IeRM response to King County response February 7th 2022
February 7th, 2022
Mr. Pat McLaughlin, Director King County Solid Waste Division
201 South Jackson St., Room 5701
Seattle, WA 98104
Dear Mr. McLaughlin,
We have reviewed your response to our challenge to you, which we submitted on November 20, 2021, and frankly, we find it not only inadequate and misinformed but condescending as well. Let me point out some obvious examples.
“Though King County is currently a national leader when it comes to overall recycling rates, our Comprehensive Plan is clear about our goals to put recyclable and reusable materials back into the economy, and we are making demonstrable progress in this area.”
This is not true, by your own admissions. Much of what is thrown away could be recycled. A significant percentage of what is initially collected as recyclable ends up in the landfill. Further, the Department of Ecology admits that once “recyclables” are collected, they have no idea what happens to them, and cannot attest to their disposition. Finally, your own advertising recommends throwing items that can easily be recycled,such as coat hangers, in the trash. Even the Department of Ecology has state that your true rate of recycling, though difficult to determine, islikely much lower than you claim. And given the continued use of single-bin collection of recycling, this is not likely to change, given cross-contamination and co-mingling of all types of plastics, most of which cannot be recycled.
“…our successful diversion of construction and demolition waste as garbage has reduced tonnage…by about 7% per year.” According to the USEPA, the definition of Municipal Solid Waste (MSW) does not include construction and demolition waste. It should never have been included in your totals to begin with. This is a false reduction.
“While we have made good progress in recycling, we also know that more is needed.” You have not made good progress on recycling (see above), and while more is needed, your approaches are not going to make any improvements. The Renew Act (HB 2003) providing for more extended product stewardship is a good start to preventing reusable materials from getting into the landfill, but the need for this legislation demonstrates the failures of our solid waste management system, as practiced by the King County Solid Waste Division, among others.
“The Solid Waste Division also continues to advance operational improvements that benefit our neighbors at the Cedar Hills Regional Landfill.” All we can say is that the complaints keep coming.
It is with the claims regarding the 90%+ rate of collection for methane gas that we have the strongest disagreements. Your estimates are based on modeling, not measurement. The USEPA, which provides the model you use, has stated that methane emissions from landfills “have been understated by a factor of two,” and that their methods for estimating these emissions are outdated and flawed. (Statement ofSusan Thorneloe, Senior Chemical Engineer, USEPA, July 13, 2021.) Your continued insistence on overly high collection rates is not believable in the face of such commentary, and the issue is not whether you ”followed the procedures” but how much methane you are emitting.
“Finally, I want to emphasize that King County is open to looking at new technologies for regional waste management, and future updates to our Comp Plan will explore landfilling alternatives, including a waste-to-energy option.” This statement is nothing short of laughable. You have had several studies done over the past decade, at least one of which recommended a waste-to-energy facility as the least-cost, best environmental solution, yet you chose to continue to expand the landfill. How much has this cost the King County taxpayer? How much will it cost our children, and their children, both financially and from an environmental and public health perspective?
While we urge you to undertake the study we proposed in our initial letter, we encourage and recommend that you plan now for the closure of the Cedar Hills Regional Landfill by 2030, and the adoption of an integrated waste management plan, based on the Waste Management Hierarchy as adopted by the USEPA and the European Union. The experience in Europe shows clearly that landfilling of MSW can be phased out, while increasing reuse and recycling, reducing waste management costs to consumers, and creating family-wage jobs in the local economy. In fact, several of our board members were instrumental in making the shift away from landfilling in the European Union. We have the expertise and the experience to support successful efforts and make it happen here.
We have squandered many opportunities over the past twenty years. Let’s not waste any more time and money. The time to act is now.
Sincerely,
Philipp Schmidt-Pathmann, President
Stephen Gerritson, Secretary
CC: County Executive Constantine; King County Council
King County Response to Challenge:
December 24, 2021
Dear Philipp Schmidt-Pathmann:
Thank you for your letter from November 20, 2021, that addresses important issues including recycling, landfill gas management, and the importance of minimizing environmental impacts while providing our essential public service. I trust that the information I have provided below will be a valuable perspective for your consideration.
Our regional solid waste system serves 37 cities and the unincorporated areas of King County. Following significant community outreach and collaboration with our regional partners, the 2019 Comprehensive Solid Waste Management Plan (Comp Plan) serves as our roadmap for waste disposal and to further improve recycling within our service area. This plan was adopted by the King County Council and approved by the majority of cities in our service area andthe Washington State Department of Ecology.
Though King County is currently a national leader when it comes to overall recycling rates, our Comp Plan is clear about our goals to put recyclable and reusable materials back into the economy, and we are making demonstrable progress in this area.
Regarding your concern that recycling rates are static, you may be encouraged to know that our successful diversion of construction and demolition waste as garbage has reduced annual tonnage at the Cedar Hills Regional Landfill by about 7% a year. King County is also making strides on programs to expand the recovery and processing of economically andenvironmentally valuable materials, such as food scraps and paper fiber, which comprise more than a third of thewaste disposed at Cedar Hills.
While we have made good progress on recycling, we also know that more is needed. Because waste reduction and recycling have such a strong nexus to King County’s climate goals, getting these materials out of the landfill is one of our most critical environmental priorities, and a keen focus of public education efforts through King County’s Recycle Right Communications Consortium, which was honored last spring as Recycler of the Year by the Washington StateRecycling Association (WSRA). King County created the consortium in 2018 to reassure the public that their recycling efforts were still environmentally valuable in the wake of China’s restrictions on the import of recycled materials, and to communicate changes to recycling programs as a result of these changes. Our public education includes an emphasis on reducing contamination that undermines the success ofcurbside recycling programs, which was subject of recent media coverage by NPR affiliate KNKX and the Seattle Times. (As a reference, here is a link to an illustrated list of what is and isn’t recyclable at King County facilities.) During the2022 legislative session, we anticipate proposed HB 1622 (Renew Act) will provide an important opportunity for ourState to consider a more integrated approach that includes producers in the efforts to eliminate waste and further accelerate the diversion and recovery of resources. King County is supportive of this pursuit and intends to help inform the evaluation process.
The Solid Waste Division also continues to advance operational improvements that benefit our neighbors at the Cedar Hills Regional Landfill. Wildlife management plans developed in 2020 as part of the Comp Plan have helped reduce the number of nuisance birds, such as starlings, and made the landfill a less desirable habitat for bald eagles to feed and roost. You may also be interested to know that a schedule for reforestation in the western buffer to replace deciduous trees with evergreens that better absorb sound and screen landfill views is underway and includes a community feedback process. Additionally, we are seeking approval from the Puget Sound Clean Air Agency to begin using a state-of-the-art odor control technology called Ecosorb to more effectively neutralize odor compounds that may travel off-site.
King County has made substantial improvements in our landfill gas collection system through the installation of new precision valves and dual-phase wells, all while maintaining full compliance with regulatory requirements for emissions. The landfill gas we collect each year is converted to renewable energy – enough to heat over 19,000 homesin King County. The sale of that gas and its environmental attributes reduces fees by about $7 million each year to thebenefit of regional ratepayers, while also reducing demand for fossil fuels.
The design, operation, and control of our landfill gas system is done with the highest levels of care for the environment and compliance with local, state, and federal requirements. We provide emissions reporting to the EPA in accordance with their prescribed methodologies.
Often, our approaches exceed the minimum requirements such as when gas collection commences within a cell and how we monitor the performance of the system. These approaches lead to a very high landfill gas capture rate well above what is typical of an average landfill. Our past estimates of 90+% gas collection are based on waste characterization, tonnage, and system design. However, last year we engaged multiple engineering firms with expertise in the modeling of landfill emissions to evaluate our emissions model. This work is continuing and will inform any appropriate updates to our model by Summer 2022.
We don’t have a current need for the study you have proposed at this time, however, we regularly hire consultants and international experts in the planning, evaluation, and execution of our services including our landfill gas capture systems. We must follow competitive procurement practices in selecting qualified firms to do this work. You can visit King County’s Procurement website for an overview of the competitive solicitation process, including how to register your company as a supplier, and how to get notifications of upcoming contracting opportunities.
Finally, I want to emphasize that King County is open to looking at new technologies for regional waste management, and future updates to our comprehensive plan will explore landfilling alternatives, including a Waste-to-Energy option. Extending the life of the landfill is at present our lowest-cost, lowest-environmental impact option for regional waste management as we plan for the landfill’s eventual closure.
Our immediate goal is reducing the amount of garbage we need to manage in the first place. Consider that on any given day, up to 70% of what goes to the landfill can be reused or recycled. Reducing the amount of garbage has the benefit of making landfill alternatives and cutting-edge technologies more economically feasible. We invite you to engage with other stakeholders and community members in regional discussions around future planning efforts.
I hope this information is helpful. Thank you again for taking the time to contact us with your ideas. If we can provide additional information, please let us know.
Sincerely,
Pat D. McLaughlin, Division Director, King County Solid Waste Division
Original Challenge:
November 20th, 2021
Mr. Pat McLaughlin, Director King County Solid Waste Division
201 South Jackson St., Room 5701
Seattle, WA 98104
Dear Mr. McLaughlin,
You have been the Director of the Solid Waste Division for more than nine years. During that time, landfill expansion has continued, in spite of calls from public officials and the public to consider alternatives. Recycling rates have remained static, and whether the materials are actually recycled is unknown, according to the State Department of Ecology. According to your own office, much of what goes into the landfill could be recycled, yet nothing has been done to change this. In fact, the Department is now telling people to throw away items such as coat hangers that can easily be recycled.
You are currently in the process of “considering” alternatives to a further expansion of the landfill, when you decided months ago that an expansion will take place. And little, if anything, has been done to address concerns of nearby homeowners regarding odors, birds and other pests, noise and vibrations, and buffer protection. This is not a record that inspires confidence.
You will not be surprised, then, when we express skepticism about your claim that the landfill’s methane collection system is more than 95% efficient at capturing the gas generated through decomposition of the organic matter in the landfill. Studies measuring methane emissions from landfills in California have shown that landfills account for 40% of all methane emissions in the state. The USEPA has stated recently that methane emissions from landfills are understated by a factor of two. And your estimates are based not on measurement, but on computer modeling – which the USEPA says uses outdated assumptions.
To be fair, however, we would like to give you the opportunity to demonstrate a realistic capture rate of methane emissions from the Cedar Hills landfill.
We are issuing this challenge:
let IeRM, an independent research organization, verify the methane capture rate, using peer-reviewed measurement technology.This analysis will cost about $50,000. The funds have already been appropriated and are in the County’s budget. Will you take the challenge?
Phasing out landfilling altogether and replacing the practice with an Integrated Waste Management System based on the international waste hierarchy and widely used in other countries, will eliminate a major source of methane, will result in much higher reuse and recycling rates, and will allow the county to recapture energy and materials that are now wasted. As more materials are recaptured and reused, CO2 emissions will be greatly reduced as well. Finally, such a system will save billions in revenue and create thousands of high-wage jobs.
The Biden Administration has promised to address methane emissions from landfills. Just last week (November 8th), Governor Inslee announced a multinational effort to reduce methane emissions from transportation, energy, and waste. Changes are coming. King County should be a leader in this effort. Let’s stop dragging our feet.
Sincerely,
Philipp Schmidt-Pathmann, President
Stephen Gerritson, Secretary