Solid Waste Transfer Facility Site Selection
Advisory Panel
Draft Report, October 16, 2000

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Solid Waste Management in Washington Metropolitan Region
Solid Waste Management in the District of Columbia
Issues Surrounding Existing Solid Waste Transfer Facilities in the District
Procedures

Recommendations

Solid Waste Transfer Facility Site Recommendations
MSW Management System Recommendations
Other Recommendations

Minority Opinion
Selected References
Selected Testimony
Acknowledgements

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Solid Waste Transfer Facility Site Selection Advisory Panel
Draft Summary Report

AUTHORIZATION OF THE PANEL

The authorization to create the Solid Waste Transfer Facility Site Selection Advisory Panel (the Panel) was provided by the D.C. Council in the fall of 1998 to address the complex issues surrounding the siting and operation of solid waste transfer stations in the City. D.C. Law 12286 went into effect on June 11, 1999, establishing new standards for solid waste transfer stations and directing the Mayor to appoint the Panel to advise the Council on siting and other issues related to solid waste transfer stations. The 1995 Solid Waste Facility Permit Act was also amended by this new public law. The Panel was directed to prepare "comprehensive recommendations to the Council that identify tracts of land suitable for solid waste transfer operations within appropriately zoned sections of the District that safeguard the health, safety and welfare of residents and businesses". Additional issues that the Law directs the Panel to study include:

• The District's reasonable carrying capacity for regional solid waste facilities.
• Impacts of existing solid waste facilities on local residents.
• The need of the District for solid waste facilities.
• Revenues received by the District from operating solid waste facilities.
• Best Available Control Technologies (BACT) for improving solid waste facility operations.

The challenge set for this Panel is to make feasible recommendations to the Council concerning sites suitable for future solid waste transfer facilities and other aspects of solid waste transfer operations within the District of Columbia.The District's reasonable carrying capacity for regional solid waste facilities. Impacts of existing solid waste facilities on local residents. The need of the District for solid waste facilities. Revenues received by the District from operating solid waste facilities. Best Available Control Technologies (BACT) for improving solid waste facility operations.

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BACKGROUND

Solid Waste Management in Washington Metropolitan Region

D.C. Law 12-286 required that the Advisory Panel consult with tie Metropolitan Washington Council of Governments (MWCOG) regarding solid waste management issues in the entire DC region. The Panel received a presentation from MWCOG staff summarizing the regional picture for solid waste transfer and a recent MWCOG on the subject.

In the Washington metropolitan region, most jurisdictions handle their solid waste independently of any other jurisdiction: Municipal solid waste (MSW) service s considered a basic municipal service that most local governments provide to their r residents through some public or public-private arrangement. Some cooperative arrangements exist for the handling of solid waste among multiple jurisdictions, such as Arlington County and the City of Alexandria sharing a waste-to-energy facility.

Several factors have contributed to an increase in demand for privately run solid waste transfer stations in the D.C. metropolitan area since the 1980's. First, the District failed to maintain and upgrade their two solid waste transfer stations over a period of two decades, resulting in the closure of those facilities to private haulers in 1993. Second, a pivotal decision by the U.S. Supreme Court (the Carbone case, 1994) applied the commerce clause to solid waste flow control, thus overturning many local laws controlling solid waste flow into and through their jurisdictions. Third, landfill costs have increased because of stronger environmental standards in U.S. Environmental Protection Agency's (USEPA) landfill requirements under Subtitle D of the Resource Conservation and Recovery Act (RCRA). Application of these new standards has resulted in the closing of local landfills and the construction of several large regional landfills. These factors and others have led to an increase in the number of transfer stations in the Washington, D.C., region in the last two decades.

These stations provide the locations where waste from local collection trucks is consolidated into larger tractor-trailer trucks for interstate transport to final disposal sites. The disposal sites most often used for waste from the Washington metropolitan region are farther away from D.C. than historical disposal, including several new landfills in central and southern Virginia. Transfer stations have developed in the region in a pattern with most of the facilities either in the center of the region (in D.C.) or in the fringes of the suburbs (Fairfax and Loudoun Counties in Virginia and Anne Arundel and Calvert Counties in Maryland). Solid waste from the District of Columbia's facilities is transferred to the Fairfax County waste-to-energy plant.

Local government policies regarding solid waste transfer stations vary substantially. Regulations have generally been effective in the suburban jurisdictions at controlling the location and potential nuisance problems of transfer stations. Virginia requires a 50-foot setback between a facility and the boundary of the transfer station site and a 200-foot distance between a facility and any home, school or recreational park, in addition to requiring a state-approved operations plan. In Maryland, the state laws are less specific but appear to be no less effective. A Maryland county must certify that a facility is in conformance with the county solid waste management plan and local land use and zoning prior to the state issuing a permit. In the District, local regulation of transfer stations has been less effective for a variety of reasons that will be discussed later in this report.

Figure 1: Regional View of Solid Waste Disposal and Transfer Facilities, Based on MWCOG July 2000

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Solid Waste Management in the District of Columbia

Although the residential population of the District has declined in recent decades, both residential population and employment are expected to increase in the future. Both are common indicators for solid waste generation and future trends. Residential population is expected to rise from 519,000 today to 588,000 by the year 2015 (source: MWCOG). According to the D.C. Office of Planning, the employment population within the District is also expected to increase with time, particularly over the next decade. Current residential and employment populations and the amount of waste generated are presented by ward in Figure 2.

Figure 2: SUMMARY OF POPULATION, EMPLOYMENT AND WASTE GENERATION IN THE DISTRICT

Source: SCS Engineers, 2000

1. 1998 residential population, Office of Planning
2. 2000 employment projection, Council of Governments

The solid waste generated by residents and employees in the District is collected by two identifiable sources: 1) District collection crews under the Department of Public Works (DPW) Solid Waste Management Administration (SWMA) and 2) private waste management companies. As is typical in many cities, District employees tend to run collection programs for the pickup of residential wastes while the private companies tend to collect commercial wastes.

District crews collected approximately 206,800 tons of waste and recyclables during FY 1999. As shown in Figure 3, these quantities can be broken down into residential solid waste, residential recyclables, and other solid wastes. Other solid wastes include yard waste, bulk waste, and waste from street and alley cleaning. District crews collect principally residential wastes generated within city limits from single-family residences and from multi-family residences of two or three units per structure only.

Solid waste collected by the District is transported to one of two District-owned solid waste transfer facilities: Benning Road or Fort Totten. Generally, the Fort Totten facility receives about two thirds (or 137,000 tons), and the Benning Road transfer station receives about a third of the incoming waste stream annually. The Fairfax County Waste-to-Energy facility serves as the final disposal site for the portion of the District's waste stream collected by District crews.

There were 73 private solid waste collectors (haulers) licensed to operate in the District in 1999. Private waste haulers collect waste generated within District boundaries from:

• Multifamily residences (with four or more housing units);
• Commercial businesses and institutions;
• Construction and demolition operations;
• A small portion of District Government buildings; and
• Federal Government buildings.

Figure 3. Solid Waste Collected by the District, FY 1999

Source: SCS Engineers

Private haulers then transport these wastes to one of the four privately owned and operated solid waste transfer stations located in the District. Alternatively, and depending on the type of materials, some materials are taken to and processed at one of the privately-owned and operated construction/demolition recycling (CAD) facilities or one of the paper stock/recyclables processing facilities also located in the District.

Combining the available figures from D.C. and private collection gives a total waste generation rate for the District of 630,200 tons per year. In addition to D.C. generated waste, private transfer stations in the District also accept wastes generated outside the District. Approximately 348,500 tons of waste were imported from outside the District in FY 1999. The amounts of outside waste imported into the District have been increasing since 1994. See Figure 4 for a current breakdown of D.C. handled waste by source of generation and collection and disposal category.

Note that D.C. government-run transfer stations presently lack the capacity to handle all of the District's trash, residential and commercial. These two transfer stations have an original design capacity of 2,400 tons per day (tpd) but they only process approximately 660 tpd currently. This current processing amount is considerably less than the city generation rate of 2,020 tons per day.

Currently, no final disposal of solid waste (either through incineration or deposition in landfills) occurs within the District of Columbia. Land use decisions, economic variables and environmental considerations currently limit the feasibility of locating such disposal facilities within the District. In addition, no large-scale facilities for rail or marine barge transfer of MSW exist in the District of Columbia. Again, land use, economic, engineering and environmental factors currently limit the feasibility of using such transfer technologies.

Figure 4: Waste Managed and Generated in the District (FY 1999)

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Issues Surrounding Existing Solid Waste Transfer Facilities in the District

Table 1 is a summary of the potential negative impacts of transfer stations based on a report from the Metropolitan Washington Council of Governments.

Table 1. Potential Transfer Station Impacts

Complaints from D.C. residents living near trash-transfer stations in the City reflect the full range of the trash-transfer impacts cited by the Council of Governments. In two public meetings held in January of this year, testimony by residents of several D.C. neighborhoods and non-profit organizations representing communities and environmental groups cited many specific examples of noxious odors, excessive noise, infestations by vermin, and heavy truck traffic in and near residential neighborhoods. While comprehensive epidemiological studies needed to link such nuisances directly with adverse human health effects in areas near trash-transfer stations do not exist, it is apparent that some D.C. residents with existing illnesses now live in environments that compromise their quality of life because of improperly located and operated trash transfer stations.

It became clear to the Panel that many of the residents' complaints resulted not only from trash-transfer operations and related truck traffic, but also from poor maintenance of trash-transfer facilities, both public and private, and a general failure by the City to enforce existing regulations.

It is important to differentiate between municipal solid waste, recyclable items in commercial and domestic use, and debris from construction and demolition (C & D). Each is an important component of MSW in D.C., and some sites and facilities may be suitable for the handling of one or another, but not all, of these MSW components.

The Panel recognizes that an important element of economic development in the City is having functional city services, including a clean, efficient system to handle solid waste. The Panel also acknowledges the interdependence of economic development activities, including construction of new buildings and the rehabilitation of existing homes and buildings on the one hand and the C & D materials-processing industry on the other. It is impractical to pursue economic development without providing for the removal, treatment and disposal of construction and demolition debris. Dedicated C & D operations have the effect of reducing loads on conventional MSW disposal facilities and provide employment opportunities for D.C. residents. Unfortunately, C & D operations may have negative characteristics in common with trash transfer stations, including heavy truck traffic, odors and dust, noise and sometimes disease vectors.

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Procedures

The Solid Waste Transfer Facility Site Selection Advisory Panel was sworn in by Mayor Anthony Williams on December 8, 1999. The Panel promptly developed and published a one-year work program to guide its efforts. The Panel hired several support staff and consultants to aid in its work, including a graduate student to provide administrative services, an editorial consultant and a transportation mapping consultant. The Panel retained SCS Engineers, a nationwide environmental consulting firm, to provide its expertise specific to the solid waste management industry and solid waste transfer station facilities. In addition, the Panel retained the services (pro bono publico) of the Washington, D.C. law firm, Covington & Burling, to advise the Panel and undertake analyses of selected legal issues related to trash-transfer activities in the city.

Public Meetings

The Panel held more than forty regular weekly meetings and several specialized work sessions to integrate the work efforts of the appointed and ex-officio members. To hear testimony from residents of D.C. neighborhoods and industry representatives concerning trash transfer stations in D.C., two public meetings were held on January 22 and 29 in Wards 5 and 7, respectively. In addition, the Panel held another public meeting on March 14 at the Reeves Government Center to hear further testimony from representatives of the D.C. Department of Public Works and local operators of trash transfer stations and from independent haulers. Copies of all submitted testimony will be included with the final report. All three public meetings were covered by the print media and were video-tape recorded and submitted to D.C. Public Channel 16 and other local commercial channels for broadcasting.

Information Gathering Activities

The Panel conducted site visits to all trash transfer sites in the District of Columbia and several sites in nearby jurisdictions, including Fairfax County in Virginia and Anne Arundel County in Maryland. Several members of the panel have also independently visited trash transfer facilities as part of their personal travels throughout the U.S. and the world, bringing photographs and information to share with the Panel.

Over the past year, the Panel has gathered information regarding solid waste transfer stations from many sources. The D.C. Department of Planning provided the Panel with a series of orthographic and city-wide maps, census data, and other information to assist the Panel with its deliberations. The Panel also reviewed a list of D.C. "brownfields" sites that have been identified for potential commercial and economic development. The D.C. Department of Public Works provided extensive material on solid waste management in the City, including transfer facilities, final disposal and financial and revenue information. The Department of Health, Environmental Health Administration, provided maps of the location of air quality monitoring sites, pollutants monitored at each station, asthma prevalence data, as well as incidence aril mortality data for 23 sites of cancer by ward. The Panel also interviewed the CEO of the private firm that provides long-haul transfer services from Fort Totten and Benning Rout under contract with the District. Special reports on rodent control, environmental regulation enforcement activity, city planning, environmental litigation, and DPW facility plans were obtained. A library of reference materials was assembled on trash transfer and related facilities for management of municipal solid waste.

Presentations from and interviews with local and regional staff provided additional input for the Panel's deliberations. Staff and official members of the Metropolitan e Council of Governments (MWCOG) gave presentations to the Panel regarding regional solid waste issues. A representative of the U.S. General Services Administration (GSA) presented information concerning the recycling and solid waste program for 135 federal buildings in the D.C. metropolitan area.

To gain a regional and national perspective on solid waste management and transfer stations, the Panel conducted interviews with public officials of Prince George's County, Maryland, Tulsa, Oklahoma, and Indianapolis, Indiana, concerning management of municipal solid waste. Written reports were obtained on specialized trash-transfer operations in other U.S. cities. The Panel interviewed representatives of the National Environmental Justice Advisory Council (NEJAC) and arranged for one member to attend the regional meeting of NEJAC in Atlanta, GA.

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RECOMMENDATIONS

Solid Waste Transfer Facility Site Recommendations

The Panel has attempted to balance the need of all the citizens of the District for clean, efficient solid waste disposal with the needs of the citizens who live and work in the neighborhoods of these facilities to be free from the odors, traffic, and disease vectors that often accompany trash transfer sites. In addition to meeting the criteria prescribed by D.C. Law 12-286, the Panel recognizes the urgent need to plan comprehensively for solid waste facilities and to improve citizen understanding and citizen opportunities to participate in the planning and siting process. The Panel also recognizes the need to make the most of the assets of the D.C. government for solid waste management.

The Panel's authorizing legislation (D.C. Law 12-286) charges the Panel with finding suitable sites for private solid waste transfer facilities. The Panel finds that the District has no suitable sites for private solid waste transfer stations that fully meet the criteria identified in the law.

However, given that solid waste transfer is an important municipal function that must be provided for the cleanliness and economic wellbeing of the City and the health of its citizens, the Panel has looked deeper into the transfer station siting issue. The District contains several publicly owned sites, some of which already provide some solid waste services, that completely or nearly meet the siting criteria for a solid waste transfer station. The Panel recommends that at least two public solid waste transfer stations operate within the District of Columbia boundaries.

Several of these sites currently serve solid waste transfer or other municipal functions. The site recommendations below also include general recommendations for the facilities and operations on each site to address some of the issues and concerns raised in earlier sections of this report.

The Panel considered specific technical criteria (e.g., a minimum site size of four acres, buffer distances to nearest residences, and traffic generation) in formulating the following recommendations. A detailed listing of all the criteria applied by the Panel and a tally of votes by Panel members for each designated site will be included in the Panel's Final Report.

• Fort Totten Transfer Station - Upgrade the current Fort Totten transfer facility to provide a fully enclosed, modern solid waste transfer station to meet the city's solid waste needs. In addition, it may be necessary to expand the Fort Totten site through property acquisition to the north of the current site to provide adequate space to meet solid waste needs, including vehicle storage, white goods and other special waste disposal, and other municipal needs.
• Southwest Impoundment Lot - Build a second transfer station on the existing Southwest impoundment lot site to meet the District's need for solid waste transfer. A new facility on part of this large parcel (approximately 15 acres) should be constructed to state-of-the-art standards, providing for fully enclosed operations and other Best Available Control Technologies and adequate operations space on site to minimize impacts to the surrounding areas. This site allows for significant buffers between the proposed facility and existing residential uses: approximately 3,000 feet to the nearest private residential units, and approximately 1,500 to temporary Job Corps housing on the D.C. Village site.

Adjacent to the proposed trash transfer site on the current impoundment lot, the Panel recommends an environmentally sound industrial operation and development opportunity that provides jobs and job training for DC citizens and contributes to the city as an economically sustained industry. Because of the shrinkage of available land in the District of Columbia, the City can no longer afford to allow the impoundment lot to utilize the land in its current form. Rather, it is urgent that the City become smarter about how such precious land is used and how it can benefit both the city and the community. Below are examples of industrial operations that could be considered for location on part of the current impoundment lot:

1. A state-of-the-art Impoundment Lot. A lot that provides protection for air, soil, water, and groundwater must replace a rearrangement of the current location of impounded cars. The lot could be smaller and could be managed by a private operator.
2. Plastics Recycling Facility. A facility could be built that would receive recycled plastics from the city's recycling program and blend the recycled plastic resins with virgin resins for the automobile and trucking industries as well as the manufacture solid waste containers and recycling bins that are used by the city. St. Jude Polymer, Inc. is a specialty plastics manufacturing company with over 100 employees that could be used as a reference for this type of operation.
3. Auto Repair, Bodywork, and Paint Facility. Numerous small auto facilities could compete in establishing such a facility (or be relocated in a land swap with the city if a current operation is located in areas to dose to residences). Such operations could work with the school system to develop a program to include vocationally oriented students from the high schools into jobs and careers in the automobile business. Moreover, a mentoring program could be set up to train and pay unemployed or underemployed residents working under the direction of senior operations for pre-determined jobs in the metropolitan area.
4. Deconstruction Facility. Deconstruction is the delicate dismantling of structures by hand to recover building materials for reuse or recycling rather than be demolished. Deconstruction is labor-intensive in the handling and processing of recoverable materials which translates into job and training options for community residents.
5. Automobile Recycling. A service similar to Comprehensive Automobile Recycling Services, Inc. in Baltimore, could be developed that dissembles old and new (but damaged) cars, and resells working parts and materials recovered. The facility could also recover automobile fluids for either resale or for environmentally safe destruction.
6. Landscaping and Composting Operation. A facility could be developed that would compost plants, manage yard debris and other organic waste streams that could be made available to citizens. Also, a relationship could be developed with the school system to create a landscaping program with school-to-job and school-to-career opportunities. Joint ventures with local businesses and government and private agencies are possibilities.
7. Reuse Enterprises. Enterprising entrepreneurs could develop profit and nonprofit business specialties in a variety of commodity groups: appliances, computers, textiles, wood pallets, art supplies, furniture and lighting fixtures. Commodities are recovered at their highest value while creating jobs for the citizens.

• Benning Road Transfer Facility - Maintain site as a transitional waste transfer facility, then continue to use for other necessary municipal functions. The location of the current Benning Road transfer facility is suitable for solid waste transfer because it meets many of the technical criteria for a transfer facility site. However, issues of cumulative impact of municipal and private industrial facilities on the neighborhood lead the Panel to conclude that this facility is not an appropriate site for solid waste transfer for the long term. Benning Road should continue to provide solid waste transfer services in the transition period until a state-of-the-art facility is in service at the impoundment lot site. The Benning Road site is valuable to the City and should be retained to fill other pressing municipal needs, such as vehicle storage, yard waste mulching, or recycling.

The Panel did not find any other sites among the many examined during this process, including both existing and potential future sites, to be suitable for solid waste transfer facilities.

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MSW management system recommendations

In addition to recommendations regarding specific sites for the transfer of solid waste, the Panel has developed recommendations for improvements in the current MSW management system in the District.

• Citizen Convenience Recycling Centers - Establish a system of clearly visible citizen convenience recycling drop-off facilities to facilitate recycling of MSW throughout the many neighborhoods of the District. Advisory Neighborhood Commissions should be involved in the selection of appropriate sites within each ward of the City. This system must be supported by a wide-ranging program of public education to encourage its use and ensure proper management. In addition, experiences with prior programs indicate that such facilities should be staffed during operating hours to ensure clean and efficient operation. The current Clean City Initiative undertaken by the Mayor's Office offers a promising basis for the establishment of a system of citizen convenience centers.
• Trash Transfer Advisory Board - Establish an independent advisory board to provide citizen input to oversight of the operations of public and private solid waste transfer and recycling facilities. The composition, by-laws, and authority of the advisory board need to be carefully crafted to create a body that can bridge the gap between neighborhoods, regulatory officials, and facility operators. The advisory board could fill many roles, including transmitting neighborhood concerns to regulatory officials and facility operators, providing education to citizens, and/or proposing changes in regulations and performance standards to decrease potential negative impacts in the locale of facilities.
• Public Facilities Element of Comprehensive Plan - Develop and implement a detailed comprehensive plan for public facilities to avoid future conflicts between the siting of competing public facilities and to ensure adequate planning for public infrastructure. Throughout the Panel's research, the lack of comprehensive planning for the provision of municipal services became evident. The current public facilities element of the Comprehensive Plan does not even address solid waste transfer facilities and does not provide substantive guidance for the siting and coordination of the wide variety of public services necessary in the District. In addition, economic development pressure is removing some land from the public sector, further limiting options for siting public facilities. The Panel recommends that the current public facilities element of the Comprehensive Plan be significantly expanded to provide for an overall coordination of the physical space necessary to provide services to the citizens of the District. Public facilities to be included in this plan include trash transfer facilities, vehicle maintenance and storage facilities, storage of snow-removal chemicals, asphalt milling facilities, driver testing facilities, vehicle impoundment lots and equipment storage, among others.
• Regulations and Standards for Construction and Demolition Recycling Facilities - Develop new laws, regulations and performance standards that are appropriate for facilities that process and transfer construction and demolition debris. Such facilities are similar in many ways to solid waste transfer stations, but the differences in the level of putrescible waste and thus the lower levels of odors, disease vectors, and other neighborhood impacts put them into their own category. The processing of construction and demolition debris is an important capacity to maintain within the city as the current economic and construction boom continues. The City should develop and adopt standards for such facilities that will protect the neighborhoods in which they are located while providing a reasonable framework within which these facilities can operate cleanly and efficiently.
• Regulations and Standards for Reduction of Diesel Particulate Matter — Develop laws and regulations to reduce the amount of particulate matter emanating from diesel trucks. Diesel particulate matter is generally recognized as a form of air pollution that is dangerous to public health; and particularly to individuals who may suffer from asthma and other chronic respiratory ailments.

It is beyond the technical competence of the Panel to make specific recommendations concerning regulatory measures that may affect vehicle inspections, the use of low-sulfur fuels, and air quality monitoring; however, the Panel urges the Council to recognize and respond to the trend toward the advocacy of such measures and the regulatory initiatives of the U.S. Environmental Protection Agency.

The Panel recognizes that, given the limitations of current science, it is not possible to measure the actual environmental effects of a given number of trucks in any specific neighborhood, and therefore presents this recommendation in the context of the city as a whole.

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Other Recommendations

• Public Education Campaign - Establish an active public education program to improve citizen awareness of the solid waste process, the precise nature of impacts on neighborhoods from solid waste facilities, and the role that citizens can play in improving the handling of solid waste in the District. This campaign could be an extension of the Mayor's Clean City Initiative and should also be coordinated with the current efforts to increase enforcement of solid waste regulations and rodent control.
• Co-Location of Business Opportunities - Create incentives for a recycling, salvage or material re-use business to locate at the site of the proposed new transfer station at the Southwest impoundment lot site. The provision of additional jobs for the community through a deconstruction or other business created as a public-private collaboration can contribute to the continuing economic resurgence of this area of the District.
• Best Available Control Technologies - All facilities, public and private, must comply with 13MPs and basic requirements of D.C. Law 12-286; comply with all site buffer and setback requirements of D.C. Law and zoning code for current public and private sites; and comply with all current permit requirements, including transportation plans, for private and public facilities. Regulations need to be enacted and codified to bring BMP and BACT requirements into effect.
• Land Use, Planning and Zoning Issues - Establish a system that creates an efficient and timely connection between planning decisions made by District government and implementation by the Zoning Commission. The fragmented control of planning and zoning responsibilities in the District, out-of-date zoning categories, and the lack of a planning commission and other planning tools make it difficult to achieve comprehensive land use planning in the District, especially for necessary but often unpleasant uses such as trash transfer stations. The City Council and Mayor should initiate a review of land use and zoning authority in the District and propose a system that allows for more comprehensive land use planning and implementation of those plans.
• Comprehensive Public Health Study - Conduct a comprehensive public health study, including potential exposures from trash-transfer stations on District of Columbia residents and neighborhoods in close proximity to trash-transfer stations. Throughout its year-long deliberations, the Panel encountered data gaps on the relationship between trash-transfer facilities and adverse health outcomes for residents who reside in close proximity to trash-transfer stations. The Panel strongly recommends that the Department of Health undertake such studies.

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MINORITY OPINION
STATEMENT OF CHAZ MILLER, Member, Solid Waste Transfer Facility Site Selection Panel

I cannot support the Panel's site selection recommendations. Instead of basing its recommendations on a rigorous examination of site criteria, the Panel recommended sites based on unsupported beliefs about what might be "suitable" sites. The Panel's decision to vote on "suitable" sites was taken without adopting site criteria and before Panel members received our consultant's analysis of proposed site criteria and the application of those criteria to particular sites. Simply put, the Panel chose sites before it chose site selection criteria.

While Panel members discussed site criteria at many meetings, we never agreed on a specific set of criteria. This decision to choose sites before approving site criteria is especially troubling in the light of the enthusiastic response of Panel members to the National Environmental Justice Advisory Council's Waste Transfer Station report. NEJAC recommended that transfer station site criteria be proposed and subjected to public review before the criteria are officially approved. Sites would then be selected based on those criteria.

As noted above, the report from the Panel's consultants includes recommendation for site criteria including zoning and setback/buffer distance. However, no reason is given in that report for limiting transfer stations do M-zoned property. Nor are any health or environmental reasons provided for the proposed revisions to the 50-foot setback and the 500-foot buffer requirements of D.C. Law 12286. Instead, our consultant is simply trying to make the unworkable requirements of D.C. Law 12-286 workable. For that matter, no Panel member has been able to provide a cogent reason for the setback and buffer requirements in D.C. Law 12286.

The Panel's recommendations to expand and upgrade the Ft. Totten transfer station and to build a new transfer facility at the Southwest Impoundment lot are fundamentally flawed. While I support upgrading the Ft. Totten facility. I do not support the panel recommendation that Ft. Totten be one of only two transfer stations in Washington. The Panel failed to undertake any analysis of the amount of solid waste an expanded Ft. Totten facility can handle; failed to examine the transportation impact of an expanded Ft. Totten facility on the roads leading into and out of the Ft. Totten facility (it is worth noting that our consultant's report lists Ft. Totten as the existing facility that is farthest away from an expressway); failed to consider how queuing can be avoided at Ft. Totten if it is one of only two transfer stations in Washington; and failed to consider the cost of purchasing land north of Ft. Totten and converting that land for solid waste needs.

The Panel's vote in favor of converting the Southwest Impoundment Lot into a transfer station was taken without a Panel visit to the site; without any consideration of the transportation impacts on the surrounding community; and without any regard of the cost to the Department of Public Works to reroute its trucks to a new transfer station location. In fact, the Panel voted to take this land without giving any thought to a new location for the impoundment lot. The Panel then voted in favor of adding a "Public Facilities Element" to the Comprehensive Plan. How can the Panel argue that the District's infrastructure needs need to be formally addressed while at the same time adding to the infrastructure problems by telling the DPW to find a new site for its impoundment lot?

Moreover, by recommending that only two transfer stations be sited in Washington, the Panel has failed to learn from the mistakes of the past. In 1993, one year before the Carbone decision, the District government excluded private haulers from the Ft. Totten and Benning Road transfer stations because those two facilities were not being maintained. Yet the Panel now wants to reinvent the wheel that failed by forcing the closure of the privately owned and operated transfer stations. And the Panel has not provided an implementation plan to ensure an orderly transition to two facilities.

Transfer stations are a vital part of the public infrastructure. In spite of the Panel's overblown rhetoric about the potential dangers of these facilities, properly operated transfer stations provide an absolutely essential public health function. The Agency for Toxic Substances and Disease Registry investigated the transfer stations in Washington and found no reason for a public health assessment. We need to ensure that these facilities continue to provide a public service.

Finally, I believe that a comprehensive public health study of District of Columbia residents and neighborhoods should be undertaken. Such a study is long overdue. When public health agencies know the true causes of disease in Washington, they can better protect the public's health.

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SELECTED REFERENCES

Blumberg, Louis and Robert Gottlieb. War on Waste: Can America Win Its Battle with Garbage?. Washington, D.C.: Island Press, 1989.

Clark, Robert Maurice. Analysis of Urban Solid Waste Services: A Systems Approach. Ann Arbor, Michigan: Ann Arbor Science Publishers, Inc., 1978.

Council of the District of Columbia Committee on Public Works and the Environment. Committee Report on Bill 13-30, "Solid Waste Facility Permit Amendment Act of 1999." Washington, D.C.: February 18, 1999.

Department of Consumer and Regulatory Affairs. Solid Waste Facility Status Report. Washington, D.C.: July, 1999.

GBB Solid Waste Management Consultants. District of Columbia Waste Tracking System: Report prepared for DC Office of Recycling, Department of Public Works. Washington, D.C.: January 15, 1993.

Government of the District of Columbia, Office of the Corporation Counsel, Government Operations Division, Land Use and Public Works Section. Opinions Relating to the Solid Waste Facility Permit Act. (Fax of November 19, 1999).

Hickman, Lanier. "Garbage: Bin there, done that." American City & County. November 1999. pp. 60-67.

Kreith, Frank (editor). Handbook of Solid Waste Management. New York: McGraw-Hill Inc., 1994.

Liptak, Bela. Municipal Waste Disposal in the 1990's. Radnor, Pennsylvania: Chilton Book Company, 1991.

Neal, Homer A. and J. R. Schubel. Solid Waste Management and the Environment: The Mounting Garbage and Trash Crisis. Englewood Cliffs, New Jersey: Prentice-Hall, Inc., 1987.

United States Environmental Protection Agency Federal Advisory Committee - National Environmental Justice Advisory Council. A Regulatory Strategy for Siting and Operating Waste Transfer Stations: A Response to a Recurring Environmental Justice Circumstance. Waste and Facility Siting Subcommittee, Waste Transfer Station Working Group, March, 2000.

World Wildlife Fund. Getting at the Source: Strategies for Reducing Municipal Solid Waste. Washington, D.C.: Island Press, 1991.

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SELECTED TESTIMONY

Jan 22, 2000

DC Solid Waste Transfer FAcility
Washington, DC 20009

Site Selection Advisory Panel:

As a concerned citizen and resident of 4th & M Street area, I'm asking for no further expansion of trash/garbage operation in this area.

The odors and trucks are sometimes unbearable including noise.

Please consider non-residential areas for this type of operation.

Sincerely,
Helen P. Lester

AMERIWASTE
9550 Berger Road
Columbia, Maryland 21046
1-877-56-WASTE
(410) 309-0462 Fax: (410) 309-1088
Email: amerwste@bellatlantic.net

March 15, 2000

District of Columbia Solid Waste Transfer Facility Site
Selection Advisory Panel

Ameriwaste services the construction and demolition industry throughout the Washington region. Our ability to service customers inside the District is greatly enhanced with utilization of the various transfer stations within the city limits. We currently operate three roll off trucks in the DC area. Without the transfer stations our company would operate five trucks in the same operational area. This equals more equipment, more pollution, more traffic, more time spent entering departing city locations.

Our company is also affiliated with a demolition firm that frequently uses two trucks all day. The equivalent truck utilization for this volume of work would be four to six.

Ameriwaste was established over fifteen months ago, we rely on the DC market to provide a volume of work flat a smaller fleet can effectively service. The companies we service will not accept a lower level of service. We cannot afford a larger fleet. We will accept a bigger role in supporting the operation at highly valued transfer station operations.

Sincerely,
David Wendell
Business Development

STATEMENT OF RONALD P. ADOLPH
Consultant to Waste Management of Maryland, Inc.
to the Solid Waste Site Selection Advisory Panel
January 29, 2000

OPENING REMARKS

• INTRODUCTION
• EDUCATION/EXPERIENCE - 18 YEARS IN SOLID WASTE MANAGEMENT
• HELPED ESTABLISH WM AT QUEENS CHAPEL FACILITY AND TURN IT INTO A CLEAN, WELL-RUN OPERATION
• FIVE POINTS I WANT TO DISCUSS TODAY:
  • MY PROFESSIONAL OPINION THAT SITE IS APPROPRIATE
  • PRIOR CONDITIONS AT THE SITE
  • IMPROVEMENTS WM HAS MADE TO THE FACILITY
  • WM's CONTRIBUTION TO ECONOMIC VITALITY OF CITY
  • WM's CONTRIBUTIONS TO THE COMMUNITY

SITE IS APPROPRIATE FOR TRANSFER STATION

• C-M ZONE DISTRICT
  • HEAVY COMMERCIAL/LIGHT INDUSTRIAL USES
  • TRANSFER STATION COMPATIBLE WITH THAT ZONE DISTRICT
    [AND WE BELIEVE PERMITTED AS A MATTER OF RIGHT PRIOR TO CREATION OF NEW CATEGORY UNDER ZONING REGS, BUT THAT ISSUES IS BEING DEBATED IN ANOTHER, APPROPRIATE FORUM]
  • IN FACT, LESS INTENSIVE OR INTRUSIVE USE THAN SOME MATTER-OF-RIGHT USES THAT ARE STILL PERMITTED, SUCH AS:
  • INCINERATOR (§ 801.7(D) OF ZONING REGS)
    • FUNCTIONS ALMOST EXACTLY THE SAME AS A TRANSFER STATION, EXCEPT
      • INCINERATOR BURNS THE TRASH, CREATING FLYASH AND OTHER AIR POLLUTANTS
      • WHILE TRANSFER STATION GENERATES NO AIR POLLUTANTS
    • WE COULD GO OUT AND BUILD AN INCINERATOR RIGHT NOW, AS A MATTER OF RIGHT, AND WE WOULDN'T BE HAVING ANY OF THESE DISCUSSIONS. BUT WE DON'T WANT TO DO THAT - WE'RE A HANDLING FACILITY. WE WANT TO COME UP WITH THE BEST SOLUTION FOR THE DISTRICT, AND WE BELIEVE THIS SITE WORKS. LET ME TELL YOU WHY.
• SITE LOCATED IN INDUSTRIAL AREA
  • INDUSTRIAL AREA LOCATED OFF NEW YORK AVE. AND BLADENSBURG RD.
  • IMMEDIATE VICINITY COMPRISED OF:
    • CEMENT PLANT
    • MACHINE SHOP
    • AUTO BODY REPAIR AND PAINT SHOP
    • TAXI REPAIR GARAGE
    • RECYCLING FACILITY
    • VACANT LIGHT INDUSTRIAL BUILDINGS
  • RR TRACKS SEPARATE INDUSTRIAL AREA FROM RESIDENTIAL NEIGHBORHOOD
• 300 FT.V. 500 FT. BUFFER
  • COMPLIES WITH 300 FT. BUFFER REQUIRED 1N ZONING REGS (§ 802.4(A))
  • IN DETERMINING APPROPRIATENESS OF 300 FT., ZONING COMMISSION AND OFFICE OF PLANNING CONSIDERED AND REJECTED 500 FT. BECAUSE:
    • IT WOULD EFFECTIVELY PROHIBIT SOLID WASTE FACILITIES FROM LOCATING IN DC, WHICH HAS A NEED FOR HANDLING APPROXIMATELY 800,000 TONS OF SOLID WASTE PER YEAR (SEE ZC ORDER NO. 542, D.C. REGISTER MARCH 27, 1998, P. 1879)
    • COMMISSION ON PUBLIC HEALTH LIKEWISE RECOMMENDED A MINIMUM OF 300 FT (ALSO IN ZC ORDER 842)
  • HIGHLY QUESTIONABLE WHETHER CITY COUNCIL HAS AUTHORITY TO INCREASE DISTANCE TO 500 FT. D.C. COURT OF APPEALS HAS REPEATEDLY STATED THAT ZONING COMMISSION HAS EXCLUSIVE AUTHORITY OVER ZONING MATTERS. THIS TYPE OF BUFFER IS A ZONING MATTER.

PRIOR CONDITIONS AT SITE

• BUILDING UNENCLOSED-DRUG HAVEN
• POORLY RUN FACILITY (NO UNIFORM MGMT POLICY)
• UNPAVED YARD THAT GENERATED DUST IN THE VICINITY-NOW PAVED
• VASTLY DIFFERENT AND IMPROVED TODAY, AS NEIGHBORS CAN ATTEST

IMPROVEMENTS THAT EXCEED MINIMUM REQUIREMENTS

• ENHANCED APPEARANCE OF FACILITY
• CONSIDERABLE SUMS EXPENDED
• TREES, GRASS AND OTHER LANDSCAPING
• FACILITY IS FULLY ENCLOSED -TRASH PROCESSING NOT VISIBLE TO THE PUBLIC (CONTRAST WITH FACILITIES ACROSS RR TRACKS NEAR THE NEIGHBORHOODS)
• Odor Abatement/Negative Air Pressure System Installed
  • NO COMPLAINTS IN LAST YEAR FROM NEIGHBORS IN NEARBY RESIDENTIAL ZONE
  • ATTRIBUTE TO NEGATIVE AIR PRESSURE FILTRATION SYSTEM
  • DESCRIBE MECHANICS:
    • VACUUM EFFECT TO KEEP AIR INSIDE
    • AIR CLEANED THROUGH FILTERS
    • STATE OF THE ART SYSTEM
    • ONLY ONE OF ITS KIND IN THE REGION
    • $150,000 TO INSTALL, $30,000 A YEAR TO MAINTAIN
    • EXCEEDS INTERIM PERMIT STDS
• "ECOLO SYSTEM"
  • ODOR CONTROL SYSTEM INSIDE BUILDING AND AT PERIMETER OF SITE
  • BREAKS DOWN ODOR MOLECULES
  • ADDS FRESHENER
  • SPRAYS TRUCKS (IN ADDITION TO COLLECTED TRASH)
• TRAFFIC CIRCULATION IMPROVEMENTS
  • NO LEFT TURN INTO RESIDENTIAL AREA
  • TRUCK QUEUING ON STREETS ELIMINATED - ALL ON SITE NOW
  • ESTABLISHED IN 1996 THE CITIZENS MONITORING COMMITTEE TO IDENTIFY PROBLEMS AND RESOLVE THEM. RESULTED IN SITE IMPROVEMENTS (PAVED YARD, NO LEFT TURN, ETC.)

CONTRIBUTIONS TO ECONOMIC VITALITY OF DISTRICT

• GENERATES APPROXIMATELY $23,000 IN REVENUE PER MONTH FOR CITY
• APPROXIMATELY 16,000 TONS OF WASTE HANDLED PER MONTH

COMMUNITY PARTICIPATION

• HENRY LEE
• PETITION IN SUPPORT
• LANGDON SCHOOL AND DOUGLAS STREET
• DOUGLAS STREET BLOCK CLUB ALSO IN SUPPORT
• NAZ CON, INC. - CEMENT PLANT ACROSS QUEENS CHAPEL ROAD
• DWIGHT A. MOSLEY MEMORIAL FUND
• ANC CONTACTS: BOB KING, ANC 5A

CONCLUSION

• WE HAVE ACTED RESPONSIBLY AND IN GOOD FAITH WITH RESPECT TO THIS FACILITY
• OUR FACILITY IS AN APPROPRIATE USE IN THIS HEAVY COMMERCIAL/LIGHT INDUSTRIAL ZONE

THANK YOU.

I WOULD BE HAPPY TO ANSWER ANY QUESTIONS YOU HAVE.

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ACKNOWLEDGEMENTS

ELECTED OFFICIALS

Council of the District of Columbia

Linda W. Cropp, Council Chair

Harold Brazil, At-Large Kathleen Patterson, Ward 3
David A. Catania, At-Large Charlene Drew Jarvis, Ward 4
Carol Schwartz, At-Large Vincent B. Orange, Sr., Ward 5
Phil Mendelson, At-Large Sharon Ambrose, Ward 6
Jim Graham, Ward 1 Kevin P. Chavous, Ward 7
Jack Evans, Ward 2 Sandy Allen, Ward 8

Mayor Anthony A. Williams

PANEL MEMBERS

Dorn C. McGrath, Jr., AICP, Chairman
Ferial S. Bishop, Vice Chairman
Lisa G. Dowden, Esq., Secretary
Marilyn W. Groves, Esq.
George E. Gurley¹
Chaz Miller
Rev. Morris L. Shearin, Sr.
Anthony L. Shum, Esq.
Richard N. Wolf, Esq.

EX OFFICIO MEMBERS

Department of Health: Ted Gordon, Director; Dr. Lynette Stokes, Designate
Office of Planning: Andrew Altman, Director; John Moore, Designate
Department of Public Works: Vanessa Dale Burns, Director², Leslie Hotaling, Interim
Director; Hallie Clemm,³ Sybil Hammond, Designates
Department of Consumer and Regulatory Affairs: Lloyd Jordan, Director;⁴ Wilbur Nelson,⁵ Designate Office of Corporation Counsel: Robert A. Rigsby, Corporation Counsel; Lisa Bell, Mary Nagelhout,⁶ Designates

SUPPORT STAFF & CONSULTANTS

Lara Fisher, Brenda Sandberg, SCS Engineers, Covington & Burling, Joseph Passonneau & Partners, Planet Vox

1. Resigned from Panel on April 21, 2000
2. Resigned from DPW, 2000
3. Resigned from DPW, May 2000
4. Resigned from DCRA, August 2000
5. Resigned from DCRA, September 2000
6. Assigned to Panel on August 18