Boonsboro Environmental Commission comments on draft “Zero Waste Plan”

EDITORS NOTE: The Maryland Department of the Environment has extended the deadline for comments until Tuesday, May 27th.

MDE and the O’Malley administration is writing a long term waste management plan titled “Zero Waste Maryland“. The goals are ambitious and laudable — and achievable. The DRAFT document is fairly thorough and detailed, but individuals and organizations have been submitting comments to offer suggestions and/or point out certain flaws and omissions.

On Thursday, the Boonsboro Environmental Commission submitted outstanding (and very read-able) comments, and we are pleased to share them here (and observe that most of the ideas and recommendations are as good advice for counties, too).


May 22, 2014

Dr. Robert Summers, Secretary
Maryland Department of the Environment
1800 Washington Boulevard
Baltimore, MD 21230

Dear Dr. Summers,

We are grateful to have the opportunity to comment on the Maryland Department of the Environment Zero Waste Draft Plan. We applaud Governor O’Malley, Lt. Governor Brown, you and the MDE staff for providing a framework to move Maryland toward a cleaner, greener future.

As members of the Boonsboro Environmental Commission (BEC), we are invested in the benefits of a Zero Waste Plan. Our Commission is the first Environmental Commission in Washington County. The mission of the Commission is to develop and promote a healthy environment for the benefit and well-being of the citizens of the Town of Boonsboro through education, community awareness and involvement, sustainable practices, responsible waste management, conservation of energy and resources, and responsible management of the environment. The Commission appreciates the efforts of your department to formulate a plan to reduce waste and offers the following comments on the plan:

Executive Summary:

    • When can we expect reporting on mandates for agricultural waste? Does this include water, animal and general waste?

Table ES-2: Summary of Zero Waste Initiatives:

    • 1.1 Study and update source reduction credits by 2016 – define and expand “source reduction credits”.

    • 1.7 Organize waste exchanges – define and expand

    • 2.1 Increase mandatory county recycling rates – define recycling. Maryland allows incineration and gasification to be included in the definition of recyclables. To most people those processes would be a reuse because recycling is commonly defined as “convert into usable material”.

    • 2.6, 2.7, and 2.8 are beneficial initiatives.

    • 6.3 is a contradiction. How can the state as a whole use less water while encouraging a business model that requires a specific and large amount of waste to be gasified? Also recyclables would be taken and then made unrecyclable by the gasification process. In addition, gasification creates dioxins, furans, sulfur compounds, CO2 emissions while producing toxic ash that cannot be cleaned.

    • 6.4 is also a contradiction. Again, the Plan encourages the State as a whole to use less and encourages a business model that requires a large amount of waste to be incinerated. Incineration requires the burning of recyclables to create the necessary high temperatures which create electricity. As with gasification, incineration creates dioxins, furans, sulfur compounds, CO2 emissions while producing toxic ash that cannot be cleaned.

Chapter 1

    • The most alarming data brought forward in Chapter 1 is the per capita amount of MSW generated by Maryland citizens. It is significantly above the national average and an upward trend is projected. The Plan indicates that a MD citizen, on average, generates 6.1 lbs. of MSW per day whereas the average U.S. citizen generates 4.4 lbs. per day. It would seem that an immediate educational blitz is needed to bring those figures down.

    • Figure 1, the pie graph on page 6, indicates that the emphasis of the educational effort should be the benefits of home, restaurant, food market, and community composting. In addition, diverting left over food from restaurants and food markets to the needy should be the norm in every community. Eliminating plastic bags when purchasing in all MD businesses, along with a ban on Styrofoam take-out containers, would reduce the per capita amount of MSW.

In response to the challenges presented at the close of Chapter 1:

    Reduce Reliance on Landfills – As long as Maryland Landfills remain enterprise systems for Counties, reduction of MSW will not be fully supported by County governments. Look to other models for best practices as a solution to this problem. In addition, secure the advice of financial experts for other ways of paying off landfill debt.

    Securing Sustainable Funding – Consider instituting a Pay as You Throw (PAYT) system for waste collection. This would encourage recycling, reducing, and reusing while providing a source of revenue.

    • Increases in Waste Generation – refer to paragraph 1 and 2 above

Chapter 2

    • The introductory paragraph is unclear as to whether waste used for incineration will be counted as waste. If the goal is to “nearly eliminate solid waste sent to landfills and incinerators”, then “all discarded materials are designed to become resources for others to use” becomes a contradiction.

    • If the goal is to restrict usage of items that cannot be composted, recycled or reused, then how will this be enforced? Pay per weight?

    • Source reduction should be defined. Is it reducing the source of the waste by addressing wasteful lifestyles or by reducing the waste itself by using compostable or recyclable plates, for instance? Will this be done by educational outreach or by imposing a bag or bottle tax? Also, will the source reduction of recyclables be prioritized into most beneficial to least? Plastics and glass can be recycled, but glass is less toxic. New products can be comprised completely of recycled glass and then recycled again and again, whereas plastic can only be recycled a limited number of times. Additionally, when plastic is heated to be compressed into pellets, it releases toxins. Products cannot be completely made of recycled plastic into a form that can be recycled again. For example, plastic can be made into carpets or cloths, but those items will not be recycled themselves as would a bottle or bag.

    • “Water reuse” on the Goals List, Table 9, page 24: Why is there not a goal to reduce water consumption? Does this fall under the idea of source reduction? Also, what would count as water reuse? Rain water collection? Grey water collection?

    • Commercial/construction waste and recycling is not addressed. This waste takes a portion of the landfill, and there should be goals to reduce that waste.

    • “Reducing GHG Emissions and Saving Energy” could be expanded. For example, reducing the amount of waste will allow for fewer pick-ups, lighter loads, and less use of gas-producing CO2. Not having to clear land for construction of landfills will allow the CO2 which the trees have captured to stay captured.

    • Expand upon “increase revenue”. How would the State encourage “expansions in recycling and reuse businesses” tax incentives?

Chapter 3

Objective 1: Increase Source Reduction and Reuse

    Initiative 1.5: Work with counties to evaluate possibilities for reuse of water within homes, including grey-water and roof runoff

    What about the availability of rain barrels or cisterns for the capture and reuse of water from roof runoff? Perhaps putting in place rebates or other initiatives for homeowners or businesses that purchase materials for these types of devices would increase their implementation.

Objective 2: Increase Recycling Access and Participation

    Initiative 2.3: Quantify the level of business recycling

    As a near or medium-term initiative, Maryland should consider making business recycling mandatory, as a handful of counties (e.g. Montgomery) have already done. Obtaining more detailed information regarding the level of business participation in such programs is certainly valuable, but making this practice mandatory as Montgomery County has done would be a major step toward achieving Objective 2 as a whole.

    Making the reporting of both waste generation and recycling mandatory could also be part of this same initiative, and would help MDE more accurately assess the levels of success and needs of the recycling program.

Objective 3: Increase Diversion of Organics

    Initiative 3.2: Publish composting facility guidance

    Perhaps the State could consider putting in place incentives for those who actively participate in various composting activities.

    Initiative 3.6: Encourage anaerobic digestion

    The State may consider the requirement of food-related businesses, such as grocery stores and restaurants, to send leftover (non-edible) food to anaerobic digesters, when feasible.

Objective 4: Address Specific Target Materials

    Initiative 4.4: Adopt a carryout bag reduction and recycling law

    With the development of the Total Maximum Daily Load (TMDL) for the Anacostia River completed, will the same study be completed for the other section of impaired water in Maryland (Patapsco River at the Baltimore Inner Harbor)?

    Initiative 4.5 Adopt a beverage container recycling law

    The State should strongly consider the requirement of deposits on beverage containers in order to help boost the recycling rates for these items. This has proven to be successful in other states, such as Maine, who reports a recycling rate of ~90% for bottles and the ten states who have deposit systems in place recycle more than the other 40 states combined (source: Blue Water Baltimore).

Objective 5: Incentivize Technology Innovation and Develop Markets

    Initiative 5.4: Establish a funding system for provision of financial incentives.

    Immediately institute a $1 per ton statewide tipping fee on solid waste disposal to be used as a funding source for innovative projects. At the same time, impose another $1 per ton fee to be distributed, on a per capita basis, to municipalities and counties for use in recycling programs. This would generate more than $12 million, for each program each year!

    Initiative 5.7: Incentivize adoption of new programs by local governments.

      • Procure, through state cooperative purchasing program, lidded composting pails for use by local municipalities, and non-profits and for-profit organizations/companies for door-to-door composting programs. Also, develop literature for use of the pails.

Objective 6: Recover Energy from Waste

    Initiative 6.3: Support gasification and other clean energy technologies.

    First, the report in the title of this Initiative assumes all WTE technologies are “clean,” asserting that the State “should continue to research and track development in other clean energy technologies.” If there is a need to “research,” then it follows that all is not known of these technologies.

    Perhaps the State should form a state-wide system to monitor the number of WTE incinerators and gasification facilities. It is predicted in the report that by 2040 only about 20 percent of the waste would need to be handled by these type of facilities. That prospect would mean only a limited number of these WTE facilities would be sustainable.

    Initiative 6.4: Utilize WTE for managing solid waste, after maximum removal of recyclables.

    This report should also attempt to delineate what types of materials would be left after all attempts at recycling, composting, etc. have been exhausted. The report seems to be assuming that there will always be material available to “fuel” WTE facilities, but gives no substantive evidence of that. How is it known that WTE processes would be more environmentally friendly, for instance, when only using the last 20 percent of disposed items? What kind of materials would remain to process?

Objective 7: Collaborate and Lead by Example

    Initiative 7.3: Seek opportunities for regional collaboration.

    Likewise, municipalities within the state should be encouraged to cooperate on various issues, including recycling and composting.

    Initiative 7.5: Increase procurement of recycled products.

    Draft and promote legislation to require all county and municipalities to approve a Green Purchasing Policy and form Environmental Commissions, in addition to using the State’s cooperative purchasing system when possible.

    Initiative 7.6: Increase State government recycling rates.

    The State should lead by example and move up the dates to meet various goals wherever possible.

Objective 8: Conduct Education and Outreach

    Initiative 8.1: Seek sustainable funding for outreach and Initiative 8.2 Provide funding to local government for outreach activities:

    Impose a $1 fee on every ton of trash taken to landfills to fund local government outreach programs. (See Initiative 5.4 comment.) Also, tax sodas at the same rate as alcoholic beverages.

    Initiative 8.5: Work with Chambers of Commerce, local Economic Development Commission and business forums to encourage business participation in recycling.

It is our hope that the Maryland Zero Waste Plan will empower the environmental grass roots groups and commissions across our state to confidently move forward with their missions. However, it is our observation, that in its current form, it is a passive, rather than a pro-active document. A word that often appears in the draft is “encourage”. The benefits of recycling, reducing, reusing, redirecting, and redesigning have long been proven. If the Plan would require, rather than encourage, some critical actions such as a ban on plastic bags and on Styrofoam take-out containers, it would send a strong message to our fellow citizens. With Maryland holding the designation as one of the top four states for placing the most tonnage into the waste stream, it is time for bold action.

Thank you in advance for considering our comments and please feel free to contact me if you would like to discuss further.


Brigitte Mary Schmidt
Boonsboro Environmental Commission

Rosemary James
Boonsboro Environmental Commission
Waste Reduction Task Force Member

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