Albany SWMP Comments From DEC 092612

7/29/2019 Albany SWMP Comments From DEC 092612

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~------------~-~r-----'-..01!!!.;~------:--I~---1NewYork State Department ofEnvironmental ConservationDivision of M aterials M anagement rBureau' of Permitting and Planning, 9thFloor -.625Broadway, Albany, New York 12233-7260Phone: (518) 402-8678 Fax: (518) 402-9024 ("Website; www.dec.ny.gov .! . J oeMartensCommissioner

S E P ' 2 6 2 0 1 2

Commissioner Nicholas D'AntonioCity of Albany Department of Public Works .One Connors Blvd. "Albany, New York 12207Dear Mr. D'Antonio:Re: Draft Capital Region Solid Waste Mafmgement Partnership Local Solid. Waste Management Plan .

Staff from the New York State Department of Environmental Conservation (Department) havereviewed the Draft Capital Region Solid Waste Management Partnership Local Solid Waste ManagementPlan (LSWMP), dated October 2010 and p~o:vide the enclosed comme.rits.. ..~ . .It is recognized that this Draft LSWMP was s~bmitted to the Department in January 2011 and dueto anumber of internal Department programmatic reasons, final review was not able to be completed untilnow. We appreciate your patience duriiigtbis period. We look.forward to working with you to addressour comments and recommend meetingl~o more fully discuss these comments as well as the next steps inthe LSWMP development and finalization process, Weare committed to working with the Planning Umtto develop an. approvable LSWMP. .. .

. ". >l; "',. .The LSWMP is an important tool toward an improved solid waste management system that will.benefit the residents of the Capital Region/ The Planning Unit is commended for recognizing thatorganics recycling is an important part of solid waste management and their efforts to increase recyclingduring the planning period and for being progressive in the pIari'sfor the establishment of a regional foodscraps recovery facility." ,'. ....'.After you have had the opp0rtm:llty to review these comments, please contact Richard Forgeainthe Region 4Office at your earliest conveD!en~e, at (51~357-2~43,to schedu17.a meeting. . ,:~2lL

:David! Vitale .Director ;.:.Bureau of Permitting and Planning

Enclosure

\

ec: . W. Bruce, City of Albany .K. Gallagher, Clough Harbor AssociatesE. Kelly, NYSDECRegioil 4 Director ".

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.-Comments on Capital Region Solid Waste Management Partnership's. Draft Local SolidWaste Management Plan .

(Dated October 2010)A review was conducted based on the requirements of 6NYCRR Section 360-15.9 for Local Solid WasteManagement Plan (LSWMP) contents. The following comments summarize the concerns and .deficiencies in the submitted draft LSWMP. These comments are divided into two sections; a generalcomments section intended to discuss some of the broader comments on the LSWMP and aspecificcomments section intended to identify more specific issues related to the text and LSWMP. Separateresponse to these comments is not required and can instead be provided as part of the text of the reviseddraft LSWMP.General Comments1. There are anumber of instances through the LSWMP where data used was considerably dated whensubmitted in January 2011 and will need updating for current reference and evaluation. In addition,

there are instances where changes may have occurred during the extended review time of theDepartinent since January 2011 that may have an impact of the Final LSWMP and will also need to beupdated. The specific comments will strive to identify those instances and the Department will workwith the planning unit to identify and minimize updates due to the extended review time of the draftLSWMP by the Department.

2. There are a number of comments that affect several portions of the LSWMP. In those instances, thespecific comments will strive to identify those instances to minimize duplication of comments.3. The text of the LSWMP often refers to aLSWMP through 2030 and in other areas including theimplementation schedule and recovery rate/disposal projections plans through 2020. The Departmentwill approve aten year planning period for LSWMPs when complete. Accordingly, all references to aterm of the planning period should be ten years. For the current draft LSWMP, that would be 2011

through 2020. However, due to the extended review time of this draft by the Department, it is. suggested the term be revised to 2013 - 2022. References in the LSWMP to time frames that reach2030 (or 2032 is adjusted) may be most appropriately referred to as a''planning horizon" as was donein the final paragraph of Section 2.1.2 and used by the State inBeyond Wasteto capture the concept ofimpacts of actions and activities undertaken during the planning period that will be more completelyrealized beyond the planning period. .

4. The four major categories of waste that need to be analyzed and addressed as part of a LSWMP are:municipal solid waste (MSW) which includes residential, commercial and institutional waste;construction and demolition (C&D) debris; industrial waste; and biosolids. This LSWMP addressesMSW, C&D debris and Industrial waste but does not address biosolids. This category of waste shouldbe incorporated into the LSWMP as appropriate through the LSWMP. It is acknowledged thatbiosolids management was noted in response to comment DISS on pages 38 and 39of the "Responseto Comments" but needs tobe included and evaluated in the LSWMP.

5. While there are anumber of instances where background information provided are the same that wasused in the 2009 LSWMP Modification, there are anumber of significant details and aspects that arenot specifically included or merely incorporated by reference in the LSWMP. Those especially relatedto the detailed activities, steps and time frames identified need to be should be included inthe reviseddraft LSWMP.

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6. Any typographical errors noted during review will be provided independently as part of future reviewmeetings or conversations for consideration in final editing.

Specific CommentsThe following review comments are provided in the order they were identified in the draft LSWMPand are not in order of significance. Section headers from the LSWMP are included for ease oforganizing these comments.

Executive Summary7. Table-E-2 (which is also Table 3-5) is missing data noted elsewhere in the LSWMP or does notcorrelate with available Department data. The Department will share available data to the planningunit to ensure the final draft includes all available information. nita used was also dated when

submitted and can be updated with more current information. Examples include the lack of inclusionof waste disposed at the North Albany C&D debris landfill noted in Section 3.4 and the amount ofwaste disposed in both the Town of Colonie Landfill and the Bethlehem C&D debris landfill.

8. The identification ofthe recycling rate on page E-3 and many other locations throughout the LSWMPwill likely need adjustment based on adjustments to base generation and disposal data as well as theinclusion of materials such as C&D debris used as alternate daily cover within recycling calculations.This issue will be discussed more completely in subsequent comments in this letter but will requireconsistent adjustment in the revised draft LSWMP.,9. Table E-3 will also require adjustment and updating concerning the amounts included in C,&D debris

recovery category as noted above as well as adjustments to the reporting of trees and brush as yardwaste instead of as land clearing debris which would be included in the general C&D debris reporting'category. These issues will be discussed more completely in subsequent comments in this letter.

10. Adjustments to the waste composition discussion and recovery rate projections and specified "maximumachievable" recovery rates may also require adjustment based on responses to comments concerning boththese topics that will be more completely addressed in subsequent comments in this letter.

11. The feasibility study for the regional solid waste management authority referenced on page ES-6 andseveral other places in the LSWMP is now complete and the text-here and, throughout the reviseddraft LSWMP should be revised accordingly to reflect the current status and findings of the study.

12. The discussion related to the hauler requirements using the Rapp Road Landfill instituted in 2009referenced on page ES-6 and several other places in the LSWMP should be updated to reflect theresults of the program. and associated annual report information.13. The discussion related to the Planning Unit Recycling Coordinator (PURC) on page ES-6 arid severalother places in the LSWMP was dated at the time of submittal, and should be updated to reflect the

details of efforts of the PURe.14. The discussion regarding land disposal on page ES-ll and throughout the plan and calculationsshould be enhanced and consistently presented to include the concept addressed on page 3-11 where itis stated "Achievement of the other primary goal of the new LSWMP. to minimize the amount of

solid waste requiring disposal, may help to extend the useful life of the Eastern Expansion beyond2016." This is'an important planning concept that is not consistently conveyed throughout theLSVIMP.

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15. The "Interim Measures" discussion on page ES12 should be updated to address concerning theprogress made on the proposed source separated organic waste (SSOW) facil ity and the solid wastemanagement authority. .Chapter 116. The following tasks were identified in the Department's June 12, 20091etter to CommissionerNicholas D' Antonio regarding the 2009 LSWMF' Modification. These tasks remain incomplete ordocumentation of their completion has not been provided to the Department and must be if thesecommunities are to be included as members in the planning unit.

a. In order for the-Town's of Beme, East Greenbush, Knox, New Scotland, Westerlo and theVi llage of Green Island to beconsidered in the same status as the other municipalities of theCapital Region Solid Waste Management Partnership Planning Unit, they were required tosubmit to the Department for review and approval, a revised local source separation law orordinance consistent with the requirements of Section 120-aa of the General municipal Lawwhich has been adopted by the respective Towns and Vi l lage. Additional ly, the Town's ofBerne, East Greenbush, Rensselaervi lle and Westerlo were also to submit a copy of aresolution agreeing to implement the LSWM P modification.A copy of all current municipal source separation laws or ordinances for the municipalitieswithin the planning uni t should be included as an Appendix to ~e LSWMP.

17. The population density discussions in section 1.:l.2 - Populations Trends and Projections on pages1-2and 1-3require adjustment to more accurately ref lect the data.18. Section 1.1.3- Significant Features Affecting Solid Waste M anagement, should be enhanced toinclude a set of l ists. maps or tables describing the planning units major population centers, schooldistricts, large retail centers, State of federal parks, large or significant industries, prisons and collegesand universities including a discussion of their impact 'on waste generation and management.19. Section 1.13 should l ist al l the food processors located in the planning unit identifying the type andamount of waste generated, and their current means to manage the waste.20. Section 1.1.3 should also include adescription of the agricultural!and use and farming in thePlanning Uni t. This should include the number of farms, the amount of land used for farming andother information germane to waste generated andmanaged or potentially managed by farms orfarming operations.21. The discussion on page 1-8 in section 1.1.4 -Background and Previous Sol id Waste Planning, relatedto yard waste and household hazardous waste management should be updated and clarified by morespecifically identifying the municipalities that have active programs and those that do.not.

22. The discussion in section 1.2- SWMP Steering Committee, should be clarified as to whether or notthe Committee is sti ll a in place and functioning and if so an identification of its intended future role.23. Section 1.3 - Goals and Objectives should be enhanced in the revised draft LSWMP to also includean identification of the :final numerical goals in addition to the descriptive goals. The last two goalsand objectives should be revised to be more definitive and affumative than using the beginningquali fier "considering!' These are also used in Section 4.3 and 6.0.

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24. Section 1.4- Public Review and Comment should be enhanced to identify the public commentprocess undertaken so ~a.rand the planned additional public comment envisioned.Chapteil25. In section 2.1 - Estimates of Solid Waste Generation, it is stated that "Haulers are not generallyrequired to record or report on the origin of the waste or recyclable material collected." AS ofJanuary 1,2009, the City of Albany has implemented acommercial hauler permit program at theRapp Road Landfill that, among other things, requires reporting from haulers. This information was

dated at the time of submittal but should now be able to be significantly enhanced with the additionaltime that has passed. This updated information along with any improvements and enhancements tothe permitting and reporting systems that will increase the planning unit's ability to obtain this dataduring the planning period of the tSWMP needs to be included in the revised draft LSWMP.. 26.' The waste generation discussions in section 2.2 - Characterization of Solid Waste, should besupplemented with waste generation data contained inBeyond Wasteas additional comparisons andreferences. Much of the information parallels the information ill the draft LSWMP however mayprovide Useful information to inform the planning effort. This base information will also be helpful inUnderstanding any related discussion and adjustments that may be made concerning the wastecomposition data based on planning unit specific generation data developed with the Department'swaste composition tools which are based on this data. The results can also be auseful tool to assessthe quality of existing data These tools are found on the Department's website at:http://www.dec.ny.gov/chemica1l65541.html. .27. Section 2.2.1 - Field Study of Solid Waste Characterization, provides a summary of the MSWcomposition data which ispresented more fully in Appendix D. This is very useful data for theplanning unit to use as part of the development of the new LSWMP and the significant effort andcommitment to gather and analyze the data is acknowledged by the Department. The Departmentdoes however have comments related to some of the information and its presentation in the draft

LSWMP.a. It isimportant to clarify that the information presented in Tables 2-4, 2-5 and 2-6 is not the

waste composition of the waste generated but is instead the waste composition of the wastedisposed as it did not include either the recyc1ables collected or analyzed in the recyclableswaste composition study conducted or any white goods and other large bulk metal.

b. The study was only a limited three-day sort for waste disposed at the end of February 2009and a limited three-day sort for the recyclables the first week of March 2009, potentiallyskewing the yard waste results and increasing the telephone directory categories.

c. It would be helpful and appropriate to enhance Table 2-6 by including waste compositiondata from the Department developed through the Department's waste composition toolsspecifically for the anticipated waste composition for the planning unit based on theinformation assembled and used in the development of Beyond Waste. There are severaldifferences in these two data sets that are worth evaluating as part of the revised draftLSWMP. Materials of note are yard trimmings and non-container ferrous metal projectsignificantly less than the planning unit data while glass and certain components of paper andplastics project significantly greater.

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d. The discussion andconclusions related to theyardwaste composition onpage 2-15 of section2.2 should berevisited aspart of the discussions withtheDepartment based onthe, projections of thewastecomposition dataand theapparent inclusion of some land clearingdebris in thetonnages included as yardwasterecovery asnoted onpage 3-14.28. Thewaste composition dataforC&D debris presented in section 2.2.2 - Construction &DemolitionDebris, should be supplemented with wastecomposition datacontained inBeyond Wasteasadditional comparisons andreferences. There areseveral differences in theprojected wastecomposition especially related towood.29. Thediscussion anddatacalculations onpage2-17 of section2.2.2need tobe adjusted toreflect thatC&D debris used asalternatedaily cover is notconsidered recycling in the calculation of overallrecycling rates and is instead considered as landfilled material. Additionally, facility dataindicatesthat greater quantities of C&D debris were disposed both insideand out of theplanning unit than isindicated in this section. TheDepartment will provide thePlanning Unit with all available disposaldataaspart of futuremeetings and discussions related todevelopment of ~revised draft LSWMP.30. In Section 2.2.3 - Non-Hazardous Industrial Waste, it is indicated that only 19of 150surveysmailedto industrial wastegenerators were completed and returned. TheLSWMP implementation scheduleshould indicate the steps tobe taken to obtain greater response andorotherwise enhance this data.31. In Table 2-8 in section2.3.1- Projected Solid Waste Quantities, there is atypographical error in thetotal wastegeneration column. This should be lO.21b/personlday instead of the 10.6listed. Therestof theTable is calculatedwith the correct 10.2value, however, this is atypographical error asthat isused is other calculations in thealternatives analysis sections in chapter 5.32. In section 2.3.2 - Future SolidWaste Generation, similar to the suggestions forTable 2-6, it would behelpful and appropriate toenhanceTable 2- : - 9 by including wastecomposition datafromtheDepartment developed through theDepartment's wastecomposition tools specifically for theanticipated wastecomposition for theplanning unit based onthe informationassembled andused in

the development ofBeyond Waste. The estimated as-generated waste composition presented in Table2-9may require adjustment in amanner similar totheas-disposed waste composition presented inTable 2-6 as thepreviously discussed differences track through the generated calculations aswell.Chapter 333. Generally, there appears tobevariation in thecategories ofrecyclables accepted by thevariousplanning unit member municipalities. This LSWMP should include an initiative to improve thestandardization of acceptable materials for recycling in all member municipalities allowing formorestreamlines andcost-effective promotional, education andenforcement efforts.34. A description of thevarious permit systems and fee structures for generators using thevarious Towntransfer stations of themember municipalities should be included in section 3.1.35. Much of the information provided in section3.1.1onpages 3-2- 3-7 describing thevariousmunicipal programs was dated at the timeof submittal and ismuchthe same as the informationpresented in the2009 LSWMP Modification. This information needs tobeupdated in the revised

draft to ensure I t represents thecurrent status of themunicipal programs. Special issues of'note forseveral of themunicipal discussions include:

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a. Bethlehem - theTown's hauler licensing program andprocedures should bedescribed inmore detail and themethod of collection of yardwaste in theTown should beclarified (e.g.,municipal collection orcontracted pickup ionbehalf of the Town). .b. Green Island - thedestination facility for yardwaste collected by theVillage should beidentified along with clarification astowhy metals arenot included in thecurbside collectionprogram. .c. Guilderland - thedescription of theTown's programs related to yardwastewhere it isindicated that leaves, grass, trees andbrush collected by theTownis transported tothetransfer station and"turned intomulch" needs clarification as totheprocess employed at thetransfer station forprocessing this material and its regulatory status. More information needstobeprovided about thestatement "When possible asphalt is recycled and reused!' Such ashow, when, whereand inwhat quantities. Additionally, themethod of collection of yardwaste in theTown should beclarified (e.g., municipal c.ollectionor contracted pickup ionbehalf of theTown).d. Knox - thediscrepancy between Table 3-1which indicates thereisnoprivate collection in theTown and the text in this section that indicates there is'needs to berectified. It is indicatedthat Town burns yardwastecollected atthe transfer station. Pleaseclarify theTown'scurrent practices for yardwastemanagement atthe transfer station.e. Rensselaer- thedescription of theCity of Rensselaer program is extremely limited andrequired enhancement.

f. Rensselaerville->- thediscrepancy between Table 31which indicates there isnoprivatecollection intheTown andthe text in this section that indicates thereis needs toberectified..It is indicated that Townhas no formal yard wasteprogram and it ismostly managed byresidents ontheir ownproperty. Please clarify theTown's current practices for yard wastemanagement fromcommercial establishments.g. Voorheesville ~Thedescription of theVillages program related to yardwastewhere it isindicated that it is collected.by theVillage and"is transported toseveral different businessesfor use in composting" needs clarification asto thequantities andregulatory status of thebusinesses.h. Watervliet - clarification asto whymetals arenot included inthe single streamcurbsidecollection program should beprovided.i. Westerlo - itis indicated that Town burns yardwaste collected atthe transfer station and hasnoyardwaste programas it is mostly managed by residents 'ontheir ownproperty. Pleaseclarify the Town's current practices for yardwastemanagement atthetransfer station andclarify theTown's current practices for yardwastemanagement fromcommercialestablishments.

36. Section3.1.2 - Commercial, Industrial and Institutional (CIl) MSW. includes information on solidwastecollection, recycling anddisposal practices of hospitals, stategovernment andsomeunspecified"large crr waste generators," It does not appear to, and should, specifically include thecollection,recycling, and disposal practices of schools orschool districts, colleges anduniversities, hotels andmotels, multi-unit residences, largeretail establishments suchasshoppingmalls andsupercenters,foodprocessors, and thePort of Albany.37. In section 3.2- C&D Collection andManagement Practices, thetext andcalculations should beadjusted toreflect thecompleteinventory of C&D debris asdiscussed previously andto consistentlycharacterize C&D debris used asADC atthe landfill here and throughout theplan asmaterialslandftlled. .

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38. I t is stated on page 3-11 in section 3.4 - Sol id Waste Management Inventory, that "Achievement ofthe other primary goal of the new LSWMP, to minimize the amount of sol id waste requiring disposal ,may help to extend the useful l i fe of the Eastern Expansion beyond 2016." A discussion as towhether or not an evaluation was performed as to the impact of restricting the amount of out ofplanning unit waste received at the landf il l as a tool to extend the usefu1life of the Eastern Expansionbeyond 2016 and if not, such an evaluation should be performed.

39. The faci li ty discussions in section 3.4 requires updating as wel l as the l ist of faci li ties in Table 3-3 asmuch of that information was dated when received and should be updated with current information.40. A description of the management of animal mortalities in the planning unit such as road kil l , slaughterwaste or other non-farm related animal mortalities or parts should be described,41. Chapter 3 describes the existing solid waste management practices and Chapter 4 describes materialsrecovery and recycling efforts currently underway in the planning unit. In neither chapter. did we finda description of public education efforts promoting the benefits of reuse and recyc1ables recoveryefforts nor did we find a description of the companion enforcement efforts. A discussion of thepublic education and enforcement efforts needs to be included in one of these chapters.Chapter 442. As noted previously, the discussion and calculations of recovery rates in section 4.0 - MaterialsRecovery" Analysis wil l need to be adjusted to ref lect revised and updated' data and calculations.43. Section 4.1.1 - Residential MSW Recycling, should be supplemented with recycling summary tablessimi lar to those provided' in the 2009 LSWMP Modification in Attachment 7 which identi fied al l thematerials recovered by type for the various planning unit municipalities. This information i s essentialin assessing the differences between programs and the basis for the reported tonnages.

. .44. Table 4-3 on page 4-3 presents data f rom 200Sw2008 which was dated at the time of submittal . Thisinformation should be updated to reflect more current information and program performance.Additionally, Table 4-3 contains some information that wil l require adjustment such as some landclearing debris reported as yard waste, some asphalt reported as residential MSW and additions to theMSW disposed l ine to reflect MSW disposed out of planning uni t as wel l as that disposed at TheRapp Road Landf il l .45. Table- 4-4 on page 4-4 presents a residential recyclables materials composition summary that mayalso require adjustment based on previously discussed waste composition issues.46. The discussion on pages 4-5 and 4-6 in section 4.1.2 - '-Commercial Industrial and Institutional MSWRecycling, needs to be adjusted to reflect that the industrial sector is a separate sector that is not partof the MSW stream and is separately addressed in section 4.2.2. Additionally on page4-6, thequantity of waste disposed reported by these generators should also be noted to determine arelative

recovery rate.47. In section 4.2.1 - C&D Recovery, the use and characterization of C&D material used as ADC at thelandf il l should be clarified consistently throughout the plan as materials landf il led. The disposal dataalso needs to be updated to clarify the current generation and management of C&D debris in theplanning unit. . .

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48. In section 43 - Potentially Recoverable Recyclable Materials, in the goals and objectives discussionon page 411 as well previously noted in Section 1.3on page 1-11 and section 6.0 on page 6-1. thelast two goals and objectives should be revised to bemore definitive and affirmative than using thebeginning qualifier "considering".

49. The list of materials in section 4.3 on page 4-12 should also include the additional plastics collectedby some municipalities along with electronics, rechargeable batteries and waste oil. '

50. Table 4-9 on page 4-13 may also need to be adjusted to correspond to any other adjustments made inresponse to previous comments related to waste composition.51. Table 4-10 on page 4-15 will likely require some adjustment to reflect the differences in yard wasterecovery as well as additional footnotes related to assumptions to reflect material collected as part ofthe returnable container act.52. Table 4-11 will need some additional supporting discussion related to the basis for determining theprojected maximum recovery rates for the designated recyclables.53. Adjustments to the discussions and calcu1.ations of current recovery rates on page 4-17 will requireadjustment in response to previous comments and will need to be consistently carried throughout thischapter and LS'WMP.54. With respect to the legal challenge to the bottle bill mentioned 'on page 4-17. there was aCourt Orderissued on October 23, 2009 lifting the injunction on implementation and enforcement of theamendments to the Returnable Container Law pertaining to bottled water products. The text should berevised accordingly. '55. The discussion pages 4-17 and 5-5 related to electronic waste and rechargeable batteries should alsobe adjusted to reflect the passage of product stewardship legislation for those materials.56. In the discussion on page 4-21 regarding the SSOW stream, there is no evaluation or inclusion ofeither non-separated designated paper from the recycling stream that can be easily diverted to theSSOW stream or the paper residues from the designated paper from the recycling stream beinginclude in or directed to the SSOW facility. Both of these streams could increase the amount ofmaterial directed to the SSOW facility.57. The conclusion drawn on page 423 related to asmall marginal increase in recovered quantities ofC&D debris is not based on the greater generation numbers of C&D in the planning unit based on

facility data received by the Department nor the concept of employing maximized C&D recovery atlocal processing facilities. Accordingly, this section needs to be revisited in the revised draft, LSWMP.Chapter 558. The time frames for and the status of or resu1.tsfrom the PAYT study done for theCity of Albany bythe contractor working through EPA notedon.page 53 in Section 5.3,1.1- Volume Based User Feesshould be provided in the revised draft LSWMP.S9. The expiration date for the waste tire management and recycling fee assessed on the sale of new tiresnoted in section 5.3,1.2 onpage 5-5was extended toDecember 31, 2013,

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60. The discussion onpage 5-7 in Section 5.3.1.4- Single StreamRecyc1ables Collection andMRF.requires updating toreflect the single streamfacility in the Port of Albany.61. Thepercentages used in thediscussion related to theDelaware County facility onpage 5-9 in Section5.3.1.6 arenotcorrect andneed tobeadjusted tomoreaccurately represent theperformance of the'facility.62. Thediscussion onpage 5-11 in section 5.3.1.7- SSOW Composting needs enhancement andupdating. Thedatethe Capital Compost facility ceased operation should beincluded in the discussiontoaccurately portray the timeperiod andthedynamics of solidwastemanagement at that time.Additionally, thedetails of theOGS SSOWprogramattheEmpire StatePlaza should be included intherevised draft LSWMP. .63. Thediscussion onpage 5-16 in section 5.3.1.9- Transfer Station, related tostatus ofthe EasternExpansion was out of dateat the time of submittal andrequires adjustment.64. Thediscussion onpage 5~20 in section 5.3.1.10 -Landfill, related to the Colonie Landfill needs to beadjusted to reflect the changes in theoperation of the landfill while the draftLSWMP hasbeenWIderreview by theDepartment. .65. In the discussion related to anaerobic digestion onpage5-25 in section 5.3.2.2 - Biological andChemical Processes, it should benoted that anaerobic digestion has and isbeing used on farms formanure andmixtures of manure and foodwaste.66. Onpage 5-30 in section 5.4 - Institutional Alternatives, theplanning unit member's inter-municipalagreement (IMA) is noted. The IMA 'current at thetimeof submittal expired onDecember 31, 2011.A copy of thenew IMA signed by eachof themember municipalities needs to be included asanAppendix of the revised draft LSWMP.67. Section5.4.1- Expansion of thePlanning Unit, needs tobeupdated toprovide theresults of the

feasibility study for aregional solid wastemanagement authority and any discussions andactivitiesthat have takenplace related toregional cooperation onsolid wastemanagement sincesubmittal ofthedraft LSWMP.68. In the discussion of section 5.5- Alternatives Implementation Scenarios, while thesebasic scenariosareappropriate for evaluation, it should beacknowledged in this section that there arecertainlypossibilities of implementing hybrids of thesebasic scenarios based on anumber of changing or. unfolding factors suchasusefu1life of theEastern Expansion, eventual planning unit andAuthoritymunicipal membership, andthe formation of theAuthority.69. As noted previously, the calculations in sections 5.6.1.2. 5.6.1.4 and 5.6.2use the 10.6#personJdayfromTable 2-8.70. While it is noted in section 5.6.1.4 thereasons forusingthe available construction andoperating costcalculations for anew combustor aspart of section 5.6.1.4, it may beappropriate torevisit those costsin the revised draft LSWMP to determine if costsfor the construction of a similar sized gasificationfacility areavailable for comparison.

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71. The Regional Solid Waste Treatment Facility discussion and analysis in section 5.6.1.4. the Cost_Analysis Sununary of Alternative Implementation Scenarios in section 5.6.1.6 and the Facility SizingAnalysis in section 5.6.2 use the full waste stream for calculation purposes which includes, MSW,C&D debris and non-hazardous industrial waste. While it is somewhat dependent on the solid wastetreatment disposal eventually selected, it is not likely that all types of C&D debris or non-hazardousindustrial waste will be suitable processing through the facility.

72. The discussions in sections 5.6.4 - Time to Implement, and its subsections should be adjusted toreflect the current schedule for implementation.73. The discussion in section 5.6.7 - hnpacts on Neighboring Jurisdictions appear to have impacts on theneighboring jurisdictions whether characterized as direct or indirect. The text should be modifiedaccordingly. -Chapter 674. All components of section 6.1- Elements ofthe Preferred Solid Waste Management Plan, and itssubsections need to provide more specific details and time frames for implementation. These shouldbe enhanced the specific steps for each aspect that will be used as building blocks to achieve theoverall-goals 'and objectives of the LSWMP. Each of these descriptions in these sections should bedirectly related to tasks identified in an enhanced implementation schedule in Figure 6-1.75. This section arid implementation schedule needs to begin with inclusion of all the individualelements identified in the 2009 LSWMP Modification that have yet to be accomplished and realignedin anew schedule. -76. The discussion in the first paragraph of section 6.1.1 - Reduction and Recovery of Materials, are fartoo broad and vague and need to be much more detailed to identify the programs and activities thatwill be carried out for each of these program elements.77. The numerical goals discussed in section 6.1.1 should be a reflection of an enhanced implementationschedule in Figure 6.1. This schedule will incorporate all the implementation steps from all the

various programs identified into amaster schedule. This schedule should be integrally linked withand form the basis of the recovery and disposal rate projections for the planning period. The wastereduction, recovery and disposal reduction goals should be established assuming that the alternativesand tasks outlined in the implementation schedule will be implemented. These goals should be

. updated or revised in each biennial compliance report along with the implementation schedule, asnecessary. As previously noted, to aid in deriving estimates for potential diversion, the Departmenthas developed waste composition tools that can be used to estimate current and projected recyclablesand waste generation and recovery quantities. These tools are found on the Department's website at:http://www.dec.ny.gov/chemica1l65541.html.78. An additional column for MSW generation per capita should be added to Table 6.1on page 6-3.79. On page 6-3 in section 6.1.1- Waste Minimization, it is stated that "The use of backyard compostingfor both yard waste and food waste will be promoted wherever feasible." This program and thequalifier ''wherever feasible" is too vague and does not describe the details of a full backyardcomposting program. The details of the proposed program should be identified and incorporated intothe implementation schedule.

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80. The discussion on page 6-4 related to promotion and how it"can take place" is very passive and ISnot .a formulated program for implementation. The details of theproposed program should be identifiedand Incorporated into the implementation schedule.

81. It is noted on page 6-4 that the planning unit will continue to work with Cornell CooperativeExtension to promote backyard composting. While these efforts are commendable, the specifics onthis work and how it will be achieved (such as will the planning unit fund publications, establishteaching sites, have ateaching site at the County fair etc) needs to be provided in the LSWMP andimplementation schedule.

82. With regard to the "Promote PA YT System Implementation" noted on page 6-4, the contractor studyand the PURC promotion of PAYT are solid first steps and are consistent with the 2009 LSWMPModification. The LSWMP should identify the steps that will build on those the initial steps todevelop specific PAYT strategies and plans for the City of Albany and other planning unit members.Mayor Jennings' Executive Order No. 422-09 established the City of Albany Sustainability Agendawhich includes Recycling and Waste Management Initiative #1- "Investigate potential use of aunit-based pricing system for recycling and household waste". This City of Albany initiative is one ofthose initial steps that can be used by the PURC to inform and educate the other planning unitmember municipalities of progressive solid waste management techniques. An identification of theother areas of the planning unit where PAYT is being implemented should be included in the reviseddraft LSWMP.

83. Specific efforts and plans that will be pursued to advance the concept of waste audits for commercialand institutionai generators as discussed on page 6-4 should be more completely identified andincorporated into the implementation schedule.84. Waste minimization in the C&D debris sector is briefly discussed on page 6-5which broadly touchesupon the concept of policies which favor building deconstruction and recycling. This section shouldbe supplemented with the details of the City of Albany's efforts in this regard outlined in the response

to comment RRR8 on page 6 of the ''Response to Comments" concerning its Ordinance Number68.102.09 (as amended) amending chapters 133 (Building Construction) and 375 (Zoning) in relationtodemolition procedures. Among other things, the ordinance now requires review by the PlanningBoard prior to the issuance permits for building demolition giving consideration to renovation insteadof demolition. Additionally the ordinance requires aminimum of 25 % of C&D debris generatedfrom certain construction, remodeling, or demolition projects to be diverted from disposal to landfillsthrough recycling, reuse or diversion programs. The plans for education of the other planning unitmember municipalities of the City of Albany's efforts and expansion to other member municipalitiesshould be identified in the LSWMP.

85. With respect to reuse initiatives, in response to comment RR7 on page 5 of the 'Response toComments," the information from the 2009 LSWMP Modification should be directly incorporatedinto the LSWMP and the identification of the over 30 companies listed on the website for reusecategories should be identified in the LSWMP.

86. In the discussion in section 6.1.1.2 - Product stewardship, the schedule for adopting supportingresolutions should be identified and incorporated into the implementation schedule. .

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87.,Mayor.Jeti.nlligs' Executive Ord.er,No.422-09 established theCity of Al~aJfYSustainability Agendawhich.includes these-Recycling and-WasteManagement Initiath:~s;. .,' ,..,1. ." of ~ : ~ "\ ;..LInitiative #1- Investigate potential use of aunit-based pricing system for recycling and

. . household waste." . . .. . . .)." ., :., -Initiatjye #2- Increase recycling rates citywidethrough outreach.and education .:(, .J~, Initiative #3;:.- Strengthen enforcement of recycling by residents and institqtioIfii". .Initiative#4-;.Increase access.and expand opportunities for recycling. .Initiative #5- Reduce use of paper and increase recycling in city.offices'. .... t Initiative #6- Increase recycling at commercial facilities and inmulti-family housing.- _ Ipitiative,#7,;-.Pilot-a composting program in cityneighborhoods. .;

. :',:: -', :" . I .e !~... . 'f.' -".("'-fI" . ' ~ Theexpected,efforts~toimple;n.ent-Vleseinitiatives should be integrated ~ntotJ:eLS~ .-implementation.scheduleand tlWplans-for expansion of theseinitiatives.to othermember .municipalities should be identitle!:. . . " '. -,I.' '.:, '. " I- ',' I . ( .'" '." " .','''' . to. I " ., :' .. ~:~ ~. ._..' ~. h"88: Anenhanced discussion of the.hauler permitting program first implem~te?p. .Janl,1~h 2009 "should'bediscussed-more completely.on page 6-6 in ~ect~on6.1).3~Continue toPromoteand ..'...ExpandLocal.Recycling astruc:ture, andthenext stepsin tl:Ie;prowarp.deyelop.m~?ltand :".'.;- -refinementneedto.be identified andincorporated intotheimplementation schedule.', ...

, . - . :.. . . . . . : 1 0 ', ' ,." '. ,,': ' . ," '''J .! t" "'" .

89. There islimited discussion of activities th~thaveoccurred related to expansion of reC;cllii"g~e'ff~rtsn.schools andpublicspaces in,tpe City of Albany. The success.of~es_e efforts and th*,c;urent ~tu:>,should bemore.completelydiscussed. While theseare important.first steps fo~thesep!,ogr~s theynot only Seemlimited in scopewithin theCity of Albanybut also-only identify-the City.of.Albany'sefforts andnot those of theother member municipalities. This section should beenhanced to identify~allcurrent.activities in the-planningunit bust alsotheplans for expansion in themember ...: : municipalities programs: ,'.. ". .' . ~,'.,. c.. j .',- ".. , l !. , . .t ;' _ '. . ~ : '. " '~t, ..~.'90:' The SSQW Task force''Ya a key component of the 20g9.!-tSwMP Modificationyef i~~ece,iv~sonly'." passingJ?enti0!l.in.!he~t LSy&n?.' Thediscussionsandplanning being;donejby thistask force isintegral tothe success ,~successful implementation of ~S~9W pr


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94. Thediscussion related to thedevelopment of theSolidWaste Treatment Facility in section 6.1.2'needs enhancement including aschedule that is coordinated withthe formation of theAuthority withclearly articulated steps for development along withabackupplan andschedule ifmajor milestonesarenotmet. ' , -'~ , I _ ''" I95. Thediscussion in section 6.1.3 - LandDisposal, doesnot addkss thegoal of extending'theuseful lifeof theEastern Expansion beyond 20 1,9..andtliecurrent progress toward that goal, Thediscussionshould be-enhancedto address this concerOpandestablish specific dates andmilestonesforevaluation andreassessment of progress alongwith implementation dates for backup plans toensuretheplanning units disposal needs aremet. '

"-96. Section 6.1.4 - InterimMeasures, needs tobeupdated andrevised to identify thenext steps forboththedevelopmentof the SSOW facilityand thedevelopment of theregional solid wastemanagementauthority currently identified in-thissection.97. Thedetailedsteps for development of theSSOW facility canbe specified as it is tobebuilt in

modular phases regardless of theoutcomeof theeffortsto formaregional solid wastemanagementauthority. Theseshould bedescribed in detail andincorporated into the implementation schedule.98. With respect tothe formation of aregional solid wastemanagement ~uthority, theproposed ne~t stepsand timeframes need to beoutlinedin theLSWMP. Thediscussion should provide,anupdate on thefeasibility study findings and changes tothe surrounding planning units suchas theoperations in theTown of Colonie, thedissolution of theGreater Troy-Area Solid WasteManagement Authorityand ;theefforts of Otsego County to'separate fromMOSA. Thenext steps envisioned inproposing and .developing interest andmembership commitments to thenew authority, proposed public disc~lion 'and involvement, and the steps for theapproval and formation of theauthority by the legislature needto beincluded in theLSWM:Pand implementation schedule. It is important toestablishmilestonesandreassessment points tobeused tomeasure progress andsurrounding infrastructure changes; :99. Asnoted previously, the implementation schedule in Figure6-1needs tobeenhanced toinclude allelements of theLSWMP. This schedule will incorporate all the.implementation steps fromall thevarious programs andwill be integrally linkedwith and formthebasis of therecovery anddisposalrateprojections for theplanning period. '

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Documents

Albany SWMP Comments From DEC 092612