I am submitting these comments on behalf of the Natural Resources Council of Maine, which has a strong interest in Maine’s Solid Waste Management Policy. In that context, we believe that this proposal comes at a time when DEP’s decision will determine the direction and tone of our State’s Materials Management efforts moving forward.¹ We strongly believe that Maine should be doing everything possible to support the solid waste hierarchy, especially the top priorities of reduce, reuse, recycle, and compost. Because the proposed landfill and disposal strategy would have an adverse effect on the State’s efforts to minimize the volume of disposed waste, and also would have negative impacts on the quality of life of the local community, we urge DEP to deny the facility application at this time.
Based on the three applicable review criteria provided, NRCM believes that the MRC proposal for an integrated solid waste management system does not provide the “substantial public benefit” required for the facility application submission. We address each of these review criteria below.
- The proposed facility meets immediate (within the next 3 years), short term (within the next 5 years), or long term (within the next 10 years) capacity needs of the State.
The state does not have immediate, short term, or long term capacity needs that would warrant the construction of a new waste disposal site. According to the 2013 DEP Materials Management Plan, the three remaining WTE facilities can accept a combined total of 544,000 tons1, or 35% more waste than they accepted in 2013.² There are 11 remaining landfills, of which only two are due to close in the next 5 years, one more in the next ten, and the rest have varying capacity dates that range from 14.8 to 66.7 years from now. NRCM believes that a smarter solution would be to extend the lives of existing landfills by banning out-of-state waste and encouraging waste reduction, reuse, recycling, and composting, and finally WTE before resorting to a new landfill. The construction of a new secure landfill or processing facility is definitely not needed at this time.
- The proposed facility is inconsistent with the State’s solid waste management hierarchy.
This proposal is not consistent with SWM hierarchy for several reasons: 1) Many of the towns that would be delivering materials to this landfilling facility are currently disposing of waste at a WTE facility, which is not a preferable alternative according to the SWM hierarchy; 2) Increasing the availability of inexpensive landfilling capacity in the state will only make landfilling more attractive and undermine efforts by communities to reduce, reuse, recycle and compost; and 3) The proposed “waste conversion technologies” may include methods of waste disposal that require little to no personal obligation to separate and reduce waste—leaving people to think that they are entitled to discard as many resources as they wish in the belief that technology will do the work for them. Additionally, if all recyclable materials, compost and waste were thrown together in one bin and then sorted out, then the quality of the recycled commodities and compost would be very low and undesirable in the market. Continued involvement by consumers in the waste separation process maintains the value of the recycled materials.
NRCM believes that it is best to have a system with incentives to reduce the amount of materials we burn and bury, and programs that encourage individual households to reduce, reuse, recycle and compost. The proposed facility would do the opposite by undermining incentives for communities to reduce waste and discouraging individuals from doing their part within the waste hierarchy.
- The proposed facility is not inconsistent with local, regional or state waste collection, storage, processing, or disposal.
There is not enough information about the proposed facility for NRCM to determine whether it would be consistent with local or regional waste management systems. All we know about this facility is that it would involve a land disposal option, and a variety or combination of other waste processing options, many of which would be new to Maine. We do not advise DEP to permit facilities that have not yet been proven to be successful.
Aside from your three criteria, residents in both Argyle, Greenbush, and neighboring communities are concerned that the proposed facility would increase the possibility of pollution entering the air they breathe and the water they drink. Many of these people live in the area to enjoy the peace and quality of life that is important for them to raise their families. These are valid concerns and the voice of local residents should be given careful consideration.
For these reasons and the fact that so little information has been provided to determine the proposed facility’s full costs, impacts, and viability that NRCM urges DEP to deny the facility application at this time. Thank you for considering these points, and I’d be happy to answer any questions that you may have.
—Sarah Nichols, NRCM Sustainable Maine Director
1 Capacity limits: PERC 304,000 tons; ecomaine 170,000 tons; MMWAC 70,000 tons.
2 The state currently landfills 237,543 tons of MSW and 121,213 tons of incinerator ash, and incinerates 354,957 tons.
