MPCA ‘s Metro Solid Waste Plan.

I submitted the following comments on the Minnesota Pollution Control Agency’s Metro area Solid Waste Plan.

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I commend the Pollution Control Agency for undertaking the Metropolitan Solid Waste Management Policy Plan, and thank you for the opportunity to comment. There are many portions of the plan that will be significant steps in the right direction. However, there are also some ways in which the plan’s goals are not aggressive enough, and could lead to some unfortunate missed opportunities.

The positive aspects of the plan are almost too numerous to mention. The dual focus on reducing, recycling, and composting and limiting the total waste going to landfills is the right fundamental approach. I commend the MPCA for instituting a ‘floor’ for recycling, composting, and reduction.

Many of the strategies laid out in the plan are tremendous ideas. Worth special mention are Extended Producer Responsibility/Product Stewardship; Improving Volume-based Pricing; Mandatory Opportunity to Recycle for Commercial, Industrial, and Institutional (CII) Sectors; Increasing Landfill Disposal Fees; and Targeting Commercial Organics. I strongly believe that each of these strategies will meet the long term goals of improving the environment, public health, and regional economy, and I urge the MPCA to implement them.

However, the plan has room for improvement in several important ways.

To begin with, the Vision laid out in the plan is not sufficient. It is time for all stakeholders in the MSW realm to embrace the long-term goal of a zero-waste society. The MPCA’s leadership in engaging the state in a serious conversation about how and when to accomplish this in relation the different potions of our waste stream would be enormously helpful. This plan provides an opportunity to begin that discussion with clear goals and a clear timeline.

Second, it is important to draw a distinction between the top tier of the solid waste management hierarchy – waste reduction, recycling, and organics recovery – and Waste to Energy. While it is true that WTE is an effective method for capturing the embedded energy from MSW, it will never be a clean source of energy. WTE facilities simply decrease air quality and generate risks to public health. Too often, the plan includes WTE in the top tier, or makes unclear that it is not included. The plan should be amended to make two things very clear. First, that WTE is absolutely preferable to landfill. Second, that reduction, recycling and organics recovery are absolutely preferable to WTE. Put another way, WTE is not among the best solutions for waste; it is the best of the worst solutions.

Third, while the plan includes many positive statements about organics recovery, the details of the plan do not support the plan’s stated goals. As table A-1 makes clear, organics comprise 22% of MSW. But the MSW Management System Objectives aim for a long-term (2030) goal of only 7-9% organics recovery. This is simply unacceptable, and calls into question the MPCA’s actual commitment to the solid waste management hierarchy; it is apparent that the MPCA has placed greater emphasis on WTE than organics recovery.

The lack of prioritization on organics recovery shows through in other aspects of the plan as well. The implementation strategy regarding commercial organics is positive; however, the plan misses the opportunity to address residential organics programs. Municipalities in the metro area can and should start to offer curbside source separated organic materials (SSO) pickup. The MPCA should play a leadership and facilitating role in making this happen, by establishing a clear goal – for instance, a goal of SSO collection service for all residences in the metro area – providing technical assistance, and helping to ensure that there is adequate SSO processing capacity.

The Potential Additional Materials Recycling and Organics Processing Capacity goals are not sufficient to meet the needs of a comprehensive organics recovery system. City of Minneapolis Solid Waste and Recycling staff has made clear that the single greatest obstacle to citywide curbside SSO collection is the dearth of facilities that can process the waste. It is my understanding that there are currently no facilities that accept commingled yard and food waste, which would be the most cost effective collection method for the City of Minneapolis. The MPCA has a critical role to play in a) streamlining the process for permitting new composting and anaerobic digestion facilities to the extent possible, b) creating new rules and procedures as necessary to allow the permitting of composting facilities that can accept commingled food and yard waste, and c) clearly stating composting and digesting targets for the Metro area, and holding stakeholders accountable for meeting these targets, thereby making clear to potential new facilities that their service will be utilized.

In summary, the plan to a great extent misses the opportunity presented by organics recovery. I consider this oversight important enough that it calls into question many of the stated goals of the plan. It is also clear that the plan does not, in regards to organics recovery, come anywhere near meeting the 2008 Legislature’s request for options to achieve 15% diversion of source-separated compostable materials by 2020. Organics recovery could and should be, along with overall reductions and increased recycling, one of the major solutions for reducing the MSW going to both landfills and WTE.

Please consider adopting stronger and clearer organics recovery goals, clarifying that WTE is a second-tier solution, and adopting a bold long-term vision for a Metro area in which all waste is treated as a resource. If the MPCA does so, the plan will be much more likely to help create a sustainable community in which, in the words of the first goal of the plan, we “manage waste in a manner that will protect the environment and public health, reduce greenhouse gas emissions and conserve energy and natural resources.”


Thank you again for the opportunity to comment,

Cam Gordon
Council Member, Minneapolis Ward 2