Connecticut Department of Environmental Protection (DEP)

Proposed Amendment to the State Solid Waste Management Plan

July 2006

Comments submitted by Cheryl Dunson, Vice President Public Issues

August 2006

The League of Women Voters of Connecticut, comprised of over 2,500 members across the state, is a nonpartisan, political organization committed to effective public policy through education and action.  The League provides testimony on public policy issues based upon positions derived from member study and consensus.  The League supports policies to: reduce the generation and promote the recycling and reuse of solid and hazardous waste; ensure safe treatment, transport, storage and disposal of waste; and recognize suitable waste as potential resources. We appreciate the opportunity to comment on the Proposed Amendment to the State Solid Waste Management Plan [the Plan].

The Plan presents an excellent but sobering look at Connecticut’s solid waste management noting the status, pressures, events and trends that are impacting our state.  Although the 1991 Plan was premised on self-sufficiency, the 2005 figures presented in the current Plan reflect an approximate 12-fold increase in the out-of-state disposal of Connecticut’s solid waste since 1991. The Plan projects that if we maintain the current 30% diversion rate (through recycling, composting, source reduction, etc.), by 2024 we will be shipping approximately 1.6 million tons of waste out of state. [1] The Plan states simply and clearly “There is not enough disposal capacity in Connecticut to handle all waste generated in the state.”[2]  This is a call for decisive and re-invigorated action during the 20 year life of the Plan. Although the entire draft is worthy of comment, the League will concentrate on the proposed statutory changes and recommendations for refinement.

Statutory Changes

The League supports the nine significant statutory changes highlighted in the Plan’s Executive Summary.[3] In particular, the League supports:

Establishment of a recycling program for electronics: According to a recent Greenwich Time article, a private equity firm invested $50 million dollars in a Texas company that recycles computers.[4] The article quotes one of the investors as saying that consumer electronics recycling is a $1.5 billion dollar industry that is growing 45% annually. Gartner Inc predicts that by 2010 more than 925 million computers worldwide will need to be replaced. In an unadvertised, i.e., word of mouth, September 2005 pilot program, Greenwich Department of Public Works Superintendent John McKee reported to the Greenwich Recycling Advisory Board that in 3 weeks, the program yielded 10 tons of e-waste, despite a lack of advertising.  The time for electronics cycling in Connecticut has come.

Addition of plastics #1 and #2 and magazines to the list of mandated recyclables: As a result of community recycling programs, many residents are accustomed to recycling #1 and#2 plastics and magazines. Requiring that these items be recycled will be “transparent” for many residents who are already doing so; for residents who currently aren’t recycling these items, mandatory recycling will significantly reduce this type of ubiquitous waste from the waste stream.  The League recognizes that the mandatory addition of #1 and #2 plastics has the potential to put a strain on local recycling budgets and therefore urges that this change be coupled with the expansion of the bottle bill. In this way, beverage containers can be removed from municipal waste stream by becoming part of the existing deposit-redemption program.

Expansion of the Bottle Bill to include plastic water bottles and Increased Funding Sources: The League has repeatedly testified in support of expanding the universe of products within the redemption program.  Last session, we supported legislation to expand the beverage container redemption program to include non-carbonated waters and non-dairy and non-soy beverages. The current beverage container redemption rates of approximately 65-70% demonstrate that Connecticut’s long-standing user-funded program is effective, i.e., has high participation, and equitable, i.e., only those that use the designated products are subject to the program. In terms of funding, we also agree that unclaimed deposits should be considered abandoned property and specifically support the proposal that would enable the State to escheat unredeemed deposits.

Permit program changes and comprehensive alignment and updating of solid waste management laws: The League supports a comprehensive review of existing laws, regulations and procedures to ensure that they will support and advance the attainment of the Plan’s goals.

Recommended Refinements

As noted above, the League commends the DEP for providing an excellent "contextual" statement that clearly sets forth the current status and future actions that will be needed to manage effectively the State’s waste.  The League would also like to credit DEP specifically for the thought and effort that went into providing the list of recommended strategies to achieve the numerous objectives of source reduction, increased recycling and composting, more effective management of solid and special waste disposal, education and outreach and others.

Having said that, the League believes that the Plan would benefit from the adoption of a concrete diversion rate goal and an explicit estimate of the funding needed. Clearly, we must increase our diversion rate but exactly what are we reaching for?  While the Department did set forth various scenarios, the League believes that the Department should adopt a goal and explicitly identify the top actions and funding needed to achieve the goal.  Although the list of strategies will help to guide actions, the Plan needs to set forth those that will provide the most gains, i.e., we need to ensure that we do not confuse activity with progress. If waste management is to compete successfully against our many other demands for public dollars, we must not shy away from articulating the steep price to pay to achieve the goal – and the steeper one if we fail to act. In relation to the latter, the League believes that the Department also should emphasize the costs associated with current and projected increases in shipments of waste out of state, both in terms of the economic and environmental costs of shipments and any dollars lost to the local economy.

                                                                                                LWVCT Comments Aug 2006 DEP SWM Plan, P.2

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