BioCycle August 2011, Vol. 52, No. 8, p. 28
Study of residential and commercial food scraps collection and composting programs identifies barriers and suggests solutions, including modifications to state permitting processes. Part II
Juri Freeman and Lisa Skumatz

BioCycle Web Extra:
Read Part I of this article
The full report on residential and commercial food scraps collection and composting programs is available via a link on this page

A NATIONAL study, funded by USEPA Region 5, of residential and commercial food scraps collection and composting programs in about 200 communities in the United States confirms the growing interest in food waste diversion. Part I of this two-part article series (“Food Scraps Programs In The United States,” July 2011) reviewed the number and location of programs identified in the study, tonnages diverted, program costs and tip fees. Part II, based on data from the same study, highlights common barriers faced by program managers across the U.S., as well provides a selection of best management practices.
The most commonly reported barriers to implementation of food waste programs include a lack of political will to implement food scraps program, permitting facilities to receive food scraps, costs and contamination, public perceptions about the food waste “yuck” factor and attracting unwanted vectors. Interviewees offered a variety of solutions to overcome them.

BARRIERS/SOLUTIONS
Political Willingness: Without political will behind a program, implementation rarely happens. Getting elected officials, business leaders and other stakeholders on-board to support a program is an important factor for success. Educate on why the program should be adopted, and motivate using avoided landfill disposal costs or saving landfill space, meeting community or business greenhouse gas reduction targets, doing “good” for the environment, job creation, and others.
Waste characterizations are helpful in showing how much of the current waste stream can be diverted (although if local residential results are not available, public data may suffice in making the point). Waste audits can be particularly useful in the commercial sector to help generators realize potential cost savings from diversion. Starting a citizens’ committee or a business or trade group to get the ball rolling is a common path toward implementation. One or two dedicated individuals in a community can go a long way toward getting a program started. Statewide stakeholder groups, gathering all the players, including generators, haulers, processors and elected officials, have helped initiate programs in states including Massachusetts and Ohio.
Facilities and Infrastructure: The most concerning barriers related to facilities permitting, lack of processing capability, NIMBYism, odors at existing operations, distance to the nearest facility, and time delays related to changing existing programs to accept food scraps. Policy changes at the state level may be needed in some areas (discussed in more detail below). Siting facilities farther from neighbors, following best practices in processing to avoid odors, and working with commercial generators to identify particular loads that may be troublesome were all suggested by interviewees. Pilot programs are also useful to allow a facility to perfect the “recipe” for processing, e.g., optimizing C:N ratio, bulking agent requirements, etc. However, a pilot may not be necessary in regions where already successful food scraps programs are operating.
Cost: Whether related to residential or commercial user fees or rate structures, community or government costs for carts, collection, trucks, etc., private hauler costs, or the food scraps tip fees, cost is a common barrier to implementing programs. This barrier is difficult to overcome; many successful programs still have cost issues yet to be fully resolved.
Communities addressed residential cost issues by partnering with other communities or counties for outreach, not giving kitchen containers to all households, (only those that request them, or using coupons), using PAYT (pay-as-you-throw) trash rates and embedding the costs of a base service level for organics collection in the trash rates (often for a 32-gallon level of service with increased fees for additional levels of service), alternating every-other-week collection of recyclables with every-other-week collection of organics using the same trucks, and applying for local, state and national grants to help get the program started.
On the commercial side, some communities are partnering with large corporations or supporting private programs (e.g., Walmart, Kroger’s, etc.), providing audits to interested businesses to show potential cost-savings by reducing trash service levels, offering small “start-up” grants for businesses to address capital needs, or providing a subsidy to commercial generators to make food scraps/organics collection competitive with trash or recycling. Establishing program rates to cover the entire costs of collection and processing will help ensure viability over the long term regardless of vagaries in the market.
Contamination: Contaminants are the nemesis of most composting programs, including those diverting food scraps. Plastic bags, disposable food service items (from packaged condiments to coffee stirrers), some biodegradable products, etc., are among the contaminant sources.
Education is key to overcoming this barrier. On the residential side, community-based social marketing can be useful; on the commercial side, employee training and staff meetings to get employees behind the program have been shown to reduce contamination. Some programs have banned use of any plastic bag regardless of whether or not it is compostable, while other programs have invested in equipment on the processing side (similar to a large vacuum) to deal with the small pieces of shredded plastic bags.
Public Perceptions: This category of barriers includes the “yuck” factor and generator perceptions. The idea that food, initially attractive and edible, becomes a pest-ridden and disgusting item once transferred from the plate to the composting pail or bin, is a common problem in food scraps composting programs, especially in the beginning. This tends to be especially true in residential programs but was also noted to be an issue among employees in some commercial programs. Additionally, the perception that combined food scraps/compostables will attract greater numbers of pests, animals and other vectors is another common barrier in this category. Typically this is not an actual issue at the curb; however it can be a factor on the facility side.
Like many of the other barriers discussed, education, persistence and a consistent message are key to overcoming the yuck factor and vector concerns. Changing the mindset for residents and businesses can be a daunting task but not a program deal-breaker. Some communities have focused on pizza boxes or other food-soiled paper as a way to get generators into the habit of source separation and move on to vegetative and eventually meat and dairy products later. Others provide directions for disposing of meat and dairy scraps that may minimize the “yuckiness,” such as freezing items, wrapping them in paper towels, putting them in cardboard boxes, and “layering” the yard trimmings and food scraps.

PERMITTING
Increasing numbers of haulers are seeing the potential of generating new revenues by offering a new food scraps collection service. At the same time, program managers are embracing food scraps diversion as a way to meet goals. However, in many regions across the country, the growth in program adoption is outpacing the growth of permitted capacity. One of the largest, if not the single largest, barrier to increased capacity development was reported to lie within the permitting process. The issues that multiple states are attempting to sort out include: developing a definition of yard trimmings, food scraps and municipal solid waste; setting the correct level of regulation that is not too stringent and not too loose; addressing potential environmental issues; and creating a stable regulatory framework and removing uncertainty in the marketplace.
Some states successfully addressed the permitting process and provide potential lessons for those still grappling with the issue. A few of the best management practices in permitting include:
Stakeholder Meetings and Public Comments: Whether or not a public process and stakeholder meetings are mandated in the rulemaking process for the state, almost all states considering changes to the regulations undertake both. By getting all of the important voices on the matter involved in the conversation, the state is able to develop a regulation that meets the needs of the generators, industry and the environment – and gather enough support to get new rules adopted.
Definition of Food Scraps: In some states, food waste falls under the MSW definition, meaning that in order for a facility to process food scraps it must obtain a solid waste facility permit. On the other hand, if food scraps are not specifically defined, they may fall under yard trimmings composting site permitting, which may not provide enough regulation to protect the environment. It is recommended to clearly define food scraps separately from yard trimmings and solid waste so that an adequate level of regulation can be developed.
Facility Classification/Tiered Regulatory Structure: By creating a tiered permitting framework and setting a classification specifically for food scraps composting, the state can promulgate regulations that encourage development of facilities with the proper level of regulation. States are leaning toward creating a kind of middle ground, i.e., a classification that covers such environmental considerations as setbacks, flood plains, pads or liners and odor control, while at the same time not being overly burdensome for food scraps facilities.
Environmental/NIMBY Factors: Odors can shut down a facility, making it important to draft regulations that deal with air quality from the start. Whether this happens via setback requirements from neighbors, cover systems, inspections or some combination, odor management must be addressed as facilities need to be good neighbors.
Lowering Permitting Fees: Many states are significantly lowering or all together dropping permitting and application fees associated with food composting facilities to encourage development of new sites and remove the cost barrier.
Exemptions For Yard Trimmings Facilities: There is a well-established composting infrastructure for yard trimmings, in part due to disposal bans enacted by about two dozen states in the late 1980s and early 1990s, and mandatory state recycling goals that encouraged yard trimmings diversion. As a way to speed adoption of additional food scraps composting programs, some states are allowing already permitted yard trimmings sites to accept a minimal amount of food scraps (generally 5% to 10%) without any changes to their existing programs.
Innovation In Rulemaking Process: New and innovative approaches to existing state regulations and rulemaking processes may be needed for states to deal with food scraps requirements. For example, Indiana chose to remove the solid waste permitting requirement for food scraps composting facilities and instead use the marketing and distribution permit. This enabled the state to quickly overcome barriers to new facility development and remove the onerous $12,000 permitting fee while still addressing environmental concerns.
Food scraps represent one of the largest remaining components of the waste stream. Whether it is diverted from the commercial or residential sector, processed as food to hogs, composted or sent to some other end use, food waste strategies are becoming main stream. By examining what has already occurred, learning from our peers and sharing knowledge, future programs can be designed to more cost-effectively divert significant and meaningful amounts of this beneficial stream from our landfills.

Juri Freeman is a Senior Environmental Analyst at The Econservation Institute (www.econservationinstitute.org) and Skumatz Economic Research Associates (www.serainc.com). Lisa Skumatz, PhD, is founder of The Econservation Institute and Principal of SERA. Freeman and Skumatz work with communities, counties, states, and federal agencies to analyze effective and cost-effective solid waste diversion strategies. This Econservation Institute project was conducted under a grant from EPA Region 5. Additional information on Best Management Practices can be found in the full report “Best Management Practices in Food Scraps Programs” available at on www.foodscrapscomposting.com.