Materials Management in Vermont: History of Materials Management and Planning Update

*Please avoid printing this document or, please print double sided.* DRAFT DOCUMENT

“Materials management is an approach to serving human needs by using and reusing resources most productively and sustainably throughout their life cycles, minimizing the amount of materials involved and all the associated environmental impacts.”

– Sustainable Materials Management: The Road Ahead (U.S. EPA 2009)

Photograph of pre-sorted single stream recyclables.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 1 TABLE OF CONTENTS

Executive Summary

History and Intent Section

I. Statutory Authority a. Act 78 adopted in 1987 b. Materials Management Plan (MMP) – formerly the “Solid Waste Management Plan (SWMP)” c. Priorities II. Why is a Materials Management Approach Important? a. Accessible Commodity b. Conservation of Natural Resources III. How much has been generated? a. National Statistics i. Trends: 1960-2010 ii. The 2010 Data iii. State of Collection b. Vermont Statistics c. Diversion and Disposal (D&D) rates compared IV. Vermont’s Waste Composition a. 2001 Vermont Waste Composition Study b. 2006 and 2010 CSWD Waste Composition Studies c. Comparison and Observations V. Current Vermont Infrastructure for Materials Management a. Facilities List b. Vermont Landfills i. Capacity ii. Extending the Anticipated Lifespan c. Composting Facilities d. Materials Recovery Facilities (MRF) e. Residual Wastes (Septage and Sludges) i. Septage ii. Residual Wastes (Sludges) iii. Biosolids f. Cost of Materials Management in Vermont i. Curbside Collection and Drop-off ii. Recyclables and Organics iii. Commercially Generated Materials g. Call for a Comprehensive Infrastructure Assessment VI. Materials Management and Municipalities a. Solid Waste Management Entities b. Evolution of Entities c. Challenges Presented by the High Number of Entities

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 2 VII. Previous Management Plans a. Reduce, Reuse, Recycle (3Rs) b. Convenient, Consistent, and Cost-Effective (3Cs) Materials Management VIII. The Future of Materials Management a. Proposed Sustainable Materials Management Vision b. Goals of the SMM Vision for Vermont c. Key Features of the Proposed Sustainable Materials Vision IX. Climate Change and Materials Management a. Effect of Waste Disposal on the Climate b. Materials Management with GHG Reduction Priorities c. Flood Resiliency and Materials Management X. Introduction to 2012 MMP a. Targeting Five Material Streams i. Recyclables ii. Organics iii. C&D iv. Toxics (HHW and CEG, and Electronic Waste) v. Residuals (Septage and Sludges) b. Tools of Action Identified i. Environmental Education ii. Product Stewardship and Extended Producer Responsibility (EPR) iii. Government Leadership iv. Infrastructure Improvements v. Mandates and Bans vi. Standards vii. Partnerships XI. Conclusion

General Materials Management State Goals, Performance Standards, and Action Items

Material Specific Management State Goals, Performance Standards, and Action Items a. Recyclables, Packaging, and Printed Materials b. Organics c. Construction & Demolition (C&D) Materials d. Household Hazardous Waste & Conditionally Exempt Generators (HHW & CEG), Electronic Waste, and Toxics e. Sludge, Septage, and Miscellaneous Residual Waste

Appendices A. Statewide Waste Composition Study 2012 (PLACEHOLDER) B. Pay-As-You-Throw Guidance (PLACEHOLDER) C. Recyclable Market Survey (PLACEHOLDER) D. Glossery of Terms

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 3 LIST of TABLES

Table 1: Total Vermont MSW diverted and disposed between 2000 and 2009.

Table 2: Landfill destination of waste disposed in Vermont by material type, and source of generation.

Table 3: Out-of-State destination of waste generated by Vermont by material type.

Table 4. Summary of Permitted Materials Management Facilities in Vermont (2011).

Table 5. Operating & Permitted Solid Waste Disposal Capacity in Vermont (2009).[3]

Table 6. Certified composting facilities in Vermont.

Table 7. CSWD Materials Recovery Facility FY2011 Data.

Table 8. - Estimated Quantities of Sewage Sludge Managed In and Out of State in 2011.

Table 9. - A Comparison of Vermont and Federal Biosolids Standards to Concentrations.(1)

Table 10 - 2011 Actual Quantities of Septage Managed In and Out of State.1 (As reported to RMS1 by All Septage Haulers Operating in Vermont). May 2012. Table 11: Solid Waste Management District Surcharges per ton of MSW and C&D over time.

Table 12: Energy savings and Greenhouse Gas reductions observed from recycling (by material).

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 4 LIST of FIGURES

Figure 1: MSW Generation Rates, 1960 to 2010. (Source: USEPA).

Figure 2a: Paper and paperboard generation and recovery, 1960 to 2010. (Source: USEPA).

Figure 2b: Metals generation and recovery, 1960 to 2010. (Source: USEPA).

Figure 2c: Glass generation and recovery, 1960 to 2010. (Source: USEPA).

Figure 2d: Plastics generation and recovery, 1960 to 2010. (Source: USEPA).

Figure 3: Total MSW Generation (by material), 2010. 250 million tons (before recycling). (Source: USEPA).

Figure 4: Total MSW Generation (by category), 2010. 250 million tons (before recycling). (Source: USEPA).

Figure 5: Vermont Population Estimates compared to MSW generated state-wide between 1987 and 2009. A per ton per person comparison.

Figure 6: Percentage of Vermont waste disposed compared to percentage diverted for reuse or recycling (including composting) state-wide between 1987 and 2009. A per ton per person comparison.

Figure 7: Management of materials generated in Vermont, and materials disposed of in Vermont as well as neighboring states, in 2009.

Figure 8: Fate of materials between 2000 and 2009. This includes some non-MSW wastes with out- of-state origins that were disposed of in Vermont.

Figure 9: Picture of Waste USA in Coventry, Vermont (photo taken December 2011).

Figure 10: Picture of WSI in Moretown, Vermont (photo taken 2008).

Figure 11: Comparative chart of all waste disposed at the Waste USA landfill for calendar years 2002 and 2009. (*OOS = Out-of-State generated waste.)

Figure 12: Comparative chart of all waste disposed at the Moretown Landfill for calendar years 2002 and 2009. (*OOS = Out-of-State generated waste.)

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 5 Figure 13: Waste composition of Vermont municipal solid waste for urban and rural communities in 2001, by percentage of material types.

Figure 14: Limited comparison of waste composition of Vermont residential municipal solid waste by percentage of material types. Data compares 2001State Waste Compositions Study to Chittenden County 2006 and 2010 Waste Composition Studies.

Figure 15: Geographical distribution of compost facilities in Vermont in 2009.

Figure 16A: Snapshot of Sewage Sludge Management, 2011. Management Strategies.

Figure 16B: Snapshot of Sewage Sludge Management, 2011. In state vs. Out of state Management.

Figure 16C: Snapshot of Sewage Sludge Management, 2011. Reused vs. Disposed.

Figure 17. – Comparison of Vermont and federal limits and typical concentration in Vermont biosolids. *Note: that this graph uses a logarithmic scale. No federal standard is established for chromium or molybdenum at 40 CFR 503.13 – Table 3. Concentrations are in units of milligrams per kilogram, dry weight. (1 mg/kg, dw = 1 part per million).

Figure 18: Solid Waste Management Entities as of August 2012.

Figure 19. The 3Rs then, and now.

Figure 20. The 3Cs: convenient, consistent, and cost effective.

Figure 21: Vermont GHG Emissions from Waste Management. (Figure and table taken from Vermont Greenhouse Gas Emissions Inventory Update: 1990 – 2008. (p. 26)).

Figure 22: USEPA Food Recovery Hierarchy is recommended as the preferred order of managing excess food.

LIST of BREAK OUT BOXES

Box 1. Defining the Components of the Materials Management Vision

Box 2. What are Biosolids???

Box 3. LFG-to-Energy Plants at Vermont Landfills

Box 4. Defining: Product Stewardship and Extended Producer Responsibility (EPR)

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 6 APPENDICES

Appendix A – Statewide Waste Composition Study Results, 2012 (PLACEHOLDER)

Appendix B – $ave-As-You-Recycle Guidance (PLACEHOLDER)

Appendix C – Recyclable Markets Survey (PLACEHOLDER)

Appendix D – Glossary of Terms

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 7 LIST OF ABBREVIATIONS

1. ANR – Agency of Natural Resources

2. D&D – Diversion and Disposal report

3. MMP – Materials Management Plan

4. SMM – Sustainable Materials Management Vision

5. SWME – Solid Waste Management Entities

6. SWMP – Solid Waste Management Plan

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 8 I. Statutory Authority

a. Act 78 adopted in 1987.

In 1987, the Vermont Waste Management law (Act 78) was adopted in response to growing concerns over health and environmental hazards observed by the mismanagement of discarded materials. As stated in the Declaration of policy and purpose “[t]he developed world continues to pollute the environment and add to the depletion of the world's resources by burning and burying resources as waste. “ (10 V.S.A. §6601(a)). Although vast improvements have been accomplished, this statement retains some accuracy as it did when it was adopted into legislation over twenty years ago.

Vermont statute broadly defines “solid waste,” requiring a comprehensive plan to facilitate sustainable and environmentally sound management practices. The overall goal of which is to reduce the amount of waste disposed in landfills, and divert as much materials for reuse and recycling (including composting). To meet this legislative requirement, the Vermont Solid Waste Management Plan (hereafter called the Materials Management Plan (MMP, or Plan)) addresses a diverse array of materials and participants affected by its management strategies. The Agency of Natural Resources (ANR) intends this document to provide forward-thinking, effective mechanisms to increase waste reduction efforts in.

b. Materials Management Plan (MMP) - formerly the “Solid Waste Management Plan (SWMP)”

As mandated by Vermont law (10 V.S.A. § 6604), “the secretary [of the Agency of Natural Resources] shall publish and adopt, after notice and public hearing…, a solid waste management plan which sets forth a comprehensive statewide strategy for the management of waste…” The statutory language also requires that the Plan be revised at least once every five years.

The initial Plan was adopted in 1989, with a Revised Plan adopted on August 31, 2001. The 2001 Plan was then readopted in 2006. Readoption resulted after thorough evaluation indicated that critical issues had not changed significantly, and that existing goals and action items continued to be an effective strategy to mitigate and manage waste generation. Additionally, it was determined that resources would be utilized best if they were dedicated to supporting ongoing efforts rather than focus on adopting a new Plan.

In 2007, a legislative mandate required ANR to evaluate the effectiveness of the current Plan, and to develop a new vision for waste management for Vermont based on the findings. (Section 293b of the 2007 Budget Bill, Appendix A). Following submittal of the Solid Waste Report to the Legislature - January 2008, ANR was required to convene a DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 9 working group of stakeholders. The Solid Waste Working Group (SWWG) was tasked with evaluating the legislative report, and to compile a list of recommended actions necessary for accomplishing goals identified in the report.

Between June and December 2008, the SWWG met six separate times. The SWWG reviewed the Solid Waste Report to the Legislature - January 2008, as well as recommendations set forth by the Life Beyond Garbage report,i and the Vermont Solid Waste District Managers Association (VSWDMA)ii. (The Life Beyond Garbage report presents the Agency’s vision for the future of materials management by promoting waste prevention as the least costly and most beneficial method to protect human health and the environment. This report serves as the basis for the five major categories of materials this MMP focuses on, in addition to the overarching themes selected to address waste production.) Contributions made by the SWWG were a driving force behind revisions made to this MMP,and in many cases are already underway. (VT House Bill 485).iii

This MMP is a significant update to the previously adopted (2001) and re- adopted (2006) Plans. Revisions integrate ten critical issues identified in the 2006 Plan, and refocus waste reduction strategies on five major categories of materials:

1. Recyclables, 2. Organics, 3. Construction and demolition (C&D), 4. Household hazardous wastes and conditionally exempt generator wastes (HHW & CEG), and 5. Septage and sludges.

Modifications to the management plan are based on analysis completed on Vermont’s waste stream, annual Diversion and Disposal reports, the Life Beyond Garbage report, recommendations of the SWWG, technical knowledge provided by ANR staff, and public comments.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 10

c. PRIORITIES Box 1. EDUCATION BREAK!!! As dictated by statute (10 V.S.A. §6604(a)(1)), key priorities for the statewide Defining the Components of the Materials Management Vision management of materials must address: Cradle-to-Cradle (C2C) is a concept focusing on the (A) the greatest feasible reduction in the life cycle management of a particular product. The amount of waste generated; goal of which is to reduce waste and toxins generated at each step in the lifecycle of a product. The 2012 MMP embraces the materials (B) materials management, which furthers the management strategies identified in the C2C model. development of products that will generate less waste; Zero Waste is the ambitious goal adopted by several states and their municipalities to attain the highest percentage of prevention and diversion (C) the reuse and closed-loop recycling of possible. With a value-retained vision of waste to reduce the greatest extent feasible the materials, the reuse and recycling markets are volume remaining for processing and expected to expand further supporting the disposal; environmental economy. The 2012 MMP also strives to achieve this through the collaboration (D) the reduction of the state’s reliance on and innovation of the people of Vermont.

waste disposal to the greatest extent feasible; Closed-loop recycling means a system in which a product made from one type of material is (E) the creation of an integrated waste reclaimed and reused in the production process or management system that promotes energy the manufacturing of a new or separate product to conservation, reduces greenhouse gases, and reduce resource extraction and waste generation.

limits adverse environmental impacts; ------

(F) waste processing to reduce the volume or QUICK Q&A toxicity of the waste stream necessary for Q: What does it mean to “dispose” of disposal. something?

Each of these priorities has been factored in to A: In its basic sense, disposal means the product is placed in a landfill where time and money is spent the planning and development of the MMP. trying to store, manage, and monitor its deterioration (if possible) to ensure it does not II. Why is a Materials Management Approach Important? contaminate the natural resources surrounding it.

a. Accessible Commodity Q: How is “recovery” related to “diversion” of materials?

A paradigm shift is underway across the A: “Recovered” materials have been removed from the waste stream in order to have their value nation that alters preconceived notions of what retained by reuse or recycling. Materials that have had their value recovered were able to do so constitutes trash. Obtaining a reduction in waste because they were separated, or “diverted,” from generation and disposal that approaches 90% or other materials destined for the landfill. more diversion is an overarching objective of many State agencies. Vermont’s interest to

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 11 progress towards this high degree of diversion has been identified in the Solid Waste Report to the Vermont Legislature – 2008, and through the Sustainable Materials Management Vision introduced in the Life Beyond Garbage reports.

A diversion rate of 90% or greater away from landfills, and incinerators is referred to in the waste reduction industry as Zero Waste.iv This term represents a materials management strategy pursued by local, state and federal agencies, as well as private businesses across the United States. Zero Waste is a forward thinking concept that encompasses the full lifecycle of a product. Product life cycle is managed for waste reduction efforts during its development, its many potential uses, and its regeneration into useful organic matter or a new primary consumer product. This overarching strategy directly reflects Vermont’s legislative directive to mitigate sending useful materials to the landfill or out-of-state disposal options. To put the concept of Zero Waste into perspective, an overarching goal of the Sustainable Materials Management Vision (further introduced in subsection VIII) is ultimately to attain Zero Waste by both reducing and reusing materials.

With adequate planning, shared responsibility, and a move towards innovative thinking, a closed loop, cradle-to-cradle management of materials is achievable. (See breakout box to the right for elaboration of these terms.) Increasing waste reduction efforts, expanding recycling markets, promoting product stewardship and extended producer responsibility (EPR), and aggressive education and outreach programs are critical aspects to the success of this management approach. These elements will facilitate the development of market forces that influence the production of sustainable materials, and celebrate inventive reuse and recycling methods. Capitalizing on availability of marketable materials allows for conservation of dwindling natural resources. b. Conservation of Natural Resources

Sustainable Materials Management is an approach that refocuses waste management efforts on programs, projects, and strategies that successfully mitigate waste generation by moving similar efforts upstream to the materials production and use process. Driving factors in altering materials management plans at a national level include escalating frustration over stagnant recyclable and compostable diversion rates, and ever-increasing waste generation and disposal rates. As with Vermont’s MMP, waste management plans revised nationally are designed to reduce waste generation, as well as mitigate a variety of consequences resulting from the consumption of natural resources.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 12 Adverse impacts observed from the production, transport, consumption, and end-of-life management of materials include more than just allocation of land for transfer stations, Material Recovery Facilities, landfills, and other materials management facilities in Vermont. Additional adverse impacts to Vermont’s natural resources resulting from waste generation include:

Off-gassing of methane from organic waste decomposition which is an identified Green House Gas (GHG)v; Emissions from the transportation of wastes by long-haul and diesel powered trucks; Thousands of gallons of landfill leachate requiring treatment per day; Use of soil as daily and interim cover when availability of beneficial use materials is sparse.

III. How much has been generated?

a. National Statistics (Summarization of EPA’s 2010 Report: Municipal Solid Waste (MSW) in the United States)

i. Trends: 1960 – 2010. It is estimated that Americans currently generate about 250 million tons of trash per year, an increase of over 160 million tons since the 1960’s. These estimates include residential, commercial and institutional waste. While the rate of increase appears to have slowed down since the beginning of 2000 (Fig. 1). It is unclear if this will be an ongoing trend or merely a brief decline due to temporary events, like a down turn in the economy. Interestingly, the per capita rate of waste generation has remained relatively stable since the 1990’s, changing by no more than about 3% (Figure 1. MSW Generation Rates, 1960 to 2010).

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 13 Figure 1: MSW Generation Rates, 1960 to 2010. (Source: USEPA).

The diversion rate – material which has been removed from the waste stream that is destined for disposal – has significantly increased since the 1960s, when the United States Environmental Protection Agency (USEPA) first started to monitor waste management nationally. A sizable change has happened since the 1980’s, growing from 10% to 34% in 2010.vi In 2010, almost 85 million tons of the total generated waste was diverted from the landfill. Approximately 65 million tons were recovered through recycling, and 20 million tons were composted.

Recyclable materials encompass a wide range of material types including: paper, plastic, metal, glass, wood, and other materials. (See Figures 2a through 2d.) Paper and paperboard generation, the most abundant material type in the market, has steadily increased since the 1960s. The recovery rate of paper and paperboard has generally paralleled the production increase. Metal generation also increased, although to a slightly lesser degree than paper and paperboard. The recovery rate of metals picked up significantly in the mid-1980s, and has also paralleled the production increase. Generation of glass plateaued, and even decreased some, since the 1980s. Mirroring that trend, recovery of glass continued to grow until the mid-1990s, and has since leveled off. Plastics generation, however, has skyrocketed since the 1960s, and the recovery rate lags DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 14 severely behind. Plastics are predicted to continue to grow at an above-average rate in the coming years.

Figure 2a: Paper and paperboard generation and recovery, 1960 to 2010.

(Source: USEPA).

Figure 2b: Metals generation and recovery, 1960 to 2010. (Source: USEPA).

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 15 Figure 2c: Glass generation and recovery, 1960 to 2010. (Source: USEPA).

Figure 2d: Plastics generation and recovery, 1960 to 2010. (Source: USEPA).

ii. The 2010 Data Waste generation and diversion is commonly examined by material type. Organic material (paper, paperboard, yard trimmings and food scraps) made up the largest component of the waste stream, at 56 percent (Figure 3. Total MSW Generated (by material), 2010). Both paper and paperboard, and yard trimmings boasted a relatively high rate of diversion. Of the 71 tons of paper and paperboard generated,

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 16 over 44 tons were recovered Other, (62.5 percent), and of the 33.4 3.4% tons of yard trimmings in the Food measureable waste stream, 19 scraps, Paper, 13.9% tons were recovered (57.5 28.5% percent). In stark contrast, only Yard 2.8 percent of food scraps were trimmings, recovered. Other material types 13.4% Wood, of note include metals and 6.4% Glass, plastics. There were about 22 Metals, 4.6% million tons of metals in the Rubber, 9.0% waste stream in 2010, 35 percent leather and textiles, of which were recovered. 8.4% Plastics, Plastics amounted to over 31 12.4% million tons, only 8 percent of Figure 3: Total MSW Generation (by material), 2010. 250 which was recovered. million tons (before recycling). (Source: USEPA).

Waste can also be considered by product type, such as containers, packaging, food, and goods (Figure 4. Total MSW Generation (by category), 2010). Over 48 percent of the most abundant product type – containers and packaging – was diverted. Paper and paperboard made up just about half of this product type, and had a recovery rate of 71 percent. Plastics, the next most abundant material type in containers and packaging (18 percent), had a recovery 1.50% rate of only 13.5 percent. Containers & Wood and glass, both a Packaging little more than 9 percent Food Scraps 21.30% of containers and 30.30% packaging, were Yard Trimmings recovered at 23 percent Durable Goods and 33 percent, 19.60% respectively. Although 13.90% Nondurable Goods steel and aluminum had 13.40% relatively high recovery Other Wastes rates (69 percent and 36 percent), they only made up 6 percent of containers Figure 4: Total MSW Generation (by category), 2010. 250 and packaging. Nondurable million tons (before recycling). (Source: USEPA). goods – those that last less

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 17 than 3 years – were recovered at a rate of 36 percent. Of the 53 tons of nondurable goods produced, over 63 percent was made up of paper and paperboard material, and more than 17 tons of the total 33. 57 tons produced were recovered. Eighteen percent of durable goods were recovered in 2010. Steel and plastics made up the majority of durable goods; 27 percent of steel durable goods were recovered, but only 6 percent of plastics were recovered. The product that had the highest recovery rate for durable goods was lead-acid batteries, with an astounding 96 percent.

iii. State of Collection There are several waste treatment technologies and facilities employed in waste management. An estimated 98,449 tons per day are put through the 633 Material Recovery Facilities (MRFs) nationwide. Similarly, 96,164 tons of waste is processed each day in Waste-to-Energy (WTE) projects across the United States. The Northeast region dominates this technology, accounting for just about 50 percent of operational WTE facilities nationally. There are about 2,000 permitted landfills across the country. Although the number of existing landfills has dropped significantly, from nearly 8,000 in 1988, the remaining landfills are much larger. The Northeast region has the lowest number (128), while the West dominates with over 700 facilities.

As of 2010, over 9,000 curbside collection programs are in place in the United States. Cities with the most successful curbside recycling programs have used variable rate pricing structures to encourage recycling participation.vii More than 90 cities and towns offer single-family residential food waste collection for composting. West coast municipalities are home to the majority of cities offering this service to their residents.

There are 10 states that have bottle bills, including Vermont. It is estimated that non-bottle bill states have a beverage container recycling rate of 24 percent, while states with bottle bills can exceed 60 percent. b. Vermont Statistics

Diversion and Disposal (D&D) reports are the compilation of Vermont’s solid waste management data. These reports have been generated annually since 1999. The D&D reports are an empirical representation of the state of waste management in Vermont for any given year. In addition to concise data presented for a particular year, the reports also include tables to compare data collated from previous years. Information provided in these reports reflects trends in materials management in Vermont over time. Moreover, they serve as a vital resource for program planning, fund allocation, and provide projections that assist in anticipating infrastructure needs in the DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 18 immediate and distant future. Strategies in this Plan have been developed with insights gained from the D&D reports, as well as national statistics provided by the USEPA.

Figure 5 provides a visual comparison between tonnage of materials generated compared to Vermont population estimates over the lifetime of Vermont’s Solid Waste Program. Between 2000 and 2009 waste generation has fluctuated, on average, to rates that are greater than 1 ton of MSW per person per year. Although during the height of the financial crisis, waste generation totals have shown a sharp decrease. This decline has been attributed to the drastic changes to consumer purchasing habits during 2008 and 2009. As the national economy recovers, it is expected that consumer purchasing will increase as will waste generation.viii

Vermont MSW Waste Generated Against State Population Estimates 700,000

650,000

600,000

550,000 Population 500,000 Estimate 450,000 Waste 400,000 Generated (tons) 350,000

300,000

Figure 5: Vermont Population Estimates compared to MSW generated state-wide between 1987 and 2009. A per ton per person comparison.

Figure 6 below represents the percentage of MSW generated per year that is either diverted or disposed. The compelling element portrayed by Figure 6 is that less than 40% of materials generated have been able to be diverted for recycling or reuse since the adoption of Act 78. Logistics, expense, and ability for municipalities to have influence over waste management contracts and ordinances factor significantly into the feasibility of materials management efforts. However, these are not the only influential factors that contribute to the success of materials management initiatives, such as DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 19 consumer behavior, which can be more difficult to modify. Although several cities across the nation are touting achievement of high diversion rates, there are far fewer states that can claim to have accomplished those rates in their entirety. The following section addresses how Vermont compares to the national average for waste generated, diverted, and disposed.

Vermont MSW Diverted and Disposed between 1987 and 2009

90%

80%

70%

60% Diverted

50% Disposed 40%

30%

20%

10%

0%

Figure 6: Percentage of Vermont waste disposed compared to percentage diverted for reuse or recycling (including composting) state-wide between 1987 and 2009. A per ton per person comparison.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 20 c. Diversion and Disposal (D&D) rates compared

Disposal and Diversion rate reports have been summarized from 2000 through 2009 (Table 1). To make direct comparisons between two different economic and technological climates, 2009 is measured against 2001 in this discussion. By comparing the two years to one another the intent is also to capture developments in infrastructure, changes to policy, and indicate the trend of material categories selected as focal points in this Plan. Note that minor deviations may exist between the D&D report calculations as reporting and evaluation methods have refined over time.

Management of materials generated in Vermont in 2009, and materials disposed of in Vermont as well as neighboring states, are represented by Figure 6. Wastes disposed in Vermont include: MSW, C&D, and wastes categorized as Other. (Wastes categorized as Other include: asbestos; bulky wastes; biosolids; contaminated soils; medical waste; paper sludge; sewer grit; and additional miscellaneous wastes.) Materials disposed in Vermont landfills originate primarily within Vermont. Only a very small percentage of waste categorized as Other may have out-of-state origins.

Table 1: Total Vermont MSW diverted and disposed between 2000 and 2009. Year Diverted Disposed 2000 33% 67% 2001 31% 70% 2002 30% 70% 2003 31% 69% 2004 29% 71% 2005 30% 70% 2006 32% 68% 2007 32% 68% 2008 33% 67% 2009 36% 64%

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 21 Desination and Percentage of MSW Disposed in 2009 for Vermont Generated Waste

Out-of-State, 16.80%

Moretown, Coventry, 27.30% 55.71%

*Chart does not include the 0.13% MSW sent to the Addison County Landfills in

Figure 7: Management of materials generated in Vermont, and materials disposed of in Vermont as well as neighboring states, in 2009.

Vermont Materials Management from 2000 through 2009

800,000

700,000

600,000 Waste Landfilled in VT (after beneficial use) 500,000

Recycling

400,000 TONS 300,000 Waste Sent Out of State (after beneficial use) 200,000 Composting 100,000

0 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

YEAR

Figure 8: Fate of materials between 2000 and 2009. This includes some non-MSW wastes with out-of-state origins that were disposed of in Vermont. DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 22 In Figure 8, the calculation of wastes landfilled both in-state and out-of-state represents tonnage remaining after subtracting the tonnage applied for beneficial use. Materials listed in the Recycling category consist of all items processed at recycling facilities, bottle redemption centers, direct to market materials, scrap metal facilities, and reuse facilities and programs. Waste sent out-of-state include the same material categories as those disposed of in Vermont landfills, that being MSW, C&D, and Other materials. Composting comprises all organic wastes diverted to organic composting facilities. The composting calculations factor in backyard composting estimates as well.

In-State Disposal

Waste disposal has fluctuated from 517,440 tons in 2001, to 577,208 tons in 2007, and back down to 508,685 tons in 2009. That tonnage includes C&D, other non-MSW waste, and MSW. It is likely that the significant decrease in disposal tonnage in 2009resulted from a variety of factors. The national economic crisis that Figure 9: Picture of Waste USA in Coventry, Vermont (photo taken December 2011). hit Americans in 2008 and 2009 are a potential explanation for the decline in disposal tonnage as a result of fewer purchases made by consumers. Additional influence on disposal tonnage may also be from an increased integration of reuse and recycling practices into the lives of Vermonters and Vermont businesses.

Between 2000 and Figure 10: Picture of WSI in Moretown, Vermont (photo 2009, the greatest increase to taken 2008).

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 23 in-state disposal rates observed was in MSW, with close to a 29,000 ton increase. The majority of MSW generated in Vermont is sent to the Waste USA landfill in Coventry, Vermont. The remainder of waste disposed in-state is sent to WSI landfill in Moretown, Vermont.

Second to MSW for in-state disposal is waste comprising the Other category, with an increase of roughly 25,000 tons between 2001 and 2009. See Table 2 for annual landfill disposal comparison by material type. While C&D disposal has decreased in the recent past, in 2009, C&D constituted nearly 20% of all waste generated in Vermont. Although, C&D has not had growth the way Other materials have, it is significant in it remains a significant portion of the waste stream.

A breakdown of wastes comprising the Other category were not clearly defined in the 2001 D&D report, making it difficult to accurately identify which waste streams in particular have increased. Of that 25,000 ton increase, roughly 19,500 more tons were being sent to Waste USA in 2009 when compared to 2001. Considering all three categories in the D&D report (MSW, C&D, and Other), the amount of materials generated in Vermont and being disposed of in the Waste USA landfill, increased by 58,000 tons from 2001 to 2009. In that same time period, the Vermont population has risen by just over 9,500 people.

Table 2: Landfill destination of waste disposed in Vermont by material type, and source of generation.

WASTE USA MORETOWN Year MSW C&D Other Other - OOS* MSW C&D Other Other - OOS* 2000 163,369 42,387 2,813 No data 99,854 16,179 1,499 No data 2001 181,866 51,692 7,885 No data 109,426 20,866 2,935 No data 2002 193,285 41,246 5,056 1,480 106,687 15,021 2,399 5 2003 202,443 53,161 5,176 148 102,689 24,586 2,263 0 2004 225,610 68,911 7,297 1,950 86,538 8,838 1,876 5 2005 234,473 80,518 5,491 797 94,560 8,981 2,632 10 2006 242,695 93,789 11,034 2,055 82,971 16,200 3,648 245 2007 227,100 78,427 28,362 3,158 107,074 7,800 3,443 52 2008 216,439 69,890 36,263 7,506 102,453 15,487 5,255 51 2009 215,734 56,406 27,350 14,747 105,788 11,285 5,732 6,295 *OOS = Out-of-State generation

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 24 Although it is not a significant amount when compared to the overall tonnage being sent for disposal in-state, there has been stark increases to the tonnage of Other categorized materials being sent to Vermont for disposal from neighboring states. (Specific quantities of materials sent to Waste USA versus WSI landfills were not identified in the 2001 D&D report, resulting in the 2002 D&D report as the most historic comparison. (See Figures 11 and 12.) In 2009, the amount of out-of-state generated waste disposed of at Waste USA increased by 4% when compared to 2002. The out-of-state tonnage sent to Waste USA in 2009 was approximately 14,747 tons. In comparison, the amount of waste sent to the WSI Landfill in Moretown, Vermont increased by nearly 5% in 2009 from the 2002 tonnage. The amount sent to Moretown in 2002 was recorded as 5 tons while, in 2009 it was reported to be 6,295 tons from out-of-state sources.

Waste Disposed at Waste USA - 2002 and 2009 Disposal Rates Compared

250,000

200,000

150,000 2002 2009

100,000 Quantities in Tons in Quantities 50,000

0 MSW C&D Other Other - OOS* Material Type as Reported

Figure 11: Comparative chart of all waste disposed at the Waste USA landfill for calendar years 2002 and 2009. (*OOS = Out-of-State generated waste.)

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 25 Waste Disposed at Moretown Landfill - 2002 and 2009 Disposal Rates Compared

120,000

100,000

80,000 2002 60,000 2009

40,000 Quantities in Tons in Quantities 20,000

0 MSW C&D Other Other - OOS* Material Type as Reported

Figure 12: Comparative chart of all waste disposed at the Moretown Landfill for

calendar years 2002 and 2009. (*OOS = Out-of-State generated waste.)

Out-of-State Disposal Overall, the tonnage of waste sent out-of-state has decreased by 51,000 tons between 2001 and 2009, see Table 3. The materials category that saw the biggest reduction in disposal or incineration of wastes was MSW. All three States that border Vermont receive materials sent for “out-of-state” disposal. New York has had the greatest decrease in waste received from Vermont between 2001 and 2009, with approximately 61,000 tons reduced. Both Massachusetts and New Hampshire have had measurable tonnage increases within that same time period. However, neither has seen an increase of more than 7,000 tons. This data suggests that although less waste has been sent out-of-state for disposal between 2001 and 2009, a larger amount is being directed to landfills in-state. Having this knowledge plays a critical role in evaluating the existing Vermont infrastructure, and identifying needs that can be anticipated for the future.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 26

Table 3: Out-of-State destination of waste generated by Vermont by material type.

Massachusetts New Hampshire New York Year MSW C&D Other MSW C&D Other MSW C&D Other 2000 1,576 3 0 44,988 2,141 1,504 74,982 8,397 227 2001 3,053 0 0 44,692 1,580 597 74,131 7,439 231 2002 2,826 0 0 54,678 1,287 504 68,655 5,475 248 2003 2,758 0 0 46,700 933 98 61,980 2,659 0 2004 6,552 0 0 60,202 2,504 628 75,115 4,824 75 2005 7,106 0 0 48,809 979 298 43,951 4,860 16 2006 15,057 347 0 51,379 5,412 484 21,505 9,508 88 2007 13,219 2 0 56,831 6,096 367 36,821 5,747 248 2008 11,226 0 0 48,574 677 270 40,732 6,769 20 2009 6,624 0 0 42,087 10,955 363 16,492 4,183 5

Household Hazardous Waste , Conditionally Exempt Generators, and Electronics A number of changes have been made to the collection and management of Household Hazardous Waste (HHW) and Conditionally Exempt Generators (CEG) over the last ten years. The 2001 D&D report did not track CEG collection. Nor did that report include data for electronics, or mercury added products collection. Participation rates at HHW events increased in 2010 to 17,678 people, up from 16,343 in 2001. This data is based on reports submitted by Solid Waste Districts, Alliances, and municipalities. These entities provided collection service for 99% of Vermont households in 2009. Although participation had a peak in 2008 with over 24,000 people, the ability to accurately track participation has proved to be a challenge. As a result, improvements in tracking and evaluating participation should be made to provide insight into HHW and CEG collection programs from year to year.

In 2010, CEG collection rates dropped to 164,404lbs from 222,643lbs in 2005; its first year of inclusion in the D&D report. Reasoning for this over 58,000lb reduction is unclear. Potential causes for this observed reduction may be a result of materials building up until the collection program became available; a decrease in generation of materials as a results of economic downturn; or potential changes in regulation resulting in different reporting requirements. Electronics collection was first included in the D&D reports in 2003. During that first year, 510,484lbs of electronics were diverted from the landfill. By 2010, that number had exponentially increased to over 1.63 million pounds (815 tons) diverted from the landfill.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 27 This data suggests a number of influences are contributing to the changes in quantities of materials collected over the years. An initial possibility being, those Vermonters are becoming more aware of what constitutes HHW and CEG and banned electronic waste. Second, that there is a possible growth in awareness of HHW, CEG, and electronics collection programs and events. A third possibility for data change over time is the potential rise of conscientious consumers and disposers in Vermont. It is difficult to pinpoint every policy or program that may have influenced diversion of HHW, CEG, and electronic wastes from landfills. Further evaluation is needed to determine if the HHW, CEG, and electronics collection programs are as successful as these numbers suggest.

Prior to 2010, collection programs funded by HHW and CEG Grants successfully diverted a combined 8,963,375lbs (approximately 4,482 tons) of electronics.

IV. Vermont’s Waste Composition

a. 2001 Vermont Waste Composition Study

In 2001, a Statewide Waste Composition Study (WCS) was contracted for the Agency. A Waste Composition Study is a thorough evaluation of the materials being disposed by Vermonters. This included residential and commercial MSW, and construction and demolition (C&D) residuals. See Figure 13, for a depiction of the data DSM Environmental Services, Inc. (DSM) reported to ANR for MSW was composition in 2001. The study found that food waste comprised 21% of the MSW samples analyzed by weight. Recyclable paper and recyclable containers comprised a significant percentage of MSW with 24% by weight as well. Reflecting on those percentages, approximately 54% of the waste disposed of by households in 2001 was recyclable or compostable. That percentage does not account for leaf and yard waste, due to the sort methodologies classifying it as “Other Waste Categories.” Additional data indicated only a small percentage of HHW (0.5%), and electronics (1.8%) amongst the materials disposed.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 28

Composisiton of Residential Waste by Weight in 2001 - DSM Study

17% Textiles 5% 21% Food Waste

7% Dirty Paper 2% Other Waste Categories

9% All Other Ferrous

Recycleable Containers

Recyclable Paper

39%

Figure 13: Waste composition of Vermont municipal solid waste for urban and rural communities in 2001, by percentage of material types.

For commercial waste generators, recyclable paper was the largest single category of materials disposed (by volume) by office and retail establishments. As one may anticipate, grocery stores and restaurants disproportionately disposed of organics. A volume-based analysis of C&D composition indicated wood waste was the greatest amount disposed followed by asphalt shingles, and clean wood.

Conducting recurring Statewide Waste Composition Studies will be essential to evaluating the effect of reuse and recycle programs on the type, and percentage of materials that comprise disposed wastes. Data from Waste Composition Studies support budgetary, and policy decisions made both at the State and municipal government level. The 2012 Vermont legislature acknowledged the importance of these studies by establishing a requirement for the Agency to conduct a statewide waste composition study once every five years. A 2012 Statewide Waste Composition Study has been contracted, and results are expected by 2013.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 29 b. 2006 and 2010 CSWD Composition Studies

In 2006 and again in 2010, the Chittenden Solid Waste Management District (CSWD) conducted two separate waste composition studies.ix After receiving training from DSM, CSWD set out to conduct seasonal waste composition studies similar to the 2001 study completed for ANR. Although Figure 14 compares the three studies based on four revised categories, the studies do not directly correlate to each other due to slight variations made to the sort categories in 2010. However, the similarities between the 2001 Statewide sort categories, and those of 2006 and 2010 are similar enough for CSWD to feel confident making a direct comparison in their independent report. For the 2010 sort, CSWD added mixed plastic to the list of mandatory recyclables which are included in the container category. Paperback books, and 6 and 12 pack beverage cartons were also added to the paper category for the 2010 sort.

Vermont ANR 2001 and CSWD 2006 and 2010 MSW Waste Composition Study Summary

60 54.5 47.5 50 46.1 2001

40 33.2 32.7 2006 29 30 2010

DISPOSED 20 16 13.7 10.6

10 5.2 5.6 6 AVG. PERCENT PERCENT AVG. WASTE OF

0 Paper Containers Organics Remainder

MATERIAL TYPE

Figure 14: Limited comparison of waste composition of Vermont residential municipal solid waste by percentage of material types. Data compares 2001State Waste Compositions Study to Chittenden County 2006 and 2010 Waste Composition Studies.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 30 c. Comparison and Observations

Three observations can be made from these three waste composition studies. It is important to recognize that the observations are limited to the CSWD waste stream, and cannot act as a proxy for the State as a whole. Despite its limitations, the following observations are worth mentioning. First the total percentage of recyclable paper disposed of in MSW has decreased nearly 5% from 2001 to 2010. Second there was a near 3% reduction in organics for the same time frame. The third observation made from Figure 14 is the near 8.5% increase in remaining waste disposed between 2001 and 2010. While diversion rates are growing, disposal rates suggest they may be increasing at a faster rate in the Chittenden Solid Waste District.

Two of the four categories that Figure 14 references (recyclables and organics), will face more stringent standards by this Plan, while the D&D discussion earlier incorporates the remaining two (C&D, and HHW and CEG). With a significant increase to general wastes discarded, a nearly stagnant diversion rate for recyclables overall, and a high percentage of organics in MSW, existing programs and infrastructure are not operating with as much success as desired. Action items introduced in this document must be implemented to improve reduction, diversion, and beneficial use of these material types. Based on the stated observations and D&D report analysis, the categories of material receiving specific attention in this document are organics, recyclables, toxics (including HHW and CEG), C&D, sludges and septage.

V. Current Vermont Infrastructure for Materials Management

a. Facilities List

It may be surprising to some that there are close to 480 certified solid waste facilities in Vermont, designed to manage the diversity of materials addressed in this document (Table 4). It is important to note that drop-off centers, like those found in Chittenden Solid Waste District, do not receive different permits for operation and therefore are combined under the category of “Transfer Station” in the Table. Several transfer stations also collect recyclables as well as organic materials which results in some duplication in facility numbers listed in Table 4. Since the re-adoption of the Plan in 2006, Greater Upper Valley and the Northwest Vermont Solid Waste Management Districts have successfully completed the recertification process to develop a lined landfill however, those projects have not been constructed yet. As such, although the projects have been removed from the “proposed, lined” landfill list, they are not added to the list of lined landfills due to their incomplete status.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 31 Table 4. Summary of Permitted Materials Management Facilities in Vermont (2011).

Facility Type Number Description Transfer stations Municipal Solid 105 88 district or municipal, 17 private. Almost all also handle Waste recyclables. Some accept wood waste and yard waste. Some host HHW events 1 to 2 times per year Tires 2 1 permitted, 1 with application pending Wood waste 1 CSWD facility, collects for McNeil plant Composting Categorical 17 Small to midsize compost facilities. All permitted under pre-2012 rule revisions, so restrictions and wastes handled are not necessarily described under current rules. Full 1 CSWD Green Mountain Compost (Williston) HHW/CEG 5 CSWD Depot (S. Burl); RCSWD Depot (at Gleason Rd. transfer station, Rutland); ACSWD Depot at the transfer station (Middlebury); NEKWMD Depot (Lyndonville, June-Oct); Northwest Vermont SWMD; Recycling Categorical 43 Small collection facilities (managing between 50 and 400 tons/year) Full 9 Single stream MRFs – CSWD Williston & Casella Rutland; Other district MRFs – WSWMD, NEKWMD, NWSWD; Privates – Gauthier, Northeast Waste, Casella Middlebury, Canusa C&D 5 All Seasons (Colchester); Marcelino (S Burl); Markowski (Brandon); Hadeka Stone (Castleton); Zaluzny (Vernon) Landfills Lined 3 2 MSW - NEWSVT (Casella, Coventry) and MLI (Moretown Landfill Inc., Moretown); 1 mineral processing waste (Omya, Pittsford) Unlined 3 2 small MSW landfills (accepting less than 1,000 tons/year) (Bristol and Salisbury); 1 C&D landfill (Burgess Brothers, Bennington) – Note: Not currently operating, may be capped or re-instated Proposed, lined 3 GUV (Hartland, cert. issued, not constructed); NWSWD (Sheldon, cert. issued, not constructed) Categorical 18 Unlined landfills that are restricted by the types of material they are permitted to accept for disposal Closed 107 Categorized as “not operating, closed.” Mostly old town dumps but also some closed stump dumps, etc. Biosolids/Septage Land Application 23 Each certification may include multiple sites Compost and other 10 Compost and/or other treatment for public distribution treatment Sludge Management 78 Treatment or storage at wastewater treatment plants where Plans biosolids are sent to another facility for treatment TOTAL: 426

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 32

Additional facility data not captured in Table 4 includes an anticipated request for approval of a significant expansion of the Waste USA landfill which is discussed further in the next section. Also, the capacity increased for the South Burlington MRF from 22,000 to 40,000 tons of recyclable material per day after the modifications were made in 2004.x The Rutland MRF converted its operation in late 2011 to a single stream facility, and the Intervale compost facility relocated to Williston under the new name of Green Mountain Compost during the summer of 2011. The most significant expansion to Table 4 in the last decade are the number of: transfer stations; closed landfills; and facility additions that expanded services provided by the existing infrastructure. Expanded services include transfer stations dedicated to tire management and wood waste, and C&D and metal recycling centers. b. Vermont Landfills

i. Capacity The two major landfills in Vermont are monitored for capacity changes annually. The most recent estimates indicate that the Waste USA landfill has a remaining permitted capacity of 5.1 million tons. The Moretown Landfill, previously the WSI Landfill, has a calculated remaining permitted capacity of 140,000 tons (Table 5). As Vermont’s landfills approach their maximum permitted capacity, available options for the State’s waste management are under consideration.

Both landfills have submitted applications to the Agency that would extend their lifespan by increasing their capacity. In 2009, Waste USA (also known as New England Waste Sciences, or NEWSVT) submitted an application to increase its capacity by had an estimated additional nine million tons. Moretown Landfill also submitted an application to increase its capacity by 4.2 million tons. Each pending application would potentially add another ten years of operational life to the existing capacity. The potential for smaller, municipal landfills to divert enough waste to expand the lifetime of both Moretown and Waste USA is minimal. Combined, the Greater Upper Valley Solid Waste District Landfill and the Northwest Solid Waste District Landfill can accept 70,000 tons annually. That amount is minor in relation to the amount that is disposed at Moretown and Waste USA annually.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 33

Table 5. Operating & Permitted Solid Waste Disposal Capacity in Vermont (2009).[3]

Remaining Maximum Permitted Capacity Capacity Estimate Fill Rate Solid Waste Landfills For Waste Based on 2009 (tons) (tons/day) (tons/year) Permit Year Waste USA Landfill, [1] Phase I, II, III & IV-1, IV-2A 400,000 Ground Survey 2,500 370,000 4/1-3/31 NEWS Landfill, [1] Phase IV- 2B, IV-3A&B, IV-4A&B 4,500,000 Not Constructed Yet WSI Landfill [2] Cell 3A & 3B 100,000 Survey 1,000 286,000 1/1-12/31 Burgess C&D Landfill (in the process of closing) 0 Estimate 1/2007 100 8,000 10/1-9/30 Totals 5,000,000 664,000

Maintains ANR Solid Waste Certification: Not planning to Greater Upper Valley Solid Waste construct in near District Hartland - Phase 1 North 250,000 200 50,000 Future Not planning to Northwest Solid Waste District - construct in near Sheldon - Cell 1 130,000 125 20,000 Future

Designing New Landfill and preparing application for submittal to ANR: Chittenden Solid Waste District – Williston

Solid waste disposed in VT landfills and landfills and waste to energy facilities in other states (2007): 563,698 Tons

[1] Waste USA Landfill. Coventry, Vermont. Also called NEWS (New England Waste Services) Landfill or Coventry Landfill. [2] Moretown Landfill. Moretown, Vermont. Previously called WSI Landfill. [3] Does not include the two 1000 TPY unlined landfills operating in Bristol Town and Salisbury and a C&D landfill in Bennington .

ii. Extending the Anticipated Lifespan As mentioned above, there is a finite time for which permitted landfills are capable of accepting permissible discarded materials. The 2009 D&D report indicated total annual tonnage disposed by Waste USA was 322,600 tons, and 123,200 tons by the Moretown Landfill. It can be inferred that if the landfills accept less tonnage annually, they will extend their operational life further into the future before reaching their maximum capacity. Moretown Landfill achieved this in 2008 and 2009 by accepting less than half of its maximum permitted fill rate thus, extending its capacity lifespan an additional year. In essence, if both landfills halved their annual tonnage totals then, their anticipated lifespan would double. Landfill permitting and operation often face extensive opposition from the community where a new facility is sited, as well as from the surrounding DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 34 communities. Acknowledging this, and the need to move away from a disposable materials based society gives VTANR reason for extending the anticipated lifespan of Vermont’s landfills. The goal to reduce the disposal rate in Vermont landfills is at the root of each performance standards contained in the 2012 MMP. Consequently, action items herein address measures necessary to lengthen the lifetime of Vermont’s landfills overall and mitigate the need to expand their waistlines. c. Composting Facilities

There were nineteen permitting composting facilities operating throughout Vermont as of 2009 (Figure 15).xi Eighteen of those facilities are categorically certified, and have restrictions on the type of organic materials permitted. Only one of the nineteen permitted compost facilities has received full certification to accept all organically classified materials under Vermont regulations (Table 6). (Subchapter 11, 6- 1101 thru 6-1105). There are currently seven different classifications for organic materials that Vermont composters may receive a permit for. The list of organic materials includes: food scraps; leaf and yard debris; manure; animal carcasses; wood waste; paper; and other organic materials that do not fall in the aforementioned classifications.

In March 2012, the state adopted revised composting regulations based on the size of facility and type of feedstock. Under these new rules, there are exemptions for small community composting, three tiers of regulation for facilities and certification requirements for anaerobic digestion facilities. Small compost facilities are not required to obtain a site specific certification, instead they register with the [Agency, SWMP] and follow the Accepted Composting Practices outlined in the Solid Waste Management Rules. Medium sized facilities are required to obtain a categorical certification, which is a less onerous certification process than a full certification. Large facilities must obtain a full certification which includes a more comprehensive public process and financial responsibility. Overall, the requirements for all types of compost facilities are more protective of the environment than the previous rules and include requirements for run- off and leachate management, operator training and finished compost maturity testing.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 35 Table 6. Certified composting facilities in Vermont. Facility Mats. Effective Facility Name Town Type Accepted* Date Exp. Date Cert. Type Over The Hill Farm Benson Composting DA. LY, WG, 4/10/2009 3/31/2014 Categorical MN Binding Site Facility Benson Composting DA, WG, MN 10/23/2008 9/30/2013 Categorical Wise Worm Burke Composting CF, LY, MN, 11/24/2009 9/30/2014 Categorical Compost WG Sandberg Farm - Corinth Composting CF, LY, MN, 7/6/2007 6/30/2012 Categorical Highfields Institute WG Fisk Haines Danby Composting CF, LY, MN, 2/20/2007 2/20/2012 Categorical Compost Facility WG Fairmont Farms East Composting CF, MN, OC 1/14/2008 12/31/2012 Categorical Montpelier Essex Composting Essex Composting LY 10/2/2008 10/1/2013 Categorical Facility Clokey/Crawford Fairfax Composting DA 8/3/2009 6/30/2014 Categorical Compost Facility Vermont Livestock Ferrisburgh Composting DA, LY, MN, 10/14/2008 9/30/2013 Categorical Slaughter & WG Processing Company Paris Farm Lyndon Composting CF, DA, LY, 7/7/2011 6/30/2016 Categorical MN, WG, OC Foster Brothers Middlebury Composting CF, LY, MN, 3/31/2006 3/31/2011 Categorical Farm WG Grow Compost of Moretown Composting CF, LY, MN, 2/25/2009 12/31/2013 Categorical Vermont WG North Hollow Farm Rochester Composting CF, LY, MN, 3/4/2009 12/31/2013 Categorical WG LaPlatte River Shelburne Composting DA, WG, MN 12/18/2009 12/18/2014 Categorical Angus Farm Green Mountain Stowe Composting DA, WG, MN 10/2/2008 10/2/2013 Categorical Soil, LLC Hudak Farm Swanton Composting CF, MN 11/18/2008 9/30/2013 Categorical Brault's Market & Troy Composting CF, MN, LY, 2/9/2010 12/31/2014 Categorical Slaughterhouse WG CSWD Organics Williston Composting CF, LY, MN, 9/20/2010 6/30/2011 Full Processing Facility WG, CP Highfields Compost Wolcott Composting DA, WG, LY, 3/3/2008 3/3/2013 Categorical MN *Material types: CF – Food scraps; CP – Paper; DA – Animal carcasses; LY – Leaf and yard; MN – Manure; OC – Other; and WG – Woody debris.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 36 d. Material Recovery Facilities (MRF)

There are nine fully certified material recovery facilities (MRF) operating in Vermont. Chittenden Solid Waste Management District (CSWD) is home to the first single stream MRF in New England.xii The MRF nearly doubled throughput following a facility upgrade in 2004. In 2011, the Rutland MRF converted to single stream. These two facilities are the largest of the MRFs scattered across Vermont. Some benefits of a single stream collection system include increasing the convenience of recycling, eliminating the complexity of separating recyclable materials by type, and decreasing the time haulers must dedicate to collection. Materials collected from haulers, transfer stations, and large generators are processed by the Figure 15: Geographical distribution of compost MRFs and prepared for sale to an facilities in Vermont in 2009. Facilities without a permit have not been verified, and may no longer end-use market. be active. (ANR is working to update facility map).

Recycling markets can generate enough revenue that in some cases, haulers are paid for the amount of material they bring to the MRF. At the CSWD MRF, haulers may receive $10 per ton of recyclables compared to paying between $80 and $100 per ton for disposal.xiii This compensation is influenced by fluctuating rates of the commodities market. CSWD received just over 39,000 tons of recyclables, according to FY2011 sales data. Recyclable paper and containers collectively generated approximately $5.1 million in revenue for CSWD in FY2011. Pricing for recyclable paper materials and containers has increased significantly in FY2011 suggesting that total revenue generated from the processing of recyclables will only be that much greater. See Table 7 for a record of market value for recyclable materials for FY2011 for the Chittenden Solid Waste District’s MRF.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 37 Growth in the industries built on the availability of marketable recyclable materials has been significant in the last decade. More entrepreneurial businesses are finding their niche in a market driven by conscientious consumers. Large commercial industries are also tapping into the recyclable markets as a method to decrease expense and broaden their customer base. The effect of which directly contributes to the state and local economy. Recycling industry employment has been recognized for its dependable positions and career expanding opportunities.xiv

Table 7. CSWD Materials Recovery Facility FY2011 Data.* Materials Total tons Avg $/ton % by weight End Use Destination Corrugated Cardboard & 15,447 154.08 39.3 new cardboard, toilet Quebec, New boxboard paper & paper towel York cores, egg cartons #8 Newsprint and mixed 15,361 96.92 39.1 newsprint, tissue Quebec, Maine, paper New York White ledger 110 242.36 0.3 writing & copy paper, Montreal, tissue Quebec RECYCLABLE PAPER 30,918 $126.00 78.7 #1 PETE Plastic Bottles 777 526.48 2 carpet, bottles, Georgia, Quebec fleece clothing #2 HDPE Plastic Bottles - 419 661.77 1.1 plastic bottles, house North Carolina, Natural vapor barrier wrap Quebec #2 HDPE Plastic Bottles - 389 489.41 1.0 plastic lumber, North Carolina, Colored bottles, playground Quebec equipment #3-7 Mixed Plastic 419 21.44 1.1 plastic lumber, China possibly new containers Steel cans 892 265.84 2.3 rebar and other steel Ontario products Aluminum 96 1,340.00 0.2 aluminum cans New York Glass - Aggregate 5,354 0.00 13.6 down-cycled into Vermont road & construction projects RECYCLABLE 8,346 $149.87 21.3 CONTAINERS TOTAL RECYCLABLES 39,264 100 RESIDUE (% shown is of 3,918 9.1 landfills Coventry & total outgoing material) Moretown landfills TOTAL (w/ residue) 43,182 *Table accessed from CSWD website: http://www.cswd.net/wp-content/uploads/2010/10/MRF_info_FY11.pdf

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 38

e. Residual Wastes (Septage and Sludges)

Wastewater from approximately 47% of Box 2. What are Biosolids??? the state’s population is treated at wastewater Biosolids is a term which applies treatment facilities (WWTFs). Septic systems specifically to sewage sludge which has been serve the remaining 53% of the state’s treated and shown to meet the standards population. Using national estimates, the such that it can be managed by beneficial wastes that each person flushes to wastewater use. Beneficial use includes land application treatment facilities each year, on average, or further treatment to produce compost or generates about 50 dry pounds of sludge per similar products. Disposal includes year (equivalent to 2500 pounds at 2% solids). dewatering followed by landfilling or The 1987 Vermont Septage and Sludge incineration. Management Plan estimated that each person In 1987, nearly all of the biosolids being using a septic system generates about 70 generated in Vermont were land applied, gallons of septage per year. These estimates but only a few of these land application are still considered to be generally valid in operations had Agency certification. By 2012. 1997, only 40% of biosolids were beneficially reused, with the remaining 60% disposed of i. Septage by landfilling or incineration, and all facilities Septage is managed primarily by were fully certified. Then, in 1998, several treatment at WWTFs (which results in wastewater treatment facilities ceased increased production of sewage sludge), landfilling or incinerating biosolids and the amount of biosolids beneficially used incineration at out-of-state facilities, or by increased to approximately 74% of the direct land application. The biochemical amount generated. oxygen demand (BOD) and solids content of septage are much higher than that of By 2011 the amount of biosolids reused regular wastewater entering a WWTF, and had dropped to approximately 28%. It is requires 30 to 70 times more treatment expected that the reuse of biosolids will again increase in coming years as several capacity than an equivalent volume of major wastewater treatment facilities and regular wastewater. This treatment possibly several solid waste management process also results in a higher production districts complete construction of systems of biosolids than an equivalent volume of that further treat biosolids and cease wastewater. landfilling as their management strategy.

In 1985, 22% of the septage pumped out of tanks were transported to WWTFs, and 78% was directly land applied. In 2011, more than 43 million gallons of septage was pumped in Vermont. Approximately 38% of that volume treated at WWTFs was reused

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 39 for biosolids, or directly land applied. (See Figure 16A through 16C, for sludge management in 2011).

As a result of uneven distribution of septage management options within the state, some septage is transported great distances for land application or treatment. Currently, there are only seven certified land application facilities, with six of these facilities located within 10 miles of Interstate 89. The number and location of wastewater treatment facilities with the ability to take septage also results in significant hauling distances for septage from some areas. ii. Residual Wastes (Sludges)

The volume of sludge produced by the treatment of drinking water supplies has not been tracked by ANR. Previous pilot projects for the Champlain Valley Water District have applied residuals as a soil amendment intended to immobilize phosphorus on agricultural lands. Currently, municipally managed residuals are disposed by landfilling. Similar to sludge produced by drinking water supplies, ANR does not fully track the volume of wood ash and fiber management wastes generated by industry (the de minimis volume for reporting is 500 tons per year). However, significant amounts of wood ash and short paper fiber are managed by private sector companies via application to agricultural lands and in reclamation projects. For all practical purposes, the only disposal options available for wastewater treatment sludge are landfilling or disposal at one of the three nearby out-of-state incineration facilities.

Table 8. - Estimated Quantities of Sewage Sludge Managed In and Out of State in 2011.* Management In-State Out-of-State Total Percent Percent Option (wet tons) (wet tons) (wet tons) of Total Managed Beneficial Uses: Land Application 7,658 0 7,658 13.6% EQ Biosolids 7,652 824 8,476 15.1% Subtotal 15,310 824 16,134 28.7% Non-Beneficial Uses: Landfill 36,503 2,420 38,923 69.3% Incineration 0 1,110 1,110 2.0% Subtotal 36,503 3,530 40,033 71.3% Total: 51,813 4,354 56,167 100% 100% Percent of Total 92.2% 7.8% In & Out of State *All reported quantities have been converted to wet tons at 15% solids to allow meaningful comparisons. As a result, these tonnages may differ from the scale house tonnages reported by the receiving facilities. Source: Vermont DEC Residuals Management Section, May 2012.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 40

A. Management Strategies EQ - 15.1% 13.6 15.1 2 incineration - 2.0%

landfill - 69.3% 69.3 land application - 13.6%

7.8 B. In state vs. Out of state

in state - 92.2% Management

out of state - 7.8% 92.2

28.7

reused - 28.7% C. Reused vs. Disposed 71.3 disposed - 71.3%

Figure 16(A-C): Snapshot of Sewage Sludge Management, 2011.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 41 iii. Biosolids The success of Vermont’s efforts to prevent excessive nutrients and oxygen- consuming solids (which factor into the biological oxygen demand (BOD) of lakes, rivers, and streams) from entering surface waters through wastewater treatment has led to the generation of approximately 93 million gallons of sewage sludge (at 2% solids) in 2011. The quantity of sewage sludge increase is due primarily to improvements in treatment, with many facilities increasing the amount of phosphorus removed from wastewater. A smaller portion of the increase is due to the increase in population.

All 32 facilities that either land apply or further treat sludges or septage in Vermont are certified by the Agency. Monitoring data on the quality of Vermont biosolids collected over the years provides some record on the concentrations of metals and other potential contaminants in biosolids. Similarly, extensive monitoring of the groundwater, soils, and crops raised on land application sites consistently demonstrate a lack of adverse impact from these management strategies. Table 9 and Figure 17, compare Vermont and Federal standards to concentrations for biosolids illustrates that in general, Vermont biosolids have low metals content.

With the increase in regulatory oversight of land application and composting since 1987, and the improvements in biosolids quality, beneficial reuse options are more environmentally sound than ever before.

Table 9. - A Comparison of Vermont and Federal Biosolids Standards to Concentrations.(1)

Element Vermont Federal Average Concentration in Percentage of Standard Table 3 Vermont Biosolids (3) Most Restrictive Standard(2) Standard

Arsenic 15 41 10.47 (5) 69.8%

Cadmium 21 39 6.08 (5) 29.0%

Chromium 1200 N.S. 58.69 (5) 4.9%

Copper 1500 1500 783.80 52.3%

Lead 300 300 112.14 37.4%

Mercury 10 17 2.58 25.8%

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 42

Molybdenum 75 N.S. 15.54 20.7%

(5) Nickel 200 420 34.82 17.4%

Selenium 100 100 5.07 (5) 5.1%

Zinc 2800 2800 994.52 35.5% (1) All concentrations are in units of milligrams per kilogram (mg/kg) on a dry weight basis. 1 mg/kg = 1 part per million

(2) Federal standard is from 40 CFR Part 503.13 - Table 3

(3) Vermont data are average concentrations detected in a 1997 study of Vermont biosolids quality

(4) N.S. = no standard established

(5) Actual concentration was lower than the analysis detection limit in more than 60% of the samples analyzed

10000

1000

VT limit 100 Federal Table 3 limit

Average VT concentration 10

1

Figure 17. – Comparison of Vermont and federal limits and typical concentration in Vermont biosolids. *Note: that this graph uses a logarithmic scale. No federal standard is established for chromium or molybdenum at 40 CFR 503.13 – Table 3. Concentrations are in units of milligrams per kilogram, dry weight. (1 mg/kg, dw = 1 part per million). DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 43 Table 10 - 2011 Actual Quantities of Septage Managed In and Out of State.1 (As reported to RMS1 by All Septage Haulers Operating in Vermont). May 2012.

Management In-State Out-of-State Total Percent Percent Option (gallons) (gallons) (gallons) of Total Managed Beneficial Uses: Land Application2 11,704,306 196,000 11,900,306 27.5% EQ Biosolids3 3,675,290 1,086,889 4,762,179 11.0% Subtotal 15,379,596 1,282,889 16,662,485 38.5% Non-Beneficial Uses: Landfill4 0 0 0 0.0% Incineration 0 3,430,222 3,430,222 7.9% WWTF 21,211,141 1,946,355 23,157,496 53.5% Subtotal 21,211,141 5,376,577 26,587,718 61.5% Total: 36,590,737 6,659,466 43,250,203 100% 100% Percent of Total 84.6% 15.4% In & Out of State 1 Includes all septage generated in Vermont regardless of where disposed, and all septage disposed in Vermont regardless of where generated. It is estimated that <1% of the total volume is generated out-of-state and disposed in Vermont. 2 Includes septage that is directly land applied or which is disposed at a WWTF that manages biosolids via land application. 3 Includes septage that is directly treated in an EQ process or disposed at a WWTF that produces EQ biosolids. 4 Includes solids from dewatered septage that is disposed at a landfill.

f. Cost of Materials Management in Vermont

In 1999, DSM conducted a study on the cost of waste management activities in Vermont. This study was repeated again in 2005 to follow up on the initial findings and collect data to allow for a comparison of expenditure changes over time. The 2005 report was contracted by ANR on the belief that tracking fluctuations in solid waste services can serve as a litmus for comparing the influences on waste generation and diversion rates. The findings were summarized in the DSM report, “The Price of Solid Waste Management Services in Vermont – 2005,” (Price of Waste).xv Data collected from the 1999 and 2005, Price of Waste studies are discussed here to highlight the numerous costs associated with materials management that are often difficult to evaluate and report accurately.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 44 i. Curbside Collection and Drop-off Availability of curbside collection for MSW has yet to reach all Vermont households. An estimate made in 2005, indicated participation in curbside collection may have been as high as 60%. Due to Vermont’s rural landscape, lengthy hauling routes often create financial disincentive for homeowners to pay for curbside collection. As a result, there are just under 100 drop-off centers and transfer stations permitted throughout the state. Between 1999 and 2005, the charge for weekly curbside collection increased an average of 22%, from $23.75 to $30.84 per month. Increases in the monthly costs were also observed for dual curbside collection for the same time period that includes MSW and recyclables, of approximately 13%.

Drop-off centers and transfer stations vary in the structure of their fee system. Many solid waste management districts (Districts) and other municipal entities have some form of volume or weight-based fee structure system, commonly referred to as Pay-As-You-Throw (PAYT) or unit based pricing. Resident and non-resident rates, as well as the rates for bulky materials and household hazardous wastes, differ between

Table 11: Solid Waste Management District Surcharges per ton of MSW and C&D over time.

# of per # of Increase Towns Est. capita Towns Est. per capita $/Ton Member in pop. $/Ton fee in pop. $/Ton fee from 2008 Districts 2008 2008* (2008)* (2008) 2011*** 2010** (2011)*** (2011)*** to 2011 Addison County 19 30,930 $33.40 $0.00 19 31,170 $33.40 $0.00 $0.00 Central Vermont 22 61,860 $21.00 $4.43 18 50,545 $30.00 $2.86 $7.43 Chittenden 18 155,027 $17.61 $0.00 19 156,545 $22.06 $0.00 $4.45 Greater Upper 10 19,381 $18.00 $8.57 10 18,265 $23.00 $18.07 $14.50 Valley Lamoille 12 27,341 $16.50 $0.00 12 26,679 $18.50 $0.00 $2.00 Regional Northeast 44 37,624 $19.25 $0.00 44 41,716 $22.55 $0.00 $3.30 Kingdom Northwest VT 15 33,347 $22.00 $1.43 16 39,492 $22.00 $1.43 $0.00 Rutland County 17 49,102 $16.97 $0.00 16 47,279 $16.97 $0.00 $0.00 Southern 13 34,828 $5.00 No 13 31,291 $5.00 $0.00 $0.00 Windsor/ data Windham Windham 19 34,490 $0.00 $12.90 19 37,451 $0.00 $17.74 $4.84 *Data taken from District Rate Comparisons 2008. ** Population estimates are based on UVM Center for Rural Studies (CRS) - based on 2010 US Census ***Data taken from VSWDMA Comparison of District Fees and Surcharges - Dec 2011. Per capita fee converted to per ton, based on an assumption of 1 ton generation per capita per year with a 30% diversion rate. DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 45 Districts. While the 2005 DSM study reported an average charge of $2.44 per bag, that average fee was based on an assumption that the average weight of a single bag disposed was 23.5lbs.xvi Table 11 below provides District surcharges, and per capita fees between 2008 and 2011 for comparison of cost increases of MSW and C&D.

To the average person, these costs may provide little information as to how it affects them at a personal level. For perspective, in 2005, it was estimated that households and businesses spent over $100 million on management of MSW when multiple expenses relating to waste management, such as the franchise and tipping fees, are considered.xvii That breaks down to an estimated $200 per household per year if total waste management costs were divided amongst the population of Vermont equally. With knowledge gathered from the annual Diversion and Disposal reports prepared by the Agency, it is known that approximately half of what is thrown out can be recycled or composted. When disposal costs are tied to a Pay-As- You-Throw (PAYT) system, households have more control over their annual disposal costs. The American economy has changed a great deal since the 2005 waste expense estimate was made. Considering the increase to the amount of materials discarded each year, District surcharges, and fuel pricesxviii it is reasonable to assume that annual expenditures have far surpassed $100 million/year estimated seven years ago. With one of Vermont’s two landfills nearing its permitted capacity, the expense of waste disposal is anticipated to increase.

In regards to proposed mandates on recycling and organics collection statewide, Vermont House Representative Robert Lewis (R- Orleans) stated, “the cost of disposing solid waste is going to be astronomical if we don’t address it.”xix

An obvious, but often neglected, fact is that waste management costs can be reduced greatly with strict adoption of reduce, reuse, and recycle methodologies. Providing Vermonters with the tools and knowledge to divert materials is a priority of the MMP. Refocused efforts are anticipated to result in a mutually beneficial relationship that accomplishes cost savings desired by residents, and boosts the State economy through the recyclable and organics commodities markets. ii. Recyclables and Organics Recyclable materials are often accepted free of charge. A few regions across Vermont have reported a minor fee for recyclables averaging $0.92 in 2005. Some facilities apply a charge if recyclables are dropped-off without trash, or if the materials are being taken to privately owned drop-off centers. However, it is a reality

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 46 that materials management is not a system without expenses. The manner in which entities choose to incentivize waste reduction and diversion absorb those expenses often differ, resulting in the diverse pricing mechanisms observed across the State. For instance, the Mad River Resource Management Alliance - Waterbury facility currently charges as much as $3.00 per 30 gallon bag for recyclables, just $1.00 less than MSW for the same volume.

National interest in food waste management practices has led to significant market support for development of organics collection programs within the last decade.xx Organics were not included in the 1999 and 2005 DSM pricing studies because of the lack of data available. Leaf and yard residuals, and food scrap residuals collection is not yet available at all certified transfer stations in Vermont. Despite the slow expansion in availability of collection services in-state, many Solid Waste Management Districts allow for organic materials to be dropped-off at their transfer stations. In the case of Chittenden Solid Waste District, food scraps are free of charge. iii. Commercially Generated Materials

Businesses discard a significant amount of materials. In 2005, charges for MSW and C&D per ton were $95.85 and $98.00 respectively for businesses on average. Single stream recycling averaged just over $4.00 per 64 gallon tote, while cardboard and office paper were close to $3.30 per cubic yard or 64 gallon tote for commercial entities. Commercially generated materials typically incur charges for their recyclables as a result of the higher quantities of materials that they generate. Those large quantities of materials whether destined for disposal or recycling, tend to require more labor and transportation to manage than an individual household would on its own. This, in effect, makes it more expensive for waste management entities to process therefore creating the need for those entities to charge commercial generators for using their services.

Several elements factor into the indicated costs faced by businesses. In 2005, District surcharges were reported as one of the greatest influences on variance in price per ton for businesses. Transportation cost is an additional major contributor to the total cost of materials management expenses. Other associated materials management costs DSM identified include, but were not limited to:

- Delivery and rental of roll-off containers - Proximity to other generators - Type of containers leased - Type and weight of materials DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 47

Where disposal tonnage was indicated as a separate line-item from dumpster pull (transport) and rental charges, the disposal tonnage averaged $98.00 per ton. The average dumpster pull cost $105.83. As with all other recycled materials, where C&D materials are recycled they are exempt from the State Franchise Fee of $6.00 per ton as well as District surcharges. Other financial incentives to divert C&D for recycling were in the form of reduced tipping fees.

g. Call for a Comprehensive Infrastructure Assessment

As the discussion of existing services and associated costs emphasize, knowledge of Vermont’s infrastructure has significant data gaps. A comprehensive evaluation of the availability of District services will identify those elements needed to advance the action items presented in this MMP. That analysis will be completed as part of a larger Agency reporting directive issued during the 2012 legislative session (Act 148). Without having thorough knowledge of the services offered, the size of the population they are available to, actual participation rates, and administrative cost associated with those services it is difficult to determine where the strengths and weaknesses of the infrastructure lie. A comprehensive analysis will also yield information gaps that are not known by the Agency. Identifying these data gaps is the first step to enhancing the existing infrastructure to achieve the convenience, consistency, and cost-effecting services the MMP strives for.

VI. Materials Management and Municipalities

a. Solid Waste Management Entities

Law states that “municipalities are responsible for management and regulation of the storage, collection, processing and disposal of solid waste within their jurisdiction in conformance with the state solid waste management plan…” (24 V.S.A. §2202a). Act 78 and the 1989 Solid Waste Management Plan were devised in a manner that municipalities, individually or cooperatively, would develop management programs, facilitate flow of materials to appropriate certified facilities, and control revenues associated with management of materials within their region. The time consumption, resource needs, and costs affiliated with materials management are demanding and burdensome on small municipalities. These compounding responsibilities have resulted in municipalities combining their efforts by formulating districts, alliances, groups, and agreements. Collectively these organizations are referred to as “entities” by the Agency.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 48 In order for municipalities to dispose of waste in Vermont they must hold ANR- approved Solid Waste Implementation Plans (SWIP). (24 V.S.A. §2202a(c)(3)). For a SWIP to be approved it must demonstrate consistency with the current MMP, and identify mechanisms it will use to meet the performance standards held within the Plan. (Recognizing that this is an oversimplification of the SWIP review process, it is intended to provide a brief summary of the elements SWIPs must include.) Rather than developing an individual SWIP for each town, the combined organization can develop and submit one document to the state on behalf of all its member towns and cities. There are significant benefits beyond SWIP development that provide incentive for independent municipalities to join others in a contracted partnership for waste management purposes. Such benefits include lower cost, and expended materials management services for their townspeople.

A majority of municipalities in Vermont have joined a SWIP entity or have pursued their own SWIPs. Of the 255 municipalities in Vermont, 230 are members of an entity (Figure 18). State laws do not limit the number of entities that may exist in Vermont, only the authority and privileges bestowed upon entities with ANR approved SWIPs. As a result, there are 41 entities: 10 Districts; 6 alliances/groups; 20 individual towns; and 5 without approved plans. The towns that do not hold an Agency-approved SWIP are not permitted to dispose of their town’s waste at a certified Vermont facility, nor are they permitted to operate a certified solid waste facility, nor receive ANR solid waste grant funding.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 49 Figure 18: Solid Waste Management Entities as of August 2012. DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 50 b. Evolution of Entities

As town and city needs have changed, so too has the composition of solid waste management entities. In 1989, there were six Districts. In 2001, there were ten Districts (164 member towns) and three inter-municipal organizations (24 towns) that were responsible for materials management in their region. To reduce redundancy in efforts and consolidate administrative needs, while maintaining some autonomous control over their particular town, some municipal officials have elected to form alliances. A majority of towns and cities have elected to relinquish that control to a larger Solid Waste Management District which typically aligns with county boundaries. The numbers of entities have not changed significantly in the last decade outside of a few modifications to which member towns/cities are party to what organization. As of August 2012, there are only 5 towns out of the 255 in Vermont, without an approved SWIP. That number is down from 18 towns in 2001 that were not part of an approved solid waste implementation plan. Over time these entities have developed, to varying degrees, a local infrastructure to facilitate the flow of materials.

Successes for the planning entities have been significant. However, a weakness has been anticipating and managing roadblocks. Although entities differ in their structure and management style, they each share the same expectations for meeting MMP performance standards. While there ostensibly exists a collective goal of sustainable materials management, the methods by which this is achieved vary drastically. A lack of cohesion between entities often perpetuates difficulties in obtaining convenient, consistent, and cost effective (3Cs) programs envisioned by the MMP. c. Challenges Presented by the High Number of Entities

To date, there are 36 entities operating in Vermont under approved SWIPs. All SWIPs submitted are evaluated according to the same criteria and standards. Entities have extensive flexibility as to the methods chosen to meet the performance measures MMP, as long as the entity meets or exceeds Solid Waste Management Program expectations as they are laid out in the MMP.

Concerns have been raised by the Vermont legislature about the existing number and structure of management entities. First there is extensive redundancy, and potentially competing, efforts between entities. Second, there may be inefficient expenditures of State and municipal funds as well as human resources. Duplication should be avoided to allow for allocation of funds to underdeveloped programs and provide stimulus to initiate others. Third, inconsistencies are apparent in the availability and cost of services, and ordinances

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 51 adopted between entities. These three concerns are compounded by the diversity of perspectives on waste management.

That is to say that when the strategy of having towns form into districts following the adoption of Act 78, the thought was that different areas of the state had different needs, demographics, funding, and should have some degree of freedom to dictate what their public services would entail. Unfortunately, there are some basic programs that must be implemented statewide in order to meet diversion goals, and cultural differences between areas of the state are not so significant as to require alternate management services.

It is true that municipal needs often differ based on their geography, population, and proximity to established infrastructure. That being acknowledged, there should be fundamental elements that Vermonters can expect regardless of location. Such elements should include collection of recyclables and organics in parallel with the collection of MSW, for example. When fundamental elements are not provided, the convenience of diversion is quickly lost in the confusion of varying materials management priorities.

VII. Previous Management Plans

a. Reduce, Reuse, Recycle (3Rs)

For several decades now, children are learning at a very early age the importance of reducing waste generation, reusing materials when possible, and recycling as much of the materials as possible. The 3Rs are so ingrained into formative education that elaborating on the abbreviation is seldom required. Curriculum has been devised to make recycled paper from scraps, conduct classroom waste composition studies, and develop performances that are attended by the entire school. Environmental education programs are extending beyond grammar school into middle and high school to continue to develop environmental literacy skills.

The 3Rs are an admirable success that has formed a lasting impression in that it is readily recognized by so many. Where it has decreased in effectiveness is partially a result of the complexity of the waste that is being generated in a post-industrial, post-Silicone Valley era. While the 3Rs will be solidified in their original verse, the SMM approach hopes to expand affiliation of the 3Rs to reflect 21St century intellect. Herein lies the evolution of the 3Rs from the 20th century end-of-life focus to reflect the 21st century upstream vision (see Figure 19).

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 52 Reduce

REDUCE REUSE

Rethink

Recycle Reuse RECYCLE

Figure 19. The 3Rs then, and now.

The intent of each step is retained but has been reformated to emphasize the control and innovation consumers have. Awareness when making point-of-purchase choices, expanding beyond traditional uses of materials, and envisioning the fleece jacket or bench the materials may become in a renewed life is essential to the sustainable materials management approach. Presenting the 3Rs with the addage of “rethinking” what it means to partake in reduce, reuse, and recycle actions maintains childhood associations, while enabling the curiosity for the mind to explore connections that may have gone unrecognized. The goal of the message being to think outside of the box in terms of identifying solutions to the materials management problems at hand. Innovative perspectives will be an essential element to achieving the goals and performance measures of the MMP.

b. Convenient, Consistent, and Cost Effective (3Cs) Materials Management

The 3Cs were identified in the 2008 Solid Waste Report to the Vermont Legislature.xxi In that report, the 3Cs were presented as one of several recommendations proposed to address deficiencies in Vermont’s solid waste management system. (See Figure 20).

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 53 The 3Cs are geared towards the materials management industry. Broadening the percentage of the population that adheres to the 3Rs will continue to be difficult to Consistent achieve, as observed from the past two decades, without improvement on the 3Cs. Aiming to provide convenient, consistent, and Cost cost-effective services for all Vermonters will Effective be considered when evaluating new and existing programs. These efforts will be Convenient coupled with ANR’s comprehensive outreach and education initiatives, discussed later in this MMP, to facilitate attainment of Statewide goals. All stakeholders in the materials

management industry must prioritize the 3Cs to Figure 20. The 3Cs: convenient, consistent, and improve options for Vermonters. Decisions based cost effective. on the 3Cs should also be forward-thinking in order to factor capacity changes associated with increases to diversion rates.

VIII. The Future of Materials Managementxxii

a. Proposed Sustainable Materials Management Vision

In order to meet the goals of the Vermont Materials Management Plan to reduce solid waste generation in Vermont and reduce reliance on disposal options, a new and innovative vision and approach are required. The vision and approach must address how Vermonters think about “waste” and “waste management”, and the adverse impacts of waste management. In addition, the vision and approach can and should help Vermont achieve sustainable growth and community development goals.

The Agency proposes the new Sustainable Materials Management Vision (Vision) for Vermont. A paradigm shift away from a discards management method.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 54 b. Goals of the SMM Vision for Vermont:

To promote sustainable materials management,

To prevent waste from being generated,

To minimize reliance on waste disposal, and

To minimize energy consumption, green house gas emissions and other adverse environmental impacts.

Vermont will refocus efforts to follow the priorities of Act 78 and Act 148, by working initially to reduce the amount of waste generated. To support those efforts, the Agency will continue to require diversion efforts in this Materials Management Plan that contribute to reducing overall waste generation by residents and businesses in Vermont.

c. Key Features of the Proposed Sustainable Materials Vision

1. Focus on Sustainable Materials Management: The state’s current model focuses on “end of pipe” waste management options. A sustainable material model is more focused on “upstream options” preventing or minimizing waste generation while using resources more effectively. A sustainable materials model would include product stewardshipxxiii and involve all stages and players in a product’s life cycle (which includes the extraction of raw materials, manufacturing, distribution, retail, consumption, and end-of life management). Vermont will need to work in partnership with national, regional, state, and local efforts. Ultimately, the shift in waste management perspective would be from the existing management strategies of “cradle-to-grave” to a revised “cradle-to-cradle”xxiv model.

2. Share Responsibility: Tackling the complex problem of reducing waste requires an integrated approach involving all residents, businesses, manufacturers, and institutions, rather than placing the primary responsibility on government and municipalities. Efforts need to be made to engage everyone in discussing the benefits of this approach. Education and outreach will be critical to promote an awareness of choices, including purchasing and the avoidance or management of unwanted material. Fostering product stewardship, as one method of shared responsibility, will include working with businesses and manufacturers, including those beyond our state borders, as well as solid waste districts, municipalities and governments.

3. Establish Statewide Waste Generation Goal: Vermont currently has a goal of diverting 50% of the waste generated from being disposed in landfills. Diverting waste from DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 55 disposal is accomplished though reuse, recycling, composting and other similar activities. While promoting diversion of waste is good, it does not address the total amount of waste that is generated, which has increased dramatically since 1987. Waste generation has increased in tandem with consumption. Vermonters should consider reducing waste generation as a goal as well.

4. More Integrated State-wide Strategies and Implementation: To be successful, all Vermonters need to have access to convenient, cost-effective, and consistent programs, services, and facilities. The plan must address the disparities that exist between different areas of the state. New strategies need to be developed and implemented to achieve state- wide success. Developing a sustainable materials economy means collaboratively working throughout the state with solid waste districts, economic developers, waste haulers, processers and businesses. Also a focus on “upstream” strategies will need a statewide (and sometimes regional and national) approach for promoting product stewardship and other similar initiatives.

5. Expand Current and Create New Partnerships: Working with others to implement this Sustainable Materials Vision will be essential. ANR will be a central partner in a large and diverse group of public- and private-sector stakeholders, such as those involved in sustainable materials management, developing businesses, and promoting better awareness of impacts of consumer choices. Partners will be both in-state and out-of-state organizations.

6. Continue to Meet Ongoing Responsibilities: While moving forward with this Vision, ANR will continue to meet its ongoing responsibility to protect human health and the environment, including oversight of solid waste activities such as responsible management and disposal of solid waste.

7. Expand Criteria Used When Making Decisions: Decisions on waste management strategies currently focus on volume, toxicity, and cost. The decision making criteria should also include other environmental impacts, such as energy use and green house gas emissions.

8. Improved Measurement Methods: New tools and measurements will be developed, where necessary, and implemented to better and more effectively measure progress towards the vision’s goals. Current measures involve amounts of waste, disposed or diverted. New measurements of success may also include: the number of business start ups, jobs created, businesses incorporating recycled materials into their products, reductions in materials and energy consumed, and reduction in green house gases emitted.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 56 X. Climate Change and Materials Management

a. Effect of Waste Disposal on the Climate

Waste management activities are identified as top leading contributor to greenhouse gas emission generated nationally, as well as in Vermont. In 2008, Vermont waste management activities (solid waste, as well as wastewater treatment efforts) were estimated as the sixth highest contributor of GHG emissions in the State.xxv Between 1990 and 2008, waste management generated 1.66 MMTCO₂e (Million Metric Tons CO2 equivalent) for the six years that emissions were surveyed. While the amount of GHG emissions generated in 2008 has reduced to 0.27 MMTCO₂e, down from 0.31 MMTCO₂e in 2000, Vermont is still above its 1990 level of 0.24 MMTCO₂e generated. (See Figure 21). Reasons for the decline are attributed to the length of time smaller landfills have been closed, and landfill gas-to-energy (LFG-to-Energy) plants. Landfills that have been out of operation for 10 or more years release less GHG per year on average as the decomposition rate of disposed organics decreases.

At a national scale, landfills are ranked as the third highest contributor to methane production in 2009.xxvi (The two highest producers were natural gas systems, and enteric fermentation respectively.) This is equates to approximately 17% of all human-related sources of methane.

Vermont GHG emissions rate was last measured at 8.37 MMTCO₂e in 2008. Box 3. LFG-to-Energy Plants at Vermont Statute Act 209, adopted in 2008, Vermont Landfills and Executive Order 07-05 require a Landfill gas-to-energy plants (in reduction of the statewide GHG emissions operation at both of Vermont’s from the 1990 baseline by 25% at the end of largest landfills), are systems that 2012, and by 50% by 2028. The 1990 harvest landfill gas and convert it into usable electricity. statewide baseline is 8.11 MMTCO₂e. LFG-to-Energy technologies at Although waste management is not the Moretown generate 3.2mW/year greatest contributor to GHG emission when from two engines. That provides compared to other sectors, it is a low power to approximately 2,800 homes annually. Coventry xxvii hanging fruit. Landfilling organic generates 8mW from four materials results in the production of engines operating and a fifth methane gas. This gas is over 20 times more available for use. That megawatt potent than carbon dioxide is in its heat capacity provides power to almost 8,400 homes annually. trapping abilities. While collection of methane gas at landfills for conversion into

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 57

energy is an option for managing the GHG, it is an inefficient option.xxviii Modern landfill designs typically lack the high number of collection wells necessary to capture even a third of the methane generated from the decomposition of organics.xxix Beyond reducing the amount of methane released from landfilling organics, there are several other benefits observed by diverting organics from landfills. Such benefits include: decrease in emissions from operational and transport equipment, need for fertilizers will decline therefore reducing fossil fuel consumption, and increases in carbon sequestration by plants through use of compost.xxx For purposes of reducing the effect of Vermont’s solid waste management system on climate change, ANR advocates for more efficient methods of managing organic residuals by promoting the materials management hierarchy for organic materials as adopted in Act 148.

Figure 21: Vermont GHG Emissions from Waste Management. (Figure and table taken from Vermont Greenhouse Gas Emissions Inventory Update: 1990 – 2008. (p. 26)).

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 58 b. Materials Management with GHG Reduction Priorities

As closed landfills continue to decline in their methane production, and WTE plants expand their operations the management of methane production from organics previously disposed in landfills will reduce. Along with those reductions, the legislative mandates and bans adopted in Act 148 will serve to divert organic materials from landfills. Options to accomplish this are outlined in by Vermont and USEPA recommended hierarchy of options previously discussed. The accomplishment of this will allow for the statewide reduction of GHG, and move closer towards reaching the executive and legislative goals established in 2008. The MMP targets waste management GHG emissions contribution by requiring implementation of composting programs in schools, increasing the diversion of organics both at home and on-the-go, and advancing education and outreach efforts as they relate to organics. Table 12 provides average energy savings and GHG reduction rates reported by the USEPA.

Table 12: Energy savings and Greenhouse Gas reductions observed from recycling (by material) :xxxi

Environmental Benefits from Recycling (USEPA, 2006) Avoided GHG emissions Material Energy Savings (MBTUs/ton) (MTCE/ton of recovered material) Aluminum cans 207 3.7 HDPE/LDPE 51-56 0.38-0.46

PET plastic 53 0.42

Steel cans 20 0.49 Newsprint 17 0.76 Corrugated 16 0.85

Phone books 12 0.72 Office paper 10 0.78 Glass containers 2.7 0.08 Aggregate 0.6 n/a

c. Flood Resiliency and Materials Management

In the aftermath of Tropical Storm Irene that devastated Vermont communities in 2011, the Agency of Natural Resources has taken a look at a wide array of management options to mitigate vulnerability to future storms. Of the management options considered by the Agency of Natural Resources, mechanisms to improve water retention by increasing soil stability is advised. This can be accomplished by promoting the incorporation of compost into State and municipal roads projects, encouraging the use of compost on agricultural lands, and as amendendment for habitat resortation projects. Studies have shown that compost imcreases DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 59 the porosity of soil enabling it to absorb a higher quantity of water before reaching its saturation level. http://www.vtwaterquality.org/rivers/docs/rv_municipalguide.pdf

X. Introduction to 2012 Materials Management Plan

a. Targeting Five Material Streams

i. Recyclables The environmental movement has been part of American life for over four decades now. Awareness of toxins in water, air, and soil has driven extensive law and policy generation at both the national and state level. Earth Day was initiated to remind citizens of the importance of conservation, and the health and environmental risks associated with pollution of shared natural resources. Now a globally recognized day, behavior changes and actions are recommended for every person to take to reduce those risks. Examples include reusing materials in creative ways, and recycling as much value- retained materials as possible.

The amount of recyclable materials discarded as MSW is equivalent to throwing hundreds of thousands of dollars into the landfill.xxxii In order to remind Vermonters of the true costs of disposal against that of recycling performance standards in this Plan strive to inform students, businesses, the general public, and elected officials of the expense of operating and managing the current materials management infrastructure. The requirement to implement of Pay-As-You-Throw programs for all municipalities by July 1, 2015, will serve to bring this message to light. Assigning an incremental dollar amount to waste disposal that adjusts with the volume, or weight, of materials discarded provides an educational component that is often forgotten when conveyed through pamphlets and public service announcements. As finances become more closely tied to waste disposal, interest in services available for material diversion will be critical to enabling the overall reduction and recycling of mandated, and marketable recyclables.

Improvements to infrastructure efficiencies can yield expanded availability and convenience in services for the existing collection facilities scattered throughout Vermont. Where infrastructure is incapable of managing diverted materials, new facilities, collection and transport logistics, or alternative management methods will need to be evaluated and implemented. In some cases, the market for recyclables and organics will facilitate this process. For example, as precious metals, fossil fuels, and

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 60 natural resources become more scarce, the markets for recyclable materials are likely to expand to allow for the collection of numerous other materials as well. With Vermont’s diversion rate plateauing in the mid 30% range, vast improvements are necessary to reduce the rate materials are landfilled or, sent out-of-state for disposal.

ii. Organics Diversion of organic materials, specifically leaf and yard debris and food scraps, infrastructure development has expanded significantly this past decade. This has been observed at the local, state, and federal government levels. A new campaign by the U.S. Environmental Protection Agency (USEPA) highlights the Food Recovery Hierarchy (Figure 22), promoted nationally to reduce and divert organics from landfilling through a prioritized list of actions. The 2012 Vermont Figure 22: USEPA Food Recovery Hierarchy is legislature recently adopted recommended as the preferred order of this hierarchy into law. (10 managing excess food. V.S.A. §6605k).

Numerous studies show that organic materials constitute approximately one-third of all materials sent to the landfill annually. As concern over anthropogenic Greenhouse Gas (GHG) production intensifies, efforts to reduce methane production from landfilled organics are prioritized. Landfills have been identified as GHG contributors due to the significant amount of methane produced from the decomposition of organic materials. A USEPA report estimated that landfills contributed as much as 17% of the GHGs generated in 2009. Methane is a GHG that contributes to global warming as it is absorbed into the atmosphere. Effects of methane on the atmosphere are considered to be over 20 times as adverse as carbon dioxide in absorption and redirecting heat back to the Earth.xxxiii Various methods have been devised to account for this source of GHG and to harness it for beneficial

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 61 use. Composting has been reported to be the method with the least production of methane gas.xxxiv

As outreach and education campaigns permeate elementary and secondary schools regionally and nationally, awareness by the general public also tends to broaden. Knowledge of, and exposure to compost is still relatively limited without dedicated academic or community programming . What can be composted, as well as where to send organic materials for composting is not widely known by Vermonters. Although the infrastructure to manage compostable materials is expanding, it remains inconvenient to divert. Organic materials are not only a significant portion of the materials disposed of in Vermont; they are also a large source of undesired GHG emissions. As such, they are targeted as a category of material requiring extensive prioritization to divert in this MMP.

iii. C&D Accounting for construction and demolition material disposal, diversion, and reuse has been challenging for Entities as well as ANR. Opportunities to divert materials exist but are not well known, or convenient to incorporate into building plans. Dependable sources of reusable materials are difficult to find in Vermont making it similarly difficult to divert used materials for reuse purposes. The ease of discarding C&D materials is offset by projects that wish to receive recognition for LEED certification, or green building designations.

As a means to improve data collection in the type and amount of C&D materials disposed and diverted, ANR is initiating an online reporting program Entities will use to report material throughput. (ReTRAC Connect is a nationally recognized waste management reporting database used by the USEPA, and several State governments including Vermont.) Clearly identifying sources of C&D, and the types of C&D is essential to improving reduction and diversion rates. As previously indicated, C&D constituted nearly 25% of all waste generated in the 2009 calendar year. Although a portion of the materials can be used as landfill cover, the remainder is buried. By recognizing that useful construction and demolition materials are needlessly disposed, this MMP intends to improve the awareness, convenience, and cost-effective means to alter the destination of reusable and recyclable materials.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 62

iv. Toxics (HHW and CEG, and Electronic Waste) Products used in the home setting such as cleaners, paints, auto fluids, and batteries pose health and environmental hazards. Everyday items contain toxins that, even in small amounts, can contaminate water and soil. Collection facilities and events have been available in Vermont for close to 25 years. The percentage of new participants to the collection program in 2010, represented approximately 75% of the total participants of HHW events that year. Unfortunately, total participation continues to represent a very small percentage of the Vermont population overall.

Hazards posed by common Household Hazardous Wastes and materials disposed by Conditionally Exempt Generators are of great concern. With the collection of more than 813,300 pounds of HHW, and 164,400 pounds of CEG in 2010, and knowledge that the participation rate is minimal it is difficult to evaluate the effectiveness of particular collection programs based on participation rates alone. For this reason, it is important for ANR, and municipal waste management entities to implement action items discussed in this MMP. In particular, significant effort must be made to increase awareness of the service availability, and public education on the types of materials that constitute Household Hazardous Waste that require special disposal.

v. Residual Wastes (Septage and Sludges) As with other organic wastes, keeping decomposable residual wastes out of landfills saves landfill space removes yet another significant source of methane (with the exception of wood ash and drinking water treatment sludge). Although wood ash and drinking water treatment sludges are not decomposable materials that will contribute to methane generation, the disposal of these wastes in a landfill still presents the consumption of landfill capacity for materials that have alternative use potential.

Unlike household trash and other closely related streams of municipal solid waste, there is very little that individual Vermont residents can do to reduce the volume of residual wastes that are being disposed versus used. Other than septage removed from on-site septic systems, an activity which itself is not conducted by individual homeowners, residual wastes are almost exclusively produced and managed by municipal facilities or by private sector businesses. Although wood ash and short paper fiber are generally managed by private sector companies that contract with generators of these wastes, and DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 63 in turn market these materials to third party customers; this is not the case for sewage sludge. Nearly 100% of sewage sludge are managed directly by the generator or, shipped directly to an incinerator or, sent to a landfill for disposal.

Opposition to land application of biosolids and septage has been steadily increasing due to public concern about potential risks to the environment and public health. Challenges to repurposing biosolids also face regulatory restrictions that limit the acceptance of biosolids by farmers for land application. Since the passage of Act 78, an Advisory Committees has studied the barriers to land application and beneficial use of biosolids and septage.xxxv The Committee found that even the acceptance of biosolids for anaerobic digestion by farms would subject them to State and Federal biosolids management regulations that can create a barrier in options for their ultimate disposal. A lack of primary research on biosolids contributes to concerns relating to public perception, and limited options for beneficial use.

One trend that is beginning to change is who manages these wastes. Since 1989, the public sector has managed most sewage sludge generated at municipally owned wastewater treatment facilities, while the private sector has provided services for the pumping, hauling, and land application of septage. Today, the private sector is starting to manage municipal wastewater treatment plants and the sewage sludge they produce as well as septage. Municipalities have not been actively involved in septage management in the same way that they have been for municipal solid waste or recycling.

It is extremely difficult to reduce the volume of residual wastes being generated. A reduction in the volume of these materials being disposed can only be achieved by fostering alternative uses that can be substituted for direct disposal. Unfortunately in Vermont, the options for alternative uses are somewhat limited. The reason being that land application uses for biosolids are dependent on the level of pathogen reduction to which they have been subjected. Class B biosolids can be directly applied to the land for agricultural use only under site specific solid waste management facility certifications. Class A biosolids can be designated as Exceptional Quality (EQ) biosolids after meeting the pathogen reduction requirements and two other tests (metals content and stability). By receiving the EQ designation, these biosolids are no longer considered to be a solid waste and may be marketed and distributed to the general public as a commodity.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 64 Incentives to facilitate and encourage the use of residual wastes include eliminatation of the franchise fee exemption for use as cover material at landfills; offer property tax credits for land application; provide subsidy funds for land application programs; provide subsidy funds to pay land application site owners/farmers to plant winter cover crops; and provide grants for solid waste management districts and municipalities to conduct a cost analysis on the use versus disposal management options for biosolids. Additional management options may be strongly reliant on tax incentives, grant assistance, or other financial mechanisms to entice the diversion of treated septage and sludges away from landfills. b. Tools of Action Identified Following a series of Solid Waste Working Group (SWWG) meetings in 2008, numerous tools were identified that are believed to be driving forces in attaining the proposed Sustainable Materials Management Vision presented in this Plan. Of the elements that were considered essential to successful waste reduction, seven were selected for further discussion. Those seven essential elements for materials management programs are targeted in this MMP as “Tools of Action.” While each of these tools is elaborated on below, suggested actions to take with each tool are encompassed within designated material chapters found in the material specific Chapters that follow. Note that partnerships are relied upon by the other six tools identified here, and as such are incorporated into each rather than holding its own subsection in each chapter.

i. Environmental Education Educating the public and school children of Vermont on materials management options and practices is critical to introducing and establishing more sustainable behaviors. Education is where initial exposure to reduction, recycling, and reuse options occur. Both formal (classroom settings) and informal (flyers, posters, radio and television) approaches to education must be utilized to reach the largest and most diverse audience possible. Overall goals of outreach campaigns should include efforts to:

- Improve reduction behaviors among those already conscientious of their consumptive habits. - Target individuals and groups unaware of the adverse effects disposed materials has on Vermont interests.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 65 - Foster the development of a unified community that all Vermonters can relate to and self-regulate.

In addition to formal and informal approaches, there must be an increase in the use of unconventional resources for future outreach campaigns. There need to be methods that blend education with innovative technologies to present information in new, exciting, and attention-getting formats. Such methods of distributing information, or reminders, may include use of VTrans message boards, developing and maintain Facebook or Twitter accounts, or advertising through ANR’s Forests, Parks and Recreation, and Fish and Wildlife Departments. To convey pointed messages in a memorable fashion, various communities and demographics should be surveyed. Surveys should be developed and distributed in such a way that collect details about group and individual values, what is known about materials management on both a broad and specific scale, and what it would take to change their behaviors to be more sustainable. Evaluation of those surveys will facilitate resource expenditures to target communities based their personal interests and lifestyle.

Initially, encouraging small behavioral changes to reduce and divert are the focus. As those habits are established and solidified, additional education can be provided to maintain interest and expand knowledge of how their actions benefit their interests as well as those of Vermont. Ideally, education efforts will not overwhelm the audience or burden them with the significant and numerous concerns of materials management. Small changes do indeed make a big difference on a collective scale. Those changes must be valued and celebrated to foster enthusiasm, and capture a collective pride for goals set and steps achieved to attain them.

Reflecting on the enthusiasm garnered by the youth of Vermont, that excitement should be utilized to deliver messages from voices passionate about the future. As it has been observed, “…children play a significant role in influencing adult behavior with respect to environmental initiatives,” says DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 66 Rob McCullough, director of solid waste management for Simcoe County, Ontario, Canada. “Establishment of early recycling behaviors and reinforcement of emerging positive patterns among residents is vital to achieving… high waste diversion targets.”xxxvi Methods of establishing these behaviors in school systems are not a new concept. Their integration into schools has been accomplished through weekly publications, school-wide program activities and projects, and several targeted lesson plans.

While development of materials management lesson plans and projects are encouraged in this MMP, it is not required. Many organizations offer access to grade-specific lesson plans free of charge. For example, USEPA offers grade-specific lesson plans for public review and use.xxxvii This MMP encourages efforts to expand presentation of lesson plans throughout Vermont schools, and to enhance opportunities for students to participate in school-wide and community-wide projects that change behaviors towards the Sustainable Materials Management Vision.

ii. Product Stewardship and Extended Producer Responsibility (EPR) A national movement is building to broaden the responsibility associated with the safe management of difficult to manage materials. Laws have been adopted in Vermont that require manufacturers to fund programs that “take-back” discarded electronics and mercury-containing light bulbs to prevent their improper disposal. These programs are paid for by manufacturers and distributors to encourage consumers to properly recycle various materials that may contains toxic chemicals, or are a valuable commodity . Such laws are referred to as Extended Producer Responsibility (EPR) legislation.

Vermont’s EPR laws resemble efforts other states across the nation have adopted within the last decade. The incorporation of EPR as a tool within this MMP is to promote voluntary programs initiated by manufacturers, and encourage the introduction of additional legislation. As previously indicated, for programs to be successful there must be consistent DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 67 expectations established across the state. Those expectations will then set a level Box 4. Defining: Product Stewardship and Extended Producer Responsibility (EPR)* playing field for all manufacturers of a particular product sold in the state to Product Stewardship: is the act of minimizing health, safety, environmental and social impacts, and adhere to. While certain purchase choices maximizing economic benefits of a product and its can be made by the consumer, a number of packaging throughout all lifecycle stages. The products are available to consumers for producer of the product has the greatest ability to minimize adverse impacts, but other stakeholders, technological reasons or by legislative such as suppliers, retailers, and consumers, also play mandate. That is the case for compact a role. Stewardship can be either voluntary or required by law. fluorescent lamps (CFL) following a federal mandatexxxviii relating to the sale of Extended Producer Responsibility: is a mandatory type of product stewardship that includes, at a minimum, incandescent bulbs nationally. the requirement that the producer’s responsibility for their product extends to post-consumer Product Stewardship are typically management of that product and its packaging. There are two related features of EPR policy: (1) voluntary “take-back” collection programs. shifting financial and management responsibility, Often a result of pressure for enhanced with government oversight, upstream to the producer and away from the public sector; and (2) corporate social responsibility (CSR), providing incentives to producers to incorporate manufacturers are being encouraged to environmental considerations in the design of their reduce the amount of toxics contained in products and packaging. their products as well as minimize the *Definitions developed by the Product Policy amount of packaging. This is also a Institute; Product Stewardship Institute; and California Product Stewardship Council. (Feb. 2012, growing trend in EPR initiatives and memo to partner Product Stewardship Councils). legislative bills locally and nationally, has focused on reducing the amount of

packaging of products.

There is diverse stakeholder interest in EPR and product stewardship laws as they relate to packaging in particular. For example, Moretown Landfill General Manager, Tom Badowski, has pinpointed packaging as a major contributor to rapid capacity diminishment of the landfill.xxxix Packaging comes in both recyclable and non-recyclable forms. Where packaging cannot be minimized further, the goal is to have manufacturers convert those materials from non-recyclable to recyclable materials. Acknowledging the importance and power of EPR and Product Stewardship to reduce waste generation, is a critical tool that will facilitate the State goals and local performance measures identified in this Plan.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 68 iii. Government Leadership Not enough can be said about the power of leading by example. Leading by example is something available to all persons to undertake. Individual actions of leadership are encouraging and provide a message to others as to the ease and importance of diverting materials from disposal. There are compounding effects when individuals embrace the 3Rs in a community. It contributes to creating social norms, and can exemplify the diversity of a concerned citizen and conscientious consumer.

As an example of government leadership, the Buildings and General Services Department (BGS) is the Vermont agency tasked with the end of life (EOL) management of discarded office materials for the State government. In particular, this includes computers and computers peripherals. In April 2012, the Vermont Agency of Natural Resources was awarded Bronze level recognition from the State Electronics Challenge, a national organization, for adhering to best practices for end- of-life management of its electronics equipment. Recognition is given in relation to the number of phases of life by which the SEC standards are met. Those phases are procurement, operation and maintenance, and end-of-life management. Gold is awarded when standards have been met for all three phases of life. The Agency continues to improve its management policies to come in line with standards set by the SEC.

Beyond reusable materials, recyclable materials have also been collected as source separated materials by BGS for several years now. A source separated collection method permits BGS to self-bale and sell direct- to-market. This direct sale enables the market value of the recyclable materials to be retained by the State.xl Beyond those materials collected for recycling by BGS, are those that are retained for reuse. The State Surplus Program is operated and maintained by BGS.xli Surplus materials typically consist of office furniture, computers and other electronic equipment, and vehicles. Vermont agencies are required to consider the availability of surplus materials prior to procurement of new materials. While this is an example of government leadership efforts at work, there is more can be done to adhere to sustainable materials management practices.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 69

As the SWWG accurately identified in 2008, government leadership is essential for each material type. Embracing government leadership as a tool for additional targeted actions must be accomplished not only by State agencies but also at the municipal level. Government that does not abide by its own proclaimed expectation is less likely to successfully motivate behavioral change by others. Additionally, what becomes a habit in the work setting is likely to continue in the home as well.

iv. Infrastructure Improvements Convenient access to certified recycling, composting, and HHW and CEG facilities is another priority for this Plan. Many options for HHW and CEG collection are infrequent events held throughout the year rather than fixed facilities that are open year round. With respect to composting, there is only one composting facility in the state with Full Certification to accept all organic material types, the rest are Categorically Certified for specific organic materials. (Certification types for compost facilities include food residuals; leaf and yard residuals; manure; animal carcasses; paper; wood residuals; and other.) An infrastructure analysis scheduled to be completed in 2013, will provide insight as to the effectiveness of the facilities and services in meeting the goals of the MMP.

v. Mandates and Bans Contrary to common belief, mandates are not the same as bans and consequently do not have the same effect as a ban would. Mandates and bans are similar in that they require governmental action to adopt and implement. Also, they both typically require public review and comment, and are devised with the intent to compel a specific action or, inaction. Mandates are the legal requirement to exhibit certain actions, where bans are a legal requirement against conducting certain actions. To simplify, a ban is a type of mandate to prevent disposal of a particular type of material. The discussion below provides examples of each.

 Mandated parallel services. Act 148 was adopted during the 2012 Vermont Legislative Session with a requirement for permitted MSW facilities and haulers to provide services to collect mandated recycling, leaf and yard residuals, and food residuals.xlii Offering additional services to collect source DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 70 separated materials outside of MSW is referred to as “parallel collection.” Mandatory parallel collection of these materials is required by phase in dates spread across the next eight years for each material type.  Expanded disposal ban. In tandem with the mandate to provide parallel collection services, Act 148 also institutes a disposal ban on mandated recyclables, leaf and yard residuals, and food residuals from disposal. By combining mandates with bans on a pre-designated timeframe, the goal is for the infrastructure to develop that can manage the influx of materials prior to a ban being enforced.

 Mandatory variable rate pricing programs. Also known as, Pay-as-you-Throw (PAYT), this mandate is included in Act 148 as a requirement for all Entities to meet by July 1, 2015. This mandate establishes that municipalities must develop and implement a program that charges generators per unit of waste disposed. This may be based on a per weight, or per volume system. As part of the MMP recommended actions, PAYT is a program that can prove to be extremely successful in both reducing waste generated and increasing materials diverted. Currently, there is no other State with a mandate to implement a PAYT program. At one point, Wisconsin had included such a mandate for municipalities that were unable to meet the state diversion goal. However, that law was repealed from statute in 2005. (Sec. 608.267).

vi. Standards It is a great concern of ANR, Entities, and our elected officials that the recommendations made in this MMP hold directives that are respected and achieved by all relevant parties whom are held to it. A famous quote reads, “Plans are only good intentions unless they immediately degenerate into hard work.”xliii By setting standards in this MMP there is a foundation established by which all Entities are expected to achieve. Specifying goals facilitates strategy development, review, and revision. Additionally, performance standards provide an idea of what stepping stones need to be in place to move closer towards goal attainment. The various material chapters of this MMP include performance standards that target improving convenience to collection services, and outreach efforts made to increase awareness and use of the expended services. Rather than creating subjective DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 71 performance standards for Entities to be evaluated against, the standards are quantitative to provide for a more objective analysis of completion.

vii. Partnerships Working collaboratively is a characteristic inherent to successful waste reduction and diversion programs locally, nationally, and internationally. Without the cumulative interest, enthusiasm, and support of persons internal as well as external to your organization the ability to make measurable progress will significantly be hindered. Uncommon partnerships have also been observed to be critical to influencing legislation, program implementation, shared responsibility for measuring progress, among other aspects. Such partnerships as the relationship the University of Vermont (UVM) Recycling group has with One Revolution and UVM Bike Users Group to carry out a pilot project designed to collect compost from offices on campus.xliv While UVM has a thorough compost collection system in place for the main student center, along with major campus events, office spaces are one location where the potential to divert food scraps remained. This type of grassroots partnership is one example of the innovative thinking that ANR envisions will result from efforts to meet the goals and performance standards laid out in this MMP.

Partnerships should be established as a way to undertake each of the tools for action identified above. While recommendations for who to establish, or improve, partnerships with are included amongst the tools for each material type in the MMP, they are not exhaustive. The connections that can, and should, be made benefit greatly if they are broad and interdisciplinary. Those working in finance departments have access to a wealth of information that the public outreach coordinators may not have. That information can benefit the outreach coordinators in their work to incorporate date into messages distributed through various media sources. This too is the case across organizations, levels of government, and private to publicly. With partnerships there is more potential for efficient expenditure of funds, and less chances for recreating the wheel. As a result, they should be prevalent and a primary component of actions taken to reduce and divert materials as the standards identify in this MMP.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 72 XI. Conclusion

With the adoption of Act 78 and formation of ANR’s Solid Waste Management Program in the late 1980s, a great deal of progress has been made by various programs to advance sustainable materials management. Between 1987 and 2009, Vermont achieved a 24% increase in its diversion rate. Although that percentage is insufficient in terms of meeting State goals, it is progress that is worth recognizing. Programs that have been implemented in the last 25 years will be part of Vermont’s infrastructure assessment to be completed within the next five years. The assessment will work to discover elements that have enabled programs to succeed, and better define challenges faced and factors that have influenced them. Only through close observation can lessons learned be addressed in a manner that benefits the design and development of new programs, or improve upon existing programs. The State goals, and Solid Waste Management Entity performance measures introduced in this MMP will serve to carry Vermont forward to attaining its Sustainable Materials Management Vision.

i Vermont Agency of Natural Resources, Life Beyond Garbage: Vermont Waste Prevention and Diversion Strategies, (May, 2008), available at http://www.anr.state.vt.us/dec/wastediv/R3/WPplanning/VT%20Waste%20Prevention%20Report%20May%202008.p df. ii Vermont Agency of Natural Resources, Solid Waste Report to the Vermont Legislature, (January, 2008), available at http://www.anr.state.vt.us/dec/wastediv/solid/documents/solid_waste_report.pdf. iii Act 148, An act relating to establishing universal recycling of solid waste, 2012 Legislative session. Effective July 1, 2012, (Vermont State Legislature documents), available at http://www.leg.state.vt.us/docs/2012/Acts/ACT148.pdf. iv Zero Waste International Alliance, Zero Waste Definition, adopted November 29, 2004, available at http://zwia.org/joomla/index.php?option=com_content&view=article&id=9&Itemid=6. v United States Environmental Protection Agency, Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990- 2010, Waste, (April, 2012), available at http://www.epa.gov/climatechange/Downloads/ghgemissions/US-GHG- Inventory-2012-Chapter-8-Waste.pdf. vi United States Environmental Protection Agency, Municipal Solid Waste Generation, recycling, and Disposal in the United States – Tables and Figures for 2010, November 2011. vii Canterbury, Janice and Sue Eisenfeld, The Rise and… Rise of Pay-As-You-Throw, (MSW Management), December 15, 2005, available at http://www.forestermedia.net/MSW/Articles/The_Rise_and_Rise_of_PayAsYouThrow_1520.aspx. viii Bogner, J., M. Abdelrafie Ahmed, C. Diaz, A. Faaij, Q. Gao, S. Hashimoto, K. Mareckova, R. Pipatti, T. Zhang, Waste Management, In Climate Change 2007: Mitigation. Contribution of Working Group III to the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [B. Metz, O.R. Davidson, P.R. Bosch, R. Dave, L.A. Meyer (eds)], Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, available at http://www.ipcc.ch/publications_and_data/ar4/wg3/en/ch10s10-5-6.html. ix Chittenden Solid Waste Management District, Summary of Vermont and CSWD Residential Waste Composition Studies, 2010. x Chittenden Solid Waste Management District, CSWD 5 Year Implementation Proposal, March, 2009, available at http://www.cswd.net/wp-content/uploads/2010/07/Waste-Plan-32509Final.pdf. xi Stone Environmental, Inc., Vermont Compost/Biogas Data Viewer, version 1.0, 2009, available at http://organics.stone-env.com/vtcompostbiogas/bin-release/index.html. NOTE: This data does not reflect current ANR permitted facilities, and should not be used as the most current source for operations and certifications across Vermont. xii , Molly Farrell, Curbside Trend: Single Stream MRF Comes to New England, BioCycle, July, 2003, at 46, available at http://people.engr.ncsu.edu/barlaz/resources/single_stream_mrf.pdf.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 73 xiii Chittenden Solid Waste Management District, CSWD Materials Recovery Facility FY 2011 Data, available at http://www.cswd.net/wp-content/uploads/2010/10/MRF_info_FY11.pdf. xiv Institute for Local Self-Reliance, Recycling Means Business, February, 1, 2002, available at http://www.ilsr.org/recycling/recyclingmeansbusiness.html. xv DSM Environmental Services, Inc., The Price of Solid Waste Management Services in Vermont – 2005: Overview of Survey Results, prepared for Vermont Department of Environmental Conservation, July, 2005, available at http://www.anr.state.vt.us/dec/wastediv/solid/pubs/prices_report.pdf. xvi Assumed bag weight for study was based on a Central Vermont Solid Waste District estimate for a 1999 report. (pg. 13, ibid). xvii (pg. 19, ibid). xviii CNN Money, Gas Prices Near Record High: Latest Survey Shows average price up 5 cents a gallon over last two weeks to $1.72 a gallon, March 10, 2003, available at http://money.cnn.com/2003/03/10/news/economy/gas_prices/index.htm. xix Dave Gram. Vermont House endorses bill to increase recycling. Burlington Free Press. March 2, 2012, available at http://www.burlingtonfreepress.com/article/20120302/NEWS03/203020306/1095/Vermont-House-endorses- bill-increase-recycling. xx Ron Alexander, Compost Market Outlook, BioCycle, January, 2008, Vol. 49, No. 1, p. 2. xxi Vermont Agency of Natural Resources, Solid Waste Report to the Vermont Legislature, January, 2008, at 10, available at http://www.anr.state.vt.us/dec/wastediv/solid/documents/Solid_Waste_Report.pdf. xxii Vermont Agency of Natural Resources, State of Vermont Revised Solid Waste Management Plan, effective October 15, 2006, available at http://www.anr.state.vt.us/dec/wastediv/solid/pubs/VTSWMgmtPlan.pdf. xxiii United States Environmental Protectation Agency. Product Stewardship, last updated May 9, 2012, available at http://www.epa.gov/epaoswer/non-hw/reduce/epr/about/index.htm#prod. xxiv Ecomii, Cradle-to-Cradle, viewed July 20, 2012, available at http://www.ecomii.com/ecopedia/cradle-to-cradle. Design is a system of thinking based on the belief that human design can approach the effectiveness and elegance of natural systems by learning from nature and incorporating its patterns. Industry can be transformed into a sustaining enterprise—one that creates economic, ecological, and social value—through thoughtful and intentional design that mirrors the safe, regenerative productivity of nature and eliminates the concept of waste. xxv Vermont Agency of Natural Resources, Vermont Greenhouse Gas Emissions Inventory Update: 1990 – 2008, September, 2010, available at http://www.anr.state.vt.us/anr/climatechange/Pubs/Vermont%20GHG%20Emissions%20Inventory%20Update%20 1990-2008%20FINAL_09272010.pdf. xxvi United States Environmental Protection Agency, Human-related Sources of methane emissions in the United States, Last updated April 18, 2011, viewed on July 13, 2012, available at http://www.epa.gov/methane/sources.html. xxvii Hoornweg, Daniel; Bhada-Tata, Perinaz. 2012. What a waste : a global review of solid waste management. Urban development series ; knowledge papers no. 15. Washington D.C. - The Worldbank, Chapter 7, at 29, available at http://documents.worldbank.org/curated/en/2012/03/16537275/waste-global-review-solid-waste-management. xxviii United States Environmental Protection Agency – Region 10, reducing Greenhouse Gas Emissions Through Recycling and Composting, May 2011, p. 24, EPA 910-R-11-003. xxix Nickolas, Themalis, J., and Priscilla, Ulloa, A., Methane Generation in Landfills, Renewable Energy, 32, 2007, p. 1243-1257. xxx X.F. Lou, and J. Nair, The impact of landfilling and composting on greenhouse gas emissions– A review, Bioresource Technology, 100, January 2009, p. 3792-3798. xxxi United States Environmental Protection Agency, Environmental Benefits from Recycling, as cited in Container Recycling Institute, Understanding Economic and Environmental Impacts of Single-stream Collection Systems, December, 2009, at 7, available at http://www.container-recycling.org/assets/pdfs/reports/2009- SingleStream.pdf. xxxii Chittenden Solid Waste Management District, CSWD Materials Recovery Facility FY 2011 Data, available at http://www.cswd.net/wp-content/uploads/2010/10/MRF_info_FY11.pdf. xxxiii Jorgenson, A. Birkholz, R. Assessing the causes of anthropogenic methane emissions in comparative perspective, 1990-2005. Ecological Economics. Vol. 69, issues 12. October 2010, at 2634. xxxiv X.F. Lou,J. Nair. The impact of landfilling and composting on greenhouse gas emissions – A review, Bioresource Technology, Vol. 100, issue 16, August 2009, at 3792.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 74 xxxv Vermont Methane Pilot Project: Resource Assessment, Prepared for the Vermont Department of Public Services and the Vermont Department of Agriculture, Food and Markets, July 2000, available at http://publicservice.vermont.gov/energy-efficiency/ee_files/methane/resourceassesment.pdf. xxxvi Bureau, Willma, Green Grades: Innovative School Recycling Outreach in Ontario, Waste Age, November 15, 2011, available at http://waste360.com/recycling/green-grades-innovative-school-recycling-outreach- ontario?page=2. xxxvii United States Environmental Protection Agency, Teachers: Cirriculum & Activities, last updated July 6, 2012, available at http://www.epa.gov/osw/education/teach_curric.htm#kids. xxxviii Energy Independence and Security Act, 2007, available at http://www.gpo.gov/fdsys/pkg/BILLS- 110hr6enr/pdf/BILLS-110hr6enr.pdf. xxxix Terri Hallenbeck, Vermont Moves Toward Mandatory Recycling, Burlington Free Press, February 11, 2012, available at http://www.burlingtonfreepress.com/apps/pbcs.dll/article?AID=2012120210032. xl Vermont Department of Buildings and General Services, Environmental Accomplishments (2002 to 2010), available at http://bgs.vermont.gov/sites/bgs/files/pdfs/Enviro-Accomplishment-2002-2010.pdf. xli Vermont Department of Buildings and General Services, State Surplus Program webpage, available at http://bgs.vermont.gov/business_services/surplus/state. xlii Act 148, An act relating to establishing universal recycling of solid waste, 2012 Legislative session. Effective July 1, 2012, (Vermont State Legislature documents), available at http://www.leg.state.vt.us/docs/2012/Acts/ACT148.pdf. xliii Peter F. Drucker quote http://blog.gaiam.com/quotes/authors/peter-f-drucker/28094. xliv University of Vermont, Recycling & Waste Management, Office Collection by One Revolution Bicycle Summer 2012 Pilot Program, available at http://www.uvm.edu/~recycle/?Page=compost/office- composting.html&SM=compost/compost-menu.html.

DRAFT

Vermont Agency of Natural Resources – Department of Environmental Conservation Page | 75 Appendix D

Glossary of Termsi

Agency, or ANR, means the Vermont Agency of Natural Resources.

Biosolids is a term which applies specifically to sewage sludge which has been treated and shown to meet the standards such that it can be managed by beneficial use. Beneficial use includes land application or further treatment to produce compost or similar products. Disposal includes dewatering followed by landfilling or incineration. Biosolids are primarily an organic material recovered from the wastewater treatment process.

Closed loop recycling means a system in which a product made from one type of materials is reclaimed and reused in the production process or the manufacturing of a new or separate product.

Commercial hauler means any person that transports: (A) Regulated quantities of hazardous waste; or, (B) Solid waste for compensation in a motor vehicle having a rated capacity of more than one ton.

Conditionally Exempt Generator (CEG) means a generator of hazardous waste which is conditionally exempted from certain provision of the Vermont Hazardous Waste Management Regulations.

Composting is the controlled biological decomposition of organic matter through active management to produce a stable humus-like material.

Construction and Demolition (C&D), in this MMP, is any waste generated from construction projects, remodeling, or demolition of buildings, but excludes road- related debris. The Solid Waste Management Rules include clean wood, painted and treated wood, plaster, sheetrock, roofing, insulation, glass, flooring, and siding as C&D waste.

Cradle-to-Cradle (C2C) is a concept focusing on the life cycle management of a particular product. The goal of which is to reduce waste and toxins generated at each step in the lifecycle of a product. The 2012 MMP embraces the materials management strategies identified in the C2C model.

Disposal means the discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or on any land or water so that such solid waste or hazardous waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any ground or surface waters.

Diversion Rate means the measurement of waste diverted (by composting, reusing, and recycling materials) compared to the sum of waste diverted and waste disposed (landfilled and incinerated).

Diversion tons diverted x100 = tons of materials reused + composted + recycled x100 Rate (%) = tons diverted + disposed tons + reused + composted + recycled + landfilled + incinerated

Electronic Waste (E-waste) means a: computer; computer monitor; computer peripheral; device containing a cathode ray tube; printer; or television from a covered entity. “Electronic waste” does not include: any motor vehicle or any part thereof; a camera or video camera; a portable or stationary radio; a wireless telephone; a household appliance, such as a clothes washer, clothes dryer, water heater, refrigerator, freezer, microwave oven, oven, range, or dishwasher; equipment that is functionally or physically part of a larger piece of equipment intended for use in an industrial, library, research and development, or commercial setting; security or antiterrorism equipment; monitoring and control instruments or systems; thermostats; handheld transceivers; a telephone of any type; a portable digital assistant or similar device; a calculator; a global positioning system receiver or similar navigation device; commercial medical equipment that contains a cathode ray tube, a cathode ray tube device, a flat panel display, or similar video display that is not separate from the larger piece of equipment; or other medical devices, as the term “device” is defined under 21 U.S.C. § 321(h) of the Federal Food, Drug, and Cosmetic Act, as that section is amended from time to time. (10 V.S.A. §7551(10)).

Extended Producer Responsibility is a mandatory type of product stewardship that includes, at a minimum, the requirement that the producer’s responsibility for their product extends to post-consumer management of that product and its packaging. There are two related features of EPR policy: (1) shifting financial and management responsibility, with government oversight, upstream to the producer and away from the public sector; and (2) providing incentives to producers to incorporate environmental considerations in the design of their products and packaging.

Household Hazardous Waste (HHW) is any waste from households (including single and multiple residences, hotels and motels, bunkhouses, ranger stations, crew quarters, campgrounds, picnic grounds and day-use recreation areas) that would be subject to regulation as hazardous wastes if it were not from households. Examples of HHW include: paint, cleaners, oils, batteries, and pesticides. Because they contain potentially hazardous ingredients, these wastes require special management.

Implementation Plan means that plan which is adopted to be consistent with the State Materials Management Plan (MMP). This plan must include all the elements required for consistency with the MMP and an applicable regional plan and shall be approved by the Secretary. This implementation plan is the basis for state certification of facilities.

Landfill gas-to-energy (LFG-to-Energy) plants (in operation at both of Vermont’s largest landfills), are systems that capture landfill gas and convert it into usable electricity. Mandated recyclable means the following source separated materials: aluminium and steel cans; aluminum foil and aluminum pie plates; glass bottles and jars from foods and beverages; polyethylene terephthalate (PET) plastic bottles or jugs; high density polyethylene (HDPE) plastic bottles and jugs; corrugated cardboard; white and colored paper; newspaper; magazine; catalogues; paper mail and envelopes; boxboard; and paper bags.

Material Recovery Facility (MRF) permitted facilities that collect mandatory recyclables and other recyclable materials for processing, baling, and sale to market.

Municipal Solid Waste (MSW) can be thought of as trash or garbage, and is the combined household, commercial, and industrial solid wastes. Organic materials, C&D, E-waste, and HHW are all subsets of MSW.

Organic Materials is composed of waste of a biological origin such as paper and cardboard, food, green and garden waste, animal waste, and biosolids and sludges. For this MMP, biosolids and sludges are discussed separately from other organics. Organic wastes are amenable to decomposition processes such as composting.

Per Capita Disposal Rate means the average amount of waste disposed (landfilled or incinerated) per person for a given year. Or, when expressed as an equation:

Per Capita (total tons landfilled + total tons incinerated) per year by a given town or district Disposal Rate= total population of that town or district (may be adjusted for seasonal population)

Product Stewardship is the act of minimizing health, safety, environmental and social impacts, and maximizing economic benefits of a product and its packaging throughout all lifecycle stages. The producer of the product has the greatest ability to minimize adverse impacts, but other stakeholders, such as suppliers, retailers, and consumers, also play a role. Stewardship can be either voluntary or required by law.

Recovered Materials mean materials that have been removed from the waste stream in order to have their value retained by reuse or recycling. Materials that have had their value recovered were able to do so because they were separated, or “diverted,” from other materials destined for the landfill.

Recycling is using waste as material to manufacture a new product. Recycling involves processing a waste and making a new object from the processed material.

Recycling Rate is the quantity of material recycled compared to the sum of recycled and disposed material. Or, when expressed as a formula:

Recycling Rate (%)= tons of materials recycled x 100 Tons of materials recycled + tons of waste disposed

Reuse is using an object or material again, either for its original purpose or for a similar purpose, without significant processing or altering its physical form.

Septage means solids and liquids pumped from septic tanks and cesspools during cleaning.

Solid Waste (SW) is any discarded garbage, refuse, septage, sludge from a waste treatment plant, water supply plant, or pollution control facility. Its also includes other discarded materials, including solid, liquid, semi-solid, or gaseous materials from industrial, commercial, mining and agricultural operations, as well as from community activities. Certain materials are specifically exempted from the solid waste definition including animal manure and absorbent bedding used for soil enrichment, high carbon bulking agents used in composting, solid or dissolved materials in industrial discharges which are “point sources” subject to Water Pollution Control permits.

Solid Waste Management means the activities that result in the storage, transportation, transfer, or treatment of solid waste or recyclable materials, on in the disposal of solid waste.

Source Separated or Source Separation means the separation of compostable and recyclable materials from noncompostable, nonrecyclable materials at the point of generation.

Special Wastes are identified in the Solid Waste Management Rules as categories of solid waste that the Agency Secretary designates because they pose special environmental, health or safety concerns or have certain characteristics (e.g. size, composition) that cause problems in handling or management. Currently, the Secretary has designated asbestos waste, infectious waste (medical waste), hazardous waste from conditionally exempt generators, and mercury added products as special waste in the Rules.

Upcycling is any process that takes used or recycled materials and creates a new product with a higher quality or value than the original materials.

Waste means a material that is discarded or is being accumulated, stored, or physically, chemically, or biologically treated prior to being discarded or has served its original intended use and is normally discarded or is a manufacturing or mining by- product and is normally discarded.

Waste Reduction are actions taken before waste is generated to either reduce or prevent the generation of the waste. Waste reduction is the combined efforts of waste prevention, reuse, composting, and recycling practices.

Waste Prevention is actions or choices that prevent the generation of waste. Waste prevention involves altering the design, manufacture, purchase, or use of products and materials to reduce the amount and toxicity of what gets thrown away.

Zero Waste is the ambitious goal adopted by several states and their municipalities to attain the highest percentage of prevention and diversion possible. With a value- retained vision of materials, the reuse and recycling markets are expected to expand further supporting the environmental economy. The 2012 MMP also strives to achieve this through the collaboration and innovation of the people of Vermont.

i The Glossary of Terms does not provide legal definitions of all terms. Instead, the intent is to provide consistent definitions of key words used in this Plan so that all readers have the same understanding of these terms as used in the context of this Plan.