actions recommended within this SWMP are optional, to be funded after meeting basic infrastructure and existing program demands. If the County solid waste program is provided with an expanded basis (through restoration of state funds or increased revenues from solid waste collection (excise tax)), the County will first focus on fully funding the DOT Facility, followed by an expansion of the education and outreach contracts that would address the goals and actions identified in Table 10-1 of the SWMP.

20 SERVICE DATE 1 f1 SEP 1 0 2015

STATE OF WASHINGTON UTILITIES AND TRANSPORTATION COMMISSION 1300 S. Evergreen Park Dr. S. W., P.O. Box 47250 • Ofympia, Wasflington 98504- 7250 (360) 664-1160 • TTY (360) 586·8203

September 10,2015

Jeff Hegedus Whatcom County Health Department 509 Girar·d Street Bellingham, Washington 982?":

RR: Whatcom County Comprehensive Solid Waste Management l)lan Docket TG-151580

Dear Mr. Hegedus:

The Washington Utilities and Transportation Commission (commission) has completed its review of the preliminary draft of the Whateom County Comprehensive Solid Waste Management Plan Update (Plan).

Staffs analysis of the Cost Assessment portion of the Plan shows no impact to regulated ratepayers in Whatcom County. The Plan states that disposal fees will not increase fi·om the current $82.50 per ton.

Stalfhas no further comment on the Plan.

Please direct questions or comments about the commission's plan review process to Penny Ingram at (360) 664- l 242 or pingram(i1)utc. W

Sincerely,

./C-2:.--- V l---r Steven V. King Executive Director and Secretary

cc: Diana Wadley Waste 2 Resources Program, Northwest Regional Office Department of Ecology 3190 160'11 AvenueSE Bellevue, WA 98008--5452

Eespect. Prof::ssionalisr.n. Integrity. Accounh1hility.