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Feature Article Elements 2001

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Text: Megalandfills : Industry Boon or Bane?

What is equivalent in volume to 8,000 Great Pyramids and covers 1,200 football fields? A megalandfill. In the last 10 years there has been a trend toward construction of increasingly larger and more remotely located solid waste landfills. Megalandfills represent a different class of facility than the vast majority of existing landfills - by virtue of their unprecedented size and life span. This article discusses some issues regarding megalandfills that raise questions with no easy answers.

By Bruce J. Clark

Megalandfill Development Drivers
Hard and Soft Issues
Stewardship: Financial Assurance for Long-Term Care
Long-Term Conformance With Need
Impacts on Local Government
Public-Sector Responsibility
Summary

There seems to be no formal definition of what a megalandfill is. For the purpose of this article, a megalandfill is one having a planned waste footprint over 1,500 ac., well over 6,000-tpd capacity, and a useful life estimated at 50-100 years. Only a handful of megalandfills exist in the United States. Several are in the planning or permitting stages; two of those are planned for the southern California desert.

Megalandfill Development Drivers

The development of megalandfills seems to be driven by a combination of factors, including:

  • closure of old, large landfills that were relatively close to the major metro areas they served (e.g., Fresh Kills in New York),
  • the difficulty and high cost of siting a new landfill or expanding an existing landfill close to source of waste generation,
  • the economy of scale that can be recognized with landfill design and construction that has become relatively standardized, and
  • the Carbone decision, which struck down flow control, making it difficult for some local governments to finance their own facilities.

Hard and Soft Issues

Megalandfill issues can be divided up into two broad categories: hard issues and soft issues. The hard issues typically are more noticeable in that they usually apply to a specific facility in the early stages of development. Hard issues include permitting and design issues, such as siting, size, and acute impacts (e.g., traffic and odor). Soft issues include factors more difficult to assess because they are subject to change, such as economic conditions, financial considerations, public policy, and long-term public benefits. Key soft issues can include:

  • stewardship: financial assurance for long-term care
  • long-term conformance with need
  • impacts on local government
  • public-sector responsibility

Some of the key potential benefits and liabilities that are part of the soft issues associated with megalandfills are as follows:

Anticipated Benefits

Economy of scale

Less regulatory burden

Longer service life

Relieves cities of siting/operating burden

Lower long-term disposal costs

Lessened overall environmental impact

Potential Liabilities

Increased hauling costs

Less user flexibility and control

Municipal revenue shortfalls

Less opportunity for integrated system

Uncertainty of adequate financial resources for closure/postclosure

The author spoke with several current or former MSW directors across the country and a state regulator about what their thoughts are on the soft issues and some of the benefits and liabilities described above.

Stewardship: Financial Assurance for Long-Term Care

Are the financial obligations for closure and postclosure maintenance substantially different for a megalandfill than for a medium-size (say 300-ac.) facility? Should they be? Does the potential for a megalandfill to operate for 100 years or more present any challenges to financial assurance? In that context, does it matter if a megalandfill is privately owned versus government-owned? These are questions without easy answers. The true megalandfills have not been in existence long enough to know.

Bill Hinkley, chief of the Bureau of Solid & Hazardous Waste for the Florida Department of Environmental Protection, notes that some concerns have been raised about the adequacy of the corporate net-worth test, a common method used by some private companies, given the volatile state of the industry highlighted by major mergers and acquisitions, increased competitiveness, and some companies’ financial problems.

Hinkley also sees some potential drawbacks to the use of an escrow account that is not dedicated to the sole purpose of closure and postclosure. Use of the escrow account by municipal governments is popular. He admits that in some cases even that is not perfect; one city had to dip into its account to cover the cost of investigation and formal closure of several old dumps.

This inactive, open-pit iron-ore mine at Eagle Mountain, CA, is the site of a proposed 20,000-tpd landfill.

It is not uncommon in some states for just two or three private companies to own the majority of the larger landfills. Tim Hunt, a consultant and former executive director of the Palm Beach County Solid Waste Authority (FL), and Hinkley believe that this situation could increase the risk a company’s not being able to fulfill its long-term closure obligations if it ran into serious financial trouble. At least in Florida, there is no specific concern that this problem could occur.

Hinkley is quick to point out that many privately owned landfills in the state exceed design standards and are some of the best operated and maintained facilities. That seems to be an indicator that these companies take their current and long-term obligations seriously. And financial problems are not unique to private companies: Municipal governments too can experience significant financial problems that could affect their ability to deal with long-term issues at landfills. Still, Hinkley believes that governments represent stability and would be there to deal with long-term postclosure maintenance and problems that might occur.

Hinkley says his department would prefer larger and less numerous landfills, assuming they were well run, because of limited staff resources for compliance inspections. He was less concerned with the risk of such environmental problems as groundwater contamination from a leaking megalandfill given the strict operating controls and sophisticated liner designs many private owners have opted to install.

Long-Term Conformance With Need

What is the best way to manage a city’s wastes? Haul it all to a megalandfill, a waste-to-energy (WTE) plant, or a combination of both? What about integrating other technologies, recycling, composting, and source reduction?

All of those interviewed expressed the view that landfills are here to stay, at least for the foreseeable future (i.e., the next 25-50 years). Big cities such as Houston, TX, and San Jose, CA, negotiated 20-year contracts for disposal at privately owned large landfills relatively close by. San Jose uses one for its residential solid waste, and Houston uses two. The estimate for those facilities’ capacities is another 20-50 years, so there is no need to go sole source to a megalandfill, at least for a while.

Ellen Ryan, manager of integrated waste management for the City of San Jose, believes that megalandfills will eventually be needed as smaller landfills continue to fill up. When exactly the smaller landfills will fill up and close is tough to say, given the recent emphasis on bioreactor landfill cells and other sustainable techniques that hold promise for increasing the life of an existing site.

Ryan says the megalandfill may be a good alternative for rural areas with no other choices, but it’s probably not as popular for high-density regions that have many other options, either in more numerous closer landfills or through other disposal methods. She adds that being locked into a sole-source megalandfill long term could prevent a city from accessing new, less expensive technologies that could come along in that time.

Tom Henderson, administrator of solid waste management for the City of Washington, DC, explains that his city is assessing ways to untangle itself from a situation that has the city locked into an "export" system in which it is almost entirely dependent on distant large landfills. About 75% of the waste goes to landfills, the balance to a WTE plant. The system spawned construction of many transfer stations to move out the waste. Many of these transfer stations were nothing more than old buildings adapted for use. Because they were not located or designed as true transfer stations, waste-truck traffic congestion, odors, and vectors at these facilities have become a significant nuisance to the neighborhoods nearby.

Although Henderson says this system has kept rates relatively low, he believes they are artificially low and do not reflect the actual costs that would have been incurred in properly planning and designing a transfer station network that would be transparent to the neighborhoods (i.e., no impact) or the other expenditure needed to maintain those landfills into perpetuity after closure.

Impacts on Local Government

Most professionals interviewed indicate that the risk to a community is greater if it has no other options than a sole-source megalandfill. A less risky situation is to have several companies (i.e., multiple disposal sites) competing for the business. A city is at less risk if it has the luxury to negotiate several contracts and to have an alternative site should one company default. In the 1990s, available capacity exceeded disposal volume, which allowed many cities to negotiate lucrative long-term deals with lower disposal rates.

Everett Bass, director of the solid waste management department for the City of Houston, indicates that his city has done well financially by contracting for disposal with two large private landfills near the city. Bass cites such items as competitive bidding, multiple contracts, lengthening the contracts from five to 20 years, and removal of rate escalators as keys to securing the lowest long-term rate.

Switching from disposal at their own landfill to exportation of wastes to a more distant private landfill can financially strain, perhaps only temporarily, some smaller municipalities that lose the tipping fees from commercial haulers. Hunt and Ryan report, however, that the revenue recognized from the disposal side of the system was generally not the largest source, at least in their cities (San Jose and West Palm Beach) when compared to the revenue generated by the collection side. It remains to be seen if a megalandfill will play a long-term role in New York City’s disposal plans and how the short-term economics will work out as it continues to refine the city’s plans for disposal.

Will the sole-source megalandfill obviate the need for an integrated system? Will it stifle other technologies (e.g., WTE) or research on new or emerging disposal technologies? Hunt and Henderson believe that the sole-source megalandfill concept will be detrimental to WTE and reduce the incentive for communities to recycle. Hunt cites studies that showed communities with high recycling rates (30-40%) typically had an integrated waste management system.

Ryan notes that her city, San Jose, emphasizes source reduction and recycling and is close to diverting 50% of its waste from landfills. Even though she has an annual disposal allocation that is not impacted by diversion, she generally diverts as much as possible and still has no problem meeting it with the city’s solid growth rate.

All of those interviewed say that any city facing the critical decision of how and where its waste should be disposed of needs to make a careful economic analysis of the alternatives. Ryan stresses that contracts must be structured with due care for providing the city the most flexibility; for example, not requiring a "put-or-pay" provision that could hamper recycling and not allowing escalator clauses that would cost the city additional money. Hunt mentions that revenues funneled into a city’s "general fund" by the public collection system are often overlooked in the economic analysis and can lead to a misleading conclusion of a major revenue shortfall if the city opts to close its landfill and contract out disposal.

Public-Sector Responsibility

What is a local government’s responsibility to its citizens as far as waste disposal goes? Should it keep control of the disposal facility or contract out? Should it contract with one megalandfill or contract with several smaller landfills? Henderson states that prior to the introduction of the megalandfill, solid waste disposal was generally treated as a local problem with a local solution. But the timing of the Subtitle D regulations, the Carbone decision, and the battering taken by the WTE industry all helped to set the stage for a change in the view of some local governments and politicians and opened the door for the private megalandfill.

Ryan indicates that the megalandfill as sole source could possibly cut down on the competition but could not say if that would lead to higher costs. When her city put out disposal contracts for bid, it separated the collection from the disposal in order to get the best rate for each activity.

Henderson believes that solid waste disposal is a utility service and that the public should be obligated to pay the true costs of waste disposal. He claims that, for his city, WTE rather than distant landfills would have been a better option, at least before Carbone. His opinion is that landfills have benefited from the generally negative portrayal of WTE plants, as it relates to trumped up concerns about air emissions and the uneven playing field that existed for many years because landfills were not required to have air-emission controls.

Henderson also cites the relative stability of fuel prices since the mid-1980s, which suited the economics of the long haul to the distant, large landfill and helped keep disposal prices artificially low. Recent surges in fuel prices, however, may dampen - if only for a while - the economic attractiveness of long haul for some cities.

Bass says the City of Houston made the decision long ago that it would be better off letting the privates handle disposal, a decision that in part spawned the formation of BFI, formerly the second-largest waste company in the world. He sees the long-term agreements the city has in place with two landfills as its security blanket. In contrast, he mentions the City of Dallas, which also took a successful but different route around the same time and invested in managing its own system. As such, Dallas has a very low, long-term disposal cost and capacity estimated at 50 years.

Summary

Only time will tell if the megalandfill becomes an unprecedented success or is plagued by some of the soft issues previously discussed. Some communities have the convenience of smaller and more numerous landfills and/or other disposal options. Others might soon have to become players in the coming megalandfill era. Megalandfills, like all disposal technologies, are inseparable from the soft issues that have been and will continue to be debated by government, industry, and the public for some time.

Bruce J. Clark is an engineer with Environmental Resources Management in Tampa, FL.

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