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| Waste Services Division |
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Plan Comments & Responses
Response to comments received from James P. Shapard, Deputy City Manager, City of Joliet in a letter dated September 17, 2001.
- “On page E-2 of the Executive Summary as much as 2,110,865 tons of waste is projected assuming no recycling. I suggest that assumption cannot be valid when most (certainly the largest) Will County municipalities have active, curbside programs.”
Response - The 2,110,865 tons of waste mentioned on page E-2 refers to the total amount of waste that will be generated during the next 20 years, based on waste generation projections performed for this Plan Update. Some of this waste will be diverted for recycling and the remainder will be disposed.
- “Also on page E-2 the Plan states ‘any transfer stations that are developed in the County must adhere to the County’s landfill contract and provide waste to that facility.’ I do not see how the County’s landfill contract binds the City of Joliet in any way.”
Response - The Solid Waste Planning and Recycling Act (415 ILCS 15/4(a)) states that, “each county with a population of 100,000 or more and each municipality with a population of 1,000,000 or more, and by March 1, 1995, each county with a population of less than 100,000, shall submit to the (Illinois Environmental Protection) Agency an officially adopted plan for the management of municipal waste generated within its boundaries.” Provisions of the County’s landfill contract comprise a major portion of the County’s Solid Waste Management Plan with regards to siting new or expanded pollution control facilities as well as directing waste to the Prairie View Recycling and Disposal Facility.
Secondly, according to an Illinois Attorney General’s opinion (94-006, dated March 24, 1994), counties may “plainly and unambiguously. . . regulate the disposal of waste from any premises within the county.” Therefore, Will County can regulate disposal of waste generated anywhere within the incorporated or unincorporated areas of the County.
Lastly, section 39.2 (viii) of the Illinois Environmental Protection Act (415 ILCS 5/39.2(viii)) states that, “if (any new or expanded) facility is to be located in a county where the county board has adopted a solid waste management plan consistent with the planning requirements of the Local Solid Waste Disposal Act or the Solid Waste Planning and Recycling Act, the facility is consistent with that plan.” Therefore, if a new or expanded pollution control facility (i.e., transfer station, sanitary landfill, incinerator or other disposal facility) is to satisfy the requirements of 39.2(viii) of the Environmental Protection Act, the new or expanded pollution control facility must be consistent with the County’s Solid Waste Management Plan.
- “Page 14, table 2-1, provides population projections through 2020. The chart refers to population in Will County and the ‘remainder of the service area’ and the ‘Prairie View service area.’ It is my understanding that federal legislation prohibits accepting refuse from outside Will County. I may not understand the table.”
Response - The federal legislation in question (Public Law No: 106-65, section 2840) states that, “The land fill established on the real property conveyed under subsection (a) may contain only waste generated in the county in which the landfill is established and waste generated in municipalities located at least in part of that county.” Therefore, all of the waste generated in cities such as Aurora, Naperville and Joliet (for instance) may be disposed of at the Prairie View Recycling and Disposal Facility.
- “On page 16 (table 2-3) the year 2000 waste generation rates for residential customers should probably be listed as pounds per capita rather than pounds per employee.
Response - The recommended change has been made.
- “On page 21, third line (under transfer stations) there is a redundant use of the word ‘only.’ “
Response - The recommended change has been made.
- “On page 28, table 3-1, do goals take into consideration the separation of yard waste from the waste stream?”
Response - The recycling goals mentioned on Table 3-1 do include separation of yard waste.
- “On pages 39 and 40 you address new and/or expansions of existing pollution control facilities. The requirement to negotiate a host agreement with the County would not apply to those facilities located within the limits of municipalities. The siting approval for such facilities would be the City Council or Village Board who would determine consistency with the Solid Waste Management Plan and whether the proposal was consistent with criteria 9 of section 39.2 of the Illinois Environmental Protection Act.”
Response - Will County, the entity responsible for authoring and implementing the County’s Solid Waste Management Plan, is the sole judge as to whether a new and/or expanded pollution control facility is consistent with the Plan. This Plan includes provisions any new and/or expanded pollution control facilities must comply with in order to be consistent with the County Plan. City Councils and/or Village Boards are the siting authorities pursuant to Section 39.2 of the Illinois Environmental Protection Act, but they do not have the authority to determine a new and/or expanded pollution control facility’s consistency with the County’s Solid Waste Management Plan.
Response to comments received from John Marc C. Sianghio, resident of Bolingbrook in a letter dated September 26, 2001.
- “The statistical data update does not show any waste characterization study to show the percentage of biodegradeables in collected waste. The closest information available is described as residential waste or landscape waste included in the generic term of municipal waste.
Response - Waste characterizations with the level of detail mentioned in your question are not required in county solid waste management plans, nor was it determined necessary to further characterize waste.
- “There is no cost data on a per capita basis indicated that can be used by the reader to study and compare with what is economically justifiable or not.”
Response - Will County determined economic justifiability on the basis of tipping fees for each ton of waste requiring disposal. Recently, the Robbins Resource Recovery facility (incinerator) ceased operation, because the cost per ton for disposal (that include costs associated with construction, operation and maintenance of the facility) was not attractive enough to compete with landfill disposal methods in this area. Since there are no other means of disposing municipal waste in northern Illinois, it was not deemed necessary to investigate other means of disposal for comparison beyond those that appeared in the original 1991 Will County Solid Waste Management Plan.
- “There appears to be no clear solution or siting offered on how the solid waste coming from outside the Will County areas will be serviced.”
Response - Will County is responsible for the waste generated within its boundaries. In addition, the service area of the Prairie View Recycling and Disposal Facility includes the remainder of those towns that are located at least partly within Will County (e.g., the Cities of Aurora, Naperville and Joliet). Areas outside of the Prairie View Recycling and Disposal Facility service area must plan for the management of waste generated in those areas.
- “Because the waste generated up to the year 2020 can still be absorbed in the proposed Joliet Army Ammunition plant site, the long term plan seems to consider that the waste management solution search is already sufficiently justifiable.”
Response - Will County has been planning for the management of waste generated within its boundaries for many years. All types of disposal technologies were investigated and it was determined after a lengthy screening process to manage the County’s waste using sanitary landfill technologies.
- “While there is mention of compost education for composting, mulching, vermicomposting or chipping as alternatives to burning and/or disposal for yard waste and specific food waste components, there is really no strong program included to pursue this as one of the best alternative and long term solution both for pollution prevention and control as well as the opportunity to lessen the search for new and future sites.”
Response - As mentioned in the previous response, Will County investigated all types of alternatives to managing municipal waste generated and settled on the landfill disposal option. Since that decision was first made in 1991, there have been no municipal waste composting operations sited, permitted or implemented in the State of Illinois.
- “We wish to recommend the following approaches in the search for long-term solutions:
- The need to establish Material Recovery Facilities and Composting Centers (paraphrased recommendation).
The private sector has already established sufficient recycling and composting capacity to serve the needs of Will County and surrounding communities. What is needed is disposal capacity and we believe we satisfy the disposal need for Will County via the Prairie View Recycling and Disposal Facility.
- Community Composting Centers must be identified and installed (paraphrased recommendation).
Composting operations for landscape waste are sufficient to meet the needs of the County. With regards to remaining organic waste in the waste stream, the infrastructure to compost municipal waste does not exist. The permitting requirements for such facilities are very stringent in Illinois, thus the lack of such facilities statewide.
- Undertake recycling and composting in the old, closed or filled up landfill sites (paraphrased recommendation).
This option is not as simple as you suggest. Closed landfills are subject to stringent post-closure permit requirements. Often these facilities also include gas and leachate collection systems that may or may not be compatible with composting or recycling operations.
- Initiate the education campaign to concentrate on waste segregation of biodegradeables and non-biodegradeables (paraphrased recommendation).”
Response - Since 1991, the County has been involved in education programs encouraging residents and businesses to segregate their recyclables from other waste. In addition, the County has provided many opportunities to segregate and properly manage other waste stream components (i.e., household hazardous waste, tires, books, consumer electronics, etc.). This system has been successful as evidenced by the County’s municipal waste recycling rate. Until disposal costs using sanitary landfills increase to such a degree to make other alternatives viable, the County will continue to promote the most economically efficient and environmentally sound waste management strategies.
OTHER
The Waste Services Division also received a memo from Tyson Warner, Chief Planner with the Planning Division on October 9, 2001 indicating the second five-year update to the Will County Solid Waste Management Plan is supported by the goals and objectives of the Land Resource Management Plan (1990).