The Massachusetts Waste Conundrum

With landfill capacity expected to decline to 600,000 tons in 2020 and combustion capacity remaining flat, a gap begins to emerge that may exceed 2 million tons a year by 2020 — depending on how successful the state is at improving the diversion rate. Part II

Zoë Neale
BioCycle February 2013, Vol. 54, No. 2, p. 35

Massachusetts has a problem. It faces the combined dilemma of landfills reaching the end of their permitted life, a combustion moratorium in place and stagnant recycling and diversion rates. The net effect is that the state must take an aggressive stance on waste options or the exportation of solid waste will become the only option. Massachusetts regulators have begun the process by revising existing regulations and creating new ones, such as removing organics from onerous solid waste regulations and redefining them as a raw material in conjunction with creating a separate set of definitions and corresponding amended and new regulations.

The Massachusetts Department of Environmental Protection (DEP) has laid the groundwork for an expected disposal ban on commercial and institutional organics (see “Setting The Table For An Organics Ban, Part I,” December 2012). The key motivation for this ban is based on data that indicates that over 20 percent of Massachusetts’ municipal solid waste (MSW) going to disposal is compostable (approximately 15% food, 7% compostable paper). Should the ban prove effective, significant amounts of organic material will be diverted thereby lessening the burden on an already disposal space constrained state. The DEP has used multiple waste bans in the past to achieve diversion goals which, critics claim, have had varying levels of success in keeping the banned materials out of landfill or combustion. The hope is that the organics ban will spur development of significant new capacity for processing, including composting sites, anaerobic digesters and slurry operations that would function as transfer stations for organics.

This article, second in a series of three, will profile the recent past, present and future solid waste landscape in Massachusetts, including the goals and approaches detailed by the 2010-2020 Draft Solid Waste Master Plan. Part III of this series will discuss the real world implementation issues associated with the upcoming organics ban.

Big Picture

Massachusetts’ solid waste and waste disposal landscape is significantly influenced by three realities: It’s old (many towns were founded in the 17th century), relatively small (200 miles long and 50 miles wide) and its population is heavily skewed to the eastern portion of the state with approximately two-thirds of residents living in the Greater Boston area. These characteristics have led to solutions that are quite different when compared to the rest of the country. In 2010 (the most recent data available), businesses and households generated a total of 10.6 million tons of nonhazardous solid waste of which 71 percent or 7.5 million tons were MSW and 29 percent or 3.1 million tons were non-MSW —the majority of that being construction and demolition debris (C&D). Recycling, composting and cocomposting led to a 48 percent diversion rate (of all solid waste, including C&D) with the remaining 52 percent being disposed via landfill (15%), combustion (30%) and export. Contrast this to the U.S. as a whole where the totals are 24 percent recycled, 69 percent landfilled and 7 percent combusted  (see “The State of Garbage In America,” October 2010) and the unique nature of the Massachusetts waste picture emerges. Space constraints and population skewed to the east have led to higher diversion, fewer landfills and more combustion.

Of the 5.4 million tons of solid waste (MSW and non-MSW) that remain after diversion, only 30 percent (1.6 million tons) goes to landfill, while a whopping 60 percent (3.2 million tons) is combusted for energy. The balance is exported via rail and truck to other states including Maine, New Hampshire and New York for MSW and Ohio for C&D. Ironically, over 400,000 tons of MSW was actually imported from Rhode Island, Connecticut and New Hampshire, most likely due to proximity to Massachusetts’ large combustion facilities.

Tables 1 and 2 summarize the 2010 data just discussed, as well as offer a comparison to 2003. Trends in Massachusetts since 2003 show a significant decline (20%) in overall solid waste generation from 13.2 million tons in 2003 to 10.6 million tons in 2010. Unfortunately MSW has only seen a decline of 1 million tons (11%) versus C&D, which has decreased by 43 percent, a dramatic change that can be wholly attributed to the softness in the real estate market. As a result, although the absolute amount of solid waste generation has declined, the proportion of waste considered MSW has actually increased.

In tandem with the declines in total solid waste generation seen in Massachusetts since 2003, diversion volumes have dropped by an even greater amount (-26%), leading to a decrease in the overall diversion rate from 52 percent to 48 percent. Over that period, despite the fact that absolute volumes of recycling and composting have remained essentially constant, C&D recycling has dropped an incredible 46 percent despite an aggressive C&D waste ban going into effect in 2006. Herein lies one of the biggest challenges the state faces: With negligible amounts of new processing capacity for organics having been developed in the last 10 years, will the anticipated disposal ban create the conditions necessary to spur new facilities?

Draft Master Plan: Hopes, Dreams And Aspirations

In 1990, the DEP introduced the Solid Waste Master Plan (SWMP) process, a rolling 10-year planning cycle that details specific challenges, goals and strategies to address the state’s solid waste landscape for the following decade. From a high level policy perspective, the state seeks to meet capacity needs through increased recycling and composting (diversion), rather than the creation of new disposal sites or expansion of existing facilities. Due to ever increasing budget constraints, it is clear that achievement of these goals is entirely dependent on private market development of new capacity. This has been a huge challenge considering that market conditions have not led to increases in either recycling or composting in the last 10 years.

To help stimulate implementation, Massachusetts has a set of initiatives, several of which are new. These include: 1) Funding recycling programs using the renewable energy credits (RECs) received from combustion facilities (facilities are required to devote 50% of the Class II RECs they generate from energy sales); 2) Establish a regional producer responsibility system; 3) Require haulers to provide full recycling services; 4) Amend siting regulations to streamline recycling, composting and anaerobic digestion facility development (see Part I, December 2012); 5) Expansion of authority over problem landfills; and 6) Establishment of more rigorous waste ban standards. Note that the funding of these initiatives is almost entirely dependent on the combustion facility RECs, currently running at around $3 million a year to state coffers versus the $6 million the 2010-2020 SWMP had modeled. This lower than expected funding has resulted in a slower than expected roll out of many of the above initiatives, particularly those focusing on market development and waste ban monitoring and oversight.

Another problematic aspect of the current SWMP is that despite the fact that the original plan was released in July 2010, the 2010-2020 Massachusetts SWMP, subtitled “Pathway to Zero Waste,” remains in draft form. The reasons behind the delay are somewhat murky although clues may be found in recent revisions to the draft released in December 2012. This draft (of the Draft SWMP) includes a controversial new element — modification of the moratorium on MSW combustion that has been in place since 1990. The original Draft explicitly stated that the moratorium would be maintained yet the December 2012 draft opens the door to thermal conversion technologies that result in energy or fuel, a change that has created considerable consternation within the environmental advocacy community. The draft released last December remains in a public comment period and should be finalized sometime in the second quarter of 2013. Whether or not the moratorium modification will remain as part of the final plan is yet to be seen.

Despite its Draft status, considerable work is already being done towards implementing its most aggressive target: Reduce solid waste disposal by 30 percent by 2020 to 4.5 million tons per year (Table 3), or by a total of 2 million tons from 2008 levels (6.6 million tons). Aside from the revision of the organics regulations in order to encourage and enforce organics diversion (see Part I), the highest profile revision to the Draft SWMP is the aforementioned combustion modification which would allow and, in fact encourage, development of alternative thermal technologies (specifically pyrolysis and gasification).  The state is looking to potentially add up to 350,000 tons/year of additional capacity from this source, which is the same volume the DEP is hoping to divert via the organics ban. Taken together, even if both organics diversion and new combustion technologies are fully realized and 700,000 tons of material find a home, that would amount to less than half of the anticipated in-state capacity shortfall expected by 2020. Unless Massachusetts can move to reduce waste and aggressively recycle more, a gap emerges that presents a true conundrum for state officials.

Snapshot Of Existing Infrastructure

Massachusetts currently has a fairly robust network of disposal, recycling and composting facilities across the state. The largest single component of the state’s solid waste picture is waste-to-energy, which in 2010 processed 3.2 million tons. There are seven active combustion facilities in the state, four operated by Covanta and three by Wheelabrator. Covanta has approximately 60 percent market share of more than 3 million tons combusted, with one single facility, SEMASS in Rochester, Massachusetts, accounting for well over 1 million tons/year — almost 20 percent of annual statewide solid waste disposal. Similar to material flows to most disposal sites, approximately 80 percent of the loads that SEMASS processes come to the facility via trailers from a transfer station and are a mixture of residential and industrial/commercial waste. This aspect will clearly represent a complicating factor in terms of implementation of the upcoming organics ban at the facility due to commingling. In the words of one operator, “This is the first waste ban category that we can’t just look at and identify banned materials when a load comes in because the vast majority of the material in incoming loads is contained in nontranslucent garbage bags!”

Disposal capacity at the 16 active landfills in Massachusetts totaled just over 2 million tons/year in total in 2012. This year marks the beginning of a steady and precipitous decline of available capacity in Massachusetts. Four landfills are expected to close by 2014, representing a loss of 800,000 tons of capacity. By 2020, only five landfills in Massachusetts will be active and permitted to receive a mere 600,000 tons/year of waste.

Diversion capacity represents another challenge to achieving the state’s waste reduction goals. Recycling rates for the MSW stream have stagnated despite multiple bans on recyclable materials (many instituted years ago). The cause can be traced in part to exceedingly low recycling rates in many of Massachusetts’ largest cities. Specifically, six out of the 10 largest cities in the state have recycling rates below 20 percent with Boston reporting only a 13 percent rate. Development of any new recycling facilities would require aggressive action to increase the material volumes in order to rationalize private investment. In terms of composting, despite the fact that there are 221 active composting sites in the state, only 23 facilities are permitted to process a combined total of approximately 150,000 tons/year of food residuals. To meet the goal of an additional 350,000 tons, substantial new industrial-scale organics processing facilities are necessary. Unfortunately, it is clear that despite significant interest from anaerobic digestion and composting infrastructure developers, a multitude of interrelated factors are hindering project capital from being committed.

Lastly, the state is encouraging the processing of source separated organics (SSO) at wastewater treatment plants (WWTPs) in Massachusetts that currently have active anaerobic digestion units. Recent rule revisions explicitly allow addition of SSO to digesters located at WWTPs. As such, these facilities represent potential “path-of-least-resistance” processing capacity for organics diversion, assuming these digesters can take the material. There are six WWTPs in the state with AD. The Massachusetts Water Resources Authority (MWRA) facility on Deer Island (the second largest in the country) is going through the due diligence necessary to determine the technical and economic feasibility and impacts of adding slurried SSO to its digesters. Ultimately, despite the fact that the MWRA is a public authority created by an act of the state legislature, should the concept prove to be technically nonviable or have a negative impact on constituents (ratepayers in particular), the Authority is under no obligation to take the material. This option is still in the proof stage as it would require significant expenditures both by the public and private sectors.

Parting Observations

With landfill capacity expected to decline to a mere 600,000 tons in 2020 and combustion capacity remaining flat, a gap begins to emerge that may exceed 2 million tons a year by 2020 — as highlighted in Table 3 — depending on how successful Massachusetts is at improving the recycling rate. Even when accounting for an incremental 350,000 tons of organics diversion and 350,000 tons of disposal from “alternative technologies,” the underlying reality is that unless residents and businesses can embrace the idea of significant waste reduction, exporting waste beyond the state borders will become the only option. Compounding the difficulties, over the last decade almost no new capacity has been added for recycling or composting, with recycling rates increasing only because capacity has remained flat while MSW volumes have decreased.

Clearly, state resources should be targeted at facilitating private market solutions in conjunction with cost-effective municipal and regional recycling programs such as variable rate incentive, e.g., Pay As-You-Throw, and increased monitoring of existing waste bans (especially in regards to paper) to ensure higher compliance levels. Finding realistic solutions to the impending gap relies on economic feasibility and private market development with public and business education as a critical component.

Zoë Neale has spent the bulk of her career as an equity mutual fund manager and advocate for socially responsible investment. She currently works as an independent business consultant and is a founder and director of Save That Stuff Organics, an organics solutions affiliate of Save That Stuff Inc. Zoë is also the Treasurer of MassRecycle and chairs the Organics Committee for that organization.

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