John Fischer
Massachusetts Department of Environmental Protection
1 Winter St., Boston

Dear Mr. Fischer,

On behalf of the cities and towns of the Commonwealth, the Massachusetts Municipal Association appreciates the opportunity to provide comment on MassDEP’s Draft 2020-2030 Solid Waste Master Plan.

In a January 2019 resolution unanimously adopted by cities and towns across the state at the MMA’s Annual Business Meeting, the MMA and municipalities affirmed our commitment to working in partnership with the Baker-Polito Administration, the Legislature, and the private and nonprofit sectors to address the challenges associated with managing solid waste and recycling across the Commonwealth. Nearly two years after the enactment of China’s National Sword policy, there remains an urgent need to reduce solid waste overall, divert organics and textiles from the waste stream, better manage hazardous and bulky items, and create new markets for processing recyclable materials. Our municipalities still feel the financial impacts of changes in the global recycling and solid waste marketplace, as well as changes to material consumption and disposal patterns. Any master plan for managing solid waste and recycling across the Commonwealth must recognize the financial and materials burden placed on cities and towns and offer some analysis of such, coupled with strategies for relief and support.

The MMA is pleased to support MassDEP’s top goals for 2030 as outlined in the draft plan, a target reduction in solid waste disposal of 30% and a continued reduction in the toxicity of the waste stream. The MMA is also encouraged by sub-goals to promote source reduction across materials categories while increasing diversion opportunities. The MMA appreciates the continued partnership between MassDEP and the cities and towns of the Commonwealth to promote recycling, reduce contamination in the solid waste and recycling streams, and divert materials from solid waste disposal. As noted in the draft Solid Waste Master Plan, since 2010, MassDEP has awarded $24 million in grants to 308 municipalities and regional groups for these purposes. Massachusetts municipalities have benefited greatly from DEP funding opportunities, while also contributing to a Commonwealth-wide solid waste reduction of 14% since 2010.

Our municipalities are committed to helping their residents implement MassDEP’s strategies for residential waste reduction – to increase the quality of and reduce contamination in residential recycling streams, and to reduce overall disposal of residential waste through source reduction, reuse, recycling and composting. We note that MassDEP has identified food material as the category with the highest diversion potential – 570,000 tons by 2030 – and believe that municipalities must be supported as essential partners in order for the state to achieve that goal. Several cities and towns have started organics composting pilots or full-scale programs, and the MMA supports the expansion of these initiatives, with MassDEP support.

The MMA is also pleased to see the inclusion of extended producer responsibility (EPR) and product stewardship under major new and expanded initiatives within the draft plan. The MMA is aligned with these priorities. As stated in our 2019 resolution, we believe that state and federal agencies and lawmakers should take steps to require that manufacturers and third-party sellers reduce the amount of packaging, both recyclable and non-recyclable, that accompanies products for sale. We also support product stewardship legislation that requires manufacturer responsibility for end-of-life recycling of mattresses, paint products, electronics, and other products that can be diverted from the local waste stream. In addition to their environmental impacts, excess packaging and hazardous, bulky, or difficult-to-manage materials place a heavy materials and cost burden on municipalities, who are largely responsible for managing and paying for their disposal.

Page 10 of the draft plan notes that MassDEP expects to develop and periodically update separate Action Plans for key areas of focus. The MMA requests that MassDEP develop a more detailed action plan specifically for reducing the use of single-use packaging and advancing EPR and/or product stewardship systems for specific products. We also support inclusion in the plan of specific language limiting or ending the use of hard-to-manage products and materials such as plastic bags, single-use plastic bottles, and Styrofoam and similar products. Specific mention of these product categories is currently absent from the draft plan.

The MMA shares MassDEP’s concern with dwindling in-state disposal capacity for solid waste. Page 21 of the draft report notes that even if we achieve the 2030 solid waste reduction goal of 30%, there will still be an in-state disposal capacity gap of approximately 700,000 tons. While we all work to achieve reduction and diversion goals across materials categories, the MMA believes that the Commonwealth and the private sector must also invest in alternatives to landfill disposal. Therefore, the MMA supports MassDEP’s commitment to permitting additional capacity for innovative waste-to-energy facilities and/or non-combustion technologies such as gasification and pyrolysis, all of which must meet robust public and environmental health standards.

Lastly, considering the impacts to municipalities stemming from changes to the global recycling marketplace over the past decade, the MMA is encouraged by MassDEP’s commitment to foster in-state market development for reusable, recyclable and compostable materials. All such efforts will not only help the Commonwealth to achieve goals related to source reduction and diversion, but will also benefit cities and towns whose solid waste and recycling contracts are dependent on the strength and diversity of the market. We are hopeful that in-state and regional market development for recyclable and related materials will alleviate some of the financial burden that our members have experienced.

As stated previously, the MMA and our member municipalities appreciate the partnership with MassDEP on all efforts related to solid waste and recycling. Thank you for considering our comments on the draft 2020-2030 Solid Waste Master Plan. If you have any questions about our comments, or require additional information, please do not hesitate to contact me or MMA Legislative Analyst Ariela Lovett at alovett@mma.org or 617-426-7272, ext. 161, at any time.

Sincerely,

Geoffrey C. Beckwith
MMA Executive Director & CEO