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Letter from Donna P. Lopez, City Clerk transmitting a report from Councillor Jan Devereux, Chair and Councillor Quinton Y. Zondervan, Co-Chair of the Health and Environment Committee for a public hearing held on October 9, 2018 to was to receive an update on progress towards Zero Waste goals and to discuss successes and challenges of the citywide composting and recycling programs to date
⚠ This document is a scan; its text was recovered by optical character recognition and may contain errors. The original PDF is authoritative.
ATTACHMENT A
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION
S POST OFFICE SQUARE SUITE 100
BOSTON, MASSACHUSETTS 02109
HEAL PROTECTO
Cabridge Health and Environmental Committee
Cambridge City Hall
795 Massachusetts Ave.
Cambridge, MA 02139
October 5, 2018
Dear City Councilors Jan Devereux and Quinton Zondervan:
We undersland that the Health and Environmental Committee that you co-chair will meet on
October 9 to discuss composting and recycling programs. and that one of the challenges to be
discussed is codigestion of food waste with biosolids at municipal water resource recovery
lacillies (WKKPS). EPA is sending this letter to provide technical information that may be of
assistance in your discussions.
First, we congratulate you on your food waste diversion program, which aligns well with
Massachuselts s Solid Waste Master Plan and is helping you to meet your own zero waste goals
Cambridge is at the forefront of US cities diverting food waste from disposal, and we hope that
your model leadership will help other cities implement similar programs in their communities.
There are many ways 1o manage organic wastes in the municipal solid waste stream, each with
advantages and disadvantages, and the appropriate management techniques are highly specific to
individual locations. The Massachusens Departmen of Environmental Protection. among other
state entities, has been promoting increasing infrastructure to manage food waste to support the
2014 Commercial Organics Ban.
To assist municipalities in decision-making around food waste recovery and diversion. EPA has
https://www.epa.gov/sustainable-management-food/food-recovery-hierarchy
The discussion about managing food waste is ofien framed as an either/or discussion between
techniques such as composting and anaerobic digestion. but the approaches can work together.
Anaerobic digestion reduces the solids volume of digested materials by about 50%, and the
remaining 50% can be composted post-digestion. EPA conducted life cycle assessment research
it a smal! WKKi in a rural location that contemplated codigesting biosolids with food waste.
then composting the digestate to Class A compost as agricultural amendment and fertilizer
replacement. The results of this life cycle assessment can be found at
https://ctpub.cpa.gov/si/si_public record_report.cfim?dirEntryld=338074.
We know concerns have been raised about toxics. As DEP states in its letter to you dated loday.
GLSD consistently meets standards under MassDEP's regulations for Land Application of
Sludge and Septage (310 CMR 32.00). These regulations work in landem with ElA's rules on
biosolids use (commonly called the "503 rule." for the part of the Code of Federal Regulations
they fall under) 1o govern material that is mixed with biosolids in a digester if the end product is
intended for benelicial reuse. EPA believes that biosolids are an important resource that can and
should be safely used. The 503 rule provides comprehensive requirements for the management of
biosolids generated during the process of treating municipal wastewater and creates incentives
for beneficial use of biosolids. For more information on the 503 rule. please sec the document "A
Plain English Guide to the EPA Part 503 Biosolids Rule" available at
https://www.cpa.gov/biosolids/plain-english-guide-cpa-part-503-biosolids-rule.
In conjunction with our 503 regulations, EPA has a robust industrial pretreatment program
designed to keep metals and other loxic chemicals from entering municipal wastewater treatment
collection systems. For more information on the National Pretreatment Program. please visit
https://www.epa.gov/npdes/national-pretreatment-program.
We applaud your effons and your leadership role in managing lood waste sustainably. EPA
supports the practice of codigestion of food waste and biosolids at municipal water resource
recovery facilities, and would be happy to provide lechnical assistance to help you navigate
questions that may come up as you consider the processing or Cambridge's municipally
collected lood waste.
Sincerely,
Ken Moralf, Director
Office of Ecosystem Protection
AMTACHMENTB
Commonwealth of Massachusetts
MassDEP
Executive Office of Energy & Environmental Affairs
Department of Environmental Protection
One Winter Street Boston, MA 02108 • [phone removed]
Charles D. Baker
Matthew A. Beaton
Governor
Secretary
Martin Suuberg
Karyn E. Polito
Commissioner
Lieutenant Governor
October 5, 2018
Vice Mayor Jan Devereux, Chair
Councilor Quinton Zondervan, Chair
Health & Environmental Committee
Cambridge City Council
Cambridge City Hall
795 Massachusetts Avenue
Cambridge, MA 02139
Dear Vice Mayor Devereux, Councilor Zondervan and other distinguished members of the
Health & Environmental Committee,
The Massachusetts Department of Environmental Protection (MassDEP) appreciates this
opportunity to comment publicly on the City of Cambridge's voluntary food waste collection
program, in light of the October 9" hearing of the Cambridge City Council Health and
Environmental Committee.
MassDEP is the state regulatory agency charged with developing the Commonwealth's Solid
Vaste Master Plan pursuant to M.G.L. c. 16, §21. The Solid Waste Master Plan is th
commonwealth's blueprint for reducing solid waste and managing solid waste that i
generated, reused, recycled, or disposed by Massachusetts residents and businesses. It
establishes a broad policy framework for solid waste management in Massachusetts over a
span of 10 years (2010-2020), including a current state assessment, a policy vision, and
concrete goals and strategies for the near and long term vision of higher reuse and recycling
rates, and reduced disposal. The City of Cambridge is taking a leadership role in reducing waste
disposal through its food waste collection program.
MassDEP is pleased to provide information to the Council regarding the benefits of collecting
and adding Cambridge's food waste to the organic materials managed by the Greater Lawrence
Sanitary District (GLSD). Both the City of Cambridge's program and LSD's processing of
This Information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at [phone removed].
TTY# MassRelay Service [phone removed]
MassDEP Website: www.mass.gov/dep
Printed on Recycled Paper
organic material at its facility advance MassDEP's 2010 Solid Waste Master Plan goais of
diverting an additional 350,000 tons of food waste from landfill disposal and supporting new
infrastructure to handle that food waste, including both anaerobic digestion (AD) and
composting facilities. In 2012 MassDEP modified solid waste regulations to support the goals of
organics diversion and renewable energy generation. The changes were completed after two
years of deliberative development, with the benefit of significant public involvement. AD
facilities provide capacity for food waste diversion, which reduces the amount of waste that
must be landfilled, incinerated or sent out-of-state for disposal. Anaerobic digesters also
provide the additional benefits of generating clean biogas and energy, offsetting energy costs
for facilities and producing fertilizer products.
The City of Cambridge has been a leader in establishing its food waste collection program - first
as a pilot and now as a voluntary city wide service. As noted on the City's website, in its first
four months of operation, more than a million pounds of food scraps have been diverted from
landfills and the City's trash has been reduced by 4 percent. It should be noted that large scale
curbside food waste collection programs always include some degree of contamination from
materials such as plastic bags or film, which means this material must be processed before it
can be composted or digested. The Cambridge program effectively addresses this need by
having this material processed at the Waste Management facility in Charlestown, ensuring a
high quality feedstock for the anaerobic digestion process.
There are both local and statewide benefits of Cambridge and GLSD collaborating to co-process
food waste and wastewater sludge. Organic materials are diverted from landfills and
incinerators, and the addition of food waste to GLSD's operation results in a significant increase
in biogas generation, reducing the need for power from the grid and decreasing GISD's energy
costs. Increased power generation capacity on-site can assist with maintaining wastewater
treatment operations even during large power outages. Although the addition of food waste
has increased the energy output from GLSD's digesters, it is not expected to increase the total
volume of sludge from the AD process due to improved digestion efficiency. Finally, the
collaboration supports GLSD's goal of operating at "zero-net-energy" by using renewable
energy resources, including the resources in the organic materials from the Cambridge food
collection program to generate all of its power.
Another benefit of the collaboration between Cambridge and GLSD is to capture and reuse
nutrients contained in the fertilizer end product. MassDEP's regulations for Land Application of
Sludge and Septage (310 CMR 32.00) were put into place to ensure that biosolids products
generated by wastewater treatment, such as the fertilizer pellets produced by GLSD, do not
pose a risk to human health or the environment. Key points of these regulations and their
application to GLSD's biosolids product are as follows:
• Any sludge product that is used, sold, or distributed for land application in
Massachusetts requires a Suitability Approval from MassDEP or "AOS".
• The AOS classifies the product into one of three different types based on treatment and
product quality,
2
• Sludge produced at GLSD has been approved by MassDEP and classified as Type I, which
ensures quality of the sludge that allows for the least restricted uses. Type I biosolids
can be used, sold, or distributed as a fertilizer product, and can be used for growing any
vegetation (eg on a farm or in a garden).
• GLSD's product is required to be tested monthly and meet specific limits for a number of
parameters to address environmental and human health risk. GLSD's monthly sampling
results have consistently complied with the requirements for a Type I product.
In summary, MassDEP supports Cambridge's food waste collection program, as well as its
partnership with Greater Lawrence Sanitary District for co-processing its food waste with
wastewater sludge. Combined, these efforts reduce solid waste being landfilled or incinerated,
produce clean reliable and renewable energy, reduce energy costs, and generate a product for
beneficial reuse.
If you have further questions about MassDEP's Solid Waste Master Plan goals or MassDEP's
Biosolids program, please contact Greg Cooper at Greg.Cooper@mass.gov or Lealdon Langley
at Lealdon. Langley@mass.gov, respectively.
Sincerely,
Starten Coope
Stephanie Cooper
Deputy Commissioner, Policy & Planning
ATTACHMENTC
Curbside Compost
Zero Waste Master Plan
Curbside Recycling:
An Update on Cambridge's
Working Toward Zero Waste:
mean for Cambridge?
What does "Zero Waste"
ZER-
WASTE
Trash (Ibs/HH/wk)
25
10
2008
22.8
2010
2012
2014
Thank you to the Recycling
Advisory Committee!
Calendar Year
2016
17.3
1991.
2050 Goal: 80% reduction, 4 Ibs/HH/wk
2018
the City since
Guidance has
and diversion
2020 Residential Trash Reduction Goal
RAC has advised
made Cambridge
in waste reduction
2020
a municipal leader
Goal:16
10/9/2018
6 tons/mo
April 2014:
600 HH Pilot
CAMBRIDGE
WASTE
ZERO
Curbside Organics
Oct 2015:
5,200 HH
30 tons/mo
• New
Recommendation - Expand
largest
program
England's
services
April 201B:
25,000 HH
140 tons/mo
• Manage Costs
• Reduce GHG emission goals
• Maintain high quality public
• Maximize operational efficiency
• Protect employee health & safety
• Meet City's waste reduction goals
ZERO
CAMBRIDGE
WASTE
Purpose of the Master Plan
2017
YEAR
2019 (proj
CAMBRIDGE
WASTE
ZERO
capacity
3,724,000 tons
5,006,000 tons
MA Trash Disposal
Expand
Evaluate
Evaluate
Promote
disposal:
2021
2021
incinerators.
Initial Master Plan
Recommendations
on new landfills &
Factors that affect trash
• 4 landfills closing by
• MassDEP moratorium
Recommendation: Evaluate Trash Collection & Disposal Processes
• 4 landfills remain after
10/9/2018
ZERO
WASTE
Disposal Cost ($/ton)
$80
$100
$120
$20
$40
$60
$35.00
Recycle**
$59.00
Compost
FY19 Disposal Costs (Tip fee only)
bins
organics
Trash
$99.00
in April 2018.
• 2 trucks for curbside
Collection & Disposal Processes
Decreased rubbish
Recommendation: Evaluate Trash
public area recycling
truck fleet from 7 to 6
3 pedal-powered bikes
are used year-round for
contamination.
**Currently pay
due to excessive
Recommendation: Evaluate Trash Collection & Disposal Processes
$70/ton to recycle
88% 86% 85%
"Trash", 30%
Trash
Other **, 13%
86% 86%
Trash serves +/- 32,000 households/week
93%
**Other: Textiles, Electronics, Scrap metal
2000 2002 2004 2006 2008 2010 2012 2014 2016
82% 80%
86%
41%
*Source: Biannual Citizen Satisfaction Telephone Survey
What's still in our trash barrels?
Residents who rate service as "excellent" or "good"
Recycling, 16%
Compostables,
Recycling
85% 86% 86%
Recommendation- Encourage Diversion
90% 88%
Recommendation: Evaluate Trash Collection & Disposal Processes
90%
2000200220042006 200820102012 2014 2016
Recycling serves +/-45,000 household /week
10/9/2018
2016
Benefits:
• Rodent control
• Less trash spills
• Sidewalk accessibility
• Reducedilming impacts
BYOB and Polystyrene
Recommendation:
Evaluate City policies
Recommendation -
Evaluate slandard trash receptacles
Encourage Diversion
use bag consumption
Ordinances went into effect in
• 50-80% reduction in single-
HARD WASTE OKe
• Trash Sorts.
• Correctly sized.
multifamily set-outs.
• Reinforced plastic.
• Tipper-compatible.
Trash receptacles must be:
Recommendation:
Evaluate City policies
Next Step: Trash set out study:
• Representative sample of set outs.
• Sensitivity Analysis associated with
Recommendation-
Encourage Diversion
Clinics)
recycle items
Initiatives (Fix-It
Reduce and Reuse
Programs in future
textiles, mattresses)
Divert more hard-to-
(turniture, electronics,
Explore New Recycling
10/9/2018
Most Preferred
diaposal
Landfill/
Incineration
Feed Animals
Source Reduction
Feed Hungry People
Divert food scrape to animal fend
Reduce the volume of surplus food genecated
Donate extra food to food banks, soup kitches and sheers
Curbside Organics
Food Recovery Hierarchy
ZERO
WASTE
North Andover
Saturday.
on disposal sites.
• Easily accessible
disposal site
• Offsets demand for fossil fuel.
• 1% site: CORe in Charlestown
process for managing organics
Processing organics
• Given scale of Cambridge's
Final processing: anaerobic digestion
3-year contract (Expires: April 1, 2021)
• Open 7am-3pm Monday-
• Can remove contamination.
Criteria for organics
• Capacity for 10-15 tons per day.
program, MassDEP guidance sought
• Methane is used to make electricity and heat.
• Waste heat used to catalyze digestion process.
• 2nd site: Greater Lawrence Sanitary District in
Both MassDEP and EPA support Cambridge's
Apprx 90% of food scraps go to making clean energy
10/9/2018
rate
$70/ton
Results thus far:
Increased Monitoring.
Impact on Cambridge:
approval rating
• 6-8 tons per day
So/ton to $35/ton
• 1.6 million pounds
• 8% decrease in trash
respondents. Over 90%
recovered (Apr 2- Oct 2)
• August 2018 survey: 1300
Global markets for recycling declined.
Tons per month
• Summer 2018: Costs increased to
40
140
160
100
120
8
• December 2017: Costs increased from
• Cambridge exceeded 7% contamination
Curbside Organics Update
Month (2018)
Tons of food scraps collected
APRIL MAY JUNE JULY AUG SEPT
NO!
CANS & FOIL
C RECYCLE
PATIENS
Recycle Right
PAPER EL
Curbside Recycling
ZERO WASTE
$35/ton.
RECYCLE
Continued high
• Jan 2019 goal: 7%
• Fall 2018: Average
and operations budget
contamination is 10%.
contamination rates will
contamination, costs to
impact recycling program
WASTE
ZERC
SANELORE
10/9/2018
collection.
Small Business
Recycling Pilot
November 2018 launch
• 120 small businesses.
• Primarily restaurant/retail:
• 3 toters, twice a week free
Major
Minimal
carts citywide
Moderate
10%
31%
59%
Cambridge Recycling
Level of Contamination in
Based on Summer 2018 survey of 1165 recycle
# of carts
# of carts
% of carts **
% of carts **
Contaminant
Contaminant
116
605
10%
52%
Textiles
Plastic
Wrappers
Clothing &
Bags, Film,
55
248
5%
21%
Bagged
Trash
Plastic
Recycling
COMPOST
What's next for Cambridge?
238
20%
52
4%
Tissues,
Napkins
Hoses
Paper Towels,
Tanglers, Cords,
**Total Percentage is greater than 100% because some carts had more than 1 contaminant
168
14%
4%
43
rollout
Excessive
Straws,
Utensils
Food & Liquid
Most Problematic Contaminants
compost piiot
• Spring 2019: Pilot
buildings curbside
curbside compost
Mattress Recycling
* Fall 2019: 13+ unit
34
3%
160
14%
• Fall 2020: Expected
Take-out
container
full 13+ unit bulldings
Electronics
Paper Plates,
Wood, Metal,
10/9/2018
waste!
Thank you for reducing your
CambridgeMA.Gov/Recycle
Recycle@CambridgeMA.Gov
10/9/2018
ATTACHMENT
For a thriving New England
62 Summer Street
CLF Massachusetts
Boston MA 02110
clf
P: [phone removed]
F: [phone removed]
conservation law foundation
www.cif.org
October 10, 2018
City Council Hearing on Zero Waste Goals
Cambridge City Hall, 795 Massachusetts Ave, Cambridge, MA,
Cambridge City Council
Health and Environmental Committee
To the Cambridge City Council Health and Environmental Committee:
My name is Kirstie Pecci, and 1 am Director of the Zero Waste Project at Conservation Law Foundation
(CLF). Following Tuesday's public hearing, CLF submits this testimony to the Committee regarding
Cambridge's Zero Waste efforts. CLF is a nonprofit, member-supported, regional environmental
organization working to conserve natural resources, protect public health, and promote thriving
with our mission, CLF commends Cambridge on their excellent Zero Waste efforts thus far, and
recommends further actions that the city should take.
Cambridge has led on waste issues, and should continue to do so
Cambridge has been a leader on Zero Waste issues in New England, implementing plastic bag and
polystyrene bans, diverting a high percentages of low-contamination recycling, and starting the first large-
scale curbside compost program in New England. The residents of Cambridge and the city staff working to
shape and build programs have turned the city into a primary example of what can and should be done in
municipalities around the region. As trash prices continue to rise, these efforts and others like them will be
necessary to mitigate the cost of disposal. Cambridge is set to pay $3 million' in tipping fees alone each
year, which will only increase as landfill space diminishes. Not only is trash disposal expensive, but it
wastes resources that could be recycled and reused, and contributes to climate change.
Beyond the economic benefits to waste reduction, less trash means less going to Massachusetts landfills
and incinerators. These facilities are dirty, polluting, and toxic to the people that live near them. Six of the
seven incinerators in Massachusetts are in Environmental Justice communities, including the Wheelabrator
incinerator and unlined ash landfill in Saugus, MA. Not reducing waste perpetuates and necessitates the
existence of these dangerous facilities.
Programs like Pay-As-You-Throw and Save Money and Reduce Trash (SMART) would continue to
decrease waste volumes in the city. Many municipalities around the region have adopted these schemes,
and have seen 20-50% reductions of their trash volume within a few years. A Waste Zero report on a study
' Cambridge is currently paying $99 a ton for disposal, and last year generated 32,500 tons of waste. While they are likely to dispose of
less in 2018 due to the composting program, Cambridge will still have to pay more than $3 M for about 31,000 tons of waste disposal.
https://www.mass.gov/lists/recycling-solid-waste-data-for-massachusetts-cities-towns
2 Pecci, K. (December 12, 2017). Municipal Solid Waste: What is it and why is it a problem? Conservation Law Foundation.
https://www.clf.org/blog/municipal-solid-waste-is-a-problem/
3 Pecci, K. (May 9, 2018). Public concerns ignored in approval of massive landfill expansion. Conservation Law Foundation.
https://www.clf.org/blog/public-concerns-ignored-in-approval-of-massive-landfill-expansion/
CLF MAINE CLF MASSACHUSETTS : CLF NEW HAMPSHIRE CLF RHODE ISLAND : CLF VERMONT
For a thriving New England
CLF Massachusetts
62 Summer Street
Boston MA 02110
clf
P: [phone removed]
F: [phone removed]
conservation law foundation
www.clf.org
of southern Maine towns with and without PAYT showed that on average towns with PAYT generated
44.8% less trash per capita.* When Worcester adopted their PAYT program in 1993, their trash was cut in
half within one year, they saved $10 million dollars over 20 years, and their recycling rate increased to
44% A 20 percent reduction in Cambridge's trash would cut the city's tonnage by 6,500 tons, and save
the city around $640,000 each year. Not incentivizing the reduction of waste is leaving money on the table.
Cambridge's planned small business recycling collection is another excellent example of progressive Zero
Waste programming. However, businesses are not the only places where recycling is needed - the City
should strive to support and expand universal access to recycling and composting for residents, businesses,
institutions, and public spaces. This includes requiring that multi-family buildings recycle, and that
composting and recycling be available in parks and government buildings. Clear, uniform signage across
the City and education programs will also help ensure that Cambridge's recycling continues to be clean of
contaminants.
While bans on polystyrene and plastic bags begin to chip away at our unsustainable consumption of single-
use plastic, we must shape new economies and models around reuse. Recycling plastic does not work for
many reasons - it's a diverse material, not all of which is recyclable, and even recycled plastic isn't often
turned back into the original product.? Bans on non-recyclable plastic pushes industry towards compostable
plastic and fiber-based materials, which in turn require increased composting infrastructure. If buried in a
landfili, these replacements contribute to methane production. Cities like Freiburg, Germany, have been
experimenting with deposit refund schemes for reusable cups within the whole city. Customers place a 1-
euro deposit on their takeout cup, and are refunded their euro when they bring the cup to any participating
business in the city. Freiburg has proven that cities like Cambridge could replicate their program and take
big steps towards eliminating single-use plastic.?
Cambridge is pioneering food waste collection
Since April of this year, Cambridge has expanded their curbside food waste collection system, providing
service to 25,000 residents within the city. Through excellent educational work, careful planning, and
dedication from DPW staff, the city has collected an impressive amount of clean, separated food waste.
Cambridge's efforts over the past several months are an example to other municipalities around the country.
However, as a model for the rest of the state and New England, we want to make sure Cambridge sets up a
sustainable, economical system that creates jobs and doesn't have hidden costs for the taxpayers.
* Waste Zero. (2018). Per Capita Residential Trash in Southern Maine: Head-to-head comparison of municipalities with PAYT and those
with no PAYT. http://wastezero.com/wp-content/uploads/2018/06/ecomaine-report-06-01-18.pdf
5 Kolling-Perin, J. (Nov. 22, 2013). Worcester, Mass. Marks 20h Anniversary of Pay-As-You-Throw Program, Celebrates Waste
Diversion and Recycling Success. WasteZero. http://wastezero.com/news/worcester-mass-marks-20th-anniversary-of-pay-as-you-throw-
program-celebrates-waste-diversion-and-recycling-success/
6 Presentation given to the Dallas City Councilors in 2018, outlining the basics of Universal Access to Recycling.
http://dallascityhall.com/government/Counci|%20Meeting%20Documents/qolac_2_universal-access-to-recycling-multifamily-and-
commercial_combined_051418.pdf
Sedaghat, L. (April 4, 2018). 7 things you didn't know about plastic (and recycling). National Geographic.
https://blog.nationalgeographic.org/2018/04/04/7-things-you-didnt-know-about-plastic-and-recycling
Cho, R. (December 14, 2017). The Truth About Bioplastics. Phys.org. https://phys.org/news/2017-12-truth-bioplastics.html
9 Martinko, K. (December 4, 2017). City of Freiburg has a brilliant alternative to disposable coffee cups. Treehugger.
https://www.treehugger.com/environmental-policy/city-freiburg-has-brilliant-alternative-disposable-coffee-cups.html
CLF MAINE CLF MASSACHUSETTS CLF NEW HAMPSHIRE CLF RHODE ISLAND CLFVERMONT
For a thriving New England
CLF Massachusetts
62 Summer Street
Boston MA 02110
clf
P: [phone removed]
F: [phone removed]
conservation law foundation
www.clf.org
Based on a lack of infrastructure, Cambridge elected to send their food waste to the Waste Management-
owned CORe facility in Charlestown. Once the waste is turned to a slurry at CORe, it is shipped to the
Greater Lawrence Sanitary District (GLSD) and mixed into anaerobic digesters processing sewage sludge.
Anaerobic digestion has no impact on the multitude of toxins in sewage sludge that have been identified by
the U.S. EPA. The sludge is then disposed of on land or in landfills - regardless, the outcome is a new
form of waste. When processed into compost, food waste restores soils, sequesters carbon, and improves
plant growth." In separated anaerobic digestion, food waste generates biogas and a clean fertilizer.
Cambridge should capitalize on their excellent collection system by working to develop sustainable
facilities for their food waste that process it without toxic sewage sludge. In the long run this will give the
City more options and less chance of markets falling apart, it will save the City money, and enhance rather
than degrade the environment.
Despite excellent collection, current end-of-life processing is toxic, and a waste of energy and money
In addition to diverting food waste from a landfill or incinerator, the primary benefit ascribed to processing
food waste at the GLSD is the energy produced in the form of biogas. For this reason, anaerobic digestion
is one step higher on the EPA's hierarchy of disposal. But while processing food waste at GLSD does
generate biogas, the entire operation is an energy sink. Energy is needed to slurry Cambridge's food waste
at the CORe facility, transport it to GLSD, heat anaerobic digesters, and lastly dry the high-liquid digestate.
The digestate is then transported to a facility where it is dried into pellets. Food waste collected in
Cambridge generates biogas, but only to offset the tremendous energy needs of the wastewater treatment
system.
GLSD follows EPA guidelines for Class 'A' biosolids, and the Massachusetts code on residuals and
biosolids (310 CMR 32.00). Both restrictions require land applied sewage sludge to be free from elevated
of polychiorinated biphenyls (PCBs). But thousands of other chemicals can exist in sewage sludge that
aren't tested for, and subsequently are spread on our fields. Sewage sludge - whether digested or not - can
contain any of the 80,000 synthetic chemicals used by industries; bacteria and viruses; pharmaceuticals;
detergents; and household chemicals put down an industrial, commercial, or residential drain.? They
include steroids and antidepressants, detergents, flame-retardants, and the disinfectant chemical triclosan,
some of which are connected to cancer, developmental harms, and endocrine disruption.
GLSD's energy intensive operation is also exorbitantly expensive. Wastewater treatment is often at or near
the top of municipal expenses. 3 Compost tipping fees generally are below $40/ton, while the CORe facility
10 National Targeted Sewage Sludge Survey, U.S. EPA (2009),
https://nepis.epa.gov/Exe/ZyPDF.cgi/P1003RL8.PDF?Dockey=P1003RL8.PDF
I Schwartz, J. (March 4, 2014). Soil as carbon storehouse: New weapon in climate fight? Yale Environment 360, Yale School of
Forestry and Environmental Studies. https://e360.yale.edu/features/soil_as_carbon_storehouse_new_weapon_in_climate_fight
12 Orlando, L. (July 11, 2017). It's Time to Talk (Again) about Sewage Sludge on Farmland. In These Times.
http://inthesetimes.com/rural-america/entry/20319/sewage-sludge-biosolids-public-health-waste-management-agriculture
13 Commonwealth of Massachusetts Office of the State Auditor. (2017). Costs, Regulation, and Financing of Massachusetts Water
Infrastructure: Implications for Municipal Budgets. https://www.mass.gov/files/documents/2017/01/wc/011717-costs-regulation-and-
CLF RHODE ISLAND
CLF MAINE CLF MASSACHUSETTS • CLF NEW HAMPSHIRE
• CLF VERMONT
For a thriving New England
62 Summer Street
CLF Massachusetts
Boston MA 02110
clf
P: [phone removed]
F: [phone removed]
www.clf.org
conservation law foundation
charges $65/ton. The tipping fee would be much higher, but state and federal energy grants' combined
with municipal funding from taxpayers hides the true cost of processing sewage sludge. By sending food
waste to GLSD, Cambridge is adding a financial burden to the taxpayers of the Merrimack Valley and the
residents of Massachusetts.
The rest of the region is watching Cambridge
What Cambridge does with their food waste will influence the development of anaerobic digestion and
composting in the region for years to come. Waste Management is prepared to build more COke tacilities,
and is anxious to partner with other wastewater treatment plants. Boston is preparing to begin food waste
culenty is to transport and aerobically compos al of cambridge i god waste with prepary or and
planning, capacity could be developed. Instead of spending money to create more waste, Cambridge should
work with regional compost companies to turn food scraps into a valuable soil amendment, part of the great
and necessary nutrient cycles.
Thank you for holding a public hearing on these important issues, and thank you for your attention to this
testimony. Please contact me if you have any questions or need any further information.
Very truly yours,
Kina Doci
Kirstie Pecci
[phone removed]
[email removed]
4 MassDEP News. (2016). Earth Day 2016 - Lasting Environmental Partnerships. http://www.gisd.org/wp-
content/uploads/2016/09/barthDayHonors-l.pd/
AMPSHIRE
CLF MASSACHUSETTS
CLF NEW
CLF VERMONT
CLF RHODE ISLAND
CLF MAINE
ATTACHMENT E
TESTIMONY OF LAURA ORLANDO
BEFORE THE CAMBRIDGE CITY COUNCIL'S
HEALTH & ENVIRONMENTAL COMMITTEE
October 9, 2018
Good afternoon councilors and others interested in Cambridge's food scrap collection program.
My name is Laura Orlando. I am a civil engineer, executive director of RILES, and an adjunct
professor at the Boston University School of Public Health.
Cambridge's food scrap collection program
Note that I am not cailing what Cambridge is doing with its food scraps "composting" because
composting is not part of the processing of this valuable waste material. It is erroneously called
"curbside composting" by the city in its marketing materials and other information made
available to the public. This is not news to anyone working for the city that is engaged in this
effort, but it may be news to members of the public. But a name change won't fix the problem.
Diverting the food scraps away from the wastewater treatment plant will.
What is happening now? Cambridge city trucks pick up food scraps collected by households and
bring them to an industrial facility in Charlestown managed by a multinational corporation called
Waste Management, Inc. There the food scraps are ground-up and mixed with water or other
liquids and then hauled in trucks to the Greater Lawrence Sanitary District (GLSD) wastewater
treatment plant in North Andover. The trucks off load the slurry with a hose fit to a pipe that
sends it to one of four anaerobic sludge digesters at the plant. Once in the digester the food slurry
comingles with sewage sludge, the always toxic byproduct of wastewater treatment. The goal of
the effort for Cambridge is to remove food scraps from landfills, which it achieves. But where
the food scraps go is of fundamental importance to the health and safety of the people of
Cambridge and the citizens of Massachusetts. Right now the city is trading one waste
management hazard for another.
What is sewage sludge?
Sewage sludge is a by-product of wastewater treatment. Wastewater brings to sewage treatment
plants all the wastes sent into the sewers from industrial and commercial drains, hospitals, toilets,
and road runoff. Whatever toxicants, hazardous materials, and other pollutants that happen to be
removed from the water in the process of wastewater treatment, and that are then concentrated in
the sludge, will remain in the sludge. Nothing in the processing of sewage sludge "treats" -e.g.,
detoxities -- sludge.
Sewage sludge is regulated for some heavy metals such as lead and copper, but hundreds of
known toxic chemicals in sludge are not. The EPA in its 2009 Targeted National Sewage Sludge
Survey concluded that all sewage sludge contains toxic and hazardous materials. ' These include
1https://nepis.epa.gov/Exe/ZyPDF.cgi/P1003RNO.PDF?Dockey=P1003RNO.PDF
1
flame retardants, antimicrobials, and surfactants -- all of which can cause harm to wildlife and
humans. A 2015 study by researchers at Arizona State University reports, "Many organics
sequestered and concentrated in MSS (municipal sewage sludge] meet the U.S. Environmental
Protection Agency's definition of being persistent, bioaccumulative, and toxic. : The United
States Geological Survey found the antiepileptic drug carbamazapine, steroids, polycyclie
aromatic hydrocarbons, detergent metabolites, fragrance compounds, and disinfection chemicals
in all of the samples of sewage sludge it tested. ' Perfluorinated alkyl substances (PFAS), a
deeply problematic chemical with serious adverse human health effects increasingly found in
drinking water, including here in Massachusetts, are in sludge too.'
What about sludge rules and regulations?
All municipal wastewater treatment facilities are required to get a National Pollutant Discharge
Elimination System (NDES) permit to operate. It stipulates the level of treatment of wastewater
and sludge. The GLSD permit regulates none of the chemicals I have mentioned here. It is
instead concerned with so-called conventional pollutants, primarily pathogens and nutrients.
GLSD is not unlike any of the other WWTPs in the US. The thousands of toxicants in
wastewater and sludge are not regulated because we do not have the technology to remove them.
Prevention is the way to mitigate the damage from toxicants. That, and backing off sewers.
The GLSD Sewage treatment plant
Before the election of Ronald Reagan in the 1981, sewage treatment plants could expect more
than 80% federal financing for capital expenditures and upkeep. After Reagan left office in 1989,
federal dollars for infrastructure like wastewater treatment plants (WWTPs) dried up. It was up
to local and state authorities to keep them running. Why does this matter in our discussion here?
Because the City of Cambridge is participating in a rebranding of WWTPs like the GLSD to
bring in revenue from new sources, such as the MA Dept. of Energy Resources, MA Renewable
Energy Trust, and the MA Executive Office of Environmental Affairs. The rebranding includes
"Organics to Energy" programs like at GLSD. For example, the GLSD will receive energy
credits for as long as it produces a particular volume of biogas, generated by the anaerobic
digestion of the sludge and food scraps in its digesters.
The GLSD manages 52 MGD of sewage. It is the second largest WWTP in Massachusetts. It
serves 168,000 residents of Andover, North Andover, Lawrence, Mathuen, and Salem, NH. 80%
of its influent is from households and 20% from industries. It has 40 significant industrial users.
It discharges treated wastewater into the Merrimack River and produces 52.5 wet tons a day of
sludge, which is dried to about 38 dry tons/day (2013). Some of those residents on the system are
the poorest in the state. This becomes an environmental justice issue when one considers the
increase in O&M from the food scraps program at the treatment plant. 50% of these costs are
carried by the people of Lawrence, the largest city on the system. Published budgets show a 20%
2 https://www.ncbi.nim.nih.gov/pmc/articles/PMC4232481/#R29
3https://toxics.usgs.gov/highlights/compounds_biosolids_study.html
4 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3776589/
2
increase in O&M since the 4th digester meant to handle food scraps went online. This won't
come out of Cambridge projects, but will instead be paid for my people in the Merrimack Valley.
GLSD built 3 anaerobic digesters in 2002 and started construction on a 4th in 2014, with
significant state funding. The 4th digester was added to prepare for food scraps that would be
coming from Massachusetts municipalities like Cambridge. But the digester cannot process the
food into biogas unless it is approximately 15% solids, so a RFP was sent out by GLSD to
establish an industrial facility to make the slurry. The contract was won by Waste Management,
Inc. (WMIl) and sited in Charlestown. This infrastructure was teed up by the state and GLSD,
with at more than $20 million in grants from the state. So when Cambridge went looking for a
place to bring its food scraps, the WMI facility in Charlestown was ready. Why does this matter?
Because millions have been invested by the state to turn your food scraps into a source of
pollution. The same investments can be made to create transfer stations and other infrastructure
necessary to turn food scraps into compost.
What about the energy produced by the digestion of food scraps at the GLSD?
Wastewater treatment plants are not carbon neutral. Their carbon footprint includes aeration
required in the secondary treatment process, sludge processing, pumps and machinery, sludge
hauling by trucks, and the production of chemicals used in the treatment process.
The IPCC estimates that 5% of global methane (CH4) emissions and 3% of global nitrous oxide
(N2O) emissions come from wastewater treatment plants. Both are greenhouse gasses more
potent than carbon dioxide (methane has 25 times the global warming potential than carbon
dioxide and nitrous oxide has 300 times the global warming potential). WWTPs use massive
amounts of electricity too, by some estimates 1% (38 billion kWh/year ) of all electricity use in
the US.
Making biogas at the plant is a dirty, dangerous operation. The purpose of sludge digestion is not
to produce biogas, but instead for volume and pathogen reduction. But capturing the gas is a
good idea. To do so, it has to be monitored, metered, cleaned, stored, and used. Why cleaned?
Because the sludge is so loaded with siloxanes -- which are silicone compounds from personal
care products, sealants and lubricants - that their oxidation forms deposits on engine parts.
These compounds cause cancer and harm the reproductive and immune systems. Once filtered
out they are brought to the landfill. WWTPs are multipliers of environmental trouble.
When there is a disruption in the service by mechanical failure or human error, the gas is
released into the atmosphere. When everything is running smoothly, 18% of the biogas is flared
and the rest goes into processing the sewage sludge -- which only consists of 8% of the energy
needs of the treatment plant - which are now increased by the addition of the food scrap slurry.
And round and round we go.
Conclusion
3
What to do? Do not mix Cambridge food scraps with sewage sludge. Instead, compost food
scraps, making a soil amendment that contributes to healthy soils. This translates into carbon
sequestration and healthy plants; helping agriculture be the foundation of public health.
The timeline for real composting has to include the development of the infrastructure to make
this happen, just as the comingling food waste with sludge was planned far in advance of the
Cambridge Compost Program. This city and our state can reverse this error and really make the
Cambridge Curbside Compost Program just that -- a compost program. Other municipalities in
Massachusetts are watching, as is the rest of the county. What Cambridge does with its food
scraps, matters greatly.
Laura Orlando
Executive Director, RILES
1330 Beacon Si. STE 355A
Brookline, MA 02445
Email: orlando @riles.org
4
ATTACHMENT F
Mila
23 Avon St #2
Perimutter Associates
Cambridge, MA 02138
[phone removed]
Thank you Committee members for inviting me here today.
Before starting my remarks, I would like to stay how lucky we in Cambridge are to have the people
we do in public works who work on recycling and waste reduction every day. We are fortunate to
have recycling programs in our schools, our organics collection program, residential curbside, our
new small business program, a vibrant recycling center, and household hazardous waste days. We
are fortunate to have City Councilors as well who care so much about the environment. We have
many of the pieces in place to move us towards being a Zero Waste city that equals those on the
west coast. But we do need to step up our game to get there. I appreciate you holding this hearing.
A quick bit about my background and why I was asked to speak today. I have been working in the
recycling field for going on four decades. I spent the first half of my career developing recycling
programs on the east and west coasts. I was a county director of solid waste in New Jersey and the
founding president of that state's recycling association. I then served as San Francisco's recycling
program director. I came to Massachusetts after that and was the founding executive director of a
statewide program that linked recycling and economic development- focusing on the demand side
of the recycling loop. For the last 15 years I have been an independent consultant, with a practice in
strategy, stakeholder engagement, project management, among other things, focusing on Zero
Waste and green chemistry. I have served on boards and advisory committees of non-profits and
start-ups involved in Zero Waste. Currently, I am leading a team of nationally recognized
consultants helping the City of Boston in development of its Zero Waste Plan, which we hope will be
completed by the end of this year. I am also a long time resident of Cambridge.
I was invited here to speak about "the China situation," what that means for Cambridge, and what
we can do about it.
For most of recycling history, the northeast US sent its recyclables to domestic mills that turned
these materials into new products. But, increasingly, over the past ten years or so, China became a
dominant market for much of our metals, plastic, and paper. The reason for this was that China's
manufacturing sector was growing and needed feedstock. They built state of the art mills that could
handle levels of contamination that our older mills could not They had cheap labor, too. The ships
that brought us our consumables would have returned empty, so they could afford to charge little
for taking back our recyclables. China's willingness to take mixed, dirty recyclables led to the
proliferation of single stream recycling programs in the US. MRE operators had little incentive to
tell communities to deliver clean recyclables, and little incentive to clean recyclables and sort them
by grade, as had previously been done. In fact, and I am not suggesting that this happened here,
some MRF operators intentionally put trash in the bales of materials as a way to dispose of it for
free. Recycling evolved from sorting of high quality commodity grades to moving large quantities of
materials through the conveyors as quickly as possible. We sacrificed quality for quantity, which is
never a good idea. Domestic mills couldn't compete, they needed higher quality and shipping was
more expensive. Many closed, as all kinds of manufacturing in the US was impacted by cheap
manufacturing in China.
We got sloppy with our recycling habits and closed our eyes to what was going on. We had no idea
how much trash was going along for the ride with our recyclables, yet counted everything collected
in our recycling rates. It wasn't sustainable.
A few years ago, China started what was called the Green Fence program, to start cutting down on
contamination in the materials they were receiving. Beginning this past January, they implemented
National Sword, as part of their Blue Skies policy, banning 24 different types of scrap materials.
Many of these materials are collected in our curbside recycling programs, such as paper and
plastics, as well as some scrap metal. In addition, they increased the quality standards for the
materials still accepted, reducing the amount of contamination allowed. The standards they set are
virtually impossible to meet. For example, in my years working with recycling collection programs,
5% was a rule of thumb for allowable contamination. China has set a standard of .5%. This has
meant that MRFs have had to slow down their sorting lines to clean the materials to these difficult
to meet standards, and are pressuring communities and businesses that recycle to clean up their
acts as well. This whole situation has increased the cost of recycling for a number of reasons:
lowering the throughput at MRFs means that fewer tons/hour can be processed, and extra shifts
need to be added to not only remove contaminants, but to sort to different grades; MRF operators
are now paying to dispose of contaminants they used to ship off to China; and transportation to new
markets is more expensive. Materials for which there are no markets are being stockpiled or
disposed if there are no markets. This includes mixed paper and some plastics, though I admit J am
not up to speed about what is happening to Cambridge's materials in particular.
China has said it will stop taking all scrap imports by 2020.
Simply put, China did this because they were tired of taking our garbage: On top of that, new tariffs
added by the Chinese in retaliation for our tariffs on their goods have led to their further reduction
in the purchase of of recyclable commodities.
Will China change its mind and open its doors again? Doubtful, but, even if so, not to the degree they
did in the past. The industries there need our materials, but the government is tired of being our
dumping ground. Paper mills are changing some of the commodities they are taking to get around
this- for example, taking cardboard, newspaper, and magazines instead of mixed paper, or taking
pulped paper from the US, but this is still a limited market and will end in 2020. If China does relax
its bans, people I know do not expect them to ever take as much as they did before. And, they would
only take high quality material.
Other Asian countries have been taking some of our materials, but they don't have the same
capacity that China did. To illustrate: all of the other Asian nations combined including India do not
collectively consume as much recovered paper as China,
To add insult to injury, Massachusetts had a glass plant that turned our glass into new bottles. The
owner of the plant announced the plant closure in the spring. Our bottles are now going from being
turned into bottles and fiberglass to aggregate and fill. Only the highest quality glass, that which is
collected through the bottle bill, is finding high value markets. A new market is being developed in
N), that I believe that will turn glass into fiberglass, but that is a while away and shipping will be
expensive.
There are always market upturns and downturns. But materials that are of high quality always
tend to have a market; it is the low value markets that drop out first, and, sadly, that is what we
allowed to happen to our recyclables, MREs in places where quality is a priority are having no
problem selling their materials at good prices, albeit at a lower price than they had been getting in
recent years. I am not a proponent of single stream, but these MRFs are showing that single stream
materials, if low in contamination to begin with, can be sorted to high grades.
The China situation is considered by many of us in the field to be a market correction. We hope that
it will get us back to basics of thinking about markets as we design our collection programs, back to
educating people about what is and isn't truly recyciable, and back to thinking about ways of
building domestic demand. With every crisis comes opportunity!
There are any number of things Cambridge can do about this:
Reduce Trash
Cambridge needs trash limits on the trash that people put out, no Zero Waste community has
unlimited or high trash limits. Trash limits have proven to reduce waste everywhere they are used.
However, that is only in the residential sector. In the commercial sector, Cambridge can enforce its
recycling policy- many businesses don't have recycling bins, don't educate their employees or
customers if they do, or don't utilize janitorial services that recycle what is separated. The City can
put carrots and sticks in place to reduce single use plastics, such as straws, disposables used in
restaurants for eating in and taking out, and more. It can provide technical assistance in the
commercial sector for reducing waste, and offer recognition to leading Zero Waste businesses in
various categories, It can require that any street fair use specific products that create less waste, or
don't use those that do. Events can be required to use washable cups and issue a deposit that is
returned when the cups are returned, this is being done elsewhere. Imagine a street-fair without
cups littering the road! Boston University provides washable Go Boxes to reduce the amount of
take-out waste. The City can also provide grants to implement Zero Waste ideas- for example,
perhaps a dishwashing business can support schools in getting rid of disposable trays, plates, and
utensils, There are endless ideas. These are great challenges to submit to students and our
universities to solvel
Reduce contamination
A major educational and enforcement campaign is needed to educate people on what is and isn't
recyclable. The DEP has developed good informational materials. We must collect only what is truly
recyclable and leave the rest behind, Letting people know what is and isn'trecyclable can also lead
to waste reduction, as people become more aware that they can't recycle everything.
Build Markets
There are things that Cambridge can do to build local and domestic markets aside from ensuring
clean materials. It can require, and even provide financial incentives to, the MRF to sell to specific
markets or types of markets deemed highest and best use. It can also retain the right to market
materials itself for the purposes of local or regional market development. The City can offer grants
to university researchers and entrepreneurs for good ideas to utilize recyclable materials locally,
such as handmade paper generated by City residents and businesses, or new clothes from old
textiles. It can identify the businesses in the City supporting the Zero Waste economy- repair shops,
consignment shops, etc.- and understand and support the needs of these businesses. The City can
incorporate building a Zero Waste economy into its economic development strategy. It can provide
or provide incentives to a landlord to develop a building that houses Zero Waste businesses.
3
Educate
Changing behavior and creating a culture of Zero Waste takes constant education and outreach and
visibility. The City does a good job of this, but it is not nearly enough. We must reinforce the
message over and over, and enforce standards. A key difference between successful Zero Waste
communities and those that are not is continual messaging. People need to hear it at home, at work,
at school, and traveling between home and work and school! They need to hear it from their friends
and neighbors and trusted sources. And the messaging shouldn't just be about what is and isn't
recyclable, but how to reduce waste, what the alternatives are, and why this is important. Thinking
that things are recyclable helps drive consumption. Understanding what is and isn't provides an
additional opportunity to educate people about how to reduce their waste. The message needs to
be infused everywhere and in ever way!
Litter has become a major problem in the City, and Zero Waste can be linked. Much of the litter on
the streets is single use packaging and cigarette butts which make their way into the sewer system
and into the environment. Drug store owners, coffee shops, convenience stores, banks, should be
incentivized- through carrots or sticks- to clean up the litter in front of their stores. Doing so may
make them more aware of how they are contributing to the problem and finding ways to solve it.
Work regionally
Boston has been undertaking its own Zero Waste Planning process. Working together, both cities
can create synergies to implement the above ideas, perhaps issuing joint RFPs for some of the grant
programs or developing prospectus' that would attract businesses to the region. The City can also
take advantage of the work that has been done to develop Boston's Zero Waste Plan and use some
of those ideas!
Since much of the markets issue has to do with processing, I would like to close by adding that the
workers at the MRF are not included in the City's living wage ordinance. They do dangerous and
important work and it is not right that they make so little. As part of its Zero Waste efforts,
Cambridge should work with neighboring communities and the MRF operator to rectify this issue
and pay these workers fairly.
Thank you again for the opportunity to be here. I am happy to answer any questions or be a
resource.
Any lalith
4
ATTACHMENTG
CERO Cooperative, Inc.
PO Box 220231 - Boston, MA 02122
Email: [email removed] - Phone: [phone removed]
Cambridge Health and Environmental Committee Hearing regarding Zero Waste
October 9, 2018
1 am a worker-owner and general manager at CERO Cooperative, Boston's only WMBE
commercial compost services company. We divert more than 50 tons of compostable waste
every week from more than 60 business and institutional customers. That's 50 tons of material
that is no longer being burned in "waste to energy" plants. At CERO we are proud to be growing
a business that provides good, green jobs and worker-ownership in our communities, while
creating a sustainable infrastructure for managing and achieving highest use potential for our
region's organic waste.
When it comes to zero waste planning, consideration of organics quickly comes forward for
attention in part because it is such a large portion of all waste generated. The MassDEP
organics waste ban, which went into effect in 2014, has encouraged more businesses to
participate in food waste diversion. Cities across the country are implementing zero waste
plans. This is great, and at the same time it means that leaders like you all, will be making critical
policy decisions with far-reaching future impact.
When food waste breaks down in landfill it produces deadly methane, one of the most toxic of
all greenhouse gases, another reason for recognition across the planet that organic "waste" is
the most obvious early target for reducing all vaste. Because diversion and recycling organic
waste is so new in this country and the amounts are so large, we need to scale organics
processing infrastructure significantly. Here is where we need to be really careful and do our
homework because how we dispose of the organics matters so much.
Organic "waste" is increasingly recognized as a valuable resource. When processed properly,
composted food waste alone can replenish all of the depleted soil on earth. In the soil it acts as
a sponge sucking up carbon and mitigating CO2, the greenhouse gas that contributes most to
climate change. We're seeing a whole new biogas industry develop around food waste that is
demonstrating the great promise for this renewable fuel. What a great alternative to fracked gas!
Organics processing technologies are evolving dynamically and they vary enormously. The
oldest forms of windrow composting have undergone major modernization and we don't have
nearly enough windrow capacity, especially within reasonable proximity to the city. So we
should support existing facilities to accept more food waste and we should establish new
facilities. Big waste to energy incinerators and anaerobic digesters (AD) have moved in to
gobble up large amounts of organics - but they are a bad alternative.
Just as over-investment in fossil fuels means there has been under-investment in renewable
energy, burning organics in incinerators or mixing food waste with sewerage in wastewater
digesters are false solutions. If that's where our organics are going we might as well flush our
food waste down the toilet. If we choose burning and flushing as primary organics solutions, we
squander the phenomenal resources organic waste offers. Instead of extracting the organics
forever away from the food growing cycle, we should view development of an organics
infrastructure as a golden opportunity to achieve positive environmental and economic impact.
We applaud the City of Cambridge for rolling out a citywide curbside compost collection
program. Now we need Cambridge to lead the way and ensure that the false solution does not
become the defacto processing method, simply because waste water treatment infrastructure is
currently in place. Instead we encourage the City to adopt zero waste policies that prioritize
highest possible use solutions. Highest use solutions maximize the value and environmental
benefit avallable in collecting organic waste. Most diversion technologies mitigate methane and
produce energy but not all technologies recycle the organic material in the ways that are best
for soil health, farming and growing food.
Leaders in other cities will be paying attention to decisions you all make here in Cambridge.
Cambridge could be in the lead by being transparent in telling residents what happens to the
waste we produce. It would be great for Cambridge to divert at least some of your organic
waste to be composted in the ways that re-earth the valuable material into the food cycle.
Longer term we should support the development of a diverse processing infrastructure so we
can keep learning and avoid unintended consequences by making hasty choices in a rapidly
evolving industry. We should lift up highest use approaches that add value such as local
employment, microgrid connection and the best products for local agriculture. Community scale
anaerobic digestion technology is available now that requires small amounts of land and
modest investment. We can build capacity over time and decentralize the benefits of reduced
trucking, clean energy creation and soil enrichment products.
1 am happy to answer questions or provide any additional information that could be helpful.
Respectfully Submitted,
Lor Holmes, General Manager
CERO Cooperative, InC.
/711
2200
nebra
phone [phone removed]
www.nebiosolids.org
EPA/903/S-18/001
United States in 2015
Food Waste in the
Anaerobic Digestion
Facilities Processing
1219
(WERE 2012a)
WARF/Sewers
food waste, for co-digestion (Lono-Batura, 2012).
Non-Biogenic CO2e Emissions (tons/yr)
1520
Mixed RF
Figure 2 Comparing the carbon footprint of seneral food waste disposal options:
landfilling, composting. delivering food waste to 10 RREs tin seners, hanling food waste to
MRRFs a tracks, and separating food waste at a mixed materials recovery facility / NIRE)
co-digestion at WRRFs.
~3 million tons
663,812 homes
these co-digesting WRRFs.
Co-digestion at WRRFs is not new or unique here.
could be powered from the
food waste processed through
renewable biogas produced by
-2015 U.S. data
In the U.S., 1238 water resource recovery facilities (WRRFs) send solids
to anaerobic digestion (AD). More than 200 take in outside waste, such as
Congratulations for choosing sustainability!
Thus as not men. Bof sou are helping lead the was toward zero
publications
Diverting organic waste from landfills combats climate change & improves soils.
Iff we are going to advance organics diversion, keeping all provem, environmentally-sound options is necessary.
NJ 3
DE 0
TN 0
ст. 0
VT: 1
better (we like both).
MA 1
NH. 0
MD 0
atmosphere; by capturing and combusting CH*; by minimizing MSW hauling distances,
waste decomposes in landfills, it creates leachate.... Diverting food waste from landfills
Electronic copy available at
Leonard 2004). In an evaluation of food waste disposal options, the Water Environment
reduces the volume of organic matter, correspondingly reducing not only the amount of
reducing truck traffic and associated air emissions (DiStefano and Belenkey 2009); and by
(WERF 2012a).... Diverting food waste from landfills can also protect water quality. When
"Co-digestion at WRRFs can reduce the carbon footprint of waste management by diverting
sequestering carbon into soil structure through the land application of biosolids (Brown and
Research Foundation (WERF) identified co-digesting hauled-in food waste at WRRFs as the
https://www.nebiosolids.org/nebra
& sustamabaits
Figure 3: Operating WRRF Food Waste Co-Digestion Systems by State (2015)
only carbon negative, i.e. greenhouse gas reducing, waste management strategy (Figure 2)
leachate but also the concentration of dissolved organic matter in the leachate." (U.S. EPA 2014)
% change over control soil
150
350
100
Carbon
Other Resources:
Microbial activity
December 2012. It
Water holding
& Development. hips: cpub.cpa.gs
Bulk density
• What is anaerobic digestion (AD)? hips
Operational AD/biogas systems in the U.S. hu
nct/2012/12/18 broga
Hes-diversion 504477
report.cim? ah
Resources re Cambridge's organics diversion program:
More than 55% of wastewater solids produced at U. S. WRRFs are applied to soil,
www.americanbiogascouncil.org/brogas_what.asp
•
-NRMRI &dirintry ld=305-470
07/1705 816/w
destroyed hi
https://www.nebo
antimicrobial soap (l
regulations grounded in research:
• Cambridge organics diversion program: https://www.wastedive.com/news/organics growth-hon-one massachuselts cily went big on curbside/51858)
https://www.ncbiosolids.org/resources:@/scientific-hasis-lov-htor
exposure to triclosan as one handwashing with
• Lono-Batura, M., Y. Qi, and N. Beecher. 2012. Biogas production and potential from U.S. wastewater treatment. BioCycle: v. 53, no. 12,
research show no significant impact on human or
environmental receptors... Example: for a typical
gardening use of biosolids to get the same level of
source reduction; regulations set limits in biosolids
org resources/#-licary-metals-trace-clements)
Concerns are addressed through stringent federal & state
GLSD biosolids are Class A - virtually all pathogens
gardener, it would take nearly 10,000 years of typical
• Heavy metals - kept from sewers by pretreatment and
Decades of biosolids research & experience
• Pennington, M. / U.S. EPA. 2018. Anaerobic Digestion Facilities Processing Food Waste in the United States in 2015. https://w..epa.go/anacrobic
Chemicals - traces are present, but risk assessment and
• GLSD Water Resource Recovery Facility AD & green energy & biosolids program: hips://www nebosolds org member-highlights/greater-lawrence-sanitary
• The CoRE food waste processing facility: https://www.youtube.com/watch?x=[email removed] and https://www.wastednc.com/news/inside-boston-
Recycling treated wastewater solids (biosolids) to soils is the best environmental option.
Pathogens - addressed through prescribed treatments...
• Cambridge organics diversion program concern: https://www.wghh.org/news/ocal-news2018/05/22/cambridges-composting-program isnt actually composting is what
including 100% from Seattle, Portland, San Francisco, L.A., Denver, Austin, Des Moines, Chicago, Portland, Concord, Greater Lawrence, Boston.
• U.S. EPA. 2014. Food Waste to Energy: How Six Water Resource Recovery Facilities Are Boosting Biogas Production and the Bottom Line. Office of Research
* The MWRA, which receives your wastewater, uses AD and recycles 100% of its biosolids to soils in the same way as GLSD - and has for ~20 years.
Biosolids recycling is one of the largest, consistent recycling programs in the U.S. (And you contribute to it daily*. Thx.)
AtTACumeNT I
HRI
HOMEOWNER'S
REHAB, INC.
October 9, 2018
To the Health and Environment Committee
Homeowner's Rehab, Inc. private nonprofit developer in
Cambridge. We own a more than 1,500 units of housing
Cambridge. We are in full support of the food waste recycling
program, and we support the Public Works Department's decision to
access the Organics To Energy program offered to the citizens. It is a
very progressive, proven and stable program, and it is sounds like the
best choice for the environment based on the science"
Jane carbone entire
Director of Development
Homeowners Rehab Inc.
United
280 Franklin Street. Cambridge, MA 02139. phone [phone removed]. fax [phone removed] . www.homeownersrehab.org
Way