Tennessee landfills approximately 8-9 million tons of solid waste and construction waste a year.  The average “tipping fee” (the cost for a truck to dump it’s load into a landfill) is $35.00 per ton. Collection, hauling, processing, and landfilling averages $110.00 per ton  which equals $1.4  billion dollars spent on waste disposal by our local businesses, citizens and local governments.  BURNT’s goal is to substantially reduce the tons of waste landfilled.

Tennessee is the only state which credits landfilled construction waste as recycled.  Tennessee solid waste numbers are extremely inaccurate–Tennessee claims 50% diversion while the Columbia University and Bio-Cycle Magazine 2010 survey of waste by state found that Tennessee diverted 4.74%–a 45% difference! This huge loop hole is symbolic of Tennessee’s solid waste management. Feel good numbers don’t create a healthy environment. Landfills are particularly problematic in Tennessee where 2/3 of the land is karst terrain (i.e. filled with caves and sinkholes). Many of our landfills are built over this terrain which allows leaks to directly contaminate our ground water.

BURNT’s primary efforts are local officials who are beleaguered by schools, roads, health, and jails.  They do not want another headache.  And, the state of Tennessee does little to reduce landfills.  Laws and regulations are out-molded and loop hole riddled.   “A Summary of Comments” is the Department reaction to public and local government comments.   We maintain these comments are riddled with untruths.

BURNT wrote many letters about the “Waste Reduction Rule” because we know this Rule will govern solid waste in Tennessee for many years.   This Rule creates a skewed market.  There is no competition with cheap landfill rates and a state government that tolerates pollution of groundwater, green house gasses, and undermining businesses, which could use solid waste and construction waste as a raw material.

Public Chapter 0462 was 2007 legislation, which TDEC was quite untruthful at the final hearing that the language on page 3–4 did not mandate the Solid Waste Control Disposal Board to consider specific factors such as costs, benefits, different regions, and distance from markets.

BURNT’s strategy is two pronged. First, demonstrate that recycling and reuse of construction waste can create jobs and business.  Construction waste is 20% of the waste stream.  Second, show that recycling, composting food waste, yard waste, and non-recycled paper can create jobs.  Food waste is 14% of the waste stream, yard waste is 13%, and non-recycled paper is 20%—47% of the 8-9 million tons of waste we landfill.  Presently, Tennessee has 70 Class III construction waste landfills and 32 Class I municipal waste landfills.  67% of the waste is construction or organic food-yard-paper waste. 

Landfills generate 16% of green house gasses.  The landfill industry pushes “methane mining” but this allows a high per cent of methane and other green houses gasses to escape.  This is not an elegant solution.

Keeping the organic food waste, yard waste, and paper out of the landfills prevents damage to the landfills and creates jobs and business and useful product

These solutions are incremental.  The 10 largest counties in Tennessee (out of 96) contain 50% of the population.  By all appearances, it is the ease of local officials and, perhaps,  the near cash nature of the annual $1.4 billion revenue which may influence some decisions on disposal.

A landfill is either an engineered depression in the ground or a reservoir built on top of the ground into which wastes are disposed.  The aim of a landfill, in addition to disposing of waste, is to avoid any water-related connection between the wastes and the surrounding  environment, particularly groundwater.  In 1987 the U.S. Environmental Protection Agency issued a report that stated “eventually all landfills leak”.  A landfill will typically leak in two ways: out the bottom if it is not lined properly or over the top if not covered.  Currently the U.S. has 3,091 active landfills and over 10,000 old municipal landfills.

Every year, the United States generates approximately 230 million tons of waste – about 4.6 pounds per person per day.  Tennessee citizens, businesses and government spend 1.0 billion dollars to landfill 10 million tons of solid waste annually.  The U.S. EPA reports that most of the country’s landfills have been closed for one or both of two reasons: (1) they were full; or (2) they were contaminating groundwater.

Environmental injustice is demonstrated because most landfills are located in economically depressed areas where poor, rural and minority populations live and work. It is estimated that 70% of the solid waste, which is landfilled, could be reused or recycled including food waste (14% of waste), yard waste (13%), and non-recycled paper (20%)

BURNT works to address these problems by providing education and research to elected state officials, Metro Nashville officials, the State Solid Waste Board, and citizens and leaders of cities in Tennessee affected by landfills.  Further, BURNT works to educate citizens, businesses and governments with research on how to manage waste as a raw material for jobs and business.

Metro Nashville’s Solid Waste Policy

Designed to Feed the Landfills

“CURBY” is Metro’s flagship recycling program–diverting 13,000 tons out of a 1 million ton waste stream at a cost of $1 million a year.

Nashville business, citizens, and local governments spend another $140 million a year collecting, processing, transporting, and landfilling waste.  Then, to add insult to obfuscation, Metro solid waste numbers are quite inaccurate. The Metro Regional Solid Waste Board meets once a year to give perfunctory approval to solid waste numbers for the State.

2008 Solid Waste Reduction Task Force    —-extra bold,1st par

The Solid Waste Reduction Tas Force was created following Public Chapter 0462 (year 2007)

[link]Public Chapter 0462. in year 2007    

by the Department (TDEC) to develop a new ‘Waste Reduction Rule’.   The Task Force members knew solid waste.  Many came to meetings and spread out over 2008 and 2009 with books and manuals about ‘Zero Waste’   Basically, the Task Force  was composed of Public Works and solid waste managers from across the state.  These knowledgeable, skilled managers knew that landfills were not the solution.  [findings of the task force stressed waste reduction and recycling—which doomed their findings]

24 out of 24 Task Members were white and 22 out of 24 were men.

BURNT is very grateful that two of our members participated.  We learned there are many fine people working with TDEC.

The Task Force proved to be a failure because TDEC would not accept their conclusion to work toward

waste reduction and recycling.  TDEC determination to landfill waste doomed the initial Rule proposed as a result of the Task Force.  From 2011–2012, TDEC doggedly pushed a new Rule which rehashed existing laws such as crediting landfilled construction waste as recycled, three different ways to count solid waste to ensure every Region achieves the  25%  waste goal, and doing virtually nothing to actually landfill or compost. [new Rule, passed 2012; one page summary of Rule and law]   The Rule passed in 2012

was a blatant violation of Public Chapter 0462  [link above]  which requires that for the Board to

develop a “Waste Reduction Rule” it must consider “incentives”, “disincentives”, “public education”, “costs and benefits of  recycling”, and  “the widely varying circumstances of the different solid waste regions”.   TDEC and the Board simply did not do this.  We worked as well as we could against this rule with multiple letters to officials [share link with MULTIPLE  LETTERS,  3RD PARAG. ;LANDFILLS]  and contesting a hearing in front of the Joint Government Operations Committee on 19 December 2012  [LINK].  

Yet, this was to no avail other than to call attention to TDEC corruption of process and procedures and to make at least some wonder about TDEC rush to landfill.  BURNT sent out 650 e-mails during the last few weeks of this process and one legislative office, apparently received 10–15 e-mails.

Bruce Wood and R. C. Bartlett (the popular BURNT Board member) attended every Task Force meeting.

The clear revelation about TDEC staff came during the first meeting when the knowledgeable Task Force

members particularly wanted to compost food waste to reduce ground water pollution.  “Oh, no” said TDEC staff with a shudder.  these Regulations are under TCA (Tennessee Code Annotated) 68-211-800, et al and landfills are regulated under  TCA 68-211100, et al.  Therefore, ground water pollution and green house gasses are not germane under recycling.   OH, thank you

The Task Force assembled strong research on Tennessee solid waste and private company solutions.

[link—to task force]  The Priority concepts of the Task Force include [link–

•   Task Force Plan for Waste Reduction: Priority Concepts, 2009

TDEC contributed a graphic on where the waste goes [LINK,  •  Where does the Waste Go? Nick Lytle, TDEC]  and ‘Solid Waste History’ in Tennessee–part 1 and Part 2  [link]


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