Friday, March 26, 2010
LANDFILL CLOSURE
Community Outraged at SCRD Decision
On March 11,2010, the Sunshine Coast Regional District Board shocked the public by voting to close the Pender Harbour Landfill, replacing it with a Transfer Station.
Residents of Area A (Pender Harbour and Egmont) had been told told that the SCRD would hold a referendum or telephone survey so their voice would be the deciding factor in their landfill’s future.
The majority of residents of Area A, and the voice of our Regional Director, Eric Graham, were ignored in this decision.
The SCRD first offered us a referendum if we paid for it at an unprecedentedly high pricetag, to allow us to pay for the entire operating cost of our landfill. Then they backed out of it to order our landfill closed.
Most of the community is outraged at this blatant disregard of democratic process: Director Graham’s resignation has been demanded by former Regional Director John Rees and others. Formal complaints have been made to the SCRD Chair, Donna Shugar, and Municipal Affairs.
The community has declared war on the SCRD, and the war is to save our landfill, our tax dollars and our self-respect as a comminity.
Thursday, March 25, 2010
One More Time: Why A Landfill?
A few people, mostly those who took advantage of low property values near the Pender landfill and a few others who bought water-access only property on Sakinaw Lake but now cheat by sneaking down a forestry access road past the landfill, think the Pender landfill is an eyesore and a nuisance. But the vast majority of Pender Residents see it differently: as an old friend that has served the community well over the years and which we will be poorer without. But it’s not just sentiment. Landfills are a valuable resource. The Ministry of Environment (MoE) “grandfathers” established sites like ours but harsh new restrictions make it prohibitive to start new ones. Powell River tried this recently but found it cheaper to truck its waste to Cache Creek at a cost of $160 a ton. At this price, the Pender landfill is worth $228,000 a year and $3.65 million over the next 20 years. This is the value of the resource the SCRD wants to throw away.
As long as we have our own landfill, we can chart our own course that is independent from that of the SCRD. This is valuable for two reasons. The SCRD’s waste function is launched on a breakneck spending binge. Its regional waste tax grew at the rate of 100% a year between 2005 and 2009. Its spending at our landfill doubled since 2007
The SCRD spends more money weighing our garbage than it does disposing of it (this is no reflection on our wonderful landfill staff who receive little of the money.) The actual landfilling activity it claims is too expensive represents only about one-fifth of the $500,000 the SCRD spends “managing” the Pender landfill. But spending at the Pender landfill is nothing compared to spending planned at the Sechelt site. One item alone, a new cover system aimed at reducing its chronic leachate problem, will cost $8 million. The SCRD wants as many paying passengers as it can get this on runaway freight train of overspending, but it is not in Area A’s interests to be aboard.
As long as we keep our own landfill, we keep open the option of leaving the SCRD waste function should we form our own municipality. Then we could rid ourselves of the staggering SCRD management costs and run a tight little community operation that would do a far better job. If we lose our landfill, we will be forever tied to a bloated SCRD waste empire that will prove a backbreaking burden on local finances.
A fate worth fighting to avoid!
As long as we have our own landfill, we can chart our own course that is independent from that of the SCRD. This is valuable for two reasons. The SCRD’s waste function is launched on a breakneck spending binge. Its regional waste tax grew at the rate of 100% a year between 2005 and 2009. Its spending at our landfill doubled since 2007
The SCRD spends more money weighing our garbage than it does disposing of it (this is no reflection on our wonderful landfill staff who receive little of the money.) The actual landfilling activity it claims is too expensive represents only about one-fifth of the $500,000 the SCRD spends “managing” the Pender landfill. But spending at the Pender landfill is nothing compared to spending planned at the Sechelt site. One item alone, a new cover system aimed at reducing its chronic leachate problem, will cost $8 million. The SCRD wants as many paying passengers as it can get this on runaway freight train of overspending, but it is not in Area A’s interests to be aboard.
As long as we keep our own landfill, we keep open the option of leaving the SCRD waste function should we form our own municipality. Then we could rid ourselves of the staggering SCRD management costs and run a tight little community operation that would do a far better job. If we lose our landfill, we will be forever tied to a bloated SCRD waste empire that will prove a backbreaking burden on local finances.
A fate worth fighting to avoid!
Thursday, March 11, 2010
RESPONSE TO STAFF COMMENTS ON H. WHITE SUBMISSION OF FEB. 11
By Howard White, Save the Landfill Committee
I would like to respond to the SCRD staff report “Pender Harbour Landfill –Response to Howard White’s Presentation to February 11, 2010 Infrastructure Services Committee” from Dion Whyte, Manager of Sustainable Services (The Report). The Report presented its comments as “clarification” but it contained more partisan argument than clarification and in any case did not succeed in refuting my main points. After reviewing both positions, I feel most objective observers would agree that case for the transfer station being the lower-cost option is based on a flawed accounting assumption no auditor would accept; that the transfer station option is not compatible with expedited waste stream reduction; and that greenhouse gas reduction would be adequately addressed through intensive recycling in combination with an active landfill at Pender. My full response follows:
Summary:
1. Area A is being unfairly treated by having the landfill function looked at in isolation from other functions where it makes a surplus contribution.
2. The Report shows the main cause of high costs at the PLF is increased spending on non-landfilling cost by the SCRD, which is already $185,000 above what SHA consultants forecast it would be fifteen years from now.
3. The Report confirms my assertion that the amount saved by closing the Pender landfill (PLF) would be small at best, representing some 15% of the present landfill cost and would not eliminate the deficit at the PLF.
4. The transfer station option is made to appear cheaper only by assuming that landfilling Area A waste at the Sechelt landfill (SLF) will not cost as much as it costs to landfill waste from all other areas there. The Report fails to resolve the logical flaw in this approach.
5. The Report fails to refute my contention that the transfer station option will impact closure fees at SLF, negating much of the anticipated $78,000-per-year saving.
6. The Report response does not adequately answer my point that transferring Pender waste would result in consumption of space at SLF that has been expensive to create, will be even more costly to replace, and must be counted as part of the cost of the transfer station option.
7. The Report errs in suggesting environmental impacts would nothave to be managed at the Pender landfill if it were closed.
8. The Report’s response to my argument that a transfer station is incompatible with zero waste objectives does not stand up.
9. The Report does not refute my position that resources would be better spent on improved waste stream diversion in Pender than on bulk trucking to Sechelt with all its attendant environmental and social issues.
10. Data used in my submission was drawn from SCRD publications except in one or two cases where there was no SCRD data available and most of my alleged errors are due to variances in SCRD data or differences in interpretation.
Full Response:
1. Funding: In my submission I stated combined Area A taxes and user fees ought to cover operating expenses at the Pender landfill (PLF), and if not, residents had expressed a willingness to pay more taxes if “convinced more is necessary.” The Report replied that this is “a question answered by looking at all services and not just one.” We agree. If the SCRD is going to make an issue of one function where Area A has an alleged funding shortfall, then it is only fair to look at other functions where it makes surplus contributions and either refund them or apply them to the function in shortfall.
2. I questioned whether there is a shortfall even at the Pender landfill, since landfill tipping fees and taxation total some $400,000, “and that more than covers the latest landfill operating costs we have seen.” The operating expenses I was referring to were those used in the Sperling Hansen report, $256,838 per year, which Sperling Hansen Associates (SHA) described as based on “actual 2007 spending.” (SHA 2.5.4.) In its response to my submission, The Report made the disturbing revelation that the operating cost of the landfill has already risen to $503,000 ($463 less closure allowance). This does indeed change the financial picture, and is a shocking development in itself. How can Pender landfill costs have risen 80% in three years? Certainly it can’t be blamed on the active landfill, because landfilling costs have remained stable at $110,000. This explosion of spending makes a mockery of the SCRD’s attempts to lower costs at Pender by closing the landfill, which by The Report’s admission would only eliminate $78,000 and still leave a “deficit” of some $150,000.
3. The Report agrees that, even using SHA figures, closing the landfill would save less than $80,000, but argues that is no small saving, and projects it over 16 years to make it seem larger. It is difficult to accept The Report’s claim that $78,000 is such a bank-breaking sum when the SCRD has overseen a $200,000 explosion in annual expenditures just to carry on normal activities at the landfill. If money must be saved, the SCRD should look to its own runaway spending.
4. In my paper I point out that the alleged saving in trucking Pender waste to Sechelt is based not on solid numbers, but on a very dubious assumption. The assumption is that while it costs $60 dollars a tonne to landfill Sechelt, Roberts Creek, Gibsons and Landale garbage at the Sechelt lanfdfill (SLF), it will only cost $15 a tonne to landfill Pender garbage there. The Report attempts to justify this by explaining that the contractor is not paid on a per unit basis and is required to handle whatever volume occurs at the same cost. Having been an SCRD landfill contractor for many years, I do not agree with this. When base volume increased and my fuel consumption and machine wear increased, I raised my contract price at the first opportunity, and the SCRD accepted the increase as justified. It is simply not sound cost estimating to assume that The SCRD can make its Sechelt contractor do 10-15% more work and not pay 10-15% more money, sooner or later. Even if that didn’t happen, to give Area A a special reduced rate for using the SLF “would be both inappropriate and illegal,” as The Report itself says about cost allocations for different shared function. Joint function costs must allocated equitably among all participating areas according to their participation rate and that is the also way they must be described for estimating purposes. If that is done, the true annual cost of the transfer station is revealed as being approximately $80,000 higher, eliminating the paper saving of $78,000.
5. In my presentation I maintained that SCRD estimates bias the result in favour of the transfer station by including closure costs for the PLF but not the SLF. The Report argues that the one-sided approach is proper, saying users of the Sechelt landfill (SLF) would have to pay for closure anyway. This is wrong in three ways. First, if Area A becomes a client of the SLF, it becomes liable for all costs of the SLF including closure costs according to its participation rate as shown above. Second, The Report is in error to say no increase in the closure cost allowance would be required should Area A waste be diverted to the SLF. If Area A waste is added, the closure cost allowance must be increased in order to generate the closure cost in a shorter time. This increase must be added to the transfer station annual cost if comparison is to be valid. Given the recently increased closure costs being experienced at the SLF and the radically reduced amortization period, the closure allowance will be much higher than the previous $55,000 per year. There is a further addition to closure costs that The Report acknowledges but does not factor into the transfer station budget. The closure fund for the Pender landfill is currently some $647,065 short of the funds necessary to pay for closure and monitoring. The Report says the board has already decided this money should be paid for from tipping fees at Sechelt, but if so, this must be added as another annual cost of the transfer station. Over16 years, this alone would add some $40,000 per year to the transfer station operating budget, a cost that is hidden at present. In my presentation I state that if closure costs are properly accounted for and landfilling costs are entered for Pender at the same level as for all other areas, “it is the transfer station that ends up costing $70,000 more per year, not the landfill.” In its response The Report says, “it is unclear how the $70,000 figure was arrived at.” This figure is arrived at by adding realistic closure costs and real landfilling costs at SLF and it is actually a conservative estimate that ignores other costs likely to be incurred by the transfer station, such as additional staff to operate proposed new equipment, which could add another $100,000 per year.
6. In my submission I wrote, “Common sense tells us that with the Sechelt landfill incurring capital costs in the many millions and having its lifespan cut to as little as 18 years, there is something wrong with just throwing away good landfill capacity as if it had no value.” It should be clear from these words that I was speaking of the Sechelt landfill and not the Pender landfill, but The Report mistakenly took it to mean that I was referring to the Pender landfill, saying that no space is being thrown away at Pender Harbour because Pender is out of space. This is disingenuous. The Pender landfill is an existing site with up to 60 years filling space left in the lease area according to the SCRD’s consultants (SHA 2.2). The provincial Ministry of Environment (MOE) has indicated that it will entertain an application to expand the site as it has so many times in past, and has stated that the decision is up to the local community. For The Report to suggest that expanding the existing landfill at Pender is “the same now as it would be in future years” is wrong and misleading. If the permit is not renewed, the site will have to be sealed at an expense of $660,540 with an additional $480,525 for monitoring (SHA 3.4.2-3). It is very unlikely that reopening a sealed site would be viewed in the same way as merely extending an active site by the MOE and would be so wasteful it is not credible to suggest it. To return to the point I intended to make about the value of space being given up at the Sechelt landfill, my contention is simply that the SLF has cost the taxpayers of the coast a lot of money, and to use up 2-3 years of its now shortened lifespan with garbage from Area A has a cost that should be accounted for. In its handbook Full Cost Accounting for Municipal Solid Waste (1997), the Environmental Protection Agency recommends that such cost should be accounted for by determining what it will cost to replace it, keeping in mind “that (fixed) costs might increase when older facilities…incur higher replacement due to the cost of new environmental requirements.” As an example of what replacement costs would be, I suggested we look at Powell River, which has recently had to replace its landfill by exporting waste at a cost of $160 per tonne. (Powell River Draft Solid Waste Management Plan, 6.0.) The Report appears to have misunderstood the principle of replacement cost, although it is a standard feature of full cost accounting. It stated that the Powell River experience does not apply to the lower Sunshine Coast because we do not intend to export our garbage. This misses the point that Powell River only exports waste because they find it more economical than creating a new landfill. The Report says the SCRD has already made plans to start a new landfill when the SLF runs out, and it depicts this as such a cheap and easy process that the costs would be “dwarfed” by the cost of extending the landfill at Pender Harbour (which would only be $155,000). To see how wrong it is the SCRD need look no further than the report of its own consultants, Sperling Hansen Associates, who state, “Siting a new landfill is a difficult process that many Regional Districts throughout BC have struggled with over recent years. It is a challenging process as a new site requires adequate buffer zones from sensitive environmental areas, such as creeks and streams [like Chapman Creek], must be geologically sound, and must not impact local groundwater or local communities. It is SHA’s belief that an existing landfill is better to be expanded…rather than develop a new site, which will impact an even greater area.” (SHA 2.6) A survey of the literature shows this is a prevailing opinion among waste engineers all over the continent: “Implementing new landfill sites is becoming increasingly difficult from a public and regulatory perspective. For this reason many municipalities and agencies are seeking to implement innovative strategies to manage solid wastes, and return old landfill sites to a productive use.” (Landfilling: Facing The Challenges Of The 21st Century, Malcolm Pirnie, Inc., White Plains, NY) For The Report to assume replacement landfill space is a resource that can be acquired cheaply and easily does not concur with the experience of other areas and does not appear to represent very prudent waste management planning. Given the difficulties described above, the $160 per tonne experienced by Powell River does not seem an unreasonable guide for the cost of replacing current disposal methods, and my estimate that the space used up by Area A waste over the next 20 years might cost $320,000 per year to replace in a new regime does not deserve to be so airily dismissed as The Report does. Its attempt to discredit my contention by quibbling over the amount of landfill waste produced by Area A fails to take account of average long-term tonnage figures for waste production in the Sperling Hansen report (SHA Table 4.1) which estimate Area A landfill tonnage at approximately 2,000 tonnes. The Report comments that my submission “appears to suggest that the SCRD avoid replacement costs at Sechelt Landfill by investing in replacement at Pender Landfill…Why would we expand Pender when it would not meet the needs of the region for more than a few years?” This represents a rather surprising misreading of my submission, which does not even come close to suggesting that Sechelt waste be trucked to Pender Harbour, an idea so absurd I can hardly believe the author seriously thinks that is what I meant. My point is a very obvious one that many casual observers have had no trouble grasping: counting the cost of landfill space at Pender but not at Sechelt as The Report does produces a biased case in favour of the transfer station. If the cost is entered accurately on both sides of the equation, the supposed advantage of trucking waste to Sechelt shifts in favour of keeping the Pender site open.
7. Environmental impacts – The Report admits that the Sechelt landfill has known leachate issues not present at the Pender site, though it still maintains “a single landfill site poses less risk …than two separate landfills covering a larger area and requiring the maintenance of multiple environmental controls.” This statement could give credence to a common misconception that the Pender landfill will somehow vanish if it were closed. In truth, it will be right where it is forever and “the maintenance and monitoring of multiple environmental controls” will be required by the MOE whether it is being used or not. There is a good case to be made that it will be better monitored and controlled if it remains in use, rather than being subject to the “out of sight, out of mind” syndrome like the old Gibsons dump. While The Report makes the case that one centralized landfill site may be more efficient for staff to maintain, it gives no weight to the preference of the local Area A community, which has strongly indicated it would like to maintain a local landfill. Nor does it adequately recognize the environmental impact of trucking waste 40 km over leaving it where it originates. The elimination of unnecessary transportation is now recognized as a primary environmental concern in food distribution, but there is a growing awareness that it applies equally to the waste stream.
8. Resource Recovery – In my submission I wrote “The transfer station option as currently planned continues the status quo at the Pender landfill, which involves landfilling largely unsorted household waste for years to come.” This was taken directly from the consultants’ report (SHA 3.1), which provides facilities only for compacting and trucking mixed raw waste and nothing to support enhanced recycling. Although the PMAC and SWMP committees have made their approval of the transfer station conditional on enhanced resource recovery, staff did not recommend any actual recovery enhancements to the board. The option recommended by staff provides only that the transfer station “be designed to support progressive enhancements” but does not actually propose any. Nor does The Report mention any enhancements in its response to me, merely arguing that when and if the SCRD does get around to enhancing recycling, the transfer station would be more adaptable to it than the landfill. Its reasoning is that the transfer station would provide a better financial incentive for waste stream reduction because trucking costs would be reduced, whereas landfilling costs “would not decline proportionately as the amount of material diverted from the landfill increases.” This is a desperate argument. As a former maintenance contractor at the Pender landfill I find it wrong on every count. It is not true, as The Report asserts, that the landfill operator must be on site every day at Pender. It is only necessary to be there when the containers get full, and that could decline to once a week or less. Nor is it true that it is necessary to bury waste on a daily basis at the Pender landfill since a portable cover is used. As a contractor I based my bid price on the amount of time required to process the daily waste pack and if that were halved, my bid price would be halved also. If the SCRD found the waste stream rapidly declining, it could shift to a more flexible payment system for landfill maintenance, or take over the job itself. The landfill space would not be wasted, it would just last longer. On the other hand, if the SCRD spends $146,000 on a transfer station ($300,000 with compactors) and the waste stream declines markedly, the equipment will sit idle, gathering rust and getting in the way, a waste of the taxpayers’ money. At the same time, the capacity of a transfer station is limited. If a house burned down and several 40-yd containers of fire waste appeared at the site in rapid succession, as sometimes happens, the transfer station would plug up. The scale attendant would have to leave her scale and operate the Bobcat to transfer the heavy loads, leaving the scale unattended, or else tend the scale and keep the trucks waiting. The SCRD would soon find itself forced to enlarge staff, adding further to the cost disadvantage of the transfer station vis-a-vis the landfill. If a surge in dumping caused the waste containers to fill up ahead of schedule, the station would have to close until a container truck could be brought in, which might take hours. With the landfill option, none of these problems would occur. The heavy loads could just be dumped at the active face and left for the contractor to handle, allowing business to continue as usual at the scale. The landfill option is far more adaptable and flexible than the transfer station in addition to avoiding the traffic problems, litter, and energy waste associated with bulk hauling.
9. A centrepiece in the SCRD case for the transfer station has been that greenhouse gas emissions could be reduced 50% by taking advantage of proposed gas controls at the SLF. In my submission I questioned whether the much-delayed LFG project would ever be completed given delays and high cost. The Report stated that it is planned for completion in 2012 and would cost only $1.2 million, not the $12 million quoted by me. This is one of the few numbers I took from a secondary source rather than documents published directly by the SCRD and I must accept The Report’s word on the matter, even though many observers believe the final cost will be much higher. In any case, $1.2 million is still a lot of money on the Sunshine Coast, the amount does not detract from my main point that the best way to reduce landfill gas is to reduce landfilling. I argued that a better way to achieve 50% reduction in greenhouse gases would be to reduce the waste stream by 50% through enhanced recycling at the Pender landfill. In its response The Report agreed that a 50% reduction in the waste stream is consistent with SCRD plans but suggested that landfill gas emissions could always be reduced more by trucking whatever residual waste remained to Sechelt. This becomes an exercise in diminishing returns. At any point it can be argued that money would be better spent on improved waste stream diversion in Pender than on bulk trucking to Sechelt with all its attendant environmental and social issues.
On balance The Report fails to refute my main contentions that closing the Pender landfill would neither save money nor serve the environment as well as an expanded landfill combined with an accelerated Zero Waste program. Unless better arguments can be found than The Report contains, it must be admitted that the benefits ascribed to the transfer station option are at the very least uncertain. That being the case, the decision should be made on the basis of the one thing that can be determined with certainty, and that is what the users of the service want. The board has already done one survey that showed residents favoured landfill expansion by the very certain margin of 83%. This result has been called into doubt by people who claim opinions have changed. There is a very simple solution to this question and that is to do a second survey. There is no need for a full-dress legal referendum costing thousands because there is no legal decision before the public .The purpose of measuring opinion in this case is only for the guidance of the board in making its decision. Even if a second mail-out survey confirmed the first one, the question would be answered. If a more sophisticated instrument such as a professional phone survey were used, so much the better. Our offer to help pay for it still stands. Our own canvassing give us complete confidence that the transfer station option is still opposed by a margin of more than 2-to-1 so we are confident any polling method will produce a result decisive enough to put the question to rest.. If it did not, the question would also be answered. If it were indecisive, the board could make its own decision with a clear conscience. We strongly urge you to do a competent, credible survey in the $5,000-7,000 cost range, abide by the result, and get on with the business of the people!
A Note on Data: The Report faults my presentation for having incorrect data in several areas. With few exceptions I took all data from SCRD publications, and many of the discrepancies referred to arise from discrepancies in the publications themselves. For instance Sperling Hansen Associates (SHA, Table 4.1) estimates the operating cost of the landfill for 2010 at $264,000, while The Report puts it at $499,000. The Sperling Hansen report makes no provision for enhanced recycling at the transfer station, but The Report contradicts this. The Report says I am incorrect for estimating Pender landfill tonnage at 2,000 tonnes because current tonnage is only 1,424. Sperling Hansen estimates the average tonnage over the whole study period at approximately 2,000 tonnes. I estimated the cost of the Sechelt LFG conversion project at $12 million but The Report puts it at $1.2 million. This is one of the very few numbers I took from a source other than the SCRD, mainly because SCRD information on the LFG project is very hard to find, and I now realize it is much too high and apologize for it. However many knowledgeable observers believe the $1.2 million figure is also incorrect, and that the final cost will be much higher. Time will tell. The Report also contains several errors in addition to those listed above, one of them being that the Pender leachate control system only cost $25,000. The actual cost was many times higher.
By Howard White, Save the Landfill Committee
I would like to respond to the SCRD staff report “Pender Harbour Landfill –Response to Howard White’s Presentation to February 11, 2010 Infrastructure Services Committee” from Dion Whyte, Manager of Sustainable Services (The Report). The Report presented its comments as “clarification” but it contained more partisan argument than clarification and in any case did not succeed in refuting my main points. After reviewing both positions, I feel most objective observers would agree that case for the transfer station being the lower-cost option is based on a flawed accounting assumption no auditor would accept; that the transfer station option is not compatible with expedited waste stream reduction; and that greenhouse gas reduction would be adequately addressed through intensive recycling in combination with an active landfill at Pender. My full response follows:
Summary:
1. Area A is being unfairly treated by having the landfill function looked at in isolation from other functions where it makes a surplus contribution.
2. The Report shows the main cause of high costs at the PLF is increased spending on non-landfilling cost by the SCRD, which is already $185,000 above what SHA consultants forecast it would be fifteen years from now.
3. The Report confirms my assertion that the amount saved by closing the Pender landfill (PLF) would be small at best, representing some 15% of the present landfill cost and would not eliminate the deficit at the PLF.
4. The transfer station option is made to appear cheaper only by assuming that landfilling Area A waste at the Sechelt landfill (SLF) will not cost as much as it costs to landfill waste from all other areas there. The Report fails to resolve the logical flaw in this approach.
5. The Report fails to refute my contention that the transfer station option will impact closure fees at SLF, negating much of the anticipated $78,000-per-year saving.
6. The Report response does not adequately answer my point that transferring Pender waste would result in consumption of space at SLF that has been expensive to create, will be even more costly to replace, and must be counted as part of the cost of the transfer station option.
7. The Report errs in suggesting environmental impacts would nothave to be managed at the Pender landfill if it were closed.
8. The Report’s response to my argument that a transfer station is incompatible with zero waste objectives does not stand up.
9. The Report does not refute my position that resources would be better spent on improved waste stream diversion in Pender than on bulk trucking to Sechelt with all its attendant environmental and social issues.
10. Data used in my submission was drawn from SCRD publications except in one or two cases where there was no SCRD data available and most of my alleged errors are due to variances in SCRD data or differences in interpretation.
Full Response:
1. Funding: In my submission I stated combined Area A taxes and user fees ought to cover operating expenses at the Pender landfill (PLF), and if not, residents had expressed a willingness to pay more taxes if “convinced more is necessary.” The Report replied that this is “a question answered by looking at all services and not just one.” We agree. If the SCRD is going to make an issue of one function where Area A has an alleged funding shortfall, then it is only fair to look at other functions where it makes surplus contributions and either refund them or apply them to the function in shortfall.
2. I questioned whether there is a shortfall even at the Pender landfill, since landfill tipping fees and taxation total some $400,000, “and that more than covers the latest landfill operating costs we have seen.” The operating expenses I was referring to were those used in the Sperling Hansen report, $256,838 per year, which Sperling Hansen Associates (SHA) described as based on “actual 2007 spending.” (SHA 2.5.4.) In its response to my submission, The Report made the disturbing revelation that the operating cost of the landfill has already risen to $503,000 ($463 less closure allowance). This does indeed change the financial picture, and is a shocking development in itself. How can Pender landfill costs have risen 80% in three years? Certainly it can’t be blamed on the active landfill, because landfilling costs have remained stable at $110,000. This explosion of spending makes a mockery of the SCRD’s attempts to lower costs at Pender by closing the landfill, which by The Report’s admission would only eliminate $78,000 and still leave a “deficit” of some $150,000.
3. The Report agrees that, even using SHA figures, closing the landfill would save less than $80,000, but argues that is no small saving, and projects it over 16 years to make it seem larger. It is difficult to accept The Report’s claim that $78,000 is such a bank-breaking sum when the SCRD has overseen a $200,000 explosion in annual expenditures just to carry on normal activities at the landfill. If money must be saved, the SCRD should look to its own runaway spending.
4. In my paper I point out that the alleged saving in trucking Pender waste to Sechelt is based not on solid numbers, but on a very dubious assumption. The assumption is that while it costs $60 dollars a tonne to landfill Sechelt, Roberts Creek, Gibsons and Landale garbage at the Sechelt lanfdfill (SLF), it will only cost $15 a tonne to landfill Pender garbage there. The Report attempts to justify this by explaining that the contractor is not paid on a per unit basis and is required to handle whatever volume occurs at the same cost. Having been an SCRD landfill contractor for many years, I do not agree with this. When base volume increased and my fuel consumption and machine wear increased, I raised my contract price at the first opportunity, and the SCRD accepted the increase as justified. It is simply not sound cost estimating to assume that The SCRD can make its Sechelt contractor do 10-15% more work and not pay 10-15% more money, sooner or later. Even if that didn’t happen, to give Area A a special reduced rate for using the SLF “would be both inappropriate and illegal,” as The Report itself says about cost allocations for different shared function. Joint function costs must allocated equitably among all participating areas according to their participation rate and that is the also way they must be described for estimating purposes. If that is done, the true annual cost of the transfer station is revealed as being approximately $80,000 higher, eliminating the paper saving of $78,000.
5. In my presentation I maintained that SCRD estimates bias the result in favour of the transfer station by including closure costs for the PLF but not the SLF. The Report argues that the one-sided approach is proper, saying users of the Sechelt landfill (SLF) would have to pay for closure anyway. This is wrong in three ways. First, if Area A becomes a client of the SLF, it becomes liable for all costs of the SLF including closure costs according to its participation rate as shown above. Second, The Report is in error to say no increase in the closure cost allowance would be required should Area A waste be diverted to the SLF. If Area A waste is added, the closure cost allowance must be increased in order to generate the closure cost in a shorter time. This increase must be added to the transfer station annual cost if comparison is to be valid. Given the recently increased closure costs being experienced at the SLF and the radically reduced amortization period, the closure allowance will be much higher than the previous $55,000 per year. There is a further addition to closure costs that The Report acknowledges but does not factor into the transfer station budget. The closure fund for the Pender landfill is currently some $647,065 short of the funds necessary to pay for closure and monitoring. The Report says the board has already decided this money should be paid for from tipping fees at Sechelt, but if so, this must be added as another annual cost of the transfer station. Over16 years, this alone would add some $40,000 per year to the transfer station operating budget, a cost that is hidden at present. In my presentation I state that if closure costs are properly accounted for and landfilling costs are entered for Pender at the same level as for all other areas, “it is the transfer station that ends up costing $70,000 more per year, not the landfill.” In its response The Report says, “it is unclear how the $70,000 figure was arrived at.” This figure is arrived at by adding realistic closure costs and real landfilling costs at SLF and it is actually a conservative estimate that ignores other costs likely to be incurred by the transfer station, such as additional staff to operate proposed new equipment, which could add another $100,000 per year.
6. In my submission I wrote, “Common sense tells us that with the Sechelt landfill incurring capital costs in the many millions and having its lifespan cut to as little as 18 years, there is something wrong with just throwing away good landfill capacity as if it had no value.” It should be clear from these words that I was speaking of the Sechelt landfill and not the Pender landfill, but The Report mistakenly took it to mean that I was referring to the Pender landfill, saying that no space is being thrown away at Pender Harbour because Pender is out of space. This is disingenuous. The Pender landfill is an existing site with up to 60 years filling space left in the lease area according to the SCRD’s consultants (SHA 2.2). The provincial Ministry of Environment (MOE) has indicated that it will entertain an application to expand the site as it has so many times in past, and has stated that the decision is up to the local community. For The Report to suggest that expanding the existing landfill at Pender is “the same now as it would be in future years” is wrong and misleading. If the permit is not renewed, the site will have to be sealed at an expense of $660,540 with an additional $480,525 for monitoring (SHA 3.4.2-3). It is very unlikely that reopening a sealed site would be viewed in the same way as merely extending an active site by the MOE and would be so wasteful it is not credible to suggest it. To return to the point I intended to make about the value of space being given up at the Sechelt landfill, my contention is simply that the SLF has cost the taxpayers of the coast a lot of money, and to use up 2-3 years of its now shortened lifespan with garbage from Area A has a cost that should be accounted for. In its handbook Full Cost Accounting for Municipal Solid Waste (1997), the Environmental Protection Agency recommends that such cost should be accounted for by determining what it will cost to replace it, keeping in mind “that (fixed) costs might increase when older facilities…incur higher replacement due to the cost of new environmental requirements.” As an example of what replacement costs would be, I suggested we look at Powell River, which has recently had to replace its landfill by exporting waste at a cost of $160 per tonne. (Powell River Draft Solid Waste Management Plan, 6.0.) The Report appears to have misunderstood the principle of replacement cost, although it is a standard feature of full cost accounting. It stated that the Powell River experience does not apply to the lower Sunshine Coast because we do not intend to export our garbage. This misses the point that Powell River only exports waste because they find it more economical than creating a new landfill. The Report says the SCRD has already made plans to start a new landfill when the SLF runs out, and it depicts this as such a cheap and easy process that the costs would be “dwarfed” by the cost of extending the landfill at Pender Harbour (which would only be $155,000). To see how wrong it is the SCRD need look no further than the report of its own consultants, Sperling Hansen Associates, who state, “Siting a new landfill is a difficult process that many Regional Districts throughout BC have struggled with over recent years. It is a challenging process as a new site requires adequate buffer zones from sensitive environmental areas, such as creeks and streams [like Chapman Creek], must be geologically sound, and must not impact local groundwater or local communities. It is SHA’s belief that an existing landfill is better to be expanded…rather than develop a new site, which will impact an even greater area.” (SHA 2.6) A survey of the literature shows this is a prevailing opinion among waste engineers all over the continent: “Implementing new landfill sites is becoming increasingly difficult from a public and regulatory perspective. For this reason many municipalities and agencies are seeking to implement innovative strategies to manage solid wastes, and return old landfill sites to a productive use.” (Landfilling: Facing The Challenges Of The 21st Century, Malcolm Pirnie, Inc., White Plains, NY) For The Report to assume replacement landfill space is a resource that can be acquired cheaply and easily does not concur with the experience of other areas and does not appear to represent very prudent waste management planning. Given the difficulties described above, the $160 per tonne experienced by Powell River does not seem an unreasonable guide for the cost of replacing current disposal methods, and my estimate that the space used up by Area A waste over the next 20 years might cost $320,000 per year to replace in a new regime does not deserve to be so airily dismissed as The Report does. Its attempt to discredit my contention by quibbling over the amount of landfill waste produced by Area A fails to take account of average long-term tonnage figures for waste production in the Sperling Hansen report (SHA Table 4.1) which estimate Area A landfill tonnage at approximately 2,000 tonnes. The Report comments that my submission “appears to suggest that the SCRD avoid replacement costs at Sechelt Landfill by investing in replacement at Pender Landfill…Why would we expand Pender when it would not meet the needs of the region for more than a few years?” This represents a rather surprising misreading of my submission, which does not even come close to suggesting that Sechelt waste be trucked to Pender Harbour, an idea so absurd I can hardly believe the author seriously thinks that is what I meant. My point is a very obvious one that many casual observers have had no trouble grasping: counting the cost of landfill space at Pender but not at Sechelt as The Report does produces a biased case in favour of the transfer station. If the cost is entered accurately on both sides of the equation, the supposed advantage of trucking waste to Sechelt shifts in favour of keeping the Pender site open.
7. Environmental impacts – The Report admits that the Sechelt landfill has known leachate issues not present at the Pender site, though it still maintains “a single landfill site poses less risk …than two separate landfills covering a larger area and requiring the maintenance of multiple environmental controls.” This statement could give credence to a common misconception that the Pender landfill will somehow vanish if it were closed. In truth, it will be right where it is forever and “the maintenance and monitoring of multiple environmental controls” will be required by the MOE whether it is being used or not. There is a good case to be made that it will be better monitored and controlled if it remains in use, rather than being subject to the “out of sight, out of mind” syndrome like the old Gibsons dump. While The Report makes the case that one centralized landfill site may be more efficient for staff to maintain, it gives no weight to the preference of the local Area A community, which has strongly indicated it would like to maintain a local landfill. Nor does it adequately recognize the environmental impact of trucking waste 40 km over leaving it where it originates. The elimination of unnecessary transportation is now recognized as a primary environmental concern in food distribution, but there is a growing awareness that it applies equally to the waste stream.
8. Resource Recovery – In my submission I wrote “The transfer station option as currently planned continues the status quo at the Pender landfill, which involves landfilling largely unsorted household waste for years to come.” This was taken directly from the consultants’ report (SHA 3.1), which provides facilities only for compacting and trucking mixed raw waste and nothing to support enhanced recycling. Although the PMAC and SWMP committees have made their approval of the transfer station conditional on enhanced resource recovery, staff did not recommend any actual recovery enhancements to the board. The option recommended by staff provides only that the transfer station “be designed to support progressive enhancements” but does not actually propose any. Nor does The Report mention any enhancements in its response to me, merely arguing that when and if the SCRD does get around to enhancing recycling, the transfer station would be more adaptable to it than the landfill. Its reasoning is that the transfer station would provide a better financial incentive for waste stream reduction because trucking costs would be reduced, whereas landfilling costs “would not decline proportionately as the amount of material diverted from the landfill increases.” This is a desperate argument. As a former maintenance contractor at the Pender landfill I find it wrong on every count. It is not true, as The Report asserts, that the landfill operator must be on site every day at Pender. It is only necessary to be there when the containers get full, and that could decline to once a week or less. Nor is it true that it is necessary to bury waste on a daily basis at the Pender landfill since a portable cover is used. As a contractor I based my bid price on the amount of time required to process the daily waste pack and if that were halved, my bid price would be halved also. If the SCRD found the waste stream rapidly declining, it could shift to a more flexible payment system for landfill maintenance, or take over the job itself. The landfill space would not be wasted, it would just last longer. On the other hand, if the SCRD spends $146,000 on a transfer station ($300,000 with compactors) and the waste stream declines markedly, the equipment will sit idle, gathering rust and getting in the way, a waste of the taxpayers’ money. At the same time, the capacity of a transfer station is limited. If a house burned down and several 40-yd containers of fire waste appeared at the site in rapid succession, as sometimes happens, the transfer station would plug up. The scale attendant would have to leave her scale and operate the Bobcat to transfer the heavy loads, leaving the scale unattended, or else tend the scale and keep the trucks waiting. The SCRD would soon find itself forced to enlarge staff, adding further to the cost disadvantage of the transfer station vis-a-vis the landfill. If a surge in dumping caused the waste containers to fill up ahead of schedule, the station would have to close until a container truck could be brought in, which might take hours. With the landfill option, none of these problems would occur. The heavy loads could just be dumped at the active face and left for the contractor to handle, allowing business to continue as usual at the scale. The landfill option is far more adaptable and flexible than the transfer station in addition to avoiding the traffic problems, litter, and energy waste associated with bulk hauling.
9. A centrepiece in the SCRD case for the transfer station has been that greenhouse gas emissions could be reduced 50% by taking advantage of proposed gas controls at the SLF. In my submission I questioned whether the much-delayed LFG project would ever be completed given delays and high cost. The Report stated that it is planned for completion in 2012 and would cost only $1.2 million, not the $12 million quoted by me. This is one of the few numbers I took from a secondary source rather than documents published directly by the SCRD and I must accept The Report’s word on the matter, even though many observers believe the final cost will be much higher. In any case, $1.2 million is still a lot of money on the Sunshine Coast, the amount does not detract from my main point that the best way to reduce landfill gas is to reduce landfilling. I argued that a better way to achieve 50% reduction in greenhouse gases would be to reduce the waste stream by 50% through enhanced recycling at the Pender landfill. In its response The Report agreed that a 50% reduction in the waste stream is consistent with SCRD plans but suggested that landfill gas emissions could always be reduced more by trucking whatever residual waste remained to Sechelt. This becomes an exercise in diminishing returns. At any point it can be argued that money would be better spent on improved waste stream diversion in Pender than on bulk trucking to Sechelt with all its attendant environmental and social issues.
On balance The Report fails to refute my main contentions that closing the Pender landfill would neither save money nor serve the environment as well as an expanded landfill combined with an accelerated Zero Waste program. Unless better arguments can be found than The Report contains, it must be admitted that the benefits ascribed to the transfer station option are at the very least uncertain. That being the case, the decision should be made on the basis of the one thing that can be determined with certainty, and that is what the users of the service want. The board has already done one survey that showed residents favoured landfill expansion by the very certain margin of 83%. This result has been called into doubt by people who claim opinions have changed. There is a very simple solution to this question and that is to do a second survey. There is no need for a full-dress legal referendum costing thousands because there is no legal decision before the public .The purpose of measuring opinion in this case is only for the guidance of the board in making its decision. Even if a second mail-out survey confirmed the first one, the question would be answered. If a more sophisticated instrument such as a professional phone survey were used, so much the better. Our offer to help pay for it still stands. Our own canvassing give us complete confidence that the transfer station option is still opposed by a margin of more than 2-to-1 so we are confident any polling method will produce a result decisive enough to put the question to rest.. If it did not, the question would also be answered. If it were indecisive, the board could make its own decision with a clear conscience. We strongly urge you to do a competent, credible survey in the $5,000-7,000 cost range, abide by the result, and get on with the business of the people!
A Note on Data: The Report faults my presentation for having incorrect data in several areas. With few exceptions I took all data from SCRD publications, and many of the discrepancies referred to arise from discrepancies in the publications themselves. For instance Sperling Hansen Associates (SHA, Table 4.1) estimates the operating cost of the landfill for 2010 at $264,000, while The Report puts it at $499,000. The Sperling Hansen report makes no provision for enhanced recycling at the transfer station, but The Report contradicts this. The Report says I am incorrect for estimating Pender landfill tonnage at 2,000 tonnes because current tonnage is only 1,424. Sperling Hansen estimates the average tonnage over the whole study period at approximately 2,000 tonnes. I estimated the cost of the Sechelt LFG conversion project at $12 million but The Report puts it at $1.2 million. This is one of the very few numbers I took from a source other than the SCRD, mainly because SCRD information on the LFG project is very hard to find, and I now realize it is much too high and apologize for it. However many knowledgeable observers believe the $1.2 million figure is also incorrect, and that the final cost will be much higher. Time will tell. The Report also contains several errors in addition to those listed above, one of them being that the Pender leachate control system only cost $25,000. The actual cost was many times higher.
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