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Sierra Club Trash Transfer Program
DC's Suggestions for Better Waste Management

MEMORANDUM

TO: The Honorable Anthony A. Williams, Mayor

FROM: Janet Bearden, Executive Director, Mayor's Environmental Council
Jim Dougherty, Sierra Club
Tom Henderson, Solid Waste Management Division
Brenda Richardson, Women Like Us
Neil Seldman, Institute for Local Self-Reliance

DATE: April 27, 2001

SUBJECT: Recommendations Regarding Trash Transfer Stations and Recycling

At the request of Jim Wareck, and in response to the November 2000 recommendations of the Council-appointed Solid Waste Transfer Facility Site Selection Advisory Panel ("Panel"), we have prepared the following information and recommendations for your consideration.

Key Conclusions and Recommendations

  • Contrary to the Panel's recommendations, we do not believe a new trash transfer facility should be opened in Ward 8. Instead, the two existing government facilities should be upgraded with major capital investment, and they should accept waste from private haulers;
  • Existing regulations governing private transfer stations should be rigorously enforced; some private facilities should be closed if, as expected, they cannot come into compliance;
  • City-wide recycling (residential, commercial, and government) should be vastly improved beyond the current rate of under 10%. This will greatly reduce the adverse effects of trash handling in the City.


Background - DC's Solid Waste Challenge

Trash

DC's solid waste stream is comprised of two distinct subsectors: Residential waste, which is the direct responsibility of the City; and non-residential, or commercial waste, including construction and demolition (C&D) waste, which is managed by the private sector under municipal rules and regulations. The residential subsector accounts for 20-25% of the total solid waste stream; the non-residential subsector accounts for 75-80%. Recycling rates for each of these waste streams in the District are abysmal, as discussed below.

Residential waste is collected by City crews and transferred from compactors to 18-wheel long-haul trucks at City facilities at Fort Totten and Benning Road. Non-residential waste is collected by private haulers and processed through private transfer stations. Currently, approximately 630,000 tons of solid waste are generated annually in the District, with another 350,000 tons imported into the City, largely from Prince George's County.

Until l985, private haulers were allowed to tip loads at Fort Totten and Benning Road for a fee. In that year, the deterioration of Fort Totten became so pronounced that the City could only handle its own residential waste. Private haulers were shut out of the facility. The same policy was adopted in 1993 at the Benning Road facility. This led directly to the opening of private transfer stations in the city.

In order to accommodate the District's commercial waste, large companies established transfer stations and began importing waste from their Maryland and Virginia routes as well. Because there were no regulations in place to control where and how these transfer stations were located or operated, many of them ended up in residential areas, creating uncontrolled pollution, noise, odors, truck traffic, and vermin. The affected neighborhoods - chiefly in Ward 5 - were understandably outraged.

DC regulations, which, among other things, required a 300' buffer between transfer stations and residential property, were not enforced adequately, and citizen pressure in l998 led to new regulations, which expanded the buffer to 500'. The new regulations were challenged in a lawsuit that is still pending; a recent court decision provides that the 300' buffer is enforceable, and the 500' buffer is not.

No discussion of solid waste is complete without recognizing that ultimately, all trash leaves the City for final disposal or incineration outside the area. The less solid waste generated and disposed, the better for the environment and the quality of life in the City's neighborhoods.

Recycling

Thirteen years after passage of the l988 Recycling Act, recycling has yet to take hold. Residential recycling was started and stopped twice by the former administrations. The prevailing rate of residential recycling is thought to be approximately 15%. Commercial recycling was never enforced and is not carried on consistently. It is a rare DC government office building or public school that recycles, despite the legal requirement to do so. Aggregating all waste streams, the overall rate of recycling in the City is under 10%.

Other major cities such as Los Angeles, Seattle, Portland, and San Francisco have recycling rates over 40%. Montgomery County, Maryland, is at 45%. Los Angeles Mayor Riordan just raised the city's recycling goals to 70%. A key to high levels of recycling in these cities is active cooperation among government, citizens and business.

High recycling rates are important. When a city reaches 20-30% recycling, the cost of recycling a ton of material falls below the cost of disposing of that ton. For every ton of material recycled in the residential and commercial waste stream, the city and its businesses save money and reduce pollution at the same time. Recycling also creates jobs. For every 10,000 tons of plastic recycled, 96 jobs are created. For every 10,000 tons of plastic disposed, one job is created.

A study undertaken in 1997 for City Council Member Harry Thomas, then chair of the Public Works Committee, indicated that the City would reap multi-million dollars savings from an effective recycling system and modernization of the Fort Totten and Benning Road facilities.

DPW has approval to hire eight new staff to be on board this summer to carry out recycling education and public awareness and other functions in the residential and non-residential sectors. Currently, only one FTE is dedicated to all recycling efforts in the City. It is important to note that increased recycling in the residential sector will NOT impact the flow of waste to the commercial private transfer stations.

Perhaps the most important benefit of establishing a city-wide recycling program is that this would permit reductions in waste collection and transfer. Granted, more recycling would mean more recycling trucks on the streets, but it would mean less putrescent garbage taken to Fort Totten and Benning Road - and reduced neighborhood impacts. The bottom line is that increased recycling brings an increased quality of life for the affected neighborhoods.

The Problem of Trash Transfer Stations

Trash transfer facilities, as they currently exist in the City, tend to be highly polluting. The Panel Report at page18 capably summarizes the many ways in which these facilities diminish their neighbors' property values and quality of life, including: air pollution from diesel trucks; traffic congestion and truck noise, facility noise (dumping and lifting operations); odors from putrescent waste, disease vectors (rodents, insects, seagulls); litter; and fire risk. These problems can be significantly alleviated by state-of-the-art mitigation measures and design features, e.g., enclosed facilities with multiple barriers (such as vestibules) that trap noise, odors, trash, and vectors. However, if for no other reason than truck traffic, such facilities will always make bad neighbors.

It would be prohibitively expensive, environmentally unsound, and probably illegal for the City to ban private trash-transfer stations -- i.e., to require that non-residential trash and recyclables be hauled from every office and apartment building directly to an out-of-town disposal facility. There must be intermediate tipping and transfer to long-haul, efficient 18-wheel trucks.

There are four private commercial trash transfer stations in the City: "Brentwood" - 1220 W St. NE, operated by Browning Ferris; "Uline Arena" - 3rd and M Sts. NE, operated by Waste Management; "Queens Chapel" -- 2160 Queens Chapel Rd. NE, operated by Waste Management; and "ETW" - 1st and O St. SE, operated by Eastern Trans Waste. In addition, two other facilities accept construction and demolition ("C&D") waste . None of the trash transfer facilities are (1) well designed, (2) appropriately sited and (3) well run. Two in particular impose unduly heavy adverse effects upon neighboring residents. Like virtually all of the large, "bad neighbors" in Washington (e.g., the power plant, the jail, and the sewage treatment plant), all trash transfer facilities are located on the east side of the City. Affected neighborhoods have proven largely unable to muster the political power needed to unburden themselves of these unwelcome facilities.

Overview of Fort Totten and Benning Road Facilities

These two transfer stations, owned and operated by the District, were both developed in the early 1970's. After almost 30 years in service with little or nothing spent on upkeep, both stations now require significant renovation in order to remain operational and to restore their original design capacity. An expenditure of $5.6 million was included in the fiscal year 2001 Capital Budget for renovation of the Fort Totten Station. With a complete renovation, this facility could handle 2000 - 2500 tons per day, up from the current 500-1000 tons per day.

The Benning Road facility now handles about 500 tons per day. With renovation, this facility could handle as much as 2000-2500 tons per day. The fiscal year 2002 Capital Budget seeks to spend $4.9 million on renovation of the Benning Road Station.

The Benning Road site is a good one from the point of view of highway access and distance from residential or commercial neighbors. However, some members of the River Terrace community vehemently oppose the use of this site for either solid waste transfer or recycling. The community believes that exhausts from this facility, the highway, and the adjacent PEPCO plant are the cause of excess cases of cancer, asthma and other diseases, and are demanding a comprehensive environmental health survey.

If the City upgrades these two facilities into modern transfer/recycling stations, it will have sufficient capacity to handle all residential and a significant amount of private sector waste. This could earn the District significant revenue and reduce the flow of trash to private transfer stations. Because of the need to continue operations during renovations, work will have to be staged so that both stations are not off line at the same time.

Upon completion of the renovations (projected by DPW to be complete in 2003), capacity will exist to handle all of the waste generated in the District and the waste from Maryland and Virginia that is currently being transferred through the four private transfer stations. While we do not believe that private transfer stations should be - or legally can be -- eliminated in the District, this will provide both the District government and the private sector with options that do not exist today.


Comments On The Panel's Report

The Panel made more than a dozen recommendations on matters ranging from facility location and construction to zoning reform. For present purposes, its core recommendations were these:

  • Upgrade the Fort Totten facility and continue trash transfer operations there;
  • Close the Benning Road facility to trash; use it for recycling and other purposes;
  • Open a new trash transfer facility at the SW Impoundment Lot, near D.C. Village, and open related businesses there, such as auto recycling and repair;
  • Adopt a new policy permitting private haulers to tip commercial trash at government-operated stations;
  • Open recycling drop-off centers within each ward.

We agree with many of the Panel's recommendations, with some notable exceptions. First, we do not believe that a new trash transfer station should be opened in Ward 8. Due largely to the dynamics of environmental injustice, Ward 8 has more than its share of undesirable facilities, and not enough desirable ones. A new transfer station at the impoundment lot would represent another insult to this community. Further, the SW Impoundment Lot site lies virtually at the southern tip of the City. This would require trash compacting trucks to make longer trips, thereby increasing the number of vehicle miles traveled, the amount of air pollution generated, and traffic congestion caused.

Second, we do not believe that DPW should open recycling drop-off centers in each ward. An invigorated residential collection program, combined with a dramatically improved commercial recycling program, should make individual drop-off facilities unnecessary. However, the Fort Totten and Benning Road facilities should accept for recycling on a daily basis a wide range of materials from those who wish to make drop-offs. These facilities should also accept household hazardous waste, obviating the very expensive special collections programs that are now operated annually at Carter Baron.

Recommendations

1. Continue to operate the Fort Totten and Benning Road facilities as trash transfer stations. However, we would do so only if several steps were taken to significantly reduce the adverse effects of these facilities.

  • Upgrade the facilities with a multi-million dollar capital improvement program, so that odors, leachate, noise, vectors and other environmental pollution are minimized;
  • Ensure that all new trash compactors purchased and operated by DPW are equipped with natural gas or other, equally low-emission engines, to eliminate diesel exhaust emissions.
  • As more fully discussed below, substantially strengthen the City's recycling collection and enforcement program, so that the amount of trash collected (and the number of truck trips needed) is reduced.

2. Reverse the policy preventing private trash haulers from tipping at Fort Totten and Benning Road. This will give the City more control over this problem, generate revenue, and ease pressure on private transfer stations.

3. Vigorously inspect and take enforcement actions against all private trash transfer facilities. This will require some facilities to close. Enforcement discretion should be exercised to permit one or two private facilities to remain in operation at least until one DC transfer station has been renovated.

4. Strengthen the City's recycling program in all aspects. This should include:

  • Improved residential recycling rates with increased public education and public awareness, and better oversight of the private contractors operating the system;
  • Initiate recycling in DC government facilities, including the school system;
  • Begin a significant education, technical assistance and enforcement campaign aimed at the commercial sector, including apartment houses.
Together, these actions will effect a sizeable reduction in trash collection and handling.

5. Commission a comprehensive public health study to investigate illness patterns across the City. Such a study would greatly inform future government decision making on matters such as facility siting and pollution control. With respect specifically to trash transfer stations, we recommend initiation of a program to collect data on environmental factors such as diesel emissions and noise.

6. Re-establish the Environmental Planning Commission as an advisory panel for the Division of Solid Waste Management in DPW as called for by the l988 Recycling Law. This will assure a steady flow of comments and ideas from impacted and well-informed citizens. The Commission should consider the merit of a City-wide bottle bill, among other issues.

7. The current legal and regulatory regime governing trash transfer stations should be reviewed and revised.

8. As called for in the 1988 Recycling Law, prepare for public review and comment a bi-annual waste management plan for the City.


Conclusion

The policy changes and capital spending that we propose, if adopted, would surely lead to changes in the routing of trash and recyclables through our City. This means that some neighborhoods will disagree with our (or, indeed, any specific) proposal and that others will agree. In some respects this is a zero-sum game in which there will always be "winners" and "losers."

The Panel was wise to approach the overall problem from a systems perspective, and not as a political tug-of-war between neighborhoods or wards. We agree. This is why we emphasize the need for (1) capital and operational improvements at Fort Totten and Benning Road to minimize their impacts, and (2) a significant commitment to recycling. These two measures would represent a major step toward reducing the aggregate impacts of trash handling in the City, and would therefore lower the temperature of the associated political debate.


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