Ms. Johanna Kertesz, Minnesota Pollution Control Agency
Re: Comments to the Draft Metropolitan Solid Waste Management Policy Plan, 2016-2036
Dear Ms. Kertesz,
Conservation Minnesota is a statewide nonprofit organization focused on finding constructive solutions to problems that affect our land, water, air and quality of life. In communicating with our network of over 65,000 Minnesotans, we consistently find that waste reduction and recycling is a broadly held concern. We find that citizens across the state strongly support access to effective recycling programs, eliminating toxins and problem materials from the waste stream, and dramatically reducing landfilling. We appreciate the opportunity to provide comments to the draft Metropolitan Solid Waste Management Policy Plan, 2016-2036.
We strongly support the vision and goals outlined in Part Two of the draft Policy Plan (Framework for Change)(p. 6). With respect to Goal 3 (p. 9), we agree with the Plan’s goal of minimizing the long term risks and ongoing costs associated with continued reliance on landfilling. While maintenance and monitoring of landfills is critical to ensuring they do not threaten the safety of nearby water supplies, the Legislature has struggled to provide the long term funding needed to maintain old landfills. Focusing on the top of the waste management hierarchy and eliminating our dependence on landfills will save long term costs and reduce the potential health risks associated with land disposal.
However, we note that while the policies and strategies outlined in the report as a whole require significant new efforts by local governments to achieve the Plan’s goals, the draft Plan fails to note the role of state government in providing financial support for these efforts. Minnesota’s Solid Waste Tax was created to provide a stable source of state support for recycling, waste reduction, and solid waste management programs. However, 30% of this revenue stream is currently sent to the state’s General Fund rather than used to support the efforts of local governments to meet the recycling goals created in statute and to execute the strategies outlined in the Solid Waste Policy Plan. The Plan should acknowledge the role of the executive branch and Legislature in ensuring that Solid Waste Tax funds are used as intended and are supporting local recycling and waste reduction programs.
We support the Plan’s Waste Abatement objectives, in particular the 1% ceiling by 2020 of land disposal. However, we note that the objective for organics recovery (10-14% by 2025) (Table 1a, p. 15) seems overly conservative. Appendix A of the Draft Plan notes that 2015 data show that organics diversion is already at an all-time high of 10.2%. We think more aggressive goals would create a greater urgency in addressing the need to remove organics from the waste stream and build effective systems for organics collection and processing.
We also support the Plan’s objective to meet the state’s 75% recycling goal by 2030 (p.21). However, we question whether the identified BMPs (standardizing recycling messages, modifying city codes that are not flexible enough for recycling infrastructure, and standardizing ordinances relating to haulers) as well as other strategies (such as focusing on high volume commercial generators) are sufficient to lead to the necessary increase in recycling. The plan should also encourage innovation by local governments that is designed to fully achieve recycling goals. For example, local governments should explore policies that would provide effective incentives for increased recycling and disincentives for the use of non-recyclable or problem materials. These innovative policies could support the increased interest in a sustainable, circular economy in which products are designed and marketed in a way that does not deplete natural resources or create unrecoverable waste. The Plan correctly highlights the largest environmental value of recycling lies primarily in providing feedstocks to manufacturing and reduced need for extraction and processing of virgin raw materials.
We support the Plan’s objective to expand recycling market development, but note that the Plan fails to identify a source of funds to invest and support this effort. The Plan notes that in the 1990s the state and private industry invested heavily in developing recycling end markets (p. 40). Since then, this investment has dramatically declined and the result has been a lack of stable domestic markets that could absorb materials when the demand from international markets evaporated. The Plan should acknowledge the fact that the state stands to benefit from the economic development and jobs created by recycling markets and must commit to investing more in this area.
Finally, we support the Plan’s continued promotion of producer responsibility. In particular, local governments and citizens should not be burdened with the cost of managing hazardous materials such as mercury-containing lamps. We believe the Plan should more clearly identify a goal of developing product stewardship policies with a priority placed on materials that are hazardous to human health.
Thank you for considering our comments to the Draft Metropolitan Solid Waste Management Policy Plan, 2016-2036.
Sincerely, Conservation Minnesota