Chapter Issues Key Recommendations to Strengthen the Zero Waste DC Plan

Testimony of Catherine Plume and Susan Schorr of the Sierra Club, DC Chapter before the DC Environmental Network (DCEN) Hearing on the Department of Public Works' (DPW’s) First Draft, Zero Waste DC Framework

September 22, 2022

Introduction: 

My name is Susan Schorr and I am the chair of the Zero Waste Committee of the Sierra Club DC Chapter. My Sierra Club DC Chapter colleague, Catherine Plume, and I are pleased to submit these comments regarding the draft Zero Waste DC Framework to the DC Environmental Network.   

In recent years, the DC Chapter has been vocal and critical of the Department of Public Works (DPW) Office of Waste Diversion (OWD) and its seeming unwillingness to take on proven programs that will help ensure that the District is a leader in waste reduction and that we meet our 2032 goals of 80% waste reduction from landfill and incineration. We see the undertaking of a zero waste plan as a positive if long overdue step. We sincerely hope that our comments will be considered by the consultants hired to develop the plan and OWD as they weigh options that will help the District achieve its goals. To that end, we here provide insight into programs that will benefit the District. I will discuss reusable food ware, the need for a beverage container deposit program to address DC’s litter and trash dumping crisis and its environmental justice impacts, composting, and how our proposed measures will lead to green jobs. Ms. Plume will cover Pay As You Throw. 

Reusable food ware  

• We need infrastructure, systems, and staff to enable effective implementation of the draft’s proposed reusable food ware requirements (calling for restaurants to serve takeout orders on reusables or compostables (Action 11).) Reusable takeout containers need to be collected, washed, and returned to restaurants. No systems for achieving this appear in the draft plan. Here’s a proposed solution: 
• The draft plan calls for widespread deployment of public compost, recycling, and trash bins, including at public transit stops. Now imagine that kiosks, where customers can easily return their reusable food ware, are sited along with these other bins.  
• Then imagine that green job employees come on their bicycles or electric vehicles to pick up the contents of the kiosks and whisk them to a municipal wash facility located at the District’s sparkling Zero Waste Campus or in other wash facilities around town. This ensures that the reusables are washed and sanitized before being delivered back to food service entities for reuse. 
• This circular economy vision means we’re not only diverting waste from landfills: we’re preventing waste from even happening.

Beverage container deposit program

• Similarly, the draft plan needs to address the District’s littering and trash dumping crisis and its associated environmental justice impacts.
• During the DPW-organized public outreach sessions, this August, we heard residents from Wards 5, 7, and 8 complain bitterly about public trash cans not being emptied. They’re left overflowing and causing massive littering in their neighborhoods. Residents expressed their distress that some contractors illegally dump trash in their neighborhoods. Frankly, this comes as no surprise to many of us speaking today. 
• The Sierra Club DC Chapter has been conducting brand audits throughout this year in partnership with Anacostia Riverkeeper (ARK) and Ward 8 Woods. We’ve audited over 4,000 beverage containers: plastic, glass, and metal alike to determine the companies selling or producing them. These beverage containers were recovered from parks and waterways abutting the Anacostia River and its tributaries. There’s so much trash that ARK, e.g., was able to collect more than 1600 plastic and glass bottles in under 3 hours at Pope Branch Park this January. Ward 8 Woods cleans up the same volume. And this is just a sample of their cleanup work. There shouldn’t be that much trash to clean up. The disproportionate impacts of waste and litter in the focus areas of these cleanups, and along the Anacostia, underscore that litter and illegal dumping are not only a solid waste crisis but also an environmental justice crisis.  
• Who are the top beverage container polluters in the District? Nestle, PepsiCo, the Coca Cola Company, Anheuser-Busch and, tied for 5th place, Costco and Cloverland Dairy. One solution is to provide more frequent trash bin pickups, something that’s not explicitly required in the draft plan. While we support more frequent service, it’s time to acknowledge that we need to stop the hemorrhaging of trash at the source by making the companies whose products are polluting our neighborhoods, parks and waterways bear responsibility for the full lifecycle of their products.
• We should be providing incentives to encourage the return of beverage containers by introducing small, refundable, deposits on the sale of all beverage containers. Why would contractors dump bottles and cans and individuals litter beverage containers if they can reclaim a deposit? Indeed, deposit return programs are proven to reduce litter. 
• Deposit return laws can also include targets for refillable bottles to reduce waste. California, the home of many of OWD’s consultants on the Zero Waste DC framework, has such a target. This is creating more green jobs to recover, wash, refill and deliver reused bottles. Again, bottle wash and refill services can be part of the Zero Waste Campus.
• While the Audubon Naturalist Society will talk about Extended Producer Responsibility for packaging, it’s important that any EPRs for packaging not include beverage containers. It’s the deposits that prevent littering and enable recovery for reuse.   

Composting measures

• The composting elements of the draft plan include many of the measures the environmental community has called for over the past years. We now need to include clear and enforceable timelines and deadlines for the implementation of the compost measures. In fact, measurable milestones, timelines, and deadlines are needed throughout the plan. 
• We can have no further delays in launching the curbside compost pilot for 10,000 households. Our neighbors in Prince George’s and Arlington Counties have long since completed their pilots and moved onto universal curbside compost pickup, a term and practice that should be incorporated systematically into our Zero Waste DC plan where compost pickup is noted. 
• Universal curbside composting pickup should be introduced shortly after the pilot – including in public housing; effective universal curbside composting would, with effective outreach and education, require participation from businesses and institutions.   
• We understand that DPW is planning to procure a provider to run the compost pilot. In addition, DPW should procure equipment for District residents, including indoor and outdoor compost collection bins/receptacles. 
• I’ve already noted concerns about effective implementation of the requirements of restaurants to serve takeout orders on reusables. Their other option, under the draft Zero Waste Framework, is compostable fiber. This should be accompanied by a requirement for restaurants to provide for separate collection of used compostable foodware and delivery to an organics processing facility. Likewise, the requirements should include protections against forever chemicals in our compostable fiber food ware.

Other issues 

• We need an extended producer responsibility law (EPR) for mattresses with features from California’s law included such as retailer take back and recycling of materials.
• The Zero Waste Campus could also be a locale for the sale of repaired and reused household and construction materials. The green jobs program should include training so District residents can become skilled in repair of household items like large and small appliances, furniture, and lighting fixtures.
• The plan also must be expanded to explicitly cover materials produced by businesses, the largest contributor to our waste stream. This includes, for example, the massive amounts of paper used by offices in the District. Action 16 could be reworded to specify that all items in the Mayor’s List of Recyclables are subject to the universal recycling and composting requirements.

Recommendations on reusable and compostable food ware, beverage container deposit programs, composting, EPRs for mattresses, green jobs creation and training, the Zero Waste Campus and additional measures to reduce waste caused by businesses. 

• Before turning the floor over to Ms. Plume, I’d like to highlight recommendations based on my comments. Please also allow me to thank DECEN for this opportunity to share these constructive comments on the draft Zero Waste DC Framework. We look forward to the ongoing process to ensure the District develops the most effective plan to achieve its waste diversion goals.

1. Measurable milestones, timelines, and deadlines for implementation throughout.
2. Widespread deployment of kiosks for the return of reusable takeout food ware co-located with recycling and compost bins, a municipal wash and delivery system for clean, sanitized reusable food ware.
3. A beverage container deposit program for all beverage containers.
4. Swift implementation of both the curbside compost pilot and a transition to universal curbside compost pickup and enforcement of composting requirements on businesses and institutions. 
5. Separate collection and organics processing of used compostable foodware by restaurants, and use of materials that are safe from “forever chemicals”.
6. Training for and creation of green jobs related to reusable food ware, beverage container refill, and repair of household items for reuse, located at the District’s Zero Waste Campus. 

Pay As You Throw (Unit-based pricing)

Definition: Unit-based pricing or Pay-As-You-throw (PAYT) (sometimes referred to as Save As You Throw (SAYT) or sometimes Save Money And Reduce Trash (SMART)), treats waste services like electricity, gas, and other utilities. Households pay a variable rate depending on the amount of service they use. Most communities with PAYT charge residents a fee for each bag or can of waste they generate.

History: PAYT is not a new concept.

• Pay As You Throw (PAYT) began in the 1920s in California. 
• The EPA published a book on lessons learned from PAYT in the 1990s
• By 2000, 6000 US cities and 200 Canadian cities had adopted some form of PAYT.  In 2002, PAYT programs resulted in residential waste declining 9-38% and increased recycling from 6-40%. 
• Today over 7000 US cities operate under PAYT programs.

Mechanics: PAYT programs can be tailored to the reality of a city.

• Waste can be measured by weight or size, or by unit counts, identified using different types of bags, tags, containers or even RFID (QR codes).
• Local grocery and convenience stores can sell the bags in various sizes: large (30 gallons, $2.60 per bag) and small (15 gallons, $1.63 per bag).
• Residents can be allotted “X” number of “free” trash bags with a fee levied on additional bags.
• Rebates/vouchers can be given to larger/income-challenged families. Many communities offer discounts or free bags for elderly and low-income residents, and most keep their recycling prices lower than trash prices. This approach usually keeps costs affordable.
• In some cities, dwellings that house more than 4 families don’t participate in PAYT due to the difficulties of instituting the program. 

source: http://payasyouthrow.org/about-pay-as-you-throw/#toggle-id-1

• PAYT programs have proven to be the most effective tool for reducing residential waste. 

source: http://payasyouthrow.org/solutions-2/

Advantages: PAYT can save both individuals (citizens) and municipalities money.

• Greater equity. One of the strongest points in favor of PAYT is the greater level of fairness it offers. Residents pay only for the trash they set out for collection.
• Waste prevention/reduction. Many communities are interested in increasing the amount of material recycled and reducing trash generation rates. (PAYT often results in households discarding between 14 and 17 % less waste, on average. Recycling amounts increase by between 32 and 59 %, on average.)
• Extended landfill capacity. By reducing disposal amounts, communities are able to prolong the life of existing landfills and postpone the need to locate new disposal facilities.
• Revenue stability. For many communities, creating a rate structure that generates a predictable level of revenue is an important objective.

Conditions for Success: Certain programs must be in place if PAYT is to be successful. 

• Free curbside recycling and composting programs, readily accessible e-cycling, shredding, reuse/repair, donations, and hazardous waste disposal programs.
• A perceived reduction in municipal taxes.
• Vouchers or some rebate program for larger/income challenged families.
• It may be possible to provide assistance to low-income households through subsidy for utility payments.

Challenges:  There are challenges to PAYT. 

• Convincing the public that they will save money under a PAYT program.
• Requires creativity to implement in multi-family buildings.
  • Dumpsters or garbage chutes can be altered to operate only when a magnetic card, trash token, or other proof of payment is used. 
  • Weight-based systems also can be used by adding a scale at the bottom of the chute that records the weight of the trash. 
  • Bag based systems can be implemented where all units are supplied with bags by building owner – or must be purchased by a household, with set-out as bags on the street.
  • Dumpster based systems where the size of the dumpster is specified by number of units with size priced accordingly.
  • Planners can have building codes for new and renovated buildings amended to require the installation of separate chutes for recycling and for garbage disposal.
• Can lead to illegal dumping or dumping waste in neighboring bins. 

Results: PAYT programs have proven successful at reducing waste.

• Austin, Texas; Population: 995,000. In 1991, Austin had a diversion rate of about 9.8 percent. As of 2010, that number was around 35 percent. In 2010, the rate of household garbage taken to the landfill has gone down more than 27 pounds per household per week from approximately 43 pounds per household per week in 1991.
• Fort Worth, Texas; Population: 950,000 cut its landfill disposal costs by more than $7 million after adopting PAYT, and in one year the city also earned $540,000 from the sale of recycled materials.
• Worcester, Massachusetts; Population: 200,000 decreased its annual waste management expenses by $1.2 million after adopting PAYT in 1993 and increased its recycling rate from 3 percent to 36 percent.
• Denver, Colorado; Population 750,000 will begin implementing PAYT in 2023. 
• In general, communities with cart-based programs throw away the most pounds per capita (PPC) each year, with tag or sticker programs having a lower PPC than cart programs, and bag-based pay-as-you-throw (with or without automated collection) having the lowest PPC of all. 

Recommendations: Implement PAYT in DC.