Date: September 30, 2011
Source: Solid Waste Association of North America
The Solid Waste Association of North America (SWANA), has submitted comments to EPA regarding its biannual waste characterization study. The EPA has been seeking comment on the report partly in response to industry and others who are pushing the agency to offer a more complete picture of the nation's solid waste stream to support activities ranging from product design to facility permitting.
SWANA says it would like to see the report expanded to include additional materials such as construction and demolition debris (C&D), yard waste, electronics and food waste. These items are increasingly entering the MSW waste stream and represent both a burden and an opportunity. It is likely that the absence of C&D and certain industrial wastes from EPA's report is one reason for the discrepancies between real-world measurements and EPA's data. SWANA would like to see the agency do more to reconcile its estimates for national waste generation and disposal quantities with data obtained from outside sources, including some of the state regulatory agencies.
Moreover, SWANA would like to see EPA combine its materials flow analysis with aggregation of site specific data. Materials flow analysis, which involves analyzing the individual components of the waste stream, allows for predicting future demand based on existing trends such as the movement away from printed newspapers towards electronic gadgets.
SWANA would also like to see per capita waste generation figures developed for different regions to account for differences in geography, population density, regulations, and climate. Can the waste stream in New York City be compared with that of Winslow, Arizona?
"It is our hope that improvements to this report can help solid waste professionals prepare for the future. The more accurate the national waste characterization study is the more likely it can be used to show future trends so that localities can effectively create long term strategic plans to address the waste streams of the future," said John H. Skinner, SWANA's Executive Director and CEO.
See also: "EPA Considering Changes to Its Municipal Waste Characterization Report," (www.wasteinfo.com/news/wbj20110810B.htm).
PRESS RELEASE
September 30, 2011
SWANA Submits Comments to EPA on Waste Characterization Study
On September 30, 2011, the Solid Waste Association of North America (SWANA) submitted comments to EPA regarding their biannual waste characterization study. SWANA made a number of recommendations which included tracking additional materials such as construction and demolition debris, yard waste, electronics and food waste. Additionally, SWANA suggested that EPA reconcile their estimates for national waste generation and disposal quantities with data obtained from real-world measurements.
SWANA also suggested EPA reanalyze their current per capita generation figure. As it stands, there is one number for the entire nation, regardless of geographic location. SWANA recommends that adjustment factors be developed based on geography, population density, regulations, and weather factors. Separate factors for each would allow sites to adjust according to their own specific circumstances.
"EPA's Waste Characterization Study has been very helpful in tracking trends in solid waste management over several decades," said John H. Skinner, Ph.D. SWANA Executive Director and CEO. "However, it would be more useful if it the estimates were verified with data from actual solid waste operations," Skinner added.
This report provides an overview of solid waste management in the United States from 1960 to the present. Its figures include per capita generation and trends in solid waste recovery and disposal. EPA had solicited comments on suggested improvements to the report.
About SWANA:
For nearly 50 years, the Solid Waste Association of North America (SWANA) has been the leading professional association in the solid waste management field. SWANA's mission is "to advance the practice of environmentally and economically sound management of municipal solid waste." SWANA serves nearly 8,000 members and thousands more industry professionals with technical conferences, certifications, publications and a large offering of technical training courses. For more information, visit www.SWANA.org.
COMMENT LETTER:
September 30, 2011
RCRA Docket ID No. EPA-HQ-RCRA-2011-0178, 76 Federal Register 46290 (August 2, 2011)
Comments on Notice: EPA Seeking Input Materials Measurement; Municipal Solid Waste (MSW), Recycling and Source Reduction Measurement in the U.S.
RCRA Docket (28221T)
Office of Resource Conservation and Recovery
Environmental Protection Agency
1200 Pennsylvania Ave. NW
Washington, DC 20460-0001
To Whom It May Concern:
On behalf of the Solid Waste Association of North America (SWANA), I would like to take this opportunity to comment on the notice, EPA Seeking Input Materials Measurement; Municipal Solid Waste (MSW), Recycling and Source Reduction Measurement in the U.S. SWANA is a not-for-profit professional association with nearly 8,000 members from both the public and private sectors of the solid waste management field.
SWANA appreciates the opportunity to comment on this notice. We believe it is very important for EPA to develop the most accurate national waste figures possible. This study has been used by SWANA members in a variety of forms, whether estimating local generation rate or developing policies on diversion goals. Our comments are divided into three main sections.
1. Usage of the Report
2. Scope of EPA's Report
3. Measurement Methodology
Usage of EPA's Characterization Report
EPA's Waste Characterization Report has been used in a variety of ways by SWANA. Members have used the report to help set their own local policies regarding recycling and diversion goals. Using these numbers as a baseline, local communities have a starting off point to develop their own solid waste management plans. The per capita numbers for solid waste generation have been used to determine landfill tonnage in localities that operate without scales. On an international scale the figures in this report are used, as well as in the financial services industry for evaluating the waste management sector. Additionally, the figures are used to compare the United States waste management sector with that of other countries.
The report has been very beneficial in providing a characterization that can be easily compared from year to year. While the numbers themselves are representations, the trends shown are very beneficial in determining the status of the solid waste industry.
SWANA would utilize the report more constructively if the generation rate was broken down into different categories. As it currently goes, there is one figure for the entire nation. This number would be much more valuable if it could be separated out by geographic location. With separate figures for urban, suburban and rural generation rates, our members would be able to use the figures more accurately. EPA can further analyze the results of this study to help predict trends for the future. For example consumer habits can be analyzed. We recommend that adjustment factors be developed based on geography, population density, regulations, and weather factors. Separate factors for each would allow sites to adjust according to their own specific circumstances.
Scope of EPA's MSW Characterization Report
We believe the scope of the report must be expanded to include new materials which are now a regular part of the municipal solid waste stream. These include yard waste, food waste, electronics, etc. In addition there are materials such as construction and demolition debris and sewage sludge, which generally are not defined as municipal solid waste but are sometime disposed of in municipal solid waste facilities. Also the methodology currently used to estimate of food wastes and yard waste is oversimplified and a better and more accurate methodology needs to be developed. Solid waste managers would be better able to utilize the report if they had a more accurate picture of the approximate tonnage these materials constitute. In addition, the scope of the report should discuss recurring one-time events such as natural disasters and the waste tonnage that develops as a result. Although a singular event locally, these occurrences nationally are not rare and can be a significant contribution to the national waste characterization.
EPA can improve the methodology of their study is to adopt a standard set of definitions. SWANA has developed a set of definitions and would like to share these with EPA to help expedite the process of standardizing the methodology used for this study. These definitions are attached as an appendix to our letter.
While we believe that the report needs to include a number of other waste streams, such as construction and demolition debris but we do not believe that these should be aggregated with the MSW figures, but just reported separately. It is important to have a separate and consistent reporting of the MSW stream.
Measurement Methodology
There are two different methodologies that have been used to determine overall waste generation: materials flow and aggregation of site specific data. We believe that there are benefits and pitfalls to both of these methods and recommend that EPA moves forward with a hybrid version of both. The materials flow methodology presents a number of problems. This methodology does not account for significant portions of the waste stream such as HHW, construction and demolition and organics. Additionally it presents numbers on a per capita basis, without regards for locality or regional issues. Comparing the current material flow results with other surveys suggests that the materials flow approach is missing significant quantities of materials. This anomaly needs to be addressed if the materials flow approach is continued to be used. On the other hand, the material flow approach yields a consistent series of estimates, that can be compared from year to year and is very helpful in identifying important trends.
Because the EPA uses a flow methodology that relies on industry data, the EPA has an opportunity to provide predictions on the future waste generation. The report can discuss increasing and decreasing production and anticipated future waste that is predicted as a result. For example, electronic goods and newspapers are obvious increasing and decreasing waste streams, respectively. However, the EPA is in a unique position to be able to provide some discussion on anticipated trends in areas that may not be apparent to those that use the site specific methodology. Therefore, we recommend that the EPA provide discussion and appurtenant graphs predicting future trends so that the industry can be best prepared to manage the anticipated waste.
In addition, the material flow methodology does attempt to account for life cycle and reuse of products in their development of disposal estimates. SWANA recommends that EPA verify these estimates by comparing those them to actual quantities disposed. The disposal portion appears to be the remainder derived after all other recycling and reuse quantities are verified through the industry sources. Only the disposal portion seems to be unverified, and this should be corrected.
The alternative method of aggregation of site specific data presents its own set of issues and can lead to a number of anomalies based on definitions, weather and reporting protocol. As EPA has pointed out there are no standard definitions of recycling and diversion. Local governments use definitions that help them meet goals and standards set by law and these vary throughout the country. For example construction and demolition debris is considered diversion in California, but not in other parts of the country. Were there standard definitions this method may be improved. SWANA recommends that EPA re-evaluate their method to include the different waste streams that are missing and update their product life spans. Aggregation of site specific data needs to be accompanied by a careful quality control effort to assure that errors in data collection and differences in definitions are accounted for.
On a related note, it would be informative to users of the report to include, perhaps a case study in an appendix, a relatively detailed comparison of the results of the EPA study data against results of a state-wide aggregation of site specific data to clearly highlight the differences these methodologies may yield. Over 10 states routinely conduct statewide disposed waste characterization studies that encompass site specific data collection from a representative cross section of disposal facilities. A thorough comparison would shed light on the pros and cons of each methodology.
It is our hope that improvements to this report can help solid waste professionals prepare for the future. The more accurate the national waste characterization study is the more likely it can be used to show future trends so that localities can effectively create long term strategic plans to address the waste streams of the future.
SWANA appreciates the opportunity to comment on this notice. We would like to take this opportunity to schedule a meeting with EPA to discuss a number of the issues we have raised. If you have any questions please feel free to contact me directly at 301.585.2898 or at jskinner@swana.org.
Respectfully,
John H. Skinner, Ph.D.
SWANA Executive Director and CEO
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