Metropolitan Solid Waste Management Policy Plan, 2022-2042

Minnesota Pollution Control Agency

520 Lafayette Road North | Saint Paul, MN 55155-4194 |

651-296-6300 | 800-657-3864 | Or use your preferred relay service. | Info.pca@state.mn.us

This report is available in alternative formats upon request, and online at www.pca.state.mn.us.

Document number: w-sw7-22

Legislative charge

Minn. Stat. § 473.149 - A metropolitan long range policy plan for solid waste management, prepared by

the Pollution Control Agency, sets goals and policies for the metropolitan solid waste system. This plan

includes goals and policies for solid waste management, including recycling consistent with section

115A.551 and household hazardous waste management consistent with section 115A.96, subdivision 6.

The MPCA shall include specific and quantifiable metropolitan objectives for abating, to the greatest

feasible and prudent extent, the need for and practice of land disposal of mixed municipal solid waste

and specific components of the solid waste stream.

Authors

Alison Cameron

Cathy Latham

Barbara Monaco

Peder Sandhei

Contributors/acknowledgements

Annika Bergen

Amanda Cotton

Tim Farnan

John Gilkeson

Wayne Gjerde

Susan Heffron

Colleen Hetzel

Greg Kvaal

Sherri Nachtigal

Cliff Shierk

Jennifer Volkman

Kayla Walsh

Melissa Wenzel

Maggie Yauk

Editing and graphic design

Scott Andre

Kevin Gaffney

Jennifer Holstad

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

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Acronyms and initialisms

CII commercial, industrial, institutional

CON Certificate of Need

CSWMP County Solid Waste Management Plans

Demolition debris construction and demolition debris

EJ Environmental Justice

EPA U.S. Environmental Protection Agency

EPD Environmental Product Declaration

EPR Extended Producer Responsibility

GHGs Greenhouse gases

GHGe Greenhouse gas emissions

HERC Hennepin Energy Recovery Center

HHW household hazardous waste

ISW industrial solid waste

LRDG Local Recycling Development Grants

MLAA Metropolitan Landfill Abatement Account

MMSW mixed municipal solid waste

MN USGBC Minnesota U.S. Green Building Council

MPP Metro Policy Plan

MSW municipal solid waste

MnDOT Minnesota Department of Transportation

MPCA Minnesota Pollution Control Agency

MRF materials recovery facility

PFAS Per- and polyfluoroalkyl substances

PUC Minnesota Public Utilities Commission

RDF refuse derived fuel

RMD recycling market development

ROD restriction on disposal

SMM Sustainable Materials Management

SSO source separated organics

TCMA Twin Cities Metropolitan Area

WARM waste reduction model

WMA Waste Management Act

WTE waste-to-energy

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Contents

Acronyms and initialisms ................................................................... i

Figures .............................................................................................. iii

Tables ............................................................................................... iv

Part one: Introduction and background ..............................................1

Part two: Framework for change .......................................................6

Part three: MPP 2022-2042 .............................................................. 10

Appendix A: Overview of the current Twin Cities Metropolitan Area

solid waste management system ...................................................... 53

Appendix B: Environmental justice review ........................................ 62

Appendix C: Predrafting notice ......................................................... 66

Appendix D: Procedures, standards, and criteria .............................. 69

Appendix E: Glossary ........................................................................ 85

Appendix F: Metro Policy Plan MMSW forecast ................................ 91

Appendix G: Strategy table ............................................................... 95

Appendix H: Air Toxic and Cumulative Impact Rules ......................... 98

Appendix I: Public Comments and Responses ................................. 100

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Figures

Figure 1. TCMA County map ......................................................................................................................... 2

Figure 2. Minnesota’s solid waste management hierarchy of preferred methods ...................................... 6

Figure 3. Total MSW Generation Forecast with the 15% source reduction objective ............................... 11

Figure 4. Non-MSW and Ash Forecast ........................................................................................................ 12

Figure 5. LCA: a methodology for modeling the environmental impacts of a material or product

from raw material extraction through end-of-life management ............................................................... 13

Figure 6. TCMA MMSW management methods: past, present, and projection (SCORE and

Certification Reports) .................................................................................................................................. 17

Figure 7. Carbon emissions impact of different management types.......................................................... 20

Figure 8. Personal consumption expenditures ........................................................................................... 26

Figure 9. Projected county infestation impact in Minnesota due to EAB ................................................... 38

Figure 10. Total GHG generated by landfill and WTE from start of disposal through closure and

beyond ........................................................................................................................................................ 44

Figure 11. Municipal Solid Waste: Landfill vs. WTE .................................................................................... 45

Figure 12. Sustainable Building SMM Guidance from most to least preferred management

methods ..................................................................................................................................................... 50

Figure 13. EPA Wasted Food Scale preferred management methods ....................................................... 56

Figure 14. Map of solid waste facilities and EJ boundaries located within the TCMA ............................... 63

Figure 15. Map of solid waste facilities and EJ boundaries located within Minneapolis and

Saint Paul .................................................................................................................................................... 64

Figure 16. Reported and forecasted TCMA MMSW collection methods amounts in tons ........................ 93

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Tables

Table 1. Waste reduction system objectives in percentages and tons (2021-2042) .................................. 15

Table 2. MMSW management system objectives in percentages (2021-2042) ......................................... 16

Table 3. MMSW management system tonnages (Based on objectives in Table 2 in thousands of tons

[2010-2030]) ............................................................................................................................................... 16

Table 4. Monthly cost of residential MMSW service in the Richfield before and after organized

collection ..................................................................................................................................................... 33

Table 5. Existing resource recovery facility capacity serving the TCMA ..................................................... 46

Table 6. 2021 disposal in facilities that accept TCMA waste ...................................................................... 49

Table 7. Organics obligation by county for FY2020-2023 ........................................................................... 58

Table 8. Organics recovered in 2021 (in tons) (data from the 2021 SCORE report) ................................... 58

Table 9. Existing resource recovery facility capacity serving the TCMA ..................................................... 59

Table 10. Landfill locations accepting TCMA waste .................................................................................... 60

Table 11. Non-MMSW landfills accepting TCMA demolition debris .......................................................... 61

Table 12. Annual capacity (in tons) for the WTE facilities servicing the TCMA. ......................................... 92

Table 13. Total TCMA MMSW forecast by management method .............................................................. 93

Table 14. Strategy table with point values and interested parties ............................................................. 95

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Part one: Introduction and background

In 1980, the Minnesota Legislature recognized the importance of waste management with the passage

of the Waste Management Act (WMA) in Minn. Stat. § 115A. This statute’s purpose is to protect the

state's natural resources and public health by improving integrated solid waste management. The

statute establishes the following hierarchy of preferred solid waste management practices, in order

from most to least beneficial to the environment:

1. Waste reduction and reuse

2. Waste recycling

3. Composting of source-separated compostable materials, including but not limited to, yard waste

and food waste

4. Resource recovery through mixed municipal solid waste (MMSW) composting or incineration

5. Land disposal which produces no measurable methane gas, or which involves the retrieval of

methane gas as a fuel to produce energy to be used on-site or for sale

6. Land disposal which produces measurable methane, and which does not involve the retrieval of

methane gas as a fuel to produce energy to be used on-site or for sale

The above hierarchy was established to achieve the following goals, as provided in Minn. Stat. §

115A.02(a):

1. Reduction in the amount and toxicity of waste generated

2. Separation and recovery of materials and energy from waste

3. Reduction in indiscriminate dependence on disposal of waste

4. Coordination of solid waste management among political subdivisions

5. Orderly and deliberate development and financial security of waste facilities including disposal

facilities

To avoid confusion as to which types of plans are being discussed, this document will be referred to as

the Metro Policy Plan (MPP); the plans the counties develop will be referred to as County Solid Waste

Management Plans (CSWMP). The language in the statutes, where quoted, is not changed and is

italicized for clarity.

Purpose of this Plan (MPP)

This MPP establishes the framework for managing the Twin Cities Metro Area's (TCMA) solid waste for

the next 20 years (2023-2043). It was prepared in accordance with the requirements of Minn. Stat. §

473.149. It will guide the development and activities of solid waste management and must be followed

by the counties in the TCMA. In addition to the counties, the MPCA, solid waste facilities, haulers,

businesses, and residents all have a role in implementing the MPP. The MPP supports the goals of the

WMA hierarchy, improving public health, reducing the reliance on landfills, conserving energy and

natural resources, and reducing pollution and greenhouse gas emissions (GHGe).

The TCMA includes Anoka, Carver, Dakota, Hennepin, Ramsey, Scott, and Washington counties.

Excluded cities from the TCMA are Northfield, Hanover, Rockford, and New Prague.

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Participants in the process

The MPCA staff held several meetings with stakeholders in advance of the release of the draft MPP.

Several public meetings were also held after the release of the draft MPP to gather input from other

MPP stakeholders, including members of the recycling and waste industry, counties, non-governmental

organizations (NGOs), and members of the public.

Figure 1. TCMA County map

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How the MPP will be used by stakeholders

The MPP will guide all stakeholders in their roles to ensure that waste is managed to the highest and

best use.

The MPP will:

1. Inform waste generators (residents, businesses, public entities) about their roles and responsibilities

in waste management.

2. Educate generators about solid waste issues and services (both public and private) available to

them.

3. Identify and direct state agencies and county governments that provide assistance.

The MPP will outline the responsibility of the waste industry in providing future solid waste facilities and

services. For the purposes of this MPP, the “waste industry” includes all entities, public and private, that

collect and/or manage solid waste in some form, including recyclables, household hazardous waste

(HHW), and problem materials.

The MPP will rely upon organizations that support the reuse industry, including repair organizations and

non-government organizations, such as thrift stores.

The MPP will:

1. Provide guidance to counties and regional governmental entities in developing county solid waste

ordinances, work plans, and budgets.

2. Direct the MPCA oversight responsibilities, including administration of the Metropolitan Landfill

Abatement Account program, CSWMP reviews, and the MPCA’s approval of solid waste facility

permits and landfill certificates of need (CON).

3. Assist the MPCA in its regulatory, enforcement, and technical assistance functions that affect the

TCMA.

4. Contribute to policy discussions regarding solid waste legislation affecting the TCMA.

5. Influence local jurisdictions in the planning and provision of services to residents and businesses.

6. Manage waste in a way that minimizes adverse impacts on the environment including, but not

limited to, GHG reduction, resource conservation, and long-term legacy impacts as a result of land

disposal.

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Current system status

The TCMA solid waste system is the result of planning and

development that began with the 1980 WMA. Since 1980, much

has been accomplished.

• The TCMA recycles 45.2% of the MMSW generated. The

recent improvement is largely due to advances in organics

collection for food to people, food to livestock, source

separated organics (SSO) management, and yard waste

composting.

• Reuse and recycling activities contribute significantly to the

economy of the region.

• Resource recovery facilities that serve the TCMA are now

operating at full capacity.

• Resource recovery facilities manage 28% of the MMSW

generated.

• Land disposal has decreased by 18% since 2008.

• Problem materials such as major appliances, mercury-

containing products, and electronic waste are banned from

the MMSW stream, and infectious wastes are separately

managed.

• A system to collect and manage HHW is available to all

residents, and all seven counties participate in an

arrangement of shared reciprocity.

As a region, we should be proud of the advances we have

made because of the efforts from product producers, waste

generators, waste industry, residents, and government.

What challenges still exist?

The Minnesota solid waste system has faced several challenges over the

past six years. A few large issues have indirectly affected the solid waste

system in a negative way. These have slowed progress toward the

objectives in the previous MPP. To meet our environmental goals, the

following challenges will need to be further addressed.

The COVID-19 pandemic significantly disrupted all systems in Minnesota in 2020 and 2021. Transmission

of the virus among solid waste workers was a safety concern, and outbreaks among staff at materials

recovery facilities (MRFs) resulted in operational shutdowns. MRFs excelled at maintaining operations to

the extent possible. However, requests for disposal allowances were yielded during this time.

The TCMA experienced social unrest following the murder of George Floyd. Some of the large

Minneapolis MRFs shut down temporarily as a precautionary measure. Limited capacity exists in the

region to absorb the material processed at that those facilities. This led to a request to dispose of

recyclable material. Permission was granted for the one-time disposal of 59.7 tons of recyclables, which

represents .000006% of the 1,000,000 tons of recyclables generated in the TCMA in 2020.

These events highlighted the lack of contingency plans the TCMA has for recyclable, reusable, and

compostable materials. Maintaining and developing new end markets will continue to be important for

A new name for this plan

The MPCA expects the fair treatment

and meaningful involvement of

communities of color, Indigenous

communities, and low-income

communities in agency actions and

decisions that affect them. As the

state takes initial steps to

acknowledge its role in systemic

racism, we recognize the power of

language. Current Minnesota statute

refers to the solid waste plans that

metro counties develop as “master”

plans. The term “master”, which is

often defined as commanding

control or being eminently skilled,

has been identified as a word to

remove in certain contexts due to its

connection with the history of

masters and slavery in the United

States. While this statute remains

unchanged as of the release of this

plan, where possible, this plan uses

the name “county solid waste plan”

in place of “county master solid

waste plan”. A noted exception is the

use of “county master plan” in

Appendix D, to remain consistent

with current statute language. An

additional benefit to using the term

"county solid waste plan" is that it

harmonizes the language with the

term used for Greater Minnesota

counties.

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Minnesota’s long-term success. A recent example of this is WestRock’s unexpected closing of its

corrugated cardboard line, resulting in a reduction of 600 tons of daily capacity, creating a major impact

to local MRFs and haulers.

Success creates challenges, too. For example, an increase in organics collection programs throughout

the TCMA point to the need for more planned programs in the coming years. Despite anticipated

increases in feedstock, there is not a corresponding increase in organics processing capacity in the

region. To meet our organics objectives, additional capacity to process organics will be necessary.

Minnesota’s changing climate is creating stresses for the solid waste system, as severe weather events

increase in frequency. Structural damage from flooding, tornados, and strong hail-producing

thunderstorms generates large amounts of solid waste. Downed trees put pressure on the yard waste

and composting facilities. The rise of EAB and other tree diseases compounds this issue as trees in

Minnesota are dying at an increasing rate. The wood from the trees affected by EAB cannot be

transported out of quarantine zones, leaving local entities to handle large volumes of wood waste

without perpetuating the spread of the EAB. The TCMA will need to identify ways to manage the

onslaught of wood waste over the coming years. Management solutions are needed to handle

generated wood safely and efficiently.

Per- and polyfluoroalkyl substances (PFAS) are a significant challenge. Invented in the 1930s, PFAS are

still commonly used for their water- and grease-resistant properties in many industrial applications and

consumer products such as carpeting, waterproof clothing, upholstery, food paper wrappings,

cookware, personal care products, fire-fighting foams, and metal plating. PFAS are persistent and can

bioaccumulate, meaning the amount builds up in the body over time. When landfilled, PFAS migrates

into the leachate, which is treated at a wastewater treatment facility. With no existing removal systems

installed at landfills or wastewater plants to remove PFAS, the treated wastewater is discharged into

surface water. It is not clear if waste-to-energy (WTE) facilities maintain the high temperatures required

to destroy PFAS. The waste industry is in the process of identifying ways to address this unusual class of

chemicals. As the solid waste system continues to evolve, adaptations are needed to safely manage new

materials.

Establishing reuse and recycling markets for new additional materials is imperative to meet reuse and

recycling goals and other objectives in the MPP. Market development is a complicated task requiring

considerable lead time. New materials that can be recycled must be generated with enough volume to

justify and sustain a business model.

Finally, the closure of the Great River Energy (GRE) processing and WTE facility has resulted in more

than 250,000 tons of waste going to landfill. This closure directly increased landfill expansions in the

TCMA. In many ways, the GRE closure was the result of an intersection of waste and energy policy.

Minnesota needs to figure out how to manage the policy nexus for these facilities. The energy created at

these facilities is not cost competitive with wind and solar and is not universally viewed as a clean

energy source. However, the important role they serve in solid waste management should not be

underscored. Left unresolved, other resource recovery facilities may follow suit. Without achieving

greater waste diversion and reduction rates, that will result in an increased amount of waste being land-

disposed.

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Part two: Framework for change

This section of the MPP lays out a framework for a regional vision, key themes, goals, and policies. This

framework will guide all decisions of the MPCA, regional governing entities, metropolitan counties, solid

waste facilities, haulers, and other stakeholders with respect to the TCMA solid waste system.

Vision

This MPP is designed to help stakeholders exceed the benchmarks established in state law. The vision is

that the TCMA will put more emphasis on the following:

• Pollution prevention

• Sustainable materials management (SMM)

• Conservation of natural resources and energy

• Reduced reliance on landfills and WTE

• Reduced toxicity of waste

• Equitable improvement in public health for all residents

• Supporting the economy

• Reducing GHGe and the impacts of climate change

The MPP sets forth a vision of sustainability for the TCMA solid waste management system. The TCMA is

a sustainable community that minimizes waste, prevents pollution, promotes efficiency, reduces GHGe

and the impacts of climate change, saves energy, reduces toxicity, and develops resources to revitalize

local economies. The integrated waste management system is an essential component of the

infrastructure of a sustainable community.

Solid waste is managed according to the principles of SMM that support sustainable communities and

environments. The benefits of sustainable and healthy communities are shared equally throughout the

region by all residents. The solid waste management hierarchy is central to attaining the twin objectives

of sustainability and proper solid waste management because it emphasizes the higher end

management methods.

Figure 2. Minnesota’s solid waste management hierarchy of preferred methods

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Key themes

The following key themes underlie all elements of the MPP.

SMM offers a systematic approach to using and reusing materials more productively over their entire

life cycles. SMM considers the environmental impact of the entire life cycle, not just disposal. This

holistic approach emphasizes management methods at the top of the waste hierarchy as well as

reducing toxicity. These methods have greater environmental benefits. For example, preventing food

waste is more impactful than increasing glass recycling rates.

GHGe reductions can be found throughout the solid waste management system. There are potential

reductions in GHGe to be found throughout the life cycle of products and in the waste management

system. This is particularly true at the top of the hierarchy and the design phase of a product when

GHGe can be avoided altogether. Other system changes can affect GHGe in other sectors. For example,

organized collection reduces the number of heavy truck miles and emissions.

The benefits and burdens of the solid waste management system must flow equally to everyone. The

MPCA is committed to ensuring that pollution does not have a disproportionate impact on any group of

people. This is a principle of environmental justice. Decisions about siting solid waste facilities should

include all stakeholders. Translating educational materials into the languages spoken in the TCMA is

important, as is including people who have not traditionally had a voice in decisions that affect them.

EPR presents great opportunities for shifting the burden of management from the counties and cities

to the producers. Product stewardship and extended producer responsibility (EPR) is a policy approach

to extend the producer’s responsibility to include environmental impacts from all stages of the product’s

life cycle. This includes incentives for durability, reusability, toxicity reduction, and finding the highest

and best use of materials and waste. In current practice, product stewardship requires manufacturers to

share in the physical and financial responsibility of collecting and recycling products at the end of their

useful life.

Minnesota has several product stewardship laws for paint and electronics and has been a leader in

product stewardship efforts. Other states such as Maine, Colorado, Oregon, and California have adopted

extensive EPR programs from which we can learn.

Goals and policies

The following goals and policies provide the basis for improving solid waste management in the TCMA.

For the purposes of this section, “goal” is defined as a desired result; “policy” is defined as a course of

action adopted by a government, party, business, or individual.

Goal 1: Protect and conserve. Manage materials in a manner that will protect the environment and

public health, reduce GHGe, conserve energy and natural resources, and reduce toxicity and exposure

to toxics.

The goal of the WMA is to protect Minnesota’s land, air, water, and other natural resources, and public

health by improving waste management to serve the following purposes: reduce the amount and

toxicity of waste generated; increase the separation and recovery of materials and energy from waste;

and coordinate the statewide management of solid waste and the development and financial security of

waste management facilities, including disposal facilities. This goal recognizes a prevention-based

approach to waste management to reduce, to the extent feasible, adverse effects on human health and

the environment.

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Policy 1: Challenge current waste management practices to identify materials with opportunities

for management methods that fall higher on the waste hierarchy.

Policy 2: Focus on reuse and prevention. Apply SMM framework to decision making to decrease

the environmental impact. Hold manufacturers responsible to design for repair, reuse, and

recyclability.

Policy 3: Support and strengthen reuse and recycling markets to increase demand for reusables

and recyclables.

Policy 4: Ensure systems are in place that foster the growth of organics recovery.

Policy 5: Promote recovery of energy when disposing of waste through WTE.

Policy 6: Strengthen compliance with cornerstone environmental statutes.

Policy 7: Increase public participation in decisions that impact them with special emphasis on

Environmental Justice.

Policy 8: Account for all phases of a material’s life cycle, including environmental and economic

impacts.

Policy 9: Reduce toxicity by working with manufacturers to eliminate the use of hazardous

components in packaging and products.

Goal 2: Whether public or private, hold all members of the solid waste system accountable for

meeting the goals of this MPP.

To achieve the aggressive goals established in this MPP and by the Legislature, all parties in the solid

waste system must be held accountable, and the MPCA must provide oversight of the system. Cities and

counties must ensure the systems are in place for the proper management of waste, emphasizing

managing it higher on the hierarchy. Generators must use the tools provided to properly manage the

waste they create and to reduce the amount of waste created. Haulers and facility operators must

ensure that waste is managed properly upon collection and look for opportunities to shift materials up

the hierarchy.

Policy 10: Support the collection of reliable data to ensure that all parties in the solid waste

system accurately measure progress toward achieving the objectives of this MPP.

Policy 11: Ensure that demolition debris and industrial wastes are categorized and are managed

according to the applicable Statutes and Rules. Measure more accurately the composition of

non-MMSW generated in the TCMA and being landfilled in Minnesota.

Policy 12: Increase opportunities for cities to implement organized collection for recycling and

MMSW.

Policy 13: Cities and counties hold haulers and businesses in their communities accountable for

managing waste according to the MPP via their licensing agreements.

Policy 14: The MPCA provides oversight of the system by holding counties and private

businesses accountable. The Legislature holds the MPCA accountable for meeting waste

management goals.

Policy 15: Hold producers responsible for the treatment or disposal of post-consumer products.

Policy 16: Set goals and performance standards following consultation with stakeholders on

product stewardship.

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Goal 3: Systematically and steadily promote more regional cohesiveness and collaboration to foster a

synergistic, regional approach.

To achieve our goals of reducing the amount of solid waste generated and recycling/composting 75% of

our solid waste by 2030, it is imperative that the counties work in concert and avoid duplication of

efforts. This includes consistent uniform ordinances, greater collaboration between staff and leaders in

each of the seven metro counties, and planning for facilities through a regional lens.

Policy 17: Develop model ordinances that could be enacted by all counties.

Policy 18: Local governments work together to develop a consistent ordinance structure that

allows private entities to smoothly operate across the region.

Policy 19: Promote efficiencies and cost effectiveness and reduce environmental costs in the

delivery of integrated solid waste management services.

Policy 20: Assure elected county officials understand the importance of supporting and

maintaining WTE facilities.

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Part three: MPP 2022-2042

The MPP provides guidance to all stakeholders responsible for TCMA solid waste management and was

developed in accordance with the requirements of Minn. Stat. § 473.149, subd. 2d. for a land disposal

abatement plan. It describes broad regional system objectives, a landfill diversion goal, and the

strategies necessary for solid waste programs and services to meet the region’s needs for the next 20

years. The MPP recognizes the inter-county complexity of the TCMA solid waste system and the value of

and need for regional approaches. Specific details associated with implementing the MPP on a local level

will be refined in the CSWMPs and any regional plan developed by the metropolitan counties. The MPP

identifies where specific stakeholder actions are necessary to implement the objectives and strategies.

The MPP:

1. Places emphasis on the upper end of the hierarchy (waste reduction, reuse, recycling, and organics

recovery).

2. Establishes objectives for each waste management method.

3. Achieves full use of resource recovery facility capacity and implements the Restriction on Disposal

(ROD) of MMSW requirements.

4. Establishes a goal to minimize the amount of metro MMSW land disposal that will occur.

The MPP includes numerous strategies for reducing waste and increasing recycling and organics

recovery. All stakeholders in the system have roles and responsibilities to ensure successful

implementation of these strategies. A table that identifies each strategy is provided in Appendix G.

Regional waste generation forecast

In 2021, the TCMA generated 3.3 million tons of MMSW. Metro MMSW generation is forecasted to

grow to 3.92 million tons by 2042 (see Figure 3). The figure also includes the 15% reduction strategy to

help visualize the intent of source reduction. Achieving a 15% reduction from the forecast amount will

require waste generation to remain equal to the current generation going forward. This forecast does

not include the non-MMSW waste stream (i.e., construction, demolition, and industrial wastes). The

MMSW forecast was generated using waste generation amounts from 2010-2021. This period was

chosen because the 2007-2009 recession created a new baseline.

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Figure 3. Total MSW Generation Forecast with the 15% source reduction objective

Non-MSW like demolition debris, contaminated soil, and industrial waste continues to experience

growth in generation of industrial and demolition debris (see Figure 4). It is forecasted that annual

generation of non-MSW will increase by 6,000,000 cubic yards over the next 18 years. Reduction of non-

MSW is vital to reach environmental goals in the future. Ash generation is forecasted to remain

consistent over the next 20 years. Reducing or ceasing operations at Hennepin Energy Recovery Center

could lower the amount of ash being land disposed but would greatly increase the need for MMSW

disposal over the life of the plan.

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Figure 4. Non-MSW and Ash Forecast

Sustainable Materials Management (SMM)

SMM overview

SMM identifies the best use and management of materials, considering the environmental impacts

throughout the life cycle of materials. The major stages in a material's lifecycle are:

• Raw materials extraction

• Product manufacturing

• Product use

• Transportation

• End of life management

To protect the environment and human health, an understanding of “waste” must broaden. The impact

of materials and waste include GHG emissions, pollution to land, air, and water, and resource depletion.

These impacts happen throughout the entire life cycle of a product. All phases of that cycle must be

considered, not simply end of life.

SMM includes traditional solid waste management. Management of the upstream impact of materials

and the toxic chemicals used to manufacture those materials are also considered. The MPCA and EPA

concede that an SMM approach seeks to:

• Use materials in the most productive way with an emphasis on using less.

• Reduce toxic chemicals and environmental impacts throughout the material life cycle.

• Ensure we have sufficient resources to meet today’s needs and those of the future.

An SMM approach invites more interested parties involved throughout the life cycle of a product to

provide perspective and provide a broader scope of impact. These potential partners include, but are

not limited to, primary chemical formulators, academic researchers, brand owners, retailers, product

designers, and consumers.

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Life Cycle Assessment

SMM uses Life Cycle Assessment (LCA) to inform decision-making. LCA is a way to model the

environmental impacts associated with a material or process from resource extraction through end-of-

life management. This yields information on environmental impact indicators, such as GHGe, toxicity,

and acidification. These metrics help policymakers focus efforts on high leverage opportunities. At this

time, the most widely used environmental indicator is GHGe. According to the EPA, materials can

account for up to 42% of GHGe in the U.S. Most of that impact happens in the production lifecycle

phase. In alignment with the waste hierarchy, the least environmentally impact action is to produce and

use less.

Figure 5. LCA: a methodology for modeling the environmental impacts of a material or product from raw

material extraction through end-of-life management

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LCA modeling can compare environmental impacts associated with one material versus another. LCA

modeling can also compare the impact of different management methods of the same material.

Designers and manufacturers can use LCA modeling to determine the life cycle phase(s) in their

products’ lifecycle with the greatest specific impacts (e.g., water, air, and human health). For instance,

electronics manufacturers may find that the use phase impacts are the energy usage by the consumer.

The manufacturer can design the product to use less energy. They could also design the product to last

longer and be reparable by producing replacement parts.

The ability to track and report on the environmental impacts of our materials management system is

critical. Measuring repair activities as a waste reduction activity will be important to support this

activity.

SMM for recycling

If Minnesotans recycled and composted all waste, GHGe would be reduced by only 3%. Recycling is

important but recycling alone is insufficient. Moreover, material attributes like recyclability do not

necessarily correlate with the greatest reduced environmental impacts. It is important to keep in mind

that if something is marketed as “compostable” or “recyclable” that does not necessarily mean that it

provides the best environmental outcome. For example, a steel coffee can is recyclable, so it may seem

like the best packaging choice. LCA modeling comparing steel cans to other coffee packaging types

shows that is not the case. Foil pouches result in fewer GHGe, despite having no material end market.

That said, recycling plays an important role in the waste management system. If light weight packaging

brings the greater environmental benefit, we should support developing recycling markets for packaging

like foil pouches. Volatile recycling markets require innovative solutions to remain relevant.

SMM tends to favor prevention and reuse yet also reaffirms the importance of recycling. Recycling is

commonly lauded for its ability to decrease demand for landfilling. However, there is a greater

demonstrated environmental benefit in recycling when the byproduct alleviates the need to extract

virgin materials by mining. The environmental degradation from extraction, energy use during

processing, and transportation often tip the scales in favor of recycling. Identifying the highest and best

use for each material is the primary consideration under this framework.

SMM and toxicity

Using an SMM approach also sheds new light on the use of toxic chemicals in manufactured materials.

The policy and purpose of the Waste Management Act calls for a reduction in the toxicity of waste

generated. Reducing toxics in the products we purchase reduces the overall toxicity of waste generated.

In the past, the State of Minnesota Office of State Procurement prioritized recycled-content products on

merit of recycled content alone. For example, a problem with the statewide flooring contract emerged

when the vinyl flooring with recycled content was found to contain legacy heavy metals. The contract

now restricts recycled content containing resilient flooring products unless they are third-party certified

to conform with NSF/ANSI Standard 332: Sustainable Assessment of Resilient Floor Covering. This

highlights the need to look at all material properties, not just recyclability.

Solid waste abatement objectives

Tables 1 and 2 set specific quantifiable objectives for abating the need for and practice of land disposal

for the TCMA region over the next 20 years, pursuant to Minn. Stat. § 473.149, subd. 2d. Landfill

abatement is best achieved through an integrated solid waste management and SMM approach.

Therefore, the statute requires “objectives for waste reduction and measurable objectives for local

abatement of solid waste through resource recovery, recycling, and source separation programs.”

Table 1 defines the waste reduction objectives by percentage and tons reduced from forecast

expectations. The forecasted trend in waste generation accounts for much of the reduction that

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currently is occurring such as light weighting of materials. This plan calls for a 15% improvement on that

trend-line following many comments that state that the waste reduction goal needs to be much more

aggressive.

Table 2 defines the objectives by percentages of waste generated, and Table 3 defines the objectives in

tons. Table 3 shows the objectives in tons based on the current waste forecast in this MPP and is subject

to change if the forecast is updated. Several factors were considered when setting the objectives,

including:

• Current statutory goals

• The regional waste forecast highlighted at the beginning of Section 3.

• Metro counties will achieve the 75% recycling rate as laid out in Minn. Stat. § 115A.551 by 2030.

• Total compliance with Restriction on Disposal (ROD) is assumed.

• Additional capacity at any given WTE facility will be used regardless of originating county

for MMSW.

• Landfilling is assumed to be a minimum of 5% given the need to manage non-processible waste,

bulky items at WTE facilities, and residuals and rejects from recycling and composting facilities.

• Baseline is the last year of observable data (2021) since the latest year of data represent the

best data available to the counties and their current education and diversion practices.

Currently, Hennepin County is the sole provider of MMSW to the Hennepin Energy Recovery Center

(HERC) facility while Ramsey and Washington split the capacity of the Ramsey-Washington Energy

Center. Each of these facilities is assumed to be at capacity due to ROD compliance. Dakota County will

continue to send MMSW to the Red Wing processing facility, estimating 10,000 tons in 2020 and 13,000

tons in all subsequent years.

Meeting the objectives will reduce GHGe, conserve resources, reduce land disposal, and recover

energy. The goals for recycling, organics, WTE, and landfilling do not change after 2030. The 75%

recycling goal will be difficult to reach, so it will remain a relevant target beyond 2030. To continuing

making progress, it is prudent to widen our regional focus to include waste reduction, given that the

greatest environmental gains occur through reducing waste. Reduced upstream impacts contribute to a

common goal with the recycling rate. The Hennepin County Board recently issued a resolution to create

a plan for closing the Hennepin Energy Recovery Center sometime between 2028 and 2040. Due to the

uncertain timeline, the MPCA is not revising the assumptions in the objective tables. However, history

shows that the closure of a WTE facility leads to increased landfilling. MPCA expects that currently

projected waste going to HERC would go to landfills if the facility closes. A robust plan to divert

additional material and an influx of resources to improve programs and infrastructure may reduce the

volume of waste that would be landfilled if HERC is closed. Without aggressive programs to replace

HERC an additional 365,000 tons of material would be landfilled per year, which is equivalent to the

largest landfill in Minnesota.

Table 1. Waste reduction system objectives in percentages and tons (2021-2042)

Management method

Current system (2021)

2025

2030

2036

2042

Waste Reduction

0%

2.9%

6.4%

10.7%

15.0%

Waste Reduction Tons

0

98,577

231,557

403,919

587,984

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Table 2. MMSW management system objectives in percentages (2021-2042)

Management method

Current system

(2021)

2025

2030

2036

2042

Recycling

28.6%

36.9%

47.4%

Organics

16.6%

21.5%

27.6%

WTE

21.4%

24.0%

20.0%

Landfill

33.4%

17.6%

5.0%

The table above shows the percentages of how waste is managed currently and projections for future

years. The data under 2021 is from the latest SCORE report. Projections are based on the assumptions

found in Appendix F.

Table 3. MMSW management system tonnages (Based on objectives in Table 2 in thousands of tons [2010-

2030])

Management method

Current system (2021)

2025

2030

2036

2042

Recycling

944,968

1,237,436

1,598,496

1,596,691

1,580,830

Organics

547,931

719,166

929,331

927,801

918,102

WTE

707,268

828,000

674,087

673,198

666,382

Landfill

1,102,165

567,014

168,522

168,299

166,595

Total

3,302,332

3,351,615

3,370,437

3,368,899

3,331,909

The table above shows the same data and projections in thousands of tons to give context to the

percentages in Table 3 and illustrates the amount of waste that needs to be managed in the TCMA.

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Figure 6. TCMA MMSW management methods: past, present, and projection (SCORE and Certification Reports)

Evaluation of the system objectives

The MPCA will evaluate progress toward achieving all the system objectives through the annual SCORE

Report submitted by the counties every April. The MPCA recognizes the challenges associated with

measuring progress and measurement in general. Measuring waste reduction has posed challenges for

years. See the

Environmental impact target section for a discourse on a more robust way to measure

environmental impact. Using data the counties currently provide, the MPCA has begun to calculate the

environmental impact in the annual SCORE report. MPCA intends to continue to improve those efforts

to better quantify the impacts of county programs on the environment. The environmental impact

target does not require the counties to submit additional information to the MPCA. The MPCA will

continue to work with local governments, haulers, and others to assure the data collected is necessary

and relevant and will continue to collect data on a statewide and regional basis. The MPCA has historically

used the SCORE Report as the method of tracking annual progress toward the objectives and has used the

Solid Waste Policy Report to recommend needed policy changes to the legislature.

Emphasis on the upper end of the hierarchy

Handling materials using methods on the upper end of the hierarchy should be measured and reported.

This includes an emphasis on waste reduction and reuse. There has been an emphasis on the legislative

recycling goals, and while recycling plays an important role in the waste management system,

measurement of success should be based on all impactful efforts. Reduction and prevention need to be

organized and implemented through the TCMA.

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Aggressive objectives for waste reduction and reuse, recycling, and organics

recovery

All stakeholders, including the MPCA, will be held accountable for meeting these objectives. The MPCA

believes the objectives are achievable, but to reach them, the TCMA will need new tools, enhanced

infrastructure, and increases in funding. The current rate of increases in recycling and compost will not

get the TCMA to the 75% recycling objective. New approaches to meeting the goal and other objectives

in the MPP are needed for environmental protection.

Waste reduction and reuse

According to the EPA, waste prevention is the most environmentally preferred strategy to reduce

impacts. Waste reduction and reuse methods are the most effective waste prevention strategies.

Meeting waste reduction and reuse objectives will reduce the amount of MMSW that needs to be

managed. Forecasting the projected MMSW generation for each county will deduct the tons of material

reduced or reused.

Benefits of achieving success

In 2021, the TCMA achieved a 45.2% combined rate for traditional recycling and organics diversion.

Minnesota would benefit from exploring additional methods to achieve the intended environmental and

human health outcomes of the 75% recycling goal. Environmental and human health impacts of

management methods should be considered. Minnesota needs to modernize data collection,

measurement, and reporting. Other priorities should include identifying the highest return on

investments in how staff time is allocated, introducing the most impactful policy changes, and investing

in strategic infrastructure needs.

Oftentimes, waste reduction and reuse efforts can be cheaper than handling the same materials as

waste. Incentivizing and tracking waste reduction and reuse separately ensures that county partners

receive recognition for those efforts. Some counties have reported prevention and reuse in their

CSWMPs and programming. Historically, reuse activities have counted towards the recycling rate via

SCORE reporting.

An analysis of the 2018 SCORE report “recycling” data for accuracy revealed that, statewide, 79 of 87

counties reported reuse activities. This illustrates the need for counties to be recognized for investing in

reuse. In response, the MPCA modified the 2021 SCORE reporting form to track reuse activities.

Prevention and reuse programming result in fewer emissions. They are not and should not be treated as

equal to recycling. The state should transition to a reporting structure that documents the increased

climate and other pollution reductions from handling materials using methods higher on the waste

management hierarchy.

Environmental impact target

To prioritize waste reduction and solid waste management with environmental and human health

benefits, MPCA is setting an environmental impact target for TCMA counties based on full LCA. Under

this environmental impact target, weight-based accounting for waste reduction, reuse, recycling, WTE,

and landfill disposal is translated into GHGe generated or avoided. In this way, counties still report and

work to meet their 75% recycling rate goal, but the environmental impact target documents overall

changes in GHGe based on all county efforts and programming. By tracking progress with GHGe

(currently the most accessible proxy for environmental impact), in addition to the recycling rate,

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counties can invest in upstream activities, report on those efforts, and reach their environmental impact

target through waste reduction and reuse programming as well.

The environmental impact target is defined by calculating the emissions avoided if the county were to

reach the materials management goals set forth in the Metro Policy Plan by 2030. This means totaling

the emissions associated with:

• Achieving a 15% waste reduction goal.

• Achieving a 75% recycling rate goal as established by the Minnesota Legislature.

• Achieving complete compliance with Restriction on Disposal, resulting in WTE facilities capturing

most of the remaining materials.

• A minimum of 5% of material sent to landfill.

The value of setting a comprehensive environmental impact target that counts emissions reduction from

the entire materials management system as all strategies become opportunities for meeting the target.

This means a county can choose to do more waste reduction or reuse to reduce their GHGe more

significantly and progress further on meeting their environmental impact, than solely focusing on

recycling to achieve their 75% recycling rate. If a county is already meeting or exceeding their

environmental target, the MPCA would recommend adjusting their target to be more ambitious and

support continued work on reducing impacts from materials being handled. County-specific calculations

will be made using 2021 SCORE data.

Each county will be able to work with their MPCA Planner to review their current progress and identify

options for meeting their environmental impact target, determining which programs will have the

greatest benefit. For example, counties will be able to see how the amount of emissions reduction

achievable by focusing on food rescue versus composting. The target will not replace the 75% recycling

goal already in statute.

The following example, using data from Scott County, illustrates how the environmental impact target

will be implemented and shows two potential scenarios. In the first scenario, Scott County meets the

75% recycling rate goal by 2030 as required by the Minnesota Legislature. The rest of their materials are

handled business-as-usual, meaning the county didn’t implement additional waste reduction, reuse, or

WTE strategies. The total GHGe savings is 234,037 metric tons of carbon dioxide equivalent (mtCO

2

e).

In the second scenario Scott County maintains their current 55% recycling rate until 2030. However,

they invest in waste reduction strategies and reduce materials by 10%. The county accomplished this by

focusing on preventing food from going to waste, reducing paper use, and eliminating a small number of

single-use items and replacing them with durable reusable systems. The total GHGe savings is 224,060

mtCO

2

e. In the second scenario, only 10% of the waste is being source reduced. Yet, compared to a 20%

increase in recycling in the first scenario, the amount of GHGe is very similar. How materials are

managed makes a big difference. Scott County can achieve nearly twice the environmental and human

health benefit by reducing materials than recycling in this scenario. This affirms the waste management

hierarchy and emphasizes the importance of first reducing, then reusing, and then continuing to manage

materials down the hierarchy as needed if the first two strategies are not feasible.

The MPCA staff will work with counties to assess their options for meeting the environmental impact

target using an interactive tool based on EPA’s WARM. The MPCA will be able to model county-specific

scenarios for materials management using data that the counties currently provide. The MPCA will not

be requesting additional information from the counties to track this new goal.

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Figure 7. Carbon emissions impact of different management types

Strategies and best management practices to achieve the objectives of the MPP

There are various approaches to meet the system objectives of this MPP. The TCMA waste management

system is governed by multiple public and private entities, and a variety of strategies provide the

flexibility to meet the needs of each program or situation. The state, counties, cities, businesses,

nonprofits, communities, and residents all have specific roles and responsibilities for improving solid

waste management. To minimize conflicts and inefficiencies, it is important to select strategies that

align public and private objectives, to work together to identify necessary changes to existing strategies,

and to indicate where new strategies are needed. Counties can proposal alternative strategies if they

see fit. Proposals must achieve comparable objectives and will be subject to agency approval. The point

value of alternative optional strategies will be determined by the MPCA. Many of these strategies will

require investment and additional funding. The MPCA will advocate for additional funding for the

system when appropriate and asks the counties to do the same.

County solid waste plan evaluation point structure

Each topic below includes key strategies that will be instrumental to reaching the objectives of this MPP.

Certain strategies are required to be incorporated into CSWMP. Optional strategies are assigned a point

value. The counties will pick from any of the optional strategies to reach a minimum of 75 points.

The strategies are weighted by difficulty and by management strategy in accordance with the Waste

Management Hierarchy. This places an incentive on environmental and human health outcomes while

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allowing counties the flexibility to design and adapt their solid waste programs. The various optional

strategies are worth 4-9 points. The optional strategy point total is 194 points, and the counties must

have a minimum of 75 points for their CSWMP to be approved. Appendix G houses a strategy

spreadsheet for counties to use in designing their solid waste plan.

Costs implications of strategies should be estimated by county staff when considering feasibility of

implementation. The MPCA is committed to achieving the objectives established in this MPP and intends

to assist with strategy implementation as noted below.

Improving the reliability of the data

The MPCA strategic plan calls for the Agency to “accelerate the availability of data and information in a

self-service format.” From a solid waste perspective, one of the best ways to accomplished this is to

ensure that data is consistently collected through the most reliable sources and that all waste and waste

reduction be tracked. The MPCA and the counties have historically focused on only MMSW. Little

attention has been directed toward the measurement of demolition debris and industrial waste (ISW).

The SCORE program created a strong framework for tracking progress toward the goals and objectives

of the WMA. Over the past 30 years, there have been some problems identified with traditional

measurement methods. Like the MPCA and counties, SCORE historically focused on only MMSW, with

no data on ISW reported or requested. In addition, the success of county programs has been measured

through a weight-based system that treats all material tons equally.

Our improved ability to understand the environmental and human health impact of different material

types has exposed the limitations of weight-based measures. Weight-based measures are important but

have limitations. Data analysis can be enhanced by collecting additional data in addition to the weight-

based measures. A moving target of what counts as recycling has added to inconsistencies. In recent

years, yard waste and compost have been added to the recycling side of the ledger.

Ultimately, a large focus has been placed on recycling in county programs to the detriment of waste

reduction and reuse. As discussed above, the greatest environmental and human health benefits are not

realized through recycling. Improved reporting provides the information needed to understand how to

achieve better environmental and human health outcomes. The added reuse component to the SCORE

report captures the reuse activities within counties. The intended outcome is to fill a data gap that has

existed since the inception of the program in the early 1990s. Hauler reporting requirements were

added in 2016, but inconsistent compliance from the haulers, inconsistent support from counties, and

staffing issues at the MPCA have led to lax enforcement and limited follow-up.

As previously mentioned, SCORE is only focused on MMSW, with no requirements to track other waste

streams. Landfills report amounts of demolition debris and industrial waste annually. Yet, there is

limited data regarding recycling rates of those two material streams. We also have limited data about

non-MMSW landfill diversion such as recycling. To improve the management of non-MMSW materials, it

is critical to have a better reporting for this waste sector. Despite these challenges, there are several

strategies that can be pursued that will improve the management of data in the TCMA.

Required strategy:

The strategy listed below is required to be incorporated into the CSWMP because it is relatively simple

or has significant environmental benefit.

1. Increase compliance with hauler reporting per Minn. Stat. § 115A.93. Compliance with hauler

reporting in metro counties has been mediocre. In 2021, these compliance rates were between 45%

and 68%, within the TCMA. There are several challenges regarding the compliance numbers. Some

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haulers may be misreporting to counties. In these cases, counties should hold haulers accountable

for completing their reporting accurately. Reliable hauler reporting provides a benchmark for the

objectives of this MPP. Hauler reporting is a shared responsibility for the state and county.

Cooperation from counties to maintain accurate license lists will allow the MPCA to trust the

information collected. Both the state and counties benefit from the collection of this data. Sharing in

the responsibility ensures accuracy and efficiency. Best practices in the promotion of compliance

with hauler reporting include:

• Sending quarterly reminders to all licensed haulers

• Reviewing submitted data in ReTRAC

• Active communication and follow-up regarding incorrect or missing hauler data

• Requiring proof of data submittal prior to license renewal

• Cleaning up the regional license data to ensure that haulers are truly operating in the

counties

Improved compliance and data integrity would facilitate the mapping of waste flow in the TCMA

from origin point to end destination. We need to understand the breakdown of residential and

commercial tonnage and the scope of material exports. Dakota County demonstrates that

improving compliance with the haulers is possible when county staff are persistent. Compliance

rates for haulers in Dakota County is 68%, compared to 45-55% in other counties in the metro.

2. Provide required county reporting. Ensure the MPCA receives all data in the state-issued format.

Counties should collaborate on creating best data practices for soliciting data from organizations.

The MPCA and counties shall standardize waste composition sorts for consistency. SCORE,

certification, and the metro county annual reports are also targeted in this strategy.

3. Require waste composition study at least once every 5 years at all landfills that are located within

your county. Waste composition study data helps identify important trends on waste types and

quantities. Landfill information will help policy, planning, and implementation, such as assessing

capture rates. Counties with landfills receiving TCMA waste should introduce an ordinance to

reinforce this requirement. Waste composition studies shall include MMSW, ISW, and demolition

debris disposal streams. The MPCA seeks to assure all landfills receiving metro waste operate with

equal requirements. Dakota County ordinance no. 110 establishes a requirement for waste

composition studies to be performed every five years at all land disposal solid waste facilities.

Performing waste composition studies on a regular schedule will help determine generation rates,

aid in capture rates, and provide material type breakdown.

Optional strategy:

The following strategy is optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

4. Improve recycling data collection at businesses within the county.

Point Value: 7

Commercial buildings required to recycle in Minn. Stat. § 115A.151 should report their recycling

tonnages to the county in which business is conducted. Exempted businesses can provide

documentation of their licensed hauler's reports to the MPCA. Develop an ordinance that requires

businesses to assign a recycling manager. The recycling manager shall report weight, material type,

and management method for self-hauling. Self-hauling shall include contracted services outside of

licensed haulers. Alternative to development of an ordinance would be developing a surveying

approach. Create a survey method resulting in a statistically significant number of annual responses.

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Review and analyze to assure reliable commercial data are being collected. Carver County conducts

an annual survey of businesses to collect data from generators who self-haul. Replicating this

approach would fulfill this strategy.

State-led strategies:

The following strategies are the responsibility of the MPCA and will support the efforts by the counties.

5. Require waste composition study at all landfills. Understanding the composition of MMSW,

demolition debris, and ISW streams is critical to perform GHG calculations and to quantify other

environmental impacts. Resource recovery facilities are currently required to conduct waste

composition studies every five years. This requirement should be extended to all disposal facilities

for consistency and equal treatment, and to have comparable information from the data. Waste

composition study data provides important trend information on waste types and quantities. The

addition of landfill information will help policy, planning, and implementation efforts, such as

assessing capture rates. The State will work to require waste compositions across the state with the

express purpose of obtaining better data.

6. Develop appropriate and consistent waste reporting systems to measure all waste. Measuring and

reporting all waste (including MMSW, demolition debris, and ISW) through annual reporting is

necessary for the state and counties to effectively manage waste to its highest and best use.

Alternative measures to weight-based reporting that encompass the environmental impacts of a

material should be researched and considered. This could include using SMM tools such as capture

rates and human health impact data that focus more on the impact of a material throughout its life

cycle. The MPCA will continue to build on initial efforts to report on the environmental and human

health impacts utilizing the data that counties currently submit. High quality data will result in the

development of strong statewide policy. Developing a system will support evidence-based decision

making for future laws, policies, rules, and program planning. Commonly recovered materials from

demolition sites are concrete, shingles, wallboard, carpet, and lumber. A robust system for

evaluating these materials will help counties and the state prioritize our efforts.

7. Continue to explore options for growing the agency’s LCA data, modeling, and resources to better

support counties in measuring and tracking environmental and human health impacts. This

includes translating county solid waste measures from weight-based measures to GHGe and other

environmental and human health impacts and periodically updating the state’s consumption-based

emissions inventory to complement the current in-boundary emissions inventory. It also includes

incorporating environmental impact data across agency materials management and solid waste

management programs to identify priority materials and strategies to target the highest-impact

categories.

8. Continue to engage with counties in the development of an environmental target that better

accounts for and incentivizes programming and actions higher on the hierarchy. The recycling rate

serves a specific purpose and there is an opportunity for the MPCA to evaluate and develop an

approach to represent county SMM efforts more holistically.

Regional solutions

The TCMA counties do not have a formal regional waste management district. Yet, it is practical to

implement certain strategies at the regional level. Collaboratively designing and modernizing a materials

management system will benefit all TCMA counties.

Required strategies:

The strategies listed below are required to be incorporated into the CSWMP because they are relatively

simple or have significant environmental benefit.

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9. Participate in an annual joint commissioner/staff meeting on solid waste. This annual or semi-

annual meeting will provide an opportunity to get a county commissioner and lead staff from all

seven counties together to discuss relevant waste topics. The purpose of this strategy is to help

ensure that all seven county boards understand the challenges that each county faces, learn from

the CSWMP of other counties, and examine places to collaborate to meet the regions solid waste

goals. MPCA will take the lead in organizing this meeting at the inception.

10. Commit to standardized outreach and education. The seven counties in the TCMA must coordinate

on their recycling messaging to avoid confusion among residents. To coordinate, each county should

attend the Recycling Education Committee (REC) meetings and use REC communications calendars.

If a deviation is made from the REC materials, the TCMA counties all must agree. Counties should

utilize or adapt the MPCA-designed library exhibits on food storage tips and the impacts of food

choices to educate residents on preventing food waste. To create regional consistency, counties

should acknowledge organics recycling and food scraps are both in use in different areas of the

TCMA. Counties should coordinate to reduce confusion associated with the use of different

terminology within the region. Outreach and education efforts should include how to handle

materials not accepted in curbside collection bins. These materials should include lithium-ion

batteries, scrap metal, and other materials accepted by environmental centers and household

hazardous waste drop-off sites.

11. Engage in efficient and value-added infrastructure planning. TCMA counties should seek to

eliminate system redundancy by sharing and co-developing CSWMP for managing all material types.

This collaboration includes the use of emerging technologies that have the potential to reduce or

manage waste higher on the waste hierarchy and that have the potential to impact materials and

processes that have a greater environmental impact. TCMA counties should foster a space for

counties and private partners to work cooperatively and not competitively to build system

resiliency. More processing capacity to assure materials with useful life are routed appropriately is

imperative. Food-derived composting and food rescue are high priorities for infrastructure planning.

MRFs face pressing issues such as overflow of materials and a need for fire suppression.

12. Develop plans for large facility closures to reduce landfill reliance. The plans must include:

• Develop a plan that identifies alternatives that can manage the waste currently managed at

the facility. This plan must include landfills, transfer station infrastructure, recycling and

composting infrastructure and other logistical solutions to manage MMSW.

• Identify a plan to push waste up the hierarchy including an effort to prioritize reduction.

• Issue a letter assuring waste to one or more of the alternative locations suitable as part of

the CON process for landfill expansions when necessary.

• Include in the plan acknowledgement of liability associated with increased landfilling

including the understanding that at some point in the future the county may be identified as

a responsible party for a superfund clean-up investigation.

• Identify and evaluate potential locations within the county or region for a disposal facility

that can be developed within the timeline of the facility closure.

• Any new facilities that are sited should take clear and effective measure to ensure

that they are not located in environmental justice areas.

• A list of policy, program, infrastructure changes needed to eliminate reliance on WTE and/or

landfilling.

• Consideration of where money saved by closing the facility could be reinvested to benefit

the region.

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Waste reduction

In accordance with Rule 9215.0580 and Minn. Stat. § 115A.02, counties are responsible for advancing

prevention and reuse along with other solid waste management strategies. Waste reduction means not

generating any materials that require further recycling, composting, disposal, or other management.

Waste reduction includes reducing the amount and toxicity of materials generated. It is at the top of the

hierarchy, because it is the best option for the environment. Using an SMM framework, counties can

design programs that direct limited resources toward waste reduction programming and infrastructure

to have the greatest impact on their communities. To quantify this impact, counties can now report their

waste reduction activities by material type to the MPCA. Related GHGe savings can be found in the

SCORE report.

Waste reduction is the most effective way to lessen the need for resource extraction, reducing pollution

at the source and conserving materials for future generations. Measuring waste reduction requires

setting a baseline of consumption and comparing all future consumption to that baseline. One example

of doing this on a broad scale is represented in the SCORE report.

Based on statewide waste generation data, starting in 2008,

Minnesotans are generating less waste than expected based on

projections using the 1997 rate. There was a dip in the actual waste

generated during the national 2008 recession that extends into 2010,

mirroring the economic recovery period. There has since been a

steady upward trend in waste generation. In 2020, however, expected

waste generation sharply declined while actual waste generation

continued to increase. This anomaly in expected waste generation is

primarily due to a large drop in per capita expenditures in the

“Services” consumption category, including food services and

accommodations, recreation services, and transportation services.

Spending in both the consumption categories of “Durable Goods” and

“Nondurable Goods” remained consistent with the trends from

previous years. This can be explained by changes in purchasing due to

the COVID-19 pandemic, in which the service industry was most

affected by periods of lockdown and residents spent more time at

home. However, because “Durable Goods” and “Nondurable Goods”

did not see the same decline, resulting waste generation will continue

to increase in future years as those purchased items in 2020 are

disposed of at the end of their useful life.

Waste reduction in real life

Source reduction in action

MN Waste Wise utilizes the

Leanpath Food Waste Prevention

Platform. This an online software

helps staff identify and

dramatically reduce food waste

and operate a more sustainable

facility. The results were

determined by measuring and

tracking purchasing of food items

throughout several months.

Overall, three restaurants reduced

their food waste by 29% in value,

totaling $40,110. Additionally, the

offered solutions allowed the

participating restaurants to

decrease their waste bills.

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Figure 8. Personal consumption expenditures

Increase and document prevention of wasted food and food rescue

Up to 40% of the food in the United States goes uneaten, according to a Natural Resources Defense

Council (NRDC) report. At the same time, one in thirteen Minnesotans face hunger. The greatest

environmental benefit—in terms of reductions in energy use and GHGe—is made when we can prevent

food from being wasted rather than managing or disposing food waste.

The MPCA recently conducted a sort of food in the MMSW stream. The waste sort uncovered that

almost half of the food Minnesotans threw in the trash could have been eaten. There is a significant

opportunity for counties to work with residents and businesses on systems improvements and behavior

changes that promote the prevention of wasted food.

Wasted food wastes the resources used to produce it, such as agricultural land, water, and energy, and

generates significant environmental impacts, such as GHGe contributing to climate change,

consumption and degradation of freshwater, degradation of soil quality, and degradation of air quality.

According to EPA’s 2021 report, “From Farm to Kitchen: The Environmental Impacts of U.S. Food

Waste,” uneaten food in the United States annually embodies:

• 140 million acres of agricultural land – an area the size of California and New York combined

• 5.9 trillion gallons of fresh water – equal to annual water use of 50 million American homes

• 778 million pounds of pesticides

• 14 billion pounds of fertilizer – enough to grow all the plant-based foods produced each year in

the United States for domestic consumption

• 664 billion kWh of energy – enough to power more than 50 million U.S. homes for a year

• 170 million MTCO

2

e GHG emissions (excluding landfill emissions) – equal to the annual CO

2

emissions of 42 coal-fired power plants

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Reducing one ton of food saves about twenty times more GHGe than composting that same amount of

food waste. Households are the biggest contributor to this waste. Preventing wasted food is one of the

more impactful ways that everyday Minnesotans can mitigate climate change. Addressing this issue

would impact not only the environment but has the potential to support the needs of TCMA residents

experiencing food insecurity. According to the NRDC, redirecting one-third of the food currently being

thrown out would be more than enough to cover unmet food needs across the country. Nearly 1 in 10

households in Minnesota experience food insecurity, as reported by the Minnesota Department of

Health.

Purchasing

Minnesota’s Sustainable Procurement Program is a partnership between the MPCA and the Department

of Administration. The Sustainable Purchasing Program currently prioritizes 19 state contracts for the

inclusion of sustainability requirements. As of fiscal year 2020, 53% of priority contracts are considered

“100% sustainable.” Allocating funds toward sustainable materials is key to ensuring support for

sustainable, non-toxic, and closed-loop markets. Sustainable purchasing considers environmental, social,

and economic factors by considering the lifecycle impacts of a product — from raw material extraction

through end-of-life management. This approach allows buyers to decrease the impact of their purchases

more strategically and effectively. Local governments can save money and identify where the greatest

reductions in impacts. Purchasing from the 19 priority state contracts available through the Cooperative

Purchasing Venture (CPV) program allows counties to easily expand the impact of the state’s

sustainability efforts.

Environmental product declarations (EPDs) are another tool to influence purchasing power at the state

level. An EPD provides transparency about the environmental life cycle impacts of a product. EPDs are

increasingly being used to account for the full scope of impact for building materials.

Required strategies:

The strategy listed below is required to be incorporated into the CSWMPs. It is required because it is

relatively simple or has significant environmental benefit.

13. Provide grants for or access to software that can track food waste. By 2025, implement county

programs that prevent wasted food to businesses and institutions that produce food waste.

According to the EPA, one-third of all food in the United States goes uneaten, of which a majority

ends up in landfills or WTE facilities. Food waste tracking software can aggregate data that can be

easily reported as a reduction in SCORE. Most software can also provide environmental metrics,

which could be used to further determine impacts. These metrics can be shared with customers and

users to educate them based on real-time results, which can have impacts on the users’ behavior

outside of these facilities. Hennepin County has previously provided some limited grant funding for

businesses to utilize software for preventing food waste. Additionally, Minnesota Waste Wise has

assisted businesses with implementing programs that rely on food waste tracking software.

14. Establish partnerships between food rescue organizations and restaurants/stores to increase food

rescue. Developing reliable networks between institutions with excess food and institutions that can

rescue the food is imperative to the success of these programs. Established organizations such as

Second Harvest Heartland can assist with food rescue efforts

. This could be accomplished by

assigning county staff or a GreenCorps member to build these networks. MPCA can be contacted to

learn more about how to host a GreenCorps member to help with these types of efforts.

15. Launch bi-annual sustainable consumption challenges for residents. These challenges should focus

on reducing waste produced by residents. Organize and run these challenges for residents that

encourage them to reduce their own waste in various areas. Examples include Zero Waste

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Challenge, EPA Get Smart Challenge, and Track Food Waste at Home – Hennepin County. The

campaigns should also incorporate messages that encourage buying more durable products and

repairing these items to extend their useful life (including textiles, electronics, and furniture.). These

products may cost more, so it is important to frame these campaigns in a way that acknowledges

how the cost can be a barrier.

16. Implement a formal county sustainable purchasing policy using MPCA guidance. Sustainable

purchasing policies shows a commitment to reducing environmental, social, and economic impacts.

The policy should increase county purchases of goods that are reused, remanufactured, and

designed for durability and repairability. Identify purchases that are not necessary and eliminate

them. County-wide spending should be analyzed for redundancies. Those redundancies should be

eliminated. Procurement professionals should collaborate and forecast purchases whenever

possible.

17. Participate in Responsible Public Purchasing Council meetings. This bi-annual meeting connects

county, city, township, and other Cooperative Purchasing Venture member organization purchasers.

The purpose of this group is to support purchasing leaders to be good stewards of public dollars and

to share information about sustainable criteria developments throughout purchasing sectors. Each

county shall plan and host two Responsible Public Purchasing Council meetings by 2030 and send a

representative to attend each meeting.

Optional strategy:

The following strategy is optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

18. Work with health inspectors to educate restaurants and other establishments that have excess

prepared food to donate.

Point Value: 7

There is widespread concern over the liability of donating prepared food. Enlisting county and city

health inspectors to help willing restaurant operators navigate the laws, statutes, and ordinances for

food donation can help to support the growth of additional sources for donations. This strategy

prevents wasted food and proposes a solution to food insecurity, which is something 1 in 17

Minnesotans face (according to Feeding America). Partner with the health inspectors in your county

to distribute information on food donation and food waste avoidance.

Reuse

Reuse is a waste reduction strategy as it extends the useful life of items or materials. This keeps

materials in use and decreases the demand for new production. Compared to recycling, reuse further

reduces environmental harms. It accounts for embodied emissions and impacts from the upstream

manufacturing of materials and products. Recycling still requires energy and resource inputs to convert

an existing product into a material stock. Only then can it be incorporated into new production. This

generates additional environmental impacts and wastes that are not created when a product is reused.

The state of Minnesota also benefits economically and socially from reuse. According to a report

published by Reuse Minnesota, the reuse economy generates between $3.1 and $4.7 billion in revenue

each year. At the time of the report publication, there were more than 13,000 reuse businesses,

accounting for more than 45,000 jobs. Reuse jobs are usually not outsourced because they handle

existing products within a community or region, making reuse inherently local. The report estimates that

reuse contributes $2.4 billion in social value (i.e., benefits such as taxes, wages, and shareholder profits).

Resale, rental, repair, and sharing also expand access to items that may otherwise be unaffordable or

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impractical to individually own. Reuse training, skills development, and local events contribute to a

strong sense of community. A thriving reuse economy often depends on established networks. It

subsequently bolsters collaboration between businesses, educational institutions, organizations, and

residents.

For these reasons, it is critical that reuse strategies and programming be a higher priority and receive

significant investment at the state and local levels. Recycling and composting strategies are more

familiar and comfortable in most systems. Without distinct reuse targets, guidance, and goals, it is often

the default to fall back on end-of-life management and primarily direct resources and infrastructure

investment towards recycling and composting.

Some of the most successful and impactful reuse strategies are not new, innovative, or expensive

technologies. Revitalizing these strategies, determining the requirements or incentives that best support

them, and raising awareness or comfort with them is an important path forward for TCMA counties.

When proposing these strategies, take the time to engage across the community. This ensures they are

developed in an inclusive way so that implementation does not disproportionately impact certain

businesses or neighborhoods and participation increases. Particularly when passing policies that require

new actions or fees for specific entities, allow time for outreach and create support systems that aid in

that transition.

Required strategy:

The strategy listed below is required to be incorporated into the CSWMP because it is relatively simple

or has significant environmental benefit.

19. Offer grants or rebates for organizations to transition to reusable food and beverage service ware.

Reusable service ware is any product designed to be used for serving, consuming, or transporting

prepared food and raw food, including but not limited to reusable plates, bowls, trays, wrappers or

wrapping, platters, cartons, condiment containers, cups or drink ware, or any container in or on

which prepared foods and raw foods are placed or packaged for consumption. Reducing or

removing the barrier of the cost of investment for reusable service ware can help institutions to

make this change. Assistance should cover both the cost of materials and building modifications to

support the cleaning, storage and maintenance of reusable food and beverage service ware.

20. Offer grants for waste reduction, reuse, and repair. Shifting more funding into this focus area can

support the goal to minimize the need for disposal or recycling. Consider broad eligibility including

public, private, and non-profit entities. Do not specifying that projects need to be innovative as

organizations may already be contributing positively with their current reuse and repair offerings

and simply need the additional funding to support or expand their existing operations. Consider

expanding support offerings for grant applications and documentation as many reuse and repair

organizations may be smaller operations that have limited capacity and staffing for grant

administration.

21. Implement a green meeting policy. A "green" meeting is one that is organized and implemented in

such a way as to minimize negative impacts on the environment and promote a positive social

impact for the host community.

Optional strategies:

The following strategies are optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

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22. Implement a county policy encouraging the use of reusable food and beverage service ware.

Point Value: 6

This can be done as a “green event policy” or as a part of a sustainable government purchasing

requirement. This policy should include tracking and reporting to ensure it is being implemented.

This should be required of all county events and meetings.

23. Adopt an ordinance with a mandatory consumer charge or ban for single-use items.

Point Value: 9

The “Bring Your Own Bag” ordinance in Minneapolis can serve as an example of how to roll out an

ordinance to set a fee for single-use items. A set fee for each container type should be determined

by the ordinance. The ordinance may allow BPI-certified compostable and recyclable take-out

service ware. The fee will serve as an incentive for customers to participate in reuse behavior.

Alternatively, the ordinance can ban certain single-use items.

24. Join and/or actively participate in a reuse network, like Reuse Minnesota, to provide county and

city staff with learning opportunities to broaden their reuse expertise.

Point Value: 6

The most effective way to reduce waste is to not create it in the first place. As a result, reduction

and reuse are the most effective ways you can save natural resources, protect the environment, and

save money. County staff participation in this type of network also supports the development of

statewide resources, helps develop county programs, improves advocacy, and strengthens

connections for reuse organizations.

25. Establish a Repair Ambassador program, like the Recycler/Composters (RCAs) Ambassador

programs.

Point Value: 7

Programs exist in several counties and can be a collection of connections between skilled

individuals, for-profit and non-profit organizations, and a volunteer coordinator. Fix-It Clinics offer

free, guided assistance from volunteers with repair skills to disassemble, troubleshoot, and

potentially fix small household appliances, clothing, electronics, mobile devices, and more. Fix-It

Clinics teach valuable troubleshooting and basic repair skills, build community connections, and

reduce the number of repairable items that are thrown in the trash. These groups should have goals

to grow the volunteer base and offer regular fixer trainings to support Fix-It Clinics or Repair Cafes.

26. Establish a reuse location for residential drop-off and pick-up.

Point Value: 7

Some items are not accepted by reuse businesses in the region because they don’t have significant

resell value. Those items not desired by the reuse businesses in the region could be made available

to the public for free (reuse warehouse at the drop-off/transfer locations) or donated to other non-

profit thrift operations in the area. Items in poor condition would be managed through the existing

county solid waste and recycling channels.

27. Establish a curbside set-out day to allow residents to set out used items for reuse.

Point Value: 7

Coordinate this day to occur 1-2 days prior to curbside, large item pick-up by haulers and with reuse

businesses to pick-up unclaimed items.

In 2021, the Bloomington City Council passed a plan to

partner with Better Futures Minnesota for collection of reusables from curbside. The pilot program

has been in place since November 2022.

State-led strategies:

During information-gathering sessions with MPCA staff, metro counties noted that two of the main

barriers to working on waste reduction and reuse are lack of statewide legislation that support or

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advance these strategies and lack of consistent and clear measurement, including both standardized

methodology and access to environmental data. The following strategies address this input and are the

responsibility of the MPCA.

28. Develop standardized guidance and methodology for tracking waste reduction and reuse activities

and their resulting benefits. With the 2021 SCORE reporting, the MPCA added a reuse table for

counties to enter data for material and product reuse by the county or by organizations/businesses

in the county. These additional resources can be developed to further support and better

acknowledge reuse programming that counties implement going forward.

29. Research and pursue financial strategies to best incentivize waste reduction and reuse, such as

grants and loans. In the shorter term, the MPCA continues to explore opportunities for ongoing

funding for reuse by expanding eligibility with current grant programs and pursuing the

development of a reuse-specific program.

Collection best practices

A variety of methods are used to collect recyclables, organics, and trash. There is some room for

diversity in methods used from one community to the next. However, implementing best management

practices will increase the recycling rates in the region.

Required strategies:

The strategies listed below are required to be incorporated into the CSWMPs because they are relatively

simple or have significant environmental benefit.

30. Collect recyclables, organics, and trash on the same day. Same day collection of recycling and trash

makes it easier for residents to remember. Tracking different collection schedules can be

challenging, especially if change occurs often. Implementing same-day collection for recycling and

trash helps residents increase waste diversion. Counties should work with their cities to implement

same day collection for recyclables and trash. Counties or cities can implement this through

licensing or ordinance provisions.

Optional strategies:

The following strategies are optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

31. Collect recycling weekly by 2030.

Point value: 7

Recycling is collected bi-weekly in most cities with single stream recycling programs. Since recycling

carts often reach capacity during the two-week interval between collections, some residents throw

the extra recyclables into their garbage container. By offering weekly collection, the recycling carts

are less likely to exceed capacity. Residents who miss a bi-weekly recycling collection find

themselves with a month’s worth of recyclable material to fit into a cart that many times is

completely full after two weeks. If current driver shortages are affecting the ability to meet this

practice, the county should collaborate with haulers to develop a solution until the driver shortage is

resolved. Counties should work with their cities to implement weekly collection for recyclables. The

county can require weekly collection, or make sure that cities require it in their respective

ordinances or license provisions. Establishing a system that allows for free additional recycling bins

could also fulfill the objective of this strategy if residents are likely to have space for additional

containers and/or other local circumstances make weekly collection untenable.

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32. Pair the option of bi-weekly trash collection with weekly recycling and organics collection.

Point value: 7

By pairing weekly recycling and organics collection with bi-weekly trash collection, communities can

achieve greater recovery rates. Since most residential waste is recyclable or compostable, very little

waste remains in the trash when curbside recycling and organics programs are provided. Organics

collection removes the portion of the waste stream likely to decay, which causes bad trash odor, so

trash does not need to be collected as frequently. Offering recycling and organics collection weekly

allows for a transition to bi-weekly trash collection for residents that may want to, leading to

potential cost savings for haulers and residents. Bi-weekly trash collection incentivizes residents to

place all recyclable and compostable materials in the weekly containers and can result in greater

recovery rates. Counties should work with their cities to have the option to pair bi-weekly trash

collection with weekly recycling and organics collection.

33. Contract for residential recycling and organics by 2030.

Point Value: 7

Research has shown that organized recycling collection programs yield a higher recycling rate when

compared to non-organized recycling programs (The Benefits of Organized Collection, MPCA,

February 2012). Roughly 60% of communities in the TCMA offer organized recycling collection.

However, many cities still rely on subscription service provided by licensed haulers. While some of

these non-organized programs have been successful, the results from communities with organized

recycling are consistently stronger. By 2030, cities in the TCMA should provide organized recycling

collection for residents. To implement this strategy, counties may:

• Require that cities offer organized residential recycling collection to receive funding for

recycling programs.

• Provide technical assistance to cities developing and implementing an organized recycling

program.

The MPCA also plays a role in implementing this strategy and may provide technical assistance to

cities developing and implementing a new, organized recycling program.

34. Contract for residential MMSW collection by 2030.

Point Value: 7

In the TCMA, 37% of cities currently contract for residential MMSW collection, compared with

approximately 70% of cities nationwide. However, over the last few years, several communities

followed the process required by Minn. Stat. § 115A.94 and successfully implemented organized

MMSW collection programs for their residents. Although transitioning from an open MMSW

collection system to an organized MMSW collection system is not simple, there are many

environmental benefits of organized collection, and counties should work with cities to make this

transition.

In addition to the environmental benefits associated with increasing recycling, creating efficiencies

in waste collection can reduce both fuel consumption and emissions. Fuel consumption during

collection activities in cities with open collection systems is typically much higher than that of cities

with organized systems. The number of haulers and their market share can affect overall fuel

consumption and emissions. In an open system, trucks from many haulers travel the same alleys or

streets. In an organized system, there may be the same number of haulers, but only one truck

travels down each alley or street, resulting in lower fuel use because fewer miles are traveled to

collect the same amount of material. Simplifying the hauler routes leads to efficiencies that would

lighten the driver shortage. Open cities with one hauler assigned to more than 60% of the market

share (e.g., Eagan) would see a significant reduction in fuel use by switching to an organized system.

A city with many haulers, each having a smaller market share, (for example, St. Paul) would realize

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even greater savings. Fewer vehicle miles traveled also results in less air pollutant emissions from

heavy duty waste/recycling collection vehicles. Public concern has increased regarding human

health and environmental impacts of particulate matter and nitrogen oxides, which are emitted in

large amounts from heavy duty vehicles. (Source: The Benefits of Organized Collection, MPCA,

February 2012).

Organized MMSW collection programs are also often more cost-effective when compared to

subscription programs. Data in Table 4 was derived from the City of Richfield which was the most

recent city to organize trash collection. During its process, the city received bills from residents to be

able to assess the cost of collection prior to implementation. The monthly cost for residential

MMSW collection varies by container size. Although the cost for a 90-gallon cart is similar in both

systems, the cost in organized collection systems is lower on average.

Table 4. Monthly cost of residential MMSW service in the Richfield before and after organized collection

Container size

35 gallon

65 gallon

95 gallon

Subscription average

$16.33

$17.99

$18.85

Organized average

$11.90

$15.03

$18.16

Recycling management

Regionally, it is important to apply SMM concepts to prioritize targeted materials that are the most

recyclable materials over those with a more energy-intensive recovery process. It is also important to

identify and focus efforts on larger generators of recyclables. A regional plan for temporary storage of

recyclables will assure diverted materials are not managed at the lowest levels of the hierarchy.

Additional space for recyclables as a contingency plan if interruptions in the system occur can avoid

those materials potentially being landfilled or incinerated at WTE facilities. Preprocessing at WTE

facilities and landfills will increase recycling rates.

Required strategies:

The strategies listed below are required to be incorporated into the CSWMP because they are relatively

simple or have significant environmental benefit.

35. Recruit a minimum of 12 commercial businesses a year to recycle at least three materials from

their operations and promote the environmental and resource benefits. The commercial recycling

statute Minn. Stat. § 115A.151 requires businesses in the TCMA that contract for four cubic yards or

more per week of solid waste to recycle at least three materials. The commercial recycling law is an

opportunity for businesses to decrease their waste, reduce their taxes by increasing recycling, and

support Minnesota’s recycling industry, which creates approximately 37,000 jobs in the state. There

is no tax on recyclables or organics in Minnesota, but there is a 17% state solid waste management

tax charged on all commercial trash. Many counties charge additional taxes or fees as high as 53%

on trash, but not on recyclables or organics.

36. Establish mandatory pre-processing of waste at resource recovery facilities and landfills by 2030.

Achievement of the 75% recycling goal will require major system changes. Upfront processing of

waste to recover recyclables at transfer stations, resource recovery facilities, and landfills may help

achieve that. Steel and aluminum are the easiest to recover from MSW, but other materials should

be considered if possible. Processing methods should be evaluated prior to implementation to

ensure optimal effectiveness.

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37. Provide assistance to multi-family properties to improve recycling (4 or more units with shared

walls). Some examples of activities that would achieve this strategy include:

• Education to residents and property managers on how to handle and route materials to

their proper bins and how to recycle items not accepted in building provided collection

• Financial and/or technical assistance for infrastructure improvements and

implementation of improvements

• Assure property manager plans and provides sufficient space for collecting recycling

based on the number of residents

• Collaborate with cities to promote assistance resources, on-site education, and

implementation of recycling improvements

• Conduct outreach to multi-family association networks (e.g., Minnesota Multi Housing

Association) to promote resources

State-led strategies:

The following strategies are the responsibility of the MPCA to support the efforts of counties.

38. Assist with tracking commercial recycling self-hauling activities. In addition to establishing a

baseline, identifying the large volume generators of recyclables is necessary to developing a

targeted, effective commercial recycling program. The MPCA should review existing data from other

states and the EPA on typical generators of large quantities of recyclables and work with counties to

interpret this data for use in program implementation. If appropriate data is unavailable, the MPCA

will work with the counties to develop a list of large volume generators, as well as a list of

generators of the most impactful materials.

Recycling market development

Traditional recycling markets

Without end markets to use recyclable material, there is no recycling. Recycling market development

(RMD) creates and maintains demand for recyclable materials. End markets buy these materials for

further processing or to produce products. RMD looks at the highest and best use of post-consumer

discards from the waste stream. Recycled material used as a commodity in a manufacturing process

generates economic activity.

MRFs and haulers have invested in artificial intelligence technologies and sorting equipment. Domestic

end markets have expanded in response to surplus of material. The COVID-19 pandemic and rise of

online shopping has shifted the market for OCC and paper. Market demand for other materials has

increased in the last 18 months.

Capacity in Minnesota's recycling economy is expanding. MyPlas, capable of processing 90 million

pounds of film plastic annually, will soon open in Rogers. Minnesota is home to manufacturing plants in

Paynesville, Worthington, and Garfield that produce plastic lumber from post-consumer materials.

Plastic lumber is made into furniture in Duluth and Jordan. Minnesota’s plastic lumber markets include

marine, landscaping, and parks and recreation.

However, there have been worrisome losses of markets since 2018 with capacity also shrinking.

WestRock in St. Paul processes 600 tons of mixed paper and cardboard per day, a reduction from the

former daily capacity of 1,200 tons after the closure of the corrugated medium manufacturing

operations in October 2022. Major closures in the TCMA since 2018 include:

• Gerdau Ameristeel Recycling Plant– recycled 560,000 tons of scrap steel annually

• Ball/Rexam– made 2 billion aluminum cans/year

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• Brotex – no longer recycles 6,000 tons/year of carpet from Minnesota

• WestRock– recycled OCC (corrugated cardboard) 200,000 tons/year (portion of their plant) in

addition to the reduced mixed paper capacity

• Verso Paper Mill in Duluth –recycled mostly industrial paper trimmings

Capacity is under attack in other ways. Overseas markets have forced MRFs and haulers to make

expensive investments in infrastructure. Minnesota has one of the lowest residual rates in the country.

Residuals are the fraction left over from processing recyclable materials. Yet with supply high and

demand low, buyers can be picky. Cleaner material is of higher value and sells more easily.

Markets are cyclical. We must maintain investment in new technologies for sorting equipment to remain

competitive. We need to focus on supporting our local businesses and economies and keeping jobs and

tax dollars in Minnesota. We need to invest in new products produced with recycled materials.

Investments in technology at MRFs helps make that possible.

State-led strategies:

The following strategies are the responsibility of the MPCA and will support counties.

39. Support and invest in new facilities and retain processors of recycled material for end markets.

Establish a directory of processors throughout the state. Dedicate staff resources to assisting and

connecting local processors that prepare collected material for end markets to manufacturers.

Processors need to maintain and upgrade equipment to be competitive. Investing in new and

upgraded facilities is a benefit to the local recycling market and supports the economy.

Organics management

Organic materials account for approximately 25% of the waste thrown away by Minnesotans. Preventing

wasted food and rescuing edible food are strategies that offer the greatest environmental benefit for

managing organic materials. Based on EPA’s WARM calculations, preventing one ton of food waste

results in 20 times fewer GHGe than composting one ton of food waste. Policies oriented to enhance

those efforts are included in the waste reduction and reuse section of this MPP. However, composting

and feeding food to livestock or backyard chickens are also important strategies for situations where

prevention and rescue were unsuccessful. Counties are encouraged to collaborate with partners to

develop and implement best practices to expand organics collections. Partnerships with organizations

like the Minnesota Composting Council (MNCC), Food Rescue non-profits, waste haulers, Minnesota

Waste Wise and others could lead to better program development and faster progress towards recovery

goals.

Anaerobic digestion is covered in the emerging technology section of this MPP.

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Anoka County Rice Creek Compost Site Organics

Pilot Project

The Anoka County Rice Creek Compost Site, located in

Lino Lakes, serves the eastern half of Anoka County.

Accepted materials are yard and tree waste, as well as

organics recycling. Visitors reported the site as difficult

to navigate due to wet and muddy road conditions.

Demand often exceeded capacity.

To address the issues, Anoka County acquired an

adjacent property on higher ground in 2015 to make

improvements. Site design, building removal, building

construction, road construction, and surface

improvements were completed in 2021 to improve site

access, improve traffic flow and safety, expand capacity

for processing of organics in the north metro, and allow

for a greater number of visitors. Over the last three

years, an average of nearly 7,000 vehicles visited

annually.

Early in the planning process, one of the existing

buildings on the new property was identified as a possible solution for processing organics collected at

the organics transfer station. Anoka County and its site contractor, OTI, Inc. approached the MPCA

with the possibility of composting organics within the covered enclosed barn as an adjacent facility to

the yard waste facility. The county discussed the operation with the MPCA and then began operating a

small-scale composting site. The site is managed in a manner consistent with MPCA rules that govern

small compost sites. This resulted in the first-of-its-kind small-scale composting facility adjacent to a

yard waste facility.

Organics are collected from the public at the organics drop-off on site, then brought into the barn and

combined with tree and leaf waste from the yard waste site to be processed into compost. The pilot

has completed, and the site is considered fully operational. The finished compost is available for

purchase to residents during spring through mid-fall.

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Required strategies:

The strategies listed below are required to be incorporated into the CSWMP because they are relatively

simple or have significant environmental benefit.

40. Make residential curbside organics collection available in cities with a population greater than

5,000 by 2030. Drop sites collecting organics have been well received in the region. However, they

appear to only be reaching the most enthusiastic residents. Like curbside recycling services,

programs should be offered to all single-family dwellings, duplexes, and small multifamily

properties. Programs that charge all eligible households must comply with Minn. Stat. § 115A.93,

subd 3 (c). This means all haulers must charge and offer organics to everyone. If offered as a

subscription service, the licensing authority must make sure that haulers are compliant with

115A.93 subd 3(c). Programs that charge all eligible households, comply with the statute, are

cheaper per household and reduce barriers to participation. Additionally, programs with the lowest

contamination are supported by robust education. Curbside collection requires proper and frequent

education to be successful. It ensures programs are accessible and maximizes participation.

41. Expand backyard composting outreach and resources for residents. Provide resources needed to

set up a simple yard waste compost pile and education to assure implementation is sustained.

Establish a webpage with an explanation all available resources. Promote the program at least twice

per year to residents. This will be especially important in areas experiencing hauler shortages for

yard waste.

42. Require management of organics from large commercial food generators by 2033.

Commercial and industrial entities that generate large volumes of organics (e.g., restaurants,

grocery stores, and food processors) must have an opportunity to reduce their environmental

impacts. They often reduce their disposal costs by first preventing food from going to waste. They

also rescue food and recycle food waste. As noted in the SMM section, the most impactful action is

to reduce the amount of food waste created. Only then should focus shift to rescue of remaining

edible food. Local policies should first require adoption of policies that support the prevention and

rescue initiatives at large generators.

After the adoption of prevention and rescue initiatives, large generators must implement organics

recycling programs. This serves to capture the remaining organic material they would otherwise

discard. Many communities like Hennepin County and Western Lake Superior Sanitary District

(WLSSD) have already adopted policies requiring large generators like grocers and restaurants to

implement these types of programs. Large volumes of material are being captured and used to

create compost or feed livestock.

Optional strategy:

The following strategy is optional and may be incorporated into a county CSWMP. Each strategy has

been assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

43. Establish additional organics recycling drop-off sites.

Point Value: 7

Many counties offer organics drop-off sites, which have been successful at capturing food waste for

households without curbside collection. Site selection should be in convenient, well-lit places. This

strategy can be paired with multi-family recycling strategies to provide opt-in access to residents

without curbside collection of organics recycling.

State-led strategies:

The following strategies are the responsibility of the MPCA to support counties.

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44. Standardize the role of compostable products in organics recycling programs by 2025. Most of

Minnesota’s composting programs have included compostable products as acceptable materials.

Some metro cities have adopted ordinances requiring the use of compostable take-out containers.

Compostable product advocates suggest they capture more food scraps and increase recycling rates;

however, MPCA is not aware of any research that confirms this claim. A study from Oregon using life

cycle analysis of compostable products has shown unfavorable results, even when compared to

single use disposable items. Standardization of compostable materials will reduce resident confusion

and reduce contamination for compost facilities.

Wood waste & EAB

The TCMA is heavily impacted by EAB, with an estimated 20% of community trees being ash. All seven

metro counties are included in the Minnesota Department of Agriculture’s (MDA) EAB quarantine area,

with infestation observed throughout the area. Additionally, climate change has increased the severity

and frequency of storms that knock down trees and branches that must be quickly removed to preserve

access to sidewalks and roads and to restore power. These factors have led to large volumes of wood

waste. The trajectory of the EAB infestation suggests we are still five to ten years from peak volumes of

wood waste in the TCMA (see Figure 9).

Figure 9. Projected county infestation impact in Minnesota due to EAB

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Currently, the St Paul Cogeneration (SPC) District Energy plant in St Paul manages approximately

250,000 tons of wood waste annually. The District Energy facility is a combined heat and power plant

fueled by biomass. In recent years, the facility has accepted wood waste at no charge and relied upon

the energy fees collected from its district heating customers and revenues from electricity sold to Xcel

Energy to finance the plant. The Public Utilities Commission has indicated it no longer supports relying

on just energy fees and electricity sale revenues to operate the facility and other revenue sources are

needed, such as a tip fee for wood waste delivered to the plant. Other solid waste streams rely on tip

fees to operate facilities to process the materials they receive. As such, it is a reasonable and credible

path forward for wood waste generators to pay a tip fee to bring wood waste to the facility in order

assist with a portion of the facility’s expenses. It is also possible that the facility will cease operations if

the facility is unable to fill the revenue shortfall.

With the District Energy facility, capacity for managing wood waste is already strained and being used to

the maximum that the current contract allows. If the facility ceases operations, capacity to handle wood

waste will be drastically reduced, likely triggering a massive increase in open burning piles. Open burning

creates a large amount of small particulate matter that can cause problems for people with asthma.

Even if District Energy operations continue, it is certain that additional markets are needed to ensure we

direct wood waste to its highest and best use and have capacity to manage the anticipated rising

tonnage of material.

Hierarchy of ash tree material management:

The MPCA partnered with the Environmental Quality Board (EQB), the Department of Natural Resources

(DNR) and the Department of Agriculture (MDA) to release a report on EAB in 2019. The report

details

the scope of the problems caused by EAB and suggests strategies for meeting the challenges. The report

also includes a hierarchy of ash tree materials management that seeks to prevent wood waste and to

utilize wood for its highest and best use. The hierarchy should guide county planning efforts to minimize

the environmental impact of managing wood in their communities. Other tree species are facing similar

infestations and diseases. Counties are encouraged to address emerging tree diseases and pests with

prevention efforts, when possible, to avoid the generation of wood waste.

The following strategies are needed to meet the challenges of managing wood waste throughout the

TCMA during the upcoming planning cycle. The strategies will flatten the curve of waste trees

generated, support existing markets for wood waste, and develop new markets to help relieve the

pressure on current markets to handle the material.

Required strategies:

The strategies listed below are required to be incorporated into the CSWMP because they are relatively

simple or have significant environmental benefit.

45. Develop plans to prevent and manage wood waste in each county and throughout the region.

Plans should assume that biomass plants, including SPC’s District Energy, will have tip fees to ensure

long-term economic viability. Plans should also not assume the Legislature will provide appropriate

funds to biomass plants to allow for their continued operations without a tip fee. Plans should be

modified to collect data to improve understanding of the wood waste challenges—at a minimum

the amount of wood waste being generated and processed at wood yards. This means that plans

should include an ordinance requiring wood yards to register with the county and report volumes of

wood waste collected, managed, stored, and disposed. Additional data should be collected on tree

inventories and on facilities and industries (biomass, compost sites, mulch producers, tree care

companies, etc.) that can participate in discussions about wood waste management. Plans should

consider setting goals, especially for wood waste management options that offer the greatest

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environmental benefits. Plans should include strategies to educate the public about EAB, tree

treatment and preservation, and responsible wood waste management.

46. Promote existing programs that use EAB-affected wood for furniture, home goods, flooring, and

other purposes. While the volume of wood waste managed via these industries in these areas is not

enormous, these industries do play an important role in the system by using wood to produce

products, thus preventing waste. Additionally, these industries frequently educate the public about

EAB, and they provide important economic benefits through the jobs they create and

support. Ensure that these organizations are successful and continue to be available. Develop

county purchasing requirements to utilize urban wood when available and encourage residents to

purchase products made from urban trees. Consider financial support when appropriate.

47. Composting and mulching operations must continue to be supported. These industries provide an

important outlet for wood waste management. Additionally, they serve as important infrastructure

to help manage additional types of organic waste (i.e., yard waste and food scraps). Support that

would meet this requirement could include grants or financial assistance to compost facilities,

contracts that commit certain volumes of material to sites over a multi-year term, assistance with

siting and/or meeting local permitting or land use requirements and promoting the use of the sites

to the public and/or alternate strategies that ensure the long-term viability of composting capacity

in the region.

Optional strategies:

The following strategies are optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

48. Update ordinances that address wood burning.

Point Value: 4

Update ordinances defining rules for burning wood, including restrictions on commercial and

municipal burning. Establish requirements that minimize the environmental and human health

impact. Open burning is the least preferable management method. Expanding other management

methods is the best way to avoid open burning.

49. Develop and distribute EAB tree care education programs for privately owned land.

Point Value: 8

Education through digital marketing and paper mailers should include an explanation of the risks to

ash trees, why a mature tree canopy is important, and focus on the benefits and cost savings of

treatment versus removal.

50. Incentivize tree treatment as a cost-effective strategy to extend the life of ash trees and to reduce

the volume of wood waste generated over the next 20 years.

Point Value: 8

Counties are encouraged to incentivize treatment of private and public trees and to develop

financial incentives and/or provide support for treatment and tree preservation. It is much less

expensive to treat trees and keep them living than to remove and replace them.

51. Allow assessments on property taxes to spread the cost of tree care over a multi-year timeframe.

Point Value: 9

Some communities have used tax assessments to fund tree care services even on private property.

This would allow homeowners to defer costs to make tree care services available and affordable.

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52. Expand composting and mulching capacity beyond existing markets.

Point Value: 5

Counties and/or cities can contribute to expanded capacity by offering commitments to deliver

organics or wood waste at stable tip fees, purchasing compost and mulch, assisting sites in coming

online and/or offering other financial, policy or technical support. This could be accomplished by

developing the capacity for biochar or other new technologies. Biochar is a carbon-rich soil

amendment and agricultural byproduct. It generates energy from biomass in the absence of oxygen.

Biochar operations are in early stages in the TCMA but may use wood waste in a beneficial way. The

City of Minneapolis collaborated with Hennepin County to begin using biochar for landscaping in

2019. Counties and cities can develop additional capacity by providing financial support and siting

assistance and adopting policies that support capacity development.

53. Support development of systems that use wood fuel.

Point Value: 4

Incentivize retrofits through financial or policy initiatives for heating with efficient, low-emissions

wood burning appliances. Encourage use of Environmental Initiative's Project Stove Swap

. Burning

wood in retrofitted stoves is preferable to open burning. This strategy also reduces reliance on fossil

fuels for home heating.

State-led strategies:

The following strategies are the responsibility of the MPCA to support counties.

54. MPCA will continue state agency coordination to address wood waste. MPCA works with

Minnesota Department of Natural Resources and Minnesota Department of Agriculture on wood

waste issues. Some of the topics needing state level coordination include, but are not limited to,

open burning permits, grants for tree management to local governments, and developing

educational resources for local government and residents.

Organics market development

The MPCA, along with many municipalities in the TCMA, is working to bring organics collections to

curbside containers, drop off sites, sports facilities, and commercial businesses. Opportunities to reduce

wasted food and rescue food are most impactful. Food waste that cannot first be prevented or donated

should be composted, fed to livestock, or rendered. There are well-identified market expansions for

compost.

Use of compost in roadside and other construction projects has many benefits. Compost helps amend

soils, so they are better equipped to support plant growth, aerate compacted soils, prevent erosion, and

infiltrate runoff to prevent pollutants from entering lakes and streams.

Required strategy:

The strategy listed below is required to be incorporated into the CSWMP because it is relatively simple

or has significant environmental benefit.

55. Require food-derived compost in county construction and landscaping projects.

Several communities have established practices to incorporate the use of compost into routine

operations. Implementing compost specifications into Minnesota’s county construction efforts

would help expand markets for compost and ensure that those projects are conducted in a way that

better protects Minnesota’s lakes, rivers, and streams. In revising their specifications for compost,

MnDOT updated the 3890 specifications to include compost products that are derived from food

scraps in Grade 2 compost. Counties should specify in ordinances the use of a percentage of Grade 2

compost in roadside construction and landscaping projects, in keeping with the MPCA stormwater

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manual. Several communities are establishing such requirements. For example, Denver Colorado has

a Soil Amendment Program that requires new residential, commercial, industrial, and government

properties to use compost. Eagan also has an ordinance requiring organic matter (Grade 2 compost)

be used at no less than 5% at sites with greater than 10,000 square feet of land disturbance.

Counties should partner with their public works departments to develop an ordinance that makes

incorporating food-derived compost a default purchase.

Optional strategy:

The following strategy is optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

56. Find new outlets to increase food to animal operations.

Point Value: 7

For food that cannot be prevented or donated, counties may work with the Board of Animal Health

(BAH) to promote and expand food-to-animals programs. A county may solicit new partners to

receive a garbage feeder permit, which must be obtained from BAH. An existing list of approved

food-to-animal garbage feeders can be found on BAH’s website:

https://www.bah.state.mn.us/swine/

. Support for the new outlets will help assure their long-term

viability. The CSWMP must include a plan for addressing food to animal opportunities within the

county.

Emerging technology

The solid waste system is evolving. Waste materials change and the technology to separate materials

continues to improve. These changes improve our ability to divert more material from land disposal. Yet,

the environmental impacts of some of these new technologies are not well known, creating challenges

because the new technologies do not fit neatly into current rules and the Solid Waste Management

hierarchy. As a result, MPCA and others need more time to understand the new technologies to

determine what permits they may need and how they may fit into the Solid Waste Management

hierarchy. An example is whether new technologies meet the technical requirements for recycling. If

they do, this brings the benefit of tax-exemption status for facilities. Processed materials could also

count toward county recycling goals. If they do not, waste is being handled lower on the waste

hierarchy.

Anaerobic digestion of food has been a focus of several metro counties, to keep food out of landfills.

Stakeholders note the need for more clarity surrounding anaerobic digestion. In response, a review of

the solid waste management hierarchy and definitions under Chapter 115A was conducted to provide

direction as to when anaerobic digestion could count towards county recycling goals. It was determined

that organic materials going to an anaerobic digestion facility do not automatically count toward county

recycling goals.

The MPCA must consider on a case-by-case basis whether activities at an anaerobic digestion facility

meet existing definitions of recycling, for purposes of meeting the recycling goals found in Minn. Stat. §

115A.551 and/or the definition of recycling in Minn. Stat. § 115A.03, subd. 25b. Please note:

• Anaerobic digestion facilities that accept source-separated compostable materials (SSCM) and

then compost the digestate can count this material towards a county recycling goal if they

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demonstrate the process used aligns with the requirements included in Minn. Stat. § 115A.03

subd. 32a

1

3

.

• Other types of organic materials may also count towards a county recycling goal if a county can

demonstrate that digestate from the anaerobic digestion process is used “in manufacturing

processes that do not cause the destruction of recyclable materials in a manner that precludes

further use.

23

45

”

• Use of digestate for alternative daily landfill cover is not considered recycling because this

application precludes further use and because landfilling is not recycling. The MPCA holds a

long-established position that alternative daily landfill cover is not recycling

4

6

.

• Anaerobic digestion processes that capture biogas but do not produce a useable digestate may

be considered resource recovery, but not recycling.

A hypothetical example of an anaerobic digestion facility that would potentially satisfy existing

definitions is one that receives source-separated organic materials, uses the anaerobic digestion process

to capture biogas to create energy for use, and produces a digestate that is composted and produces a

class I or class II compost. In view of the variety of materials and designs for anaerobic digestion

facilities, the MPCA looks forward to discussing proposals with stakeholders for purposes of meeting

recycling goals and solid waste planning. Stakeholders are encouraged to reach out to agency staff to

initiate conversations about specific scenarios for further clarity on classification of materials sent to

anaerobic digesters.

Additionally, it is important to note that the EPA’s food hierarchy describes anaerobic digestion as a

process that produces both biogas and a soil amendment

5

. The MPCA is continuously engaging with EPA

on this topic to ensure consistency and accounting for the best available information. The agency is also

pursuing LCA research to provide Minnesota-based environmental analysis for the anaerobic digestion

of food waste.

Gasification and plastics-to-oil technology have been proposed and even temporarily in business in the

state. The long-term viability of these technologies is unknown as Rational Energies in Plymouth went

out of business when it was unable to sell its fuel. The MPCA views them as similar to WTE operations

rather than recycling. As such, the MPCA does not allow for these types of facilities to take source

separated plastics or other recyclables in their operations.

State-led strategies:

The following strategies are the responsibility of the MPCA to support counties.

57. Develop a process for gathering the information necessary to make timelier and consistent policy

decisions. The MPCA should evaluate the various levels of the hierarchy using a life cycle

perspective to determine future policy decisions around new technologies. The evaluation should

include:

• Use of existing life cycle analysis, such as the Municipal Solid Waste Decision Support Tool

1

https://www.revisor.mn.gov/statutes/cite/115A.03#stat.115A.03.32a

2

https://www.revisor.mn.gov/statutes/cite/115A.551#stat.115A.551.1

3

https://www.revisor.mn.gov/statutes/cite/115A.03#stat.115A.03.25a

4

https://www.pca.state.mn.us/sites/default/files/w-sw-1-31.pdf

5

Per EPA’s Anaerobic Digestion section of their Food Recovery Hierarchy: https://www.epa.gov/sustainable-management-

food/industrial-uses-wasted-food

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• Research waste management methods including, but not limited to, land disposal, resource

recovery, composting, anaerobic digestion, plastics to oil, recycling, and food to livestock

• Identification of gaps in life cycle analysis data and research funds needed to fill those gaps

• Development of solid waste life-cycle policy recommendations

• When needed update state rules for new technology such as anaerobic digestion once

sufficient data is in place to inform the process

• Develop a framework for preferred technology

Waste-to-energy

The Waste Management Act identifies a hierarchy that the MPCA is bound by statute to follow, which

outlines WTE is preferred over landfills. The following items support this preference for WTE over

landfills as a method for waste disposal.

WTE has a significantly smaller climate impact. Landfills produce over three times the amount of GHGe

compared to WTE. While operational, the GHGe are similar from WTE and landfills. There is a stark

difference at end-of-life. Landfills continue to generate GHGe for decades after closure, while WTE

facilities only emit GHGe while operational.

Figure 10. Total GHG generated by landfill and WTE from start of disposal through closure and beyond

After closure, landfills continue to create pollution. Beyond the creation of GHGe, landfills continue to

create leachate with contaminants in it. Unless properly managed, leachate can seep into groundwater.

Leachate that goes to wastewater treatment plant in part ends up in surface waters due to lack of

treatment technologies for many of the contaminants.

WTE recovers more materials and energy compared to landfills. A portion of the MMSW delivered to

resource recovery facilities is diverted to be recycled or recovered for organics management, which is

counted as recycled in the objectives in Table 2 and Table 3 (see table footnotes). WTE generates heat

and power that contributes to the power grid across the state. Without WTE facilities, additional heat

and power must be generated through other methods, which can include burning natural gas or coal to

make up the difference.

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WTE provides other useful services. WTE facilities are used to destroy pharmaceuticals and drugs for law

enforcement departments. Disposal of pharmaceuticals in landfills leads to additional contaminants in

leachate, that are not treated.

While WTE has benefits compared to landfilling, the waste hierarchy prioritizes waste reduction, reuse,

recycling, and composting over WTE.

Air emissions from WTE and landfills, while meeting state and federal standards, contribute to the

overall impacts experienced by neighboring communities. Landfills and WTE facilities located in or near

environmental justice areas have a negative impact on communities already overburdened by pollution.

WTE facilities in general produce more dioxins, furans, lead, and NOx (nitric oxide), while landfills create

more fine particulate matter (PM

10

and PM

2.5

), CO (carbon monoxide), methane, and VOCs (volatile

organic compounds).

Figure 11. Municipal Solid Waste: Landfill vs. WTE

The MPCA acknowledges the impacts to residents near WTE facilities and landfills that the past siting of

facilities disproportionally impacted disadvantaged communities. Reducing our reliance on WTE facilities

and landfills through waste reduction and increased reuse, recycling, and organics recovery is the best

way to avoid shifting pollution from one environmental justice area to another. Only then would it be

appropriate to set a timeline for taking facilities off-line.

The MPCA supports managing waste as high on the waste hierarchy as possible, as is evident from the

strategies in this plan. The solid waste system of the TCMA is not prepared for closing WTE facilities

without development of needed infrastructure, programing, and education. The closure of the Elk River

WTE facility resulted in increased landfilling, rather than increasing recycling and composting.

On October 24, 2023, the Hennepin County Board passed a board action resolution that instructs county

staff to develop a plan for the closure of HERC between 2028 and 2040. Considering the Board’s

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decision, MPCA expects Hennepin County to develop a contingency plan consistent with the

expectations under strategy 12. Ensure there are contingency plans in place if for large facility closures

in order to reduce the likelihood of landfill reliance. Changes in management strategies involving large

volumes of waste will have regional and potentially statewide impacts. Planning and resource

investments are needed to ensure subsequent waste management systems minimize environmental

impacts, are cost effective and do not result in increased burdens in communities already experiencing

environmental justice concerns.

Table 5. Existing resource recovery facility capacity serving the TCMA

MMSW processing

facility

Permitted

capacity

Greater Minnesota-

forecast tons per

year

TCMA- forecast

tons per year

Total -

forecast tons

per year

HERC

365,000

0

365,000

REC

450,000

0

450,000

City of Red Wing

36,000

23,000

13,000

36,000

Interested parties in the public and private sector need to work collaboratively to improve processing of

collected materials in a way that will capture more recyclables and assess the efficacy of policies.

The MPCA has regulatory authority to ensure implementation of ROD (Minn. Stat. § 473.848) and public

entity requirements (Minn. Stat. § 115A.471), both of which require processing of MMSW. Hennepin

County and jointly Ramsey and Washington counties have successfully directed waste to their own

processing facilities. Designation in Goodhue County has stabilized the base amount that Red Wing

receives with tonnage being supplemented with contract waste from two cities in Dakota County. These

efforts have allowed the three facilities to operate at full capacity. If there are delivery shortages of

waste at the resource recovery facilities listed above, the landfills are obligated to fill the shortage or

stop accepting waste. The MPCA expects that operational WTE facilities will continue to run at full

capacity going forward.

Required strategy:

The strategy listed below is required to be incorporated into the CSWMP because it is relatively simple

or has significant environmental benefit.

58. Counties must continue to support the implementation of Minn. Stat. § 473.848 Restriction on

Disposal. Operating resource recovery facilities at full capacity is important. Continue to require

delivery of county waste to WTE facilities, if available. Submit timely ROD reports. Continue to

actively participate in the quarterly certification process. Facilitate communication between

facilities.

Landfilling

The system objectives strive to reduce land disposal to 5% of MMSW generation within the next ten

years, recognizing that some MMSW is not processible. Some disposal options will always be necessary.

If the MMSW cannot be prevented, reduced, reused, recycled, or composted, it should first go to a

resource recovery facility. Only then, if the waste is not processible, should it be landfilled.

Optional strategies:

The following strategies are optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

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59. Implement additional fees to better account for the externalities of land disposal.

Point Value: 4

Landfilling is the least expensive option at the point of disposal, but the externalities like operating

the closed landfill program, groundwater monitoring, and managing vapor intrusion, make it more

expensive in the long run. Closed landfills must be monitored and managed in perpetuity to protect

the environment and human health. They produce contaminated fluids (leachate) and gases that

must be managed properly to avoid polluting groundwater or affecting nearby structures. Finding

solutions to minimize land disposal and move waste up the hierarchy will save taxpayers money in

the long term. Ramsey County’s environmental charge on MMSW is a good example of a possible

strategy to better reflect the true costs associated with disposal. Placing a county fee on every ton

of MMSW delivered to landfills can provide revenue for preferable waste management programs

and can contribute to prices for residents and businesses that reflect actual, long term disposal

costs.

Product stewardship

Managing waste in Minnesota is a challenge that requires consistent innovation. One evolving concept

pertains to who should be responsible for managing waste. The beverage industry's shift from reusable

containers to disposable resulted in an increased amount of waste. In the 1970s, other states began to

introduce "bottle bills." also known as container deposit return laws, to address these concerns. This

introduced the concept of industry managed product return programs.

Product stewardship was introduced in the 1990s. Product stewardship aims to shift responsibility for

negative impacts to the economy, environment, public health, and worker safety to designers,

manufacturers, retailers, and users of consumer products. Product stewardship should focus on the

impacts of a product and its packaging throughout all lifecycle stages. This includes the material type,

toxicity, raw materials, design, and recyclability.

Minnesota was a product stewardship leader in the early 1990s. Lawmakers introduced Minn. Stat. §

325E.125, subd. 3, requiring manufacturers to collect and recycle rechargeable batteries. Since then,

more than 30 states have adopted product stewardship laws, including 25 states with e-waste laws. The

manufacturer takes responsibility by paying to collect and recycle the products covered under law, with

the products covered varying widely from state to state.

Manufacturers have continued to produce without planning for the end-of-life (EOL) management of

products and by-products. Updates to the law are needed to address the full scope of the lithium

battery issue. When manufacturers are responsible for end-of-life costs, it incentivizes toxicity

reduction, consideration of processing costs, and recovery yields. First Solar's take-back program is a

great example of EPR. The company recovers materials from retired solar panels to create new panels.

The cost of this service is passed on to the owners of the solar panels.

States have been introducing product stewardship laws that focus on materials such as solar panels,

carpet, mattresses, and packaging. Studying the development of product stewardship adaptation in

other areas of the country provides many benefits. It gives Minnesota an opportunity to avoid pitfalls

and focus on proven strategies.

Required strategy:

The strategy listed below is required to be incorporated into the CSWMP because it is relatively simple

or has significant environmental benefit.

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60. Participate with the Product Stewardship Committee under the Solid Waste Administrators

Association (SWAA). SWAA provides peer-to-peer networking opportunities, and the Product

Stewardship Committee allows for targeted information sharing. Consistency in product stewardship

goals between the metro counties is imperative for planning how to handle post-consumer

materials. Strong county coordination and support of product stewardship approaches by the

counties can help enact legislation and programs at the state level to move the state forward. State

policy and actions can help lead to regional and national initiatives.

Household Hazardous Waste (HHW)

HHW facilities play an important role in capturing products or wastes that are not amenable to

management at other waste facilities. They reduce the toxicity of the solid waste stream by providing

households with an opportunity to bring pesticides, drain cleaners, mercury thermometers, stains, or

varnishes, and other such products to drop-off sites. This prevents exposure and operational problems

at other solid waste facilities from common HHW.

HHW collection programs are statutorily mandated to remove hazardous materials from the solid waste

stream. Each of the metropolitan counties has at least one year-round site for the collection of HHW. A

Reciprocal Use Agreement allows residents to use any of the HHW collection sites located in Anoka,

Carver, Dakota, Hennepin, Ramsey, and Washington.

Required strategy:

The strategy listed below is required to be incorporated into the CSWMP because it is relatively simple

or has significant environmental benefit.

61. Encourage retailers to increase consumer awareness of responsible end-of-life handling for

products containing lithium-ion batteries. It is illegal to discard rechargeable batteries in the trash.

It is important to manage batteries properly to avoid creating serious safety hazards. HHW sites are

safely collecting these, but consumers are not always aware that products they purchase contain

lithium-ion batteries. This strategy can be accomplished by sending a letter to all licensed tobacco

retailers in your county with information such as how to request signage about HHW drop-off

locations and the risks associated with improper disposal of lithium-ion batteries.

62. Continue participation in the reciprocal use agreement for HHW collection sites. This agreement

allows residents of all seven metro counties to use any collection site located in the TCMA. The

MPCA values the convenience provided to TCMA residents with the reciprocity agreement. The

agreement should continue to be in place into the future to continue providing this service to area

residents.

63. Partner with cities to increase participation in HHW collection.

Traditional methods of HHW collection capture some of this waste, but there are households that

do not participate for a variety of reasons.

Private companies providing specialized HHW services,

retailers, cities, and other counties should collaborate to increase the number of households

effectively diverting their HHW from their trash. Expanding methods of collection could increase the

amount of HHW collected.

Optional strategies:

The following strategies are optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

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64. Host monthly drop-off sites in locations other than a permanent HHW site.

Point Value: 8

The focus can be on a particular type of material, like lawn and garden chemicals in the fall, or a

general collection of HHW. Ramsey County has a mobile site for general HHW collection that moves

to a new location each month.

Sustainable Building and Deconstruction

Construction, renovation, and demolition of buildings, roads, and bridges produces demolition debris.

Traditional demolition is wasteful and destroys usable, valuable materials. Demolition activities usually

involve destruction of building materials, which are then mixed and placed in a dumpster. Once

materials are mixed, it is difficult to separate them. Mixed materials may be sent for recycling, but at

that stage the amount that can be recovered is minimal.

Most of the mixed materials end up going to a landfill. Better handling and preservation of existing

materials would reduce unnecessary waste. Materials like concrete, wood, and metals could be diverted

for reuse or recycling. In 2021, an estimated 4,842,000 tons of ISW and demolition debris was land

disposed. Current ISW designation has resulted in inexpensive land disposal. While it is not the intended

use, ISW designation can be used for demolition debris. The result has been growth in non-MMSW

(demolition debris and ISW combined) since 2009. By comparison, MMSW experienced modest growth.

Construction and demolition waste landfills in Minnesota are governed by laws promulgated in the late

1980s, which do not require these landfills to be lined. Groundwater monitoring from these landfills

found heavy metals at amounts that exceed levels safe for human health. The presence of contaminants

of emerging concern were also detected.

Table 6. 2021 disposal in facilities that accept TCMA waste

Waste type

Landfill type

Quantity

Industrial Solid Waste (ISW)

MMSW landfills, ISW Landfills, Class III Demo

landfills or to ISW cells at MMSW landfills

3.41 million

tons

Construction/Demolition Debris

MMSW landfills, ISW landfills, all types of

Demolition Landfills

1.43 million

tons

Mixed Municipal Solid Waste

(MMSW)

MMSW Landfills

1.10 million

tons

Industry has opportunities to improve sustainability in earlier stages of material design and

manufacturing. The production of building sector contributes significant GHGe. Building design,

maintenance, preservation, and removal also provide opportunities to address sustainability. TCMA

counties must consider the broader climate impacts of buildings, beyond end-of-life management.

The greatest environmental benefits are driven by prevention, achieved by reusing existing structures

and materials. For example, reuse of buildings with average energy performance provides a greater

GHGe reduction when compared to energy efficient new construction. Building preservation and reuse

provide the greatest opportunity to avoid GHGe. Furthermore, reused building materials are also

diverted from landfills. The TCMA has a low recycling rate for construction and demolition material.

While increasing the recycling rate could have benefits, prevention will be the most impactful.

Preservation maintains the location and as much of the existing structure as possible. Renovation can

provide improved efficiency and usability. Structural moving keeps a functional building in circulation.

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Figure 12. Sustainable Building SMM Guidance from most to least preferred management methods

Required strategies:

The strategy listed below is required to be incorporated into the CSWMP because it is relatively simple

or has significant environmental benefit.

65. Implement the use of a Building Material Management Plan. Also commonly known as Material

Conservation and Waste Management Plan, this tool is for buildings going through renovation or

deconstruction to document the destination of materials in building/unbuilding projects during and

after project completion.

Require that a building material management plan be used for specific non-government projects or

for all publicly owned buildings being modified or removed within the jurisdiction. Jurisdictions must

document the type and quantity of materials that get reused, recycled, or landfilled/incinerated for

all publicly owned buildings being modified or removed. Consider using the MPCA’s Building

Material Management Plan Template. It is provided as a customizable Microsoft (MS) Excel

spreadsheet so cities, counties, and other organizations can gather building material data to support

their programs and convey important information regarding construction, renovation,

deconstruction, and demolition goals or requirements within their jurisdiction.

Optional strategies:

The following strategies are optional and may be incorporated into a CSWMP. Each strategy has been

assigned a point value, which is added to the total amount of points the county must achieve for

approval of their CSWMP by the MPCA.

66. Prior to demolition of county-owned buildings, require that SMM strategies are considered.

Point Value: 7

For greatest impact, consider implementing these approaches in the order they are listed. Reassign

the building for other government purposes. Sell the building to be used as-is or with renovations. If

it is not feasible to use the building, deconstruct with all useful materials diverted from the waste

stream. Divert a minimum of 75% of materials from disposal and at least 10% of materials reused.

Recycle if/when deconstruction is not an option. Consider requiring publicly owned buildings

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applying for a demolition permit to provide a feasibility study for deconstruction before a permit is

granted.

67. Host a building material collection event or swap.

Point Value: 8

Partner with supporting cities within the county and with resale non-profits to accept used items in

good condition for reuse. Promotional opportunities could include postcards, city newsletters, social

media, and email. Promotional outreach should include education on the climate and other

environmental and human health impacts of the lifecycle of building materials, guidelines, and lists

of what is/is not accepted.

68. Provide financial assistance to offset the additional cost of building deconstruction, used building

material installation, and/or structural moving.

Point Value: 8

Offer grants for building deconstruction, structural moving, and building material reuse to reduce

the amount of wasted building materials and the need to manufacture new items, as well as to

effectively divert materials otherwise bound for landfill. Partner with organizations that have strong

relationships with lower income communities where single-family homes, multi-family units,

businesses, and community centers would benefit from funding and assistance to update (ensuring

repairs are done in a way that also support energy efficiency). Consider adding a step in the

permitting process where the contractor is introduced to these programs.

For example, Hennepin County began offering deconstruction grants for residents in 2020. Owners

of 2–4-unit housing are now offered up to $5,000 ($2 per square foot) to use deconstruction

techniques. This grant expanded in 2022 for projects that incorporate used building materials.

Ramsey County began offering grants for homeowners and developers in 2021, offering the same

funding as Hennepin County for residential properties. Commercial properties are eligible for up to

$10,000. Washington County followed suit in 2022.

69. Provide deconstruction training.

Point Value: 8

To support the “unbuilding” of buildings that have reusable materials, contractors will need

deconstruction training. Arrange virtual and in-person courses. Aim to develop a workforce ready to

provide deconstruction services within your county. Collaborate with other counties to provide

trainings, if desired.

70. Annually host or aid with home and building repair and refurbishment trainings.

Point Value: 8

These training should encourage extending the life of products and materials over

replacement. Many of these types of classes are already offered through community education or

building preservation organizations. Sponsoring these courses to provide free or reduced cost

enrollment would fulfill this strategy. This should also be paired with EPA’s Renovator Training to

avoid lead exposure.

71. Use purchasing guidelines to require environmental product declaration (EPD) for concrete.

Point Value: 7

Select products with the lowest carbon concrete for all new buildings, sidewalks, and roadways. An

EPD is a comprehensive report that includes a life-cycle analysis that provides specific

environmental information on a product in a common format. EPDs provide clear information on

the environmental benefits of products like energy efficiency. Requiring EPDs for building materials

can provide institutions with the information they need to meet specific environmental goals and

report on impacts.

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State-led strategies:

The following strategies are the responsibility of the MPCA to support counties.

72. Study waste classification practices.

The MPCA should evaluate the meaning and application of

statutory and rule definitions of MMSW, industrial solid waste, and industrial waste. The MPCA will

analyze the solid waste system for equity opportunities. Once the evaluation is complete, the MPCA

will make recommendations and changes to ensure that all parties within the system understand

how to properly classify MMSW, ISW, and demolition debris.

73. Propose changes to B3 guidelines to strengthen deconstruction requirements. The sustainable

building guideline used by the state is Buildings, Benchmarks & Beyond (B3). B3 studies building

performance and develops standards to advance strategies for measuring and increasing

performance of buildings receiving state funds. Most buildings participating in the B3 program are

state-owned. Yet some buildings developed by local governments, including housing, have

participated. The B3 Guidelines (B3-MNBG) are a series of required and recommended performance

standards. Among them are energy and waste efficiency standards (SB 2030).

74. Incentivize deconstruction over landfilling MMSW and demolition debris. The MPCA has been

working with stakeholders connected to sustainable building material management. The goal is to

support and incentivize the deconstruction and reuse of demolition debris materials, since the cost

of disposal is so low. The MPCA will focus on direct deconstruction incentives.

75. Lead Sustainable Building Group (SBG) developments. The MPCA will serve as a technical expert for

various built environment conferences, host working groups and meetings, develop legislative

proposals to advance waste reduction regulations, and provide guidance for B3 and GreenStep

Cities. The stakeholders in this group established a list of final recommendations, which would

establish training, grants, ordinance templates, and other incentive programs to encourage reuse in

construction and deconstruction.

See Appendix G

for the full strategy table.

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Appendix A: Overview of the current Twin Cities

Metropolitan Area solid waste management

system

We cannot solve on the backend the problems that are created upstream. Consumption directly leads to

waste and there is little the solid waste industry can do to mitigate the issues caused by

overconsumption. In 2020, the TCMA generated an estimated 3.29 million tons of MMSW.

Approximately 8.6 cubic yards of non-MMSW was reported in 2021. This waste includes demolition

debris, industrial, and medical waste. Non-MMSW is sent to demolition debris and/or industrial waste

landfills. The TCMA solid waste infrastructure is comprised of private and public entities. Materials

generated by homes, businesses, and institutions are first collected then transported, recycled,

recovered, incinerated, or land disposed.

Description of the system

Minn. Stat. § 115A

The goal of this section is to protect the state's land, air, water, and other natural resources and the

public health by improving waste management in the state to serve the following purposes:

1. Reduction in the amount and toxicity of waste generated

2. Separation and recovery of materials and energy from waste

3. Reduction in indiscriminate dependence on disposal of waste

4. Coordination of solid waste management among political subdivisions

5. Orderly and deliberate development and financial security of waste facilities including disposal

facilities

Minn. Stat. § 473.803 requires metropolitan counties to plan and manage an integrated solid waste

system. A recycling implementation strategy for meeting the goal of 75% by 2030 is mandated. The

recycling rate includes both traditional recyclables, yard waste, and source-separated compostable

materials. If current trends continue, we cannot expect the recycling rate to exceed an average of 61%

by 2030. The MMSW recycling rate as of 2021 is 45.2 %, which has grown by almost 20% over the past

10 years.

Collection

Approximately 200 waste hauling businesses are licensed in the TCMA via a regional joint powers

agreement to collect and transport MMMSW. State law requires waste haulers to provide volume-based

service. TCMA communities have two types of agreements with waste haulers: open collection and

organized collection. Open collection allows residents and businesses to choose their waste hauler.

Cities that contract with haulers on behalf of communities have systems referred to as organized

collection. About 38% of communities in the TCMA have organized trash collection and about 59% have

organized recycling collection. Yard waste, organics recycling, and recycling drop-off sites serve many

communities.

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Toxicity reduction

Waste that is hazardous as defined by federal and state laws and local ordinances poses environmental

and public health and safety risks. Toxicity reduction is an effort to manage the risks associated with the

hazardous character of waste.

The TCMA addresses the hazardous character or toxicity of waste in two ways. The first, aimed at

residents, encourages reduction of wastes with hazardous character, coupled with a network of HHW

programs operated by counties. The second, aimed at commercial generators of hazardous waste,

includes regulating under the federal Resource Conservation and Recovery Act standards for businesses

in the TCMA.

HHW collection programs are imperative for removing toxic materials from the waste stream. Year-

round operation of an HHW site is present in each metropolitan county. Efforts to capture HHW also

include seasonal, temporary, satellite, or special one-day collections. TCMA residents may use any of the

HHW collection sites located in TCMA counties due to an effective reciprocity program among the metro

counties.

Chemicals in the environment are a growing concern. Their presence indicates that there are opportunities

for reducing exposure to toxic chemicals through pollution prevention. Apart from lead and perhaps

mercury, none of these chemicals would have been found in people 70 years ago. Air, water, and soil

sampling also document the unintended presence of many toxic chemicals due to human activity.

The MPCA is conducting a PFAS source evaluation and reduction initiative with the goal of supporting

operators of PFAS conduits to the environment, such as landfills. Solid waste facilities perform an

essential function in society of managing waste while minimizing environmental and human health

impacts. Unlike industrial facilities using or producing PFAS products, landfills have limited options for

managing PFAS inputs into their facilities, and PFAS levels will reflect a composite of historic and

ongoing levels in disposed materials. The MPCA regulates solid and hazardous waste in Minnesota to

support an integrated waste management system and to ensure protection of public health and

Minnesota’s land, air, and water resources.

Recycling

Residential recycling programs consist of curbside collection and drop-off sites. Curbside recycling

programs contract with a municipality or operate through subscription service. Most counties provide

some funding for municipal programs. There are public drop-off locations for recyclables in five

counties. Many businesses have active recycling programs, and commercial recycling accounts for a

considerable part of the recycling in the region. The success of the region’s recycling program is not only

a result of county and city efforts, but also of the significant contribution the private sector has made

through the development of markets, provision of drop-off locations, and the many elements needed

for the recycling infrastructure.

Recyclables collected are taken directly to a recycling market, a recycling broker, or to an MRF. Materials

commonly recovered for recycling include:

• Steel & aluminum cans

• Newspaper and magazines

• Office paper and mail

• Cardboard

• Boxes: food, beverage, toiletries

• Glass jars and bottles

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• Plastic bottles, containers, jugs (#1, #2, & #5)

• Cartons

Presently, eight businesses operate MRFs that manage residential recyclable materials generated in the

TCMA: Republic in Inver Grove Heights, Republic in Minneapolis, DemCon in Shakopee, Dick’s Sanitation

(Recycle Minnesota) in Lakeville, Eureka Recycling in Minneapolis, Republic Services in Delano, Tennis

Sanitation in Saint Paul Park, and Waste Management in Minneapolis. In 2021, the materials recycled

came from these sources: 65.5% from commercial and 34.5% from residential. Historically, 20 to 25% of

the residential waste and about 50% of CII waste is recycled.

Lithium-ion batteries should be disposed of via e-waste streams. However, some are disposed of in

unsuitable places. Dangerous fires in garbage trucks, at transfer stations, MRFs, and landfills have

resulted. Uncontrolled burning of waste is a threat to human health and the environment. Fires cause

structural damage that require repairs, increased insurance costs, and require the organizations to

spend funds on repairs. Insurers offering coverage to waste facilities may reasonably estimate a high risk

of a severe fire breaking out, leading them to pass the financial burden of that danger to their

customers. Not only are prices increasing, but also insurers are leaving the market, making it more

difficult for MRFs to get insurance. The industry, which had almost 50 insurance options as little as three

years ago, now has fewer than 10.

Yard waste

Under state law, yard waste should be separated from MMSW and is banned from land disposal. A few

cities offer the collection of yard waste mixed with other organics for composting. Yard waste is

managed through county, municipal, and private programs. Yard waste collection sites located

throughout TCMA operate year-round or seasonally. They are operated by counties, cities, or private

firms. Curbside collection of yard waste occurs in many areas using separate collection vehicles.

Documented yard waste volumes are reported to the MPCA; in 2020,424,762 tons of yard waste was

reported in the TCMA. The capture rate for yard waste in TCMA is 88.8%.

Invasive earthworms known as jumping worms are an emerging issue in Minnesota, with confirmed

presence in Hennepin and Ramsey counties dating back to 2007. Tree diseases and invasive insects will

continue to be an issue, despite efforts to diversify the tree canopy.

EAB is now identified in 30 Minnesota counties and continues to spread, which leads to the creation of

wood waste. District Energy’s Saint Paul Cogeneration (SPC) facility is the only outlet at this time to

manage the hundreds of thousands of tons of wood waste generated each year via biomass.

The PUC regulates energy production activities at SPC, as the facility is a source of energy production.

SPC currently processes about 250 tons of wood waste annually. WTE facilities play a strong role in

waste management and SPC is increasingly important in dealing with wood waste. EAB projections

suggest this will continue to be a pervasive issue, with greater spread and impact.

SPC provides an important service that is environmentally preferable. If SPC were to discontinue

services, it would leave the TCMA without a biomass energy resource and would lead to intentional

open burning or spontaneous fires. Uncontrolled burning of wood contributes to air pollution by

releasing PM2.5, benzene, formaldehyde, acetaldehyde, acrolein, and polycyclic aromatic hydrocarbons

(PAHs). Extensive scientific evidence demonstrates short-term exposure to PM2.5 causes cardiovascular

health effects. In 2020, reported emissions at SPC were 77,200 tons of CO2e and a combined total of

0.34 tons of PM10 and PM2.5, 20.5 tons VOC and 255 tons NOx. Control equipment at SPC greatly

reduces other pollutants like lead, ammonia, and sulfur dioxide.

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Organic waste management

Organics recovery programs include food rescue, food-to-livestock, and composting. Each management

method can capture different mixtures of feedstock. Waste reduction opportunities to reduce organic

materials diverted to trash should take priority. Further reducing or recovering organic materials from

the trash can be accomplished through different diversion strategies. The MPCA is assessing the newly

released EPA Wasted Food Scale to determine how it applies to operations and activities throughout

Minnesota. The Food Scale was developed by EPA’s assessment of various common pathways for

managing food and prioritizes them based on their environmental impacts and potential contributions

to a circular economy.

Figure 13. EPA Wasted Food Scale preferred management methods

Organic materials account for a large portion of the MMSW sent to landfills and resource recovery

facilities. The Burnsville Sanitary Landfill conducted a waste characterization study in 2019, which

identified organics made up 49.13% of waste sorted. Hennepin Energy Recovery Center conducted a

similar study in 2017, which identified organics accounting for 28.8% of total composition of waste. The

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nearly 20% difference between facilities could be explained by Hennepin county’s early adaption of

curbside collection of organics.

Each management method has different requirements regarding what materials are acceptable, but it is

clear there is substantial opportunity to reduce or recover organic materials that are currently ending up

in the trash.

Access to organics collection has improved and increased in the last six years. Ramsey and Washington

will roll out a joint effort for curbside collection to residents by late 2023. These counties are also

looking to add anaerobic digestion as an additional method for processing organic waste, as is Hennepin

County. Hennepin requires residential collection of organics. Dakota County has passed an ordinance

that sets tiered effective dates to require commercial collection for different types of businesses to

divert and collect food scraps from their back-of-house operations. Individuals willing to self-haul their

organics have access to drop sites in every metro county.

Curbside collection primarily utilizes one of three methods:

1. Collecting organics curbside in a cart – including only food scraps, non-recyclable paper, and

compostable plastics, in a compostable bag

2. Co-collecting organics with yard waste

3. Co-collecting organics, in a durable compostable bag, with MMSW (sorting facilities to remove

compostable bags are required with this model)

The TCMA is currently served by several food rescue organizations, four food-to-livestock operations

with garbage feeder permits (able to accept meat and vegetative food scraps), three large scale

composting operations that are permitted to accept SSO, and many yard waste composting facilities.

With the introduction of new programs, capacity is now a challenge. Transfer capacity, route density,

and access to hauling service also remain a challenge.

In 2020 and 2022, the Legislature increased SCORE funding for the state by $500,000 and $700,000

respectively. The Waste Management Act includes language that requires metro counties to spend half

of any increase in funding as compared to a base year of 2014 on organics (i.e., food rescue, composting,

food-to-livestock, anerobic digestion). The counties’ obligations for organics spending are listed in Table

7. Metro counties detail how funding is spent as part of the annual reporting process. Their reports have

confirmed compliance with this requirement and frequently show spending on organics far exceeds

their obligation.

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Table 7. Organics obligation by county for FY2020-2023

Metro

county

FY2020 Organics

obligation

FY2021 Organics

obligation

FY2022 Organics

obligation

FY2023 Organics

obligation

Anoka

$104,192.00

$105,832.50

$125,626.00

$126,377.50

Carver

$38,311.00

$38,496.00

$43,430.00

$45,238.00

Dakota

$123,311.50

$123,854.50

$154,999.50

$156,174.00

Hennepin

$375,199.00

$383,780.50

$449,543.50

$448,556.50

Ramsey

$163,542.50

$164,105.00

$183,106.00

$178,877.50

Scott

$47,606.50

$48,828.00

$59,816.00

$61,625.50

Washington

$79,516.50

$77,492.00

$97,598.00

$99,625.50

Metro total

$931,679.00

$942,388.50

$1,114,119.00

$1,116,503.50

TCMA counties reported collecting a total of 549,135 tons of organics in calendar year 2020. Table 9

provides the total amount of organics recovery reported, by type, in the 2021 SCORE report for the

TCMA counties.

Table 8. Organics recovered in 2021 (in tons) (data from the 2021 SCORE report)

Material type

Tons collected

Change from 2020

Food to livestock

107,133

-0.8%

Food to people

23,585

34.7%

Other materials

1,944

198%

Source-separated organic materials

79,891

103.7%

Yard Waste

335,379

-12.6%

The yard waste stream is primarily coming from residential sources. The food-to-livestock and food-to-

people figures come from commercial sources. The 2020 data showed disparities among metro counties

for organics diversion. The metro average decreased from 2019 to 2020 by nearly 20%, while some

counties, like Washington, experienced growth year-on-year of nearly 80%.

It is also worth noting that the items included in the organics calculation now include yard waste

composting. That policy change took effect in 2013 and now counties include documented yard waste in

their annual reports to the MPCA. This change in reporting process resulted in a significant increase in

the combined organics/recycling rate. Further increase in the organics recovery rate will likely be more

challenging to achieve in future years.

Resource recovery

Three MMSW resource recovery facilities serve the TCMA. The Elk River Resource Recovery Project

(GRE-Elk River) was an RDF processing plant owned by Great River Energy (GRE). The site became a WTE

facility in 1989 and closed in 2019. GRE-Elk River’s operational capacity was about 250,000 tons per

year, all of which is now diverted to landfills.

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Table 9. Existing resource recovery facility capacity serving the TCMA

MMSW

Processing

Facility

Permitted

capacity

Greater Minnesota-

forecast tons per year

Forecast tons per

year - TCMA

Forecast tons per

year - Total

HERC

365,000

0

365,000

REC

450,000

0

450,000

City of Red Wing

36,000

23,000

13,000

36,000

The HERC facility in Minneapolis uses a mass-burn technology, producing energy for district heating and

electricity. The facility also recovers ferrous metal for recycling from the ash. HERC managed 361,502

tons of waste in 2021.

The Ramsey/Washington County Resource Recovery Facility (Recycling and Energy Center) is a refuse-

derived fuel (RDF) facility owned by Ramsey and Washington counties. The facility was purchased by the

two counties in 2016. Mixed waste is sorted into processible and non-processible waste on the tipping

floor, processed, and separated into three waste streams: RDF, recyclable metal, and residue. The RDF is

transported for combustion to Xcel Energy power plants in Red Wing and Mankato, where it is burned to

generate electricity. The facility recovers ferrous and non-ferrous metals for recycling, and unprocessible

waste and residue from processing is delivered to landfills. Recycling and Energy Center’s permitted

capacity is 450,000 tons per year.

The city of Red Wing (City) operates an RDF processing plant in Red Wing. Mixed waste is sorted into

processible and non-processible waste on the tipping floor, processed, and separated into three waste

streams: RDF, recyclable metal, and residue. The RDF is transported for combustion to Xcel Energy’s

power plant in Red Wing. The facility recovers a variety of recyclable materials including paper, plastics,

and ferrous and non-ferrous metals for recycling. Unprocessible waste and residue from processing is

delivered to a landfill. Red Wing’s permitted capacity is 16,000 tons per year for metro and surrounding

counties and 20,000 tons for Goodhue County.

The three resource recovery facilities have a combined operating processing capacity of 802,627 tons

per year, down from the over 1.15 million tons capacity the metro had before GRE-Elk River closed. In

addition, there is available unpermitted, but installed capacity, of 40,000 tons per year at HERC. In 2021,

PCA prevailed in court on ROD. Since that time, processing capacity has been fully utilized at the three

remaining facilities. There is currently no additional capacity, which has increased use of land disposal.

Landfills

In 2021, 33% of the TCMA MMSW was land disposed. Nine landfills received 1,102,177 tons of TCMA

MMSW, with 15% destined for landfills located out of state. Figure A-2 shows total amounts of TCMA

MMSW that the landfills received in 2021, with 93% of total waste headed to landfill classified as

unprocessed MMSW. Four Minnesota landfills receive the majority of TCMA MMSW, with collective

remaining permitted MMSW capacity of approximately 10.2 million cubic yards. If these facilities

continue to receive waste at approximately the same rate in the future, the permitted capacity will

range from 4.9 to 14 years. Notwithstanding, this does not consider the additional design capacity

that could potentially be permitted or practices that move materials up the waste management

hierarchy.

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Table 10. Landfill locations accepting TCMA waste

State

Landfill name

Owner

Total tons

Minnesota

Elk River Landfill SW-74

Waste Management

255,741

Minnesota

Pine Bend Sanitary Landfill SW-45

Republic Services

474,508

Minnesota

Burnsville Sanitary Landfill SW-56

Waste Management

160,481

Minnesota

Spruce Ridge Resource Management Facility

SW-6

Waste Management

44,830

Minnesota

Nobles County Landfill Inc SW-11

Waste Connections

2,038

Minnesota

N/A

736

Wisconsin

Lake Area Landfill

Republic Services

43,606

Wisconsin

Rice Lake Landfill

Allied Waste Services

1,225

Wisconsin

Seven Mile Creek Landfill

GFL Environmental Inc.

27,859

Iowa

Central Disposal Landfill

Waste Management

91,153

MN Total

938,334

Out of State

total

163,843

Grand total

1,102,177

Of note, Seven Mile Creek Landfill was acquired by a Wisconsin-based hauler, and it no longer accepts

TCMA waste. If TCMA landfills are not allowed to expand, Twin Cities residents could end up with no

facility to send their waste. In January 2021, four landfills applied for additional capacity. The agency has

made determinations of how TCMA waste would be allocated to the four applicant facilities that

requested additional capacity:

• Burnsville Sanitary Landfill – 1,692,893 tons

• Dem-Con Landfill – 627,244 tons

• Pine Bend Sanitary Landfill – 2,398,746 tons

• Rich Valley Landfill – 893,889 tons

Permitting capacity is in flux because two of these facilities have not submitted permit applications to

accept MMSW.

Expanding landfill capacity in TCMA is a direct result of the closure of GRE. Minnesota has four MMSW

landfills. The TCMA currently houses two, both located in Dakota County. The Burnsville Sanitary

Landfill, located in Burnsville, is owned by Waste Management Inc. (WMI). The Pine Bend Sanitary

Landfill, located in Inver Grove Heights, is owned by Republic Waste. Both landfills operate methane gas-

to-energy systems that capture methane gas generated by the decaying waste. Two other Minnesota

landfills that receive significant amounts of TCMA MMSW are the WMI Spruce Ridge Landfill in McLeod

County and the WMI Elk River Landfill in Sherburne County. These also operate methane gas-to-energy

systems. For the four Minnesota landfills that receive the majority of TCMA MMSW, while the efficiency

of the gas collection systems has not been established, it is estimated that an average of 75% of the

methane that is captured is used to produce electricity, and the remaining captured methane is flared.

Two out-of-state landfills received TCMA MMSW in 2021, including the Republic Services Lake Area

Landfill in Sarona, Wisconsin, and the Rice Lake Landfill in Rice Lake, Wisconsin.

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Non-MMSW management

In 2021, an estimated 4,841,899 tons of non-MMSW waste was land disposed. The TCMA is served by

nine landfills that accept industrial wastes and/or demolition debris, or non-MMSW. These landfills have

approximately 25 million cubic yards of remaining capacity. Non-MMSW includes nonhazardous

industrial waste, demolition debris, materials banned from disposal with MMMSW, problem materials,

infectious waste, and other waste streams that are not MMSW or otherwise defined or regulated as

hazardous waste.

Materials separated for recycling at some demolition debris transfer stations and landfills include

concrete, bituminous asphalt, aluminum, copper, steel, brick, mattresses, appliances, and tires. Other

materials have the potential to be separated and recycled from the demolition debris. Private

businesses own and operate most of the TCMA facilities that manage non-MMSW. There is some public

sector activity in managing certain non-MMSW materials in the TCMA, such as tree waste processing

and crushing, and concrete or road base material recycling.

Table 11. Non-MMSW landfills accepting TCMA demolition debris

Facility name

Demolition debris tons

Industrial tons

Dawnway Demolition Landfill - SW-303

32,033

0

Dem-Con Landfill Hawick SW-629

14,556

0

Dem-Con Landfill, LLC - SW-290

315,033

141,264

DKV Demolition Landfill - SW-429

762

0

Elk River Landfill - SW-74

2

0

Ladd Demolition Landfill - SW-469

152

0

Pine Bend Landfill - SW-45

761

225,258

Rolling Hills Landfill, Inc - SW-60

0

2,399

Shamrock Landfill -SW-399

51

30

SKB Lansing Landfill - SW-514

316

1,739

SKB Rosemount Industrial Waste Facility – SW-383

885,460

2,775,210

Spruce Ridge Resource Management, Inc. – SW-6

2,924

39,727

Valley Demolition and Recycling, LLC – SW-527

2

0

Vonco II Becker - SW-580

182,708

221,512

Grand total

1,434,760

3,407,139

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Appendix B: Environmental justice review

The MPCA defines environmental justice as the fair treatment and meaningful involvement of all people

regardless of race, color, national origin, or income with respect to the development, implementation,

and enforcement of environmental laws, regulations, and policies. This will be achieved when everyone

benefits from the same degree of environmental protection and has equal access to the decision-making

processes that contribute to a healthy environment. In May 2022, the MPCA released the

Environmental

Justice Framework which established the vision, strategies, and implementation actions for integrating

environmental justice principles into the MPCA’s work. This report includes a commitment to evaluate

the environmental justice implications of program policies. The MPCA is developing an environmental

justice review tool, which can be used broadly across all the agency’s work, as well as detailed tools for

specific program areas. The MPCA will share these tools and resources with counties once they are

complete.

The following sections constitute the MPCA’s environmental justice review of the MPP. Counties are

required to complete an environmental justice review when developing their respective CSWMP.

1. Identify potentially affected communities. Identify facilities that are in areas of concern for

environmental justice. This is defined by the MPCA as census tracts using data from the U.S. Census

and American Community Survey and meet one or both demographic criteria. These two criteria are

defined as:

• Total population of people of color greater than 40%

• At least 35% of people reported income less than 200% of the federal poverty level

2. Identify who is likely to be affected by the proposed policy. What are the impacts of the proposed

policy on communities of concern for environmental justice? Will it create disproportionate impacts

or increase existing disproportionate impacts on minority or low-income populations? Examples

include impacts on health, quality of life (from noise or visual impacts, etc.), personal finances, etc.

3. Review for impact. What are the opportunities for action? If the proposed policy would result in

negative environmental or socio-economic impacts, or would add to cumulative impacts to people

of color and low-income populations, what steps could be taken to avoid or mitigate these impacts?

Additionally, does the proposed policy present opportunities to address existing disproportionate

impacts on people of color, low income, or indigenous populations? Develop a list of likely impacts

and actions to ensure that negative impacts are mitigated, and positive impacts are enhanced.

4. Assess engagement. How have you involved community members and stakeholders? What specific

measures have been taken to engage community members in areas of concern for environmental

justice?

5. CSWMP must include description of how the county has engaged with disadvantaged communities

during the development of the CSWMP. Solid waste facilities must also engage with disadvantaged

communities in their area when appropriate. Counties and facilities must always consider the impact

to residents, particularly the disadvantaged communities that are more difficult to hear from, when

making decisions about solid waste management.

Our models show low-income communities and areas of higher concentrations of people of color are at

a greater risk from air pollution. Residents in 46% of lower income areas and 91% of communities of

color experience air pollution risk above health guidelines (compared to only 32% of communities

statewide). For this reason, the MPCA uses these criteria, as well as tribal boundaries, as a preliminary

screening to identify areas where additional review or action is needed or desired. Additional

information on variables such as language, education, and housing are considered and factored into

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decisions and actions for areas where the preliminary screening has indicated a need to take a closer

look.

Figures 10 and 11 show solid waste facility locations and census tracts that are considered areas of

concern for environmental justice. Areas marked with purple lines are census tracts with more than 40%

of the population earning income less than 185% of the federal poverty level. As of 2022, this is an

annual income of $51,338 for a family of four.

Figure 14. Map of solid waste facilities and EJ boundaries located within the TCMA

Areas shaded in green are census tracts with greater than 50% people of color.

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Figure 15. Map of solid waste facilities and EJ boundaries located within Minneapolis and Saint Paul

The first priority of the MPP is to ensure the proper management of waste to protect human health and

the environment. The MPP also supports reducing waste and increasing recycling. The policies and

strategies proposed in the MPP are intended to reduce the environmental impacts associated with

waste, because reduction in environmental impacts is beneficial to all Minnesotans.

The TCMA is home to several waste management facilities – out of 125 facilities, 42 of these are in areas

of concern for environmental justice. Reducing waste generation would mean less material would need

to be managed by these facilities. Meeting the landfill diversion goals established in the MPP would

likely divert material from landfills to regional recycling, organics recovery, and resource recovery

facilities, including the facilities located within areas of concern for environmental justice. The potential

impacts include increases in traffic and noise, as well as potential impacts to air quality due to increased

vehicular traffic and facility emissions.

If the objectives in the MPP are attained, the region may need more recycling and organics recovery

facilities. These facilities would be subject to the standard process for new facility development,

outlined in Appendix D. In addition, as described in the MPCA’s environmental justice framework when

considering permit applications for new facilities and during renewal of existing permits for facilities

located in areas of concern for environmental justice, the MPCA will:

• Identify facility and permit types that warrant additional actions based on the potential for

adverse effects.

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• Identify and evaluate additional measures, beyond meeting established permit limits, to avoid

and diminish impacts.

• Increase civic engagement, public participation, and outreach for community groups and

residents.

• Foster increased community involvement and actions on the part of the entities that we

regulate.

• Consider ways to prioritize work to enhance benefits to areas of concern for environmental

justice.

A large role of the MPCA is ensuring that facilities are properly permitted to minimize human health and

environmental harm. During permitting for facilities in areas of concern for environmental justice, the

MPCA can identify and evaluate additional measures, beyond meeting established permit limits, to avoid

and diminish impacts. This could include changing processes or procedures, installing additional

pollution control equipment, or otherwise achieving a lower level of pollutant release than required by

state or federal requirements. The MPCA can also work with the permittee to incorporate these

measures into the permit or supplemental documents as possible.

Compliance and enforcement are other tools the MPCA can use to mitigate potential impacts. The

MPCA could determine that more frequent inspections at facilities in areas of concern for environmental

justice is needed to ensure the facilities are meeting applicable regulations and permit conditions.

Consistent with the WMA hierarchy, this MPP prefers resource recovery to landfilling. Communities of

concern for environmental justice have indicated their concern about air emissions from resource

recovery facilities located within their boundaries. To reduce reliance on resource recovery facilities and

landfills, this MPP promotes best practices designed to reduce waste and increase recycling and organics

recovery. While the MPCA recognizes that waste will continue to be processed at resource recovery

facilities and disposed at landfills, the aggressive objectives established in this MPP encourage the TCMA

to significantly reduce reliance on these less preferable management methods.

Certain strategies proposed in this MPP would directly benefit communities in areas of concern for

environmental justice. For example, the MPP recommends implementing organized collection for

MMSW. Organized collection is a more efficient method of managing trash and can lead to reductions in

illegal dumping, a common concern in lower income communities. Lower mobile source emissions and

reduced truck traffic are additional benefits of organized collection. The MPP also includes an

environmental justice review in the permitting process – for new and existing facilities – to ensure that

environmental justice concerns are addressed.

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Appendix C: Predrafting notice

Statement of subjects expected to be covered by revisions to the

Metropolitan Area Solid Waste Policy Plan

Introduction

The Minnesota Pollution Control Agency (MPCA) has started the process to prepare revisions to the

TCMA Solid Waste Management Policy Plan (MPP). The current MPP can be viewed online

or it can be

provided by request. The current MPP was adopted by the MPCA on April 6, 2017. The new revised MPP

will be adopted by the MPCA Commissioner by December 31, 2022.

Revisions to the MPP will be prepared in accordance with Minn. Stat. § 473.149. The MPP contains goals

and policies for solid waste (i.e., all waste, except wastewater and other liquid wastes) management,

including recycling and household hazardous waste management. The statute requires that the MPP

contain objectives to decrease the landfilling of MMSW, what most of us consider garbage, and specific

components of the solid waste stream, including residuals and ash. The MPP must be followed by

entities who play a role in TCMA solid waste management.

The MPCA is required to prepare this pre-draft notice to solicit public comments on the anticipated

revisions to the MPP. MPCA welcomes public comments. They will be carefully reviewed and taken into

consideration when MPCA makes decisions regarding updates to the MPP. Public comments must be

received within 45 days from the date of the publication in the State Register. Questions about the

document or the process may be directed to Peder Sandhei at 651-757-2688 or 1-800-657-3864 (toll-

free in Minnesota). Public meetings are currently scheduled for May 26, 2021, for MPCA staff to answer

questions, and hear comments.

Written comments on the pre-draft notice should be sent to: peder.sandhe[email protected]n.us

Comments must be received by the MPCA by 4:30 p.m., C.S.T., July 12, 2021. [Written correspondence

may be sent to the following address: Peder Sandhei, Minnesota Pollution Control Agency, 520 Lafayette

Rd. N., 2nd Floor, St. Paul, Minnesota 55155-4100]

If you wish to stay informed on the development of the MPP, please submit a comment on the pre-draft

notice by the deadline indicated above. All comments will be published on the Agency’s MPP website

page and commenters will be added to a stakeholder list and be notified of any future MPP

developments. If you do not submit a comment on the pre-draft notice but would like to be included on

future MPP related distributions, please contact Mr. Sandhei.

Overall approach and philosophy

The MPP revisions will focus on:

• Reduction in the amount of waste generated

• Reduction in the toxicity of waste generated

• Recycling and composting

• Recovery of energy from waste

• Reduction in land disposal (landfilling)

• Coordination of solid waste management among cities, counties, townships, etc.

• Broadening participation and accountability for all parties involved in solid waste management

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• Protection of public health and state’s air, land, water, and other natural resources

• Additional emphasis on SMM principles and environmental benefits that consider life cycle

analysis, such as GHG impacts, rather than tons diverted from land disposal

• Environmental Justice

The MPP will continue to support: SMM principles, treating waste as a resource; minimizing the use of

landfills; waste and toxicity reduction; the management of all solid waste; recycling and organics goals;

region-wide waste processing; regional coordination; and minimizing environmental impacts. The MPP

will continue to support policies aimed at preventing, reducing, and managing all wastes such as

household solid waste, construction and demolition waste, industrial solid waste, and ash.

The MPP revisions will be developed consistent with the State policies and purposes expressed in Minn.

Stat. § 115A.02 of the Minnesota Waste Management Act (WMA). The MPP will support the WMA

hierarchy of preferred waste management methods.

The MPCA will consult with the seven metro counties, the public and private sector, and other

interested stakeholders in the revision of the MPP.

Description of how the existing solid waste system serves the Twin Cities Metropolitan Area

The TCMA’s current solid waste infrastructure has developed extensively since the passage of the 1980

WMA. In 2019, 47% was recycled or composted, and additional 21.5% was processed for energy

recovery, and 31% was landfilled.

The MPP will describe how the existing solid waste system benefits the TCMA, including the

environmental benefits, and how the new MPP proposes to increase those benefits. The MPP will also

identify the amount of waste and types of materials managed by the different solid waste management

methods.

The MPP will show how a comprehensive waste prevention, reuse, recycling, composting, processing,

and disposal system to manage solid waste (integrated solid waste system), consistent with the waste

management hierarchy, protects public health, supports a vibrant economy, reduces emissions of air

pollutants such as GHGs, conserves energy and resources, and produces energy. It will also discuss how

the solid waste system can be improved through more effective governance, a more efficient collection

system, broadened accountability, and additional landfill reduction.

Addressing obstacles in the metro solid waste system

The MPP will discuss some challenges that face the TCMA solid waste system, including, but not limited

to:

• Local government responsibility over solid waste management

• Accountability throughout the system

• Collection of SMM accurate and meaningful data

• Expansion of SMM principles

• A need for effective recycling

• Recycling market development

• Opportunities to advance productive use and disposal of materials

Solid waste management facilities and programs

The MPP will include goals and policies for solid waste management, including recycling consistent with

Minn. Stat. § 115A.551, and household hazardous waste management consistent with Minn. Stat. §

115A.96, subdivision 6, in the TCMA.

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The MPP will include specific and quantifiable regional objectives for minimizing waste generation and

reducing reliance on the practice of landfilling of MMSW and other components of the solid waste

stream. The objectives will be stated for a period of at least 20 years. The MPP will also include

objectives for waste reduction, reuse, and minimization of solid waste through recycling, organic waste

composting, and resource recovery, for a period of at least 20 years.

The MPP will identify:

• Environmental and resource management benefits of waste processing (WTE)

• Quantities and geographic origin of waste requiring processing

• Available WTE facility capacity, and the inter-county regional opportunities for the development

of future processing capacity and opportunities for inter-county sharing of waste

The MPP will evaluate the existing state and regional administration structure and make appropriate

recommendations that best fulfill the needs of integrated solid waste management. The MPP also will

explore issues beyond the TCMA jurisdiction that affect the regional solid waste system.

MPP implementation tools

The MPP will include procedures, standards, and criteria regarding the MPCA review of: CSWMP; annual

waste certification reports; waste facility permits; certificates of need; waste designation, and solid

waste supply contracts and processing agreements. The usefulness of these reviews will also be

examined to determine if some of them should be eliminated, changed or if others are needed.

Finally, the MPP will include standards and criteria for the MPCA review of solid waste facility permits

regarding the following matters: general location; capacity; waste supply; operation; processing

techniques; environmental impact; effect on existing, planned, or proposed collection services and

waste facilities; and economic viability.

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Appendix D: Procedures, standards, and criteria

Minn. Stat. § 115A, 116 and 473 authorize the MPCA to formulate and set out procedures, standards,

and criteria to implement the Metropolitan Solid Waste Management Policy Plan (MPP) 2023 to 2043

and facilitate the MPCA’s review of:

• Solid waste facility permit applications

• Solid waste supply and processing contracts

• Waste district proposals

• Waste designation proposals

• Landfill certificates of need proposals

• County annual and waste certification reports

• County solid waste management plans (CSWMP)

The MPCA will implement the MPP when conducting these reviews. Public and private entities subject

to review are encouraged to contact the MPCA before preparing and submitting approval requests. The

MPCA will coordinate its review with other applicable state and local procedures.

Solid waste facility terms and definitions

The MPCA will administer the MPP using terms and definitions used in chapters 115A, 116, and 473 and

related rules.

Solid waste facility permit applications

The MPCA review of solid waste facilities is governed primarily by Minn. Stat. § 473.823. Minn. Stat. §

473.823, subd. 3(b) provides that a permit may not be issued for the operation of a solid waste facility in

the TCMA that is not “in accordance with the Metropolitan Policy Plan.” The statute also provides that in

making this determination, “the commissioner shall consider the areawide need and benefit of the

applicant facility and the effectiveness of proposed buffer areas to adequately protect surrounding land

uses in accordance with the Metropolitan Policy Plan, and may consider, without limitation, the effect of

the applicant facility on existing and planned solid waste facilities.” In this section of the MPP, the MPCA

establishes the procedures that shall be applied for review of new and existing solid waste facility permit

applications, including the information to be submitted in particular applications, when those

applications will be requested, and how the MPCA will approve, disapprove, or conditionally approve

such facilities.

Minn. Stat. § 473.823 is reproduced below

473.823 RULES AND PERMITS.

Subd. 3. Solid waste facilities; review procedures. (a) The agency shall request applicants for

solid waste facility permits to submit all information deemed relevant by the commissioner

for review, including without limitation information relating to the geographic areas and

population served, the need, the effect on existing facilities and services, the effectiveness of

proposed buffer areas to ensure, at a minimum, protection of surrounding land uses from

adverse or incompatible impacts due to landfill operation and related activities, the

anticipated public cost and benefit, the anticipated rates and charges, the manner of

financing, the effect on metropolitan plans and development programs, the supply of waste,

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anticipated markets for any product, and alternative means of disposal or energy

production.

(b) A permit may not be issued for the operation of a solid waste facility in the metropolitan

area which is not in accordance with the metropolitan policy plan. The commissioner shall

determine whether a permit is in accordance with the policy plan. In making this

determination, the commissioner shall consider the areawide need and benefit of the

applicant facility and the effectiveness of proposed buffer areas to adequately protect

surrounding land uses in accordance with the policy plan, and may consider, without

limitation, the effect of the applicant facility on existing and planned solid waste facilities.

(c) If the commissioner determines that a permit is in accordance with the policy plan, the

commissioner shall approve the permit. If the commissioner determines that a permit is not

in accordance with the policy plan, the commissioner shall disapprove the permit. Approval

of permits may be subject to conditions the commissioner determines are necessary to

satisfy criteria and standards in the policy plan, including conditions respecting the type,

character, and quantities of waste to be processed at a solid waste facility used primarily for

resource recovery and the geographic territory from which a resource recovery facility or

transfer station serving such a facility may draw its waste.

(d) A permit may not be issued in the metropolitan area for a solid waste facility used

primarily for resource recovery or a transfer station serving the facility, if the facility or

station is owned or operated by a public agency or if the acquisition or betterment of the

facility or station is secured by public funds or obligations issued by a public agency, unless

the commissioner finds and determines that adequate markets exist for the products

recovered and that establishment of the facility is consistent with the criteria and standards

in the metropolitan and county plans respecting the protection of existing resource recovery

facilities and transfer stations serving such facilities.

Procedures for obtaining MPCA approval of solid waste facility permits

Coordination of MPCA review. For existing facilities, the MPCA will request information related to the

solid waste facility and information required in the MPP before the MPCA completes review and

reissues the permit. The MPCA may request additional information from solid waste facility permit

applicants after the adoption of the MPP. The application will need to contain information related to the

proposed solid waste facility and information required in the MPP.

Basic information required. To obtain MPCA approval solid waste facility permit applicants must

include:

• Information relating to the geographic areas and population served, including highlighting areas

of concern for environmental justice

• The need for the facility, including information that shows that new or expanded resource

recovery and disposal facilities are consistent with MPCA most recent forecast of waste

generation and waste management objectives

• The effect of the facility on existing facilities and services

• For public facilities: The effect of public facilities on existing comparable public and private

facilities

• The effectiveness of proposed buffer areas to ensure, at a minimum, protection of surrounding

land uses from adverse or incompatible impacts due to landfill operation and related activities

• The anticipated public costs and benefits of the facility

• The anticipated rates and charges

• The manner of financing

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• The effect on metropolitan CSWMPs and development programs

• The supply of waste

• Solid waste supply contracts subject to Minn. Stat. § 473.813

• Anticipated markets for any product

• Alternative means of disposal or energy production

• Additional information required by the commissioner, including but not limited to,

environmental justice review criteria (see Appendix B for more information)

• All solid waste facilities located in environmental justice zones must:

 Do an annual impact review. Identify how the facility is impacting the neighborhood in

which it resides. Develop a list of impacts and benefits to the community. Examples of

impacts could include air emissions such as particulate matter, traffic concerns due to

trucks, odors, or others.

 Develop a plan for mitigating the negative impacts and enhancing the benefits to the

community including the process for community engagement.

 Engage with the local community on an annual basis to make sure their concerns are

addressed in the plan.

• The owner or operator of any landfill or waste combustor shall conduct a waste composition

study. Waste composition analysis must include the following:

• Sampling protocol must follow the most recent ASTM International Test Standard D 5231-

92 or an alternative as approved by the MPCA.

• Material waste type categories must be consistent with the most recent Statewide Waste

Characterization or otherwise approved by MPCA prior to the sort occurring

Standards/criteria for approval of solid waste facility permits as consistent and

in accordance with the MPP

Following receipt of a complete application, the commissioner shall determine whether a permit is

consistent and in accordance with the MPP within 90 days. In making this determination, the

commissioner shall consider:

• The area wide need and benefit of the applicant facility.

• The effectiveness of proposed buffer areas to adequately protect surrounding land uses in

accordance with the MPP.

• The effect of the applicant facility on existing and planned solid waste facilities.

• The requirements of Restriction on Disposal in Minn. Stat. § 473.848.

• For a solid waste facility used primarily for resource recovery or a transfer station serving the

facility and owned or operated by a public agency or if the acquisition or betterment of the

facility or station is secured by public funds or obligations issued by a public agency (public

facility), the owner must demonstrate that:

• Adequate markets exist for the products recovered.

• The public facility does not displace comparable private and public facilities already

existing in the area unless the displacement is required in order to achieve the waste

management objectives identified in the MPP.

• The public facility is consistent with the applicable CSWMP.

• The public facility is necessary to achieve the waste management objectives identified in

the CSWMP.

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• The public facility is consistent with state policy and purposes outlined in Minn. Stat. §

115a.02 and Minn. Stat. §§ 473.842 to 473.849.

Minn. Stat. § 473.149 provides that “For solid waste facilities owned or operated by public agencies or

supported primarily by public funds or obligations issued by a public agency, the plan shall include

additional criteria and standards to protect comparable private and public facilities already existing in

the area from displacement unless the displacement is required in order to achieve the waste

management objectives identified in the plan.” For solid waste facilities owned or operated by public

agencies or supported primarily by public funds or obligations issued by a public agency (public facility),

the owner must demonstrate that the public facility:

• Does not displace comparable private and public facilities already existing in the area unless the

displacement is required in order to achieve the waste management objectives identified in the

CSWMP.

• Is consistent with the applicable CSWMP.

• Is necessary to achieve the waste management objectives identified in the CSWMP.

• Additional information required by the commissioner, including but not limited to,

environmental justice review criteria (see Appendix B for more information)

• All solid waste facilities located in environmental justice zones must:

• Do an annual impact review. Identify how the facility is impacting the neighborhood in

which it resides. Develop a list of impacts and benefits to the community. Examples of

impacts could include air emissions such as particulate matter, traffic concerns due to

trucks, odors, or others.

• Develop a plan for mitigating the negative impacts and enhancing the benefits to the

community including the process for community engagement.

• Engage with the local community on an annual basis to make sure their concerns are

addressed in the CSWMP.

• The owner or operator of any landfill or waste combustor shall conduct a waste composition

study every five years. Waste composition analysis must include the following:

• Sampling protocol for waste composition studies must follow the most recent ASTM

International Test Standard D 5231-92 or an alternative as approved by the MPCA.

• Material waste type categories must be consistent with the 2013 Statewide Waste

Characterization or otherwise approved by MPCA prior to the sort occurring

• Is consistent with state policy and purposes outlined in Minn. Stat. § 115A.02 and Minn. Stat. §§

473.842 to 473.849.

If the commissioner determines that a permit is in accordance with the MPP, the commissioner shall

approve the permit. If the commissioner determines that a permit is not in accordance with the MPP,

the commissioner shall disapprove the permit.

Solid waste supply and processing contracts

Cities, counties, and towns in the TCMA can enter contracts for the delivery of solid waste to waste

facilities and can enter into contracts for the processing of solid waste (Minn. Stat. § 473.813, subd. 1).

Before a local unit of government enters into a waste management contract for a period of longer than

five years in duration, they must get MPCA approval (Minn. Stat. § 473.813, subd. 2). The success of

waste facilities often depends on long-term commitments for waste supplies and processing. It is

anticipated that long-term supply and processing contracts may continue to be used as new or existing

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contracts are renewed or renegotiated. Existing MPCA contract approvals will remain in effect unless (1)

the contract term is extended; or (2) the contract is amended or revised during its term.

Minn. Stat. § 473.813 is reproduced below

473.813 CITIES, COUNTIES, TOWNS; SOLID WASTE CONTRACTS.

Subdivision 1. For up to 30 years. Notwithstanding any contrary provision of law or charter,

and in addition to the powers or authority granted by any other law or charter, a city,

county, or town in the metropolitan area may directly negotiate and

enter into contracts,

for a term not to exceed 30 years, for the delivery of solid waste to a waste facility and the

processing of solid waste. Contracts made by direct negotiations shall be approved by

resolution adopted by the governing body of the city, county, or town.

Subd. 2. Review by commissioner. Before a city, county, or town enters into any contract

pursuant to subdivision 1 for a period of more than five years, the city, county, or town shall

submit the proposed contract and a description of the proposed activities under the contract

to the commissioner for review and approval. The commissioner shall approve the proposed

contract if the commissioner determines that the contract is consistent with the

metropolitan policy plan, permits issued under section 473.823, and county reports or

approved master plans. The commissioner may consolidate the review of contracts

submitted under this section with the review of related permit applications submitted under

section 473.823 and for this purpose may delay the review required by this section.

Procedures for review of solid waste supply and processing contracts

• Procedure: Any city, county, or town entering into a contract for the delivery of solid waste to a

waste facility and the processing of solid waste for a term longer than five years, shall submit

that contract to the MPCA for review at least 90 days prior to the anticipated effective date of

the contract. Contracts subject to this review include waste delivery agreements, organized

collection contracts, host community fee agreements in lieu of fees authorized under Minn.

Stat. §§ 115A.919 and 115A.921 if they include a waste delivery provision, and other

agreements including waste delivery provisions.

• Application of standards to contracts: MPCA will approve contracts if the proposed contract is

consistent with the MPP, permits issued under Minn. Stat. § 473.823, and county annual reports

and approved CSWMP. A contract to deliver waste to a facility that is not specified in the

applicable CSWMP will not be approved. To be approved, a contract to deliver waste must have

a provision that terminates the contract in less than 30 years.

• Timely MPCA contract review: All contracts submitted to the MPCA for review will be reviewed

and approved or not approved within 60 days. The MPCA will notify the city, county, or town of

its decision, and if the contract is disapproved MPCA will notify the city, county, or town of the

reasons for disapproval.

• Consolidation of contract review with permit review: MPCA may consolidate the review of

contracts submitted under this section with the review of related permit applications submitted

under Minn. Stat. § 473.823 and, for this purpose, may delay the review required by this

section.

• Contracts that are inconsistent with the MPP: If MPCA determines that a contract is not

consistent with the MPP, then MPCA may require that the parties to the contract revise its

terms and re-submit the revised contract for MPCA approval.

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Waste management districts

The procedure, standards, and review criteria for waste management districts is set out in Minn. Stat. §§

115A.62 to 115A.72. Minnesota counties, including metropolitan counties, can form waste management

districts. This authority enables counties to implement waste management practices they may not be

able to conduct independently, or which can be more effectively performed jointly. The establishment

of a waste management district must be approved by the MPCA. Specific conditions may be

incorporated as part of the MPCA’s approval. Minn. Stat. § 115A.63, subd. 3 provides that a waste

management district formed by metropolitan counties must have the same procedural and substantive

responsibilities and duties as a metropolitan county, including requirements for preparing a

comprehensive solid waste management plan. The requirements for county solid waste planning are

contained in Minn. Stat. § 473.803 and in the MPP.

Waste designation proposals

The Waste Management Act, Minn. Stat. §§ 115A.80 to 115A.893, allows county or waste district to

designate a facility where all MMSW generated within its boundaries, or a service area thereof, is

required to be delivered. Using designation to direct the waste to a particular destination is referred to

as waste designation or waste assurance. The MPCA approval of waste designations is required for

designation to take effect. Designation is authorized by the Minnesota Legislature to further state

policies and purposes, as articulated in Minn. Stat. § 115A.02, and to advance the public purposes

served by effective solid waste management. See Minn. Stat. § 115A.80.

The procedures, standards, and criteria for approval of waste designation are contained in Minn. Stat.

§§ 115A.80 to 115A.893.

Landfill Certificate of Need

The Metropolitan Landfill Abatement Act, Minn. Stat. § 473.823, subd. 6, states that no new land

disposal capacity for MMSW shall be permitted in the TCMA without a CON issued by the MPCA

indicating that the additional disposal capacity is needed. The MPCA must certify need only to the

extent that there are no feasible and prudent alternatives to land disposal. Alternatives that are

speculative or conjectural cannot be deemed to be feasible and prudent. Economic considerations alone

cannot justify the CON or the rejection of alternatives. Minn. Stat. § 473.823, subd. 6 requires the MPCA

to include in the MPP the standards and procedures for certifying need. The standards and procedures

must be based on the metropolitan disposal abatement plan and the solid waste disposal facilities

development schedule, both included in the Metropolitan System Plan (Part 3), and with approved

CSWMPs that are consistent with the abatement plan and development schedule.

Minn. Stat. § 473.823, subd. 6 is reproduced below

Certification of need. No new mixed municipal solid waste disposal facility or capacity shall

be permitted in the metropolitan area without a certificate of need issued by the

commissioner indicating a determination that the additional disposal capacity planned for

the facility is needed in the metropolitan area. The commissioner shall amend the policy

plan, adopted pursuant to section 473.149, to include standards and procedures for

certifying need that conform to the certification standards stated in this subdivision. The

standards and procedures shall be based on the metropolitan disposal abatement plan

adopted pursuant to section 473.149, subdivision 2d, the solid waste disposal facilities

development schedule adopted under section 473.149, subdivision 2e, and the provisions of

any master plans of counties that have been approved under section 473.803, subdivision 2,

and that are consistent with the abatement plan and development schedule. The

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commissioner shall certify need only to the extent that there are no feasible and prudent

alternatives to the disposal facility, including waste reduction, source separation and

resource recovery which would minimize adverse impact upon natural resources.

Alternatives that are speculative or conjectural shall not be deemed to be feasible and

prudent. Economic considerations alone shall not justify the certification of need or the

rejection of alternatives.

Procedures for obtaining MPCA CON for landfills in the Metropolitan Area

Scope: MPCA will apply these standards to applications for additional MMSW capacity for MMSW

landfills located in the Metropolitan Area.

Timing of CON application: MPCA will notify landfills located in the Metropolitan Area and will issue a

public communication of MPCA’s intent to accept CON applications for additional MMSW land disposal

capacity after the adoption of the MPP and after MPCA approval of all county solid waste management

plans (CSWMP). If the facility does not currently have an approved permit to accept MMSW, the CON

application must come in first, however, the CON determination cannot be finalized until environmental

review and other permitting requirements are completed.

Process order:

1. MPCA issues notice of intent to accept CON applications

2. The facility must submit the documents within a 180-day application period following the notice

of intent.

3. MPCA reviews applications for completeness after the closure of the 180-day application period.

(90-day review period)

4. MPCA issues preliminary CON determinations

5. Must issue public notice to get comment on the preliminary determinations.

6. Facilities must submit a complete permit application within 18 months of receiving a preliminary

determination if they do not currently have an MSW permit. If the 18-month deadline is not

met, the preliminary capacity will be revoked and either, held until a future notice of intent to

accept CON applications is issued, allocated to other Metro facilities that applied or will be held

aside for Greater Minnesota facilities to apply for. How that capacity will be treated will be

driven by county letters and existing waste flows. The applicant facility will have to wait until the

next MPCA intent to accept CON to reapply. If existing preliminary determinations do not have

facility permit applications submitted, the 18 months starts at the issuance date of this Plan.

7. Notify the facilities and the public of the preliminary determinations for facilities that need to

complete environmental review

8. Final determinations are approved as each facility completes environmental review. The final

approvals are not issued at the same time, but rather as each individual facility completes their

respective permit processes.

9. The facility cannot use the additional CON until their permit is finalized or a minor modification

is completed.

Submittal of CON applications: CON applications from MMSW landfills located in the Metropolitan

Area must be submitted within a period of 180 days after MPCA’s CON notification is published. A CON

application must include the following:

• Annual solid waste estimates. The CON application shall include estimates of the amount (in

tons) and type of solid waste to be managed annually at the facility during its design life.

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• Origin of waste. The CON application shall include identification of the origin of the solid waste

including estimates of the amount of solid waste to be received annually from each county or

district of origin. Information about quantities of solid waste from counties or districts outside

the metropolitan area shall be based on information in approved CSWMP. Information about

quantities of solid waste from counties or districts within the metropolitan area shall be based

on information in the MPP and approved CSWMP.

• If an approved CSWMP does not state that solid waste from a county or district will be

managed at the proposed facility, the application shall include a letter from the county

or district board of the county or district generating the solid waste indicating that in the

county's or district's best estimate the amount of solid waste in question is available for

management at the proposed facility. The letter must be consistent with the approved

greater Minnesota solid waste management plan (SWMP), the CSWMP, and any

applicable CSWMP amendments. Counties shall provide the letter to the facility with

projected annual amounts expected to go to the applicant facility. County letters must

be specific to the facility or facilities considered in the metro application. New letters

must be provided for separate CON requests that occur outside of the metro process.

The letter must be signed by the county board or by an employee with documented

board approved delegation.

• Alternatives. The CON application shall include an analysis of alternatives to the new or

expanded disposal capacity if the new capacity has not been included in the approved Greater

Minnesota county solid waste management, the MPP, or CSWMP.

• Estimate errors. If the amount of new capacity needed is greater than the amount identified in

the approved CSWMP, SWMP, or the MPP due to assumptions concerning the amount of solid

waste generated, the application must document the basis for calculating the amount of

capacity.

Public informational meeting on CON application: The MPCA may hold a public informational meeting

on its preliminary determination to approve or deny the application for a CON if the commissioner

determines that a public informational meeting would help to clarify and resolve issues regarding the

CON application.

Standard: No new MMSW disposal facility or capacity shall be permitted in the Metropolitan Area

without a CON issued by the commissioner indicating a determination that the additional disposal

capacity planned for the facility is needed in the Metropolitan Area. The MPCA will approve CON

applications only if MPCA determines that no feasible and prudent available alternative MMSW

management facilities, including existing permitted land disposal capacity, can substitute for the

proposed capacity.

The MPCA will apply the following criteria to determine whether CON can be granted:

• Restriction on disposal: MPCA will not accept or review any application for additional land

disposal capacity for a landfill located in the Metropolitan Area unless MMSW resource recovery

facilities serving the TCMA are functioning at full capacity and waste has been certified as

unprocessible by metro counties.

• Orderly and deliberate development of facilities: Pursuant to Minn. Stat. § 115A.02, the MPCA

must ensure the orderly and deliberate development of facilities, including landfills. To avoid a

situation where the TCMA is dependent on the services of a single disposal facility, MPCA will

not grant all CON to one landfill.

• Tonnage as basis of CON: MPCA will grant CON in tons to a landfill instead of cubic yards or

other volume units.

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• Alternatives: MPCA will consider existing permitted capacity in the service area of the facility

seeking the CON. The fact that a permit for a facility may expire during the expected service life

of the facility seeking CON shall not be deemed to extinguish permitted capacity assuming that

the existing permitted facility is likely to be re-permitted.

• Plan consistency: MPCA will not grant a CON unless the new landfill capacity is consistent with

the MPP, with applicable CSWMP, applicable greater Minnesota comprehensive solid waste

management plans, and applicable information from other solid waste management

jurisdictions outside of the state of Minnesota.

• Forecasting tons: If the amount of new capacity needed is greater than the amount identified in

the MPP, approved CSWMP or SWMP due to errors in forecasting MMSW generated, the

application must document the basis for calculating the amount of capacity needed and provide

an analysis of alternatives, including landfill abatement programs.

• Least cost alternative: MPCA will not approve a CON application based solely on a

determination that it is the least-cost alternative.

• The agency shall revoke or revoke and reissue the certificate of need if the commissioner

determines that the information contained in the certificate of need is no longer accurate or

that the owner or operator of the disposal facility has not fulfilled all applicable state and

federal requirements.

County annual report and waste certification reports

The TCMA counties are required to submit annual solid waste reports and certification reports to the

MPCA for approval under Minn. Stat. §§ 473.803, subd. 3 and 473.848, subd 2. The MPCA will review

these reports for consistency with the MPP and for consistency with the requirements of Minn. Stat. §

473.848, which states that no person shall dispose of unprocessible MMSW generated in the TCMA at a

land disposal facility unless it is certified as unprocessible. Minn. Stat. § 473.848, subd. 4 states that the

MPCA may adopt standards for determining when waste is unprocessible and procedures for expediting

certification and reporting of unprocessed waste. The MPCA will use the information contained in the

reports to enforce Minn. Stat. § 473.848 with respect to permitted waste facilities and public entities.

MPCA permitted waste facilities, including MMSW resource recovery facilities and MMSW landfills, are

required by state law to comply with Minn. Stat. § 473.848. The restriction on disposal in Minn. Stat. §

473.848, subd. 1 applies only to solid waste management and landfilling within Minnesota. Public

entities that manage solid waste or contract for the management of solid waste are required by Minn.

Stat. § 115A.46, subd. 5(b) to manage the waste consistent with the CSWMP.

The TCMA counties shall submit certification reports to the MPCA as a separate report before the

deadline of April 1, of each year and include the certification report in the annual solid waste report. The

TCMA counties may submit more frequent reports, such as quarterly certification reports, during each

year to the MPCA to assist MPCA obtain compliance with Minn. Stat. § 473.848.

Minn. Stat. § 473.848 subd. 2 is reproduced below

Subdivision 1. Restriction. (a) For the purposes of implementing the waste management

policies in section 115A.02 and metropolitan area goals related to landfill abatement

established under this chapter, a person may not dispose of unprocessed mixed municipal

solid waste generated in the metropolitan area at a waste disposal facility unless the waste

disposal facility meets the standards in section 473.849 and:

(1) the waste has been certified as unprocessible by a county under subdivision 2; or

(2)(i) the waste has been transferred to the disposal facility from a resource recovery facility;

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(ii) no other resource recovery facility serving the metropolitan area is capable of processing

the waste; and

(iii) the waste has been certified as unprocessible by the operator of the resource recovery

facility under subdivision 3.

(b) For purposes of this section, mixed municipal solid waste does not include street

sweepings, construction debris, mining waste, foundry sand, and other materials, if they are

not capable of being processed by resource recovery as determined by the council.

Subd. 2.County certification; office approval. (a) By April 1 of each year, each county shall

submit an annual certification report to the office detailing:

(1) the quantity of waste generated in the county that was not processed prior to transfer to

a disposal facility during the year preceding the report;

(2) the reasons the waste was not processed;

(3) a strategy for development of techniques to ensure processing of waste including a

specific timeline for implementation of those techniques; and

(4) any progress made by the county in reducing the amount of unprocessed waste.

The report shall be included in the county report required by section 473.803, subdivision 3.

(b) The Pollution Control Agency shall approve a county's certification report if it determines

that the county is reducing and will continue to reduce the amount of unprocessed waste,

based on the report and the county's progress in development and implementation of

techniques to reduce the amount of unprocessed waste transferred to disposal facilities. If

the Pollution Control Agency does not approve a county's report, it shall negotiate with the

county to develop and implement specific techniques to reduce unprocessed waste. If the

Pollution Control Agency does not approve two or more consecutive reports from any one

county, the Pollution Control Agency shall develop specific reduction techniques that are

designed for the particular needs of the county. The county shall implement those techniques

by specific dates to be determined by the Pollution Control Agency.

Standard for approval of county certification: The MPCA will approve a county’s reports if it determines

that the county is reducing and will continue to reduce the amount of unprocessed waste based on the

report and the county's progress in development and implementation of techniques to reduce the

amount of unprocessed waste transferred to disposal facilities.

Procedures

• Required report: MPCA will notify the TCMA counties that annual reports and certification

reports are required to be submitted to the MPCA on or before April 1 each year. Additional

quarterly certification reports, including the information required in Minn. Stat. § 473.848,

subd. 2, paragraph (a), clauses 1, 2, 3, and 4, may be submitted on or before April 30, July 31,

October 31, and January 31.

• Content and Form: MPCA will provide forms and instructions to the TCMA counties that outline

the information and data required in the annual reports/certification reports.

• MPCA review and approval: MPCA will review and approve or disapprove a certification report

if it determines that the county’s certification shows the county is reducing and will continue to

reduce the amount of unprocessed waste.

The MPCA will apply the following criteria to approval of county certification reports

• Unprocessible waste: The MPCA will not approve a county certification if it certifies waste as

unprocessible when there is reasonably available capacity in the TCMA system that could be

used to process solid waste generated in the county. In determining reasonably available

capacity, the MPCA will give consideration to the specific geographic area that typically supports

each of the processing facilities that serves the TCMA. The TCMA processing system is described

in Appendix A, but this system could change periodically. The MPCA will annually provide a list

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of processing facilities that serve the TCMA to the counties prior to the date the certification

report is due. To be fully utilized, the processing facility must be operating at 100% of its

operating capacity, taking into account outages for maintenance and repair.

• Facility Provided ROD Reports: The landfills and resource recovery facilities must fill out

quarterly reports for submittal to the MPCA. These reports must include the following

information:

• Monthly data provided quarterly

• County of origin of the waste (Transfer stations must provide to landfills)

• Projected shortages and days affected

• Date of notice and date of expected shortage

• Amount sent to resource recovery on behalf of landfill to cover shortage

• Other information as needed to determine compliance.

• As stated in the signed settlement agreement, “Landfill shall be entitled to rely on a

presumption that each resource recovery facility is operating at full capacity except for any

particular time period for which Landfill is notified at the specified email address by a particular

resource recovery facility of an Anticipated Shortage 14 days in advance. If the Landfill takes the

steps outlined in this Schedule of Compliance, MPCA will not bring an enforcement action and

will advise the TCMA counties that the MMSW disposed of at the Landfill for that year will be

considered and should be certified as unprocessible.”

• If there is a market change in the number of landfills serving the TCMA, then the landfills must

agree to revise their compliance plans. The MPCA may facilitate the obligation discussion

between facilities if needed. Once new obligations amounts are determined, the facilities must

notify MPCA.

• Approval/disapproval

• Annual reports must enumerate the actions the county is taking and the actions taken on

behalf of the county to implement the goals and objectives of the MPP.

• Annual reports must contain sufficient detail of programs so that the MPCA can determine

if programs are effective and embody best practices for the management of waste.

• Annual reports must show that the county is taking effective actions to ensure that no

unprocessible MMSW goes to land disposal facilities in accordance with the requirement

of Minn. Stat. § 473.848.

• MPCA will approve annual reports if the reports describe and report on the specific

barriers to implement the objectives and goals of the MPP, contain a description of the

county programs that will be implemented to overcome the barriers, and contain

recommendations to MPCA to assist in overcoming the barriers.

Regional and County Solid Waste Management Plans (CSWMP)

The Metropolitan counties are required by Minn. Stat. § 473.803 to prepare and submit CSWMP to the

MPCA for approval. The MPCA will review the CSWMP in accordance with the requirements of Minn.

Stat. §§ 473.149, 473.803, and 473.848. In accordance with Minn. Stat. § 473.803, subd. 2, the MPCA

will review the CSWMP for consistency with the MPP. The general content requirements for CSWMP are

contained in Minn. Stat. § 473.803. If the MPCA disapproves a CSWMP, the county must within 90 days

submit a CSWMP to the MPCA for approval.

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Minn. Stat. § 473.803 is reproduced below

473.803 METROPOLITAN COUNTY PLANNING.

Subdivision 1. County master plans; general requirements. Each metropolitan county,

following adoption or revision of the metropolitan policy plan and in accordance with the

dates specified therein, and after consultation with all affected local government units, shall

prepare and submit to the commissioner for approval, a county solid waste master plan to

implement the policy plan. The master plan shall be revised and resubmitted at such times as

the metropolitan policy plan may require. The master plan shall describe county solid waste

activities, functions, and facilities; the existing system of solid waste generation, collection,

and processing, and disposal within the county; proposed mechanisms for complying with

the recycling requirements of section 115A.551, and the household hazardous waste

management requirements of section 115A.96, subdivision 6; existing and proposed county

and municipal ordinances and license and permit requirements relating to solid waste

facilities and solid waste generation, collection, and processing, and disposal; existing or

proposed municipal, county, or private solid waste facilities and collection services within the

county together with schedules of existing rates and charges to users and statements as to

the extent to which such facilities and services will or may be used to implement the policy

plan; and any solid waste facility which the county owns or plans to acquire, construct, or

improve together with statements as to the planned method, estimated cost and time of

acquisition, proposed procedures for operation and maintenance of each facility; an

estimate of the annual cost of operation and maintenance of each facility; an estimate of the

annual gross revenues which will be received from the operation of each facility; and a

proposal for the use of each facility after it is no longer needed or usable as a waste facility.

The master plan shall, to the extent practicable and consistent with the achievement of other

public policies and purposes, encourage ownership and operation of solid waste facilities by

private industry. For solid waste facilities owned or operated by public agencies or supported

primarily by public funds or obligations issued by a public agency, the master plan shall

contain criteria and standards to protect comparable private and public facilities already

existing in the area from displacement unless the displacement is required in order to

achieve the waste management objectives identified in the plan.

Subd. 1a. [Repealed, 1991 c 337 s 90]

Subd. 1b. [Repealed, 1995 c 247 art 1 s 67]

Subd. 1c. County abatement plan. Each county shall revise its master plan to include a land

disposal abatement element to implement the metropolitan land disposal abatement plan

adopted under section 473.149, subdivision 2d, and shall submit the revised master plan to

the commissioner for review under subdivision 2 within nine months after the adoption of

the metropolitan abatement plan. The county plan must implement the local abatement

objectives for the county and cities within the county as stated in the metropolitan

abatement plan. The county abatement plan must include specific and quantifiable county

objectives, based on the objectives in the metropolitan abatement plan, for abating to the

greatest feasible and prudent extent the need for and practice of land disposal of mixed

municipal solid waste and of specific components of the solid waste stream generated in the

county, stated in six-year increments for a period of at least 20 years from the date of

metropolitan policy plan revisions. The plan must include measurable performance

standards for local abatement of solid waste through resource recovery and waste reduction

and separation programs and activities for the county as a whole and for statutory or home

rule charter cities of the first, second, and third class, respectively, in the county, stated in

six-year increments for a period of at least 20 years from the date of metropolitan policy

plan revisions. The performance standards must implement the metropolitan and county

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abatement objectives. The plan must include standards and procedures to be used by the

county in determining annually under subdivision 3 whether a city within the county has

implemented the plan and has satisfied the performance standards for local abatement. The

master plan revision required by this subdivision must be prepared in consultation with the

advisory committee established pursuant to subdivision 4.

Subd. 1d. Plans for required use of resource recovery facilities. Plans proposing designation

of resource recovery facilities pursuant to section 473.811, subdivision 10, shall evaluate the

benefits of the proposal, including the public purposes achieved by the conservation and

recovery of resources, the furtherance of local, district, or regional waste management plans

and policies, and the furtherance of the state policies and purposes expressed in section

115A.02, and also the costs of the proposal, including not only the direct capital and

operating costs of the facility but also any indirect costs and adverse long-term effects of the

designation. In particular the plan shall evaluate:

(a) whether the required use will result in the recovery of resources or energy from materials

which would otherwise be wasted;

(b) whether the required use will lessen the demand for and use of land disposal;

(c) whether the required use is necessary for the financial support of the facility;

(d) whether less restrictive methods for ensuring an adequate solid waste supply are

available;

(e) all other feasible and prudent waste processing alternatives for accomplishing the

purposes of the proposed designation, the direct and indirect costs of the alternatives,

including capital and operating costs, and the effects of the alternatives on the cost to

generators.

Subd. 1e. [Repealed, 1995 c 247 art 1 s 67]

Subd. 2. Commissioner review. The commissioner shall review each master plan or revision

thereof to determine whether it is consistent with the metropolitan policy plan. If it is not

consistent, the commissioner shall disapprove and return the plan with its comments to the

county for revision and resubmittal. The county shall have 90 days to revise and resubmit the

plan for the commissioner's approval. Any county solid waste plan or report approved by the

council prior to July 1, 1994, shall remain in effect until a new master plan is submitted to

and approved by the commissioner in accordance with this section.

The commissioner shall review the household hazardous waste management portion of each

county's plan.

Subd. 2a. Waste abatement. The commissioner may require any county that fails to meet the

waste abatement objectives contained in the metropolitan policy plan to amend its master

plan to address methods to achieve the objectives. The master plan amendment is subject to

review and approval as provided in subdivision 2 and must consider at least:

(1) minimum recycling service levels for solid waste generators;

(2) mandatory generator participation in recycling programs including separation of

recyclable material from mixed municipal solid waste;

(3) use of organized solid waste collection under section 115A.94; and

(4) waste abatement participation incentives including provision of storage bins, weekly

collection of recyclable material, expansion of the types of recyclable material for collection,

collection of recyclable material on the same day as collection of solid waste, and financial

incentives such as basing charges to generators for waste collection services on the volume

of waste generated and discounting collection charges for generators who separate

recyclable material for collection separate from their solid waste.

Subd. 3. Annual report. By April 1 of each year, each metropolitan county shall prepare and

submit to the commissioner for approval a report containing information, as prescribed in

the metropolitan policy plan, concerning solid waste generation and management within the

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county. The report shall include a statement of progress in achieving the land disposal

abatement objectives for the county and classes of cities in the county as stated in the

metropolitan policy plan and county master plan. The report must list cities that have not

satisfied the county performance standards for local abatement required by subdivision 1c.

The report must include a schedule of rates and charges in effect or proposed for the use of

any solid waste facility owned or operated by or on its behalf, together with a statement of

the basis for such charges.

The report shall contain the recycling development grant report required by section 473.8441

and the annual certification report required by section 473.848.

Subd. 4. Advisory committee. Each county shall establish a solid waste management advisory

committee to aid in the preparation of the county master plan, any revisions thereof, and

such additional matters as the county deems appropriate. The committee must consist of

resident representatives, representatives from towns and cities within the county, and

representatives from private waste management firms. The committee must include

residents of towns or cities within the county containing solid waste disposal facilities. The

commissioner or the commissioner's appointee is a nonvoting ex officio member of the

committee.

Subd. 5. Role of private sector; county oversight. A county may include in its solid waste

management master plan and in its plan for county land disposal abatement a

determination that the private sector will achieve, either in part or in whole, the goals and

requirements of sections 473.149 and 473.803, as long as the county:

(1) retains active oversight over the efforts of the private sector and monitors performance

to ensure compliance with the law and the goals and standards in the metropolitan policy

plan and the county master plan;

(2) continues to meet its responsibilities under the law for ensuring proper waste

management, including, at a minimum, enforcing waste management law, providing waste

education, promoting waste reduction, and providing its residents the opportunity to recycle

waste materials; and

(3) continues to provide all required reports on the county's progress in meeting the waste

management goals and standards of this chapter and chapter 115A.

CSWMP standards and procedures

The MPP hereby sets out the following specific procedures, standards and review criteria for the

administration of Metropolitan CSWMP:

Procedures

• Scope: MPCA will review CSWMP submitted to MPCA for approval under Minn. Stat. § 473.803.

• Timeline for CSWMP: MPCA requires counties to formulate, submit and obtain MPCA approval

of a new CSWMP within 12 months of the MPCA’s adoption of the MPP. If a county fails to

formulate and obtain MPCA approval of a new CSWMP within 24 months after the MPCA’s

adopts the MPP, then MPCA may withhold the disbursement of SCORE block grants under Minn.

Stat. § 115A.557.

• Requirements for the contents of CSWMP: See statute above and additional standards outlined

below.

• MPCA review of CSWMP: MPCA will review CSWMP and submit comments if there are any

deficiencies in the CSWMP in accordance with the standards and criteria outlined below.

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Standard. To be approved by the MPCA, the CSWMP must contain the information contained in Minn.

Stat. § 473.803 and implement the CSWMP, including the goals and objectives of the MPP. The MPCA

will review the CSWMP to determine:

• Whether the CSWMP implements the local abatement objectives for the county and cities

within the county as stated in the Metropolitan System Plan (Part 3).

• Whether the CSWMP includes specific and quantifiable county landfill abatement objectives,

based on the objectives in the metropolitan landfill abatement plan, for abating to the greatest

feasible and prudent extent the need for and practice of land disposal of mixed municipal solid

waste and of specific components of the solid waste stream generated in the county, stated in

six-year increments for a period of at least 20 years from the date of the MPP revisions.

• Whether the CSWMP includes measurable performance standards for local abatement of solid

waste through resource recovery and waste reduction and separation programs and activities

for the county as a whole and for statutory or home rule charter cities of the first, second, and

third class, respectively, in the county, stated in six-year increments for a period of at least 20

years from the date of the MPP revisions.

• Whether the performance standards implement the metropolitan and county abatement

objectives.

• Whether the CSWMP includes standards and procedures to be used by the county in

determining annually under Minn. Stat. § 473.803, subd. 3 whether a city within the county has

implemented the CSWMP and has satisfied the performance standards for local abatement.

• Whether the CSWMP outlines specific and measurable actions to be taken by entities delegated

by the county to implement the MPP.

• Whether the CSWMP outlines specific measures to maintain oversight over entities delegated

by the county to implement the MPP.

• Whether the CSWMP outlines accountability measures for solid waste programs delegated to

the private sector.

•

Whether the CSWMP includes criteria and standards to protect comparable private and public

facilities already existing in the area from displacement unless the displacement is required to

achieve the waste management objectives identified in the CSWMP. Specifically, the CSWMP

must require that for all solid waste facilities owned or operated by public agencies or

supported primarily by public funds or obligations issued by a public agency (public facility), the

owner must demonstrate that the public facility:

• Does not displace comparable private and public facilities already existing in the area

unless the displacement is required in order to achieve the waste management objectives

identified in the CSWMP

• Is consistent with the applicable CSWMP

• Is necessary to achieve the waste management objectives identified in the CSWMP

• Is consistent with state policy and purposes outlined in Minn. Stat. § 115A.02 and Minn.

Stat. §§ 473.842 to 473.849

Role of private sector; county oversight. Pursuant to Minn. Stat. § 473.803, subd. 5, a county may

include in its CSWMP and in its CSWMP for county land disposal abatement a determination that the

private sector will achieve, either in part or in whole, the goals and requirements of sections 473.149

and 473.803, as long as the county:

6. Retains active oversight over the efforts of the private sector and monitors performance to ensure

compliance with the law and the goals and standards in the MPP and the CSWMP.

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7. Continues to meet its responsibilities under the law for ensuring proper waste management,

including, at a minimum, enforcing waste management law, providing waste education, promoting

waste reduction, and providing its residents the opportunity to recycle waste materials.

8. Continues to provide all required reports on the county's progress in meeting the waste

management goals and standards of Minn. Stat. §. 473 and 115A.

To approve a CSWMP that includes this element, the CSWMP must include:

9. Specific quantifiable plans and strategies formulated and provided to the county by the private

sector that shows how the private sector will implement applicable portions of the MPP and

CSWMP.

10. Specific quantifiable methods and strategies that the county will implement to hold the private

sector accountable for achieving waste management objectives. These strategies must include a

description of applicable fees, subsidies, agreements, regulations, licenses, reporting requirements,

and/or other institutional arrangement that are manifest in the arrangement that the county has

with the private sector that will assure the private sector will implement applicable parts of the

CSWMP and the MPP.

11. Specific measures that counties will implement to maintain oversight and measurement of

outcomes of the programs delegated to the private sector. The CSWMP must also specify what fees,

subsidies, agreements, regulations, licenses, reporting requirements, sanctions and/or other

institutional arrangements that will be used to correct actions taken by the private sector if, in

measuring the actions of the private sector, the county finds that the private entity is not managing

waste as specified in the MPP and the CSWMP.

CSWMP approval. While a county is developing a new CSWMP for submittal to the MPCA, the existing

CSWMP remains in effect until the MPCA approves or disapproves the new CSWMP. If the MPCA

disapproves a county CSWMP, the county shall resubmit the CSWMP with changes that reflect the

MPCA’s comments within 90 days. If the CSWMP is not approvable after revision, the MPCA will

disapprove the CSWMP and will terminate the eligibility of the county for grants pursuant to Minn. Stat.

§ 115A.557subd. 3(b)(1).

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Appendix E: Glossary

Terms used in this MPP are intended to have meanings consistent with state statutes. Any words not

defined in this appendix should be understood to have a meaning consistent with state law.

Collection

The aggregation of waste from the place at which it is generated and includes all activities up to the time

the waste is delivered to a waste facility. (Minn. Stat. § 115A.03, subd. 5)

Composting

The controlled microbial degradation of organic waste to yield a humus-like product. (Minn. R.

7035.0300, subp. 20)

Construction debris

Waste building materials, packaging and rubble resulting from construction, remodeling, repair and

demolition of buildings and roads. (Minn. Stat. § 115A.03, subd. 7). Also referred to in the MPP as

construction and demolition waste.

Disposal facility

A waste facility permitted by the MPCA that is designed or operated for the purpose of disposing of

waste on or in the land, together with any appurtenant facilities needed to process waste for disposal or

transfer to another waste facility. (Minn. Stat. 115a.03, subd. 10)

Governance

Governance is the process by which materials are managed for the public good with an emphasis on

highest and best use of materials and overall system sustainability. Governance includes the goals and

activities of government entities, businesses, nonprofits, communities, and individual residents.

Hazardous waste

Any refuse, sludge, or other waste material or combinations of refuse, sludge or other waste materials

in solid, semisolid, liquid, or contained gaseous form, which because of its quantity, concentration, or

chemical, physical, or infectious characteristics may (a) cause or significantly contribute to an increase in

mortality or an increase in serious irreversible, or incapacitating reversible illness; or b) poses a

substantial present or potential hazard to human health or the environment when improperly treated,

stored, transported, or disposed of, or otherwise managed. Categories of hazardous waste materials

include but are not limited to explosives, flammables, oxidizers, poisons, irritants, and corrosives.

Hazardous waste does not include source, special nuclear, or by-product material as defined by the

Atomic Energy Act of 1954, as amended. (Minn. Stat. § 116.06, subd. 11)

Household hazardous waste

Waste generated from household activity that exhibits the characteristics of or that is listed as

hazardous waste under MPCA rules but does not include waste from commercial activities that is

generated, stored, or present in a household. (Minn. Stat. § 115A.96, subd. 1b)

Industrial waste

Solid waste resulting from an industrial, manufacturing, service, or commercial activity that is managed

as a separate waste stream. (Minn. Stat. § 115A.03, subd. 13a)

Industrial solid waste

All solid waste generated from an industrial or manufacturing process and solid waste generated from

nonmanufacturing activities such as service and commercial establishments. Industrial solid waste does

not include office materials, restaurant and food preparation waste, discarded machinery, demolition

debris, municipal solid waste combustor ash, or household refuse. (Minn. R. 7035.0300, subp. 45)

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Land disposal

Depositing of materials in a land disposal facility.

Land disposal facility

Any tract or parcel of land, including any constructed facility, at which solid waste is disposed of in or on

the land. (Minn. R. 7035.0300, subp. 52)

Leachate

Liquid that has percolated through solid waste and has extracted, dissolved, or suspended materials

from it. (Minn. R. 7035.0300, subp. 56)

Local governmental unit

Cities, towns, and counties. (Minn. Stat. § 115A.03, subd. 17)

Long-term care

Actions to prevent or minimize the threat to public health and the environment posed by a mixed

municipal solid waste disposal facility that has stopped accepting waste by controlling the sources of

releases or threatened releases at the facility (Minn. Stat. § 115B.39, subd. 2.(c)).

Major appliances

Defined by statute as clothes washers and dryers, dishwashers, hot water heaters, heat pumps,

furnaces, garbage disposals, trash compactors, conventional and microwave ovens, ranges and stoves,

air conditioners, dehumidifiers, refrigerators, and freezers. (Minn. Stat. § 115A.03, subd. 17a)

Materials recovery facility (MRF)

Facility designed for centralized sorting, processing, and/or grading of collected recyclable materials for

marketing.

Twin Cities Metropolitan Area (TCMA)

Means the area over which the Metropolitan Council has jurisdiction, including only the counties of

Anoka; Carver; Dakota excluding the city of Northfield; Hennepin excluding the cities of Hanover and

Rockford; Ramsey; Scott excluding the city of New Prague; and Washington. (Minn. Stat. § 473.121,

subd. 2)

Municipal Solid Waste (MSW)

Means mixed municipal solid waste (MMSW), materials banned from MMSW such as yard waste and

specific problem materials, recyclable materials, and other solid waste that is solid waste that is

generated by residential, commercial, industrial, and community activities.

Mixed municipal solid waste (MMSW)

(a) Garbage, refuse and other solid waste from residential, commercial, industrial and community

activities that the generator of the waste aggregates for collection, except as provided in paragraph (b),

(b) mixed MSW does not include auto hulks, street sweepings, ash, construction debris, mining waste,

sludges, tree and agricultural wastes, tires, lead acid batteries, motor and vehicle fluids and filters, and

other materials collected, processed and disposed of as separate waste streams, but does include

source-separated compostable materials. (Minn. Stat. § 115A.03, subd. 21)

Non-municipal solid waste (non-MMSW)

Solid waste resulting from construction, demolition, or industrial activities which is not mixed municipal

solid waste.

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Organic material

Organic waste typically includes food waste, non-recyclable paper products, yard waste, and other

materials that readily degrade. According to EPA, “Organic matter in landfills breaks down and releases

methane, a potent GHG, and contributes to landfill leachate that can pollute waterways.”

Organized collection

A system for collecting solid waste in which a specified collector, or a member of an organization of

collectors, is authorized to collect from a defined geographic service area or areas some or all the solid

waste that is released by generators for collection. (Minn. Stat. § 115A.94, subd. 1)

Postconsumer material

A finished material that would normally be discarded as a solid waste having completed its life cycle as a

consumer item. (Minn. Stat. § 115A.03, subd. 24b)

Problem material

Material that, when it is processed or disposed of with mixed municipal solid waste, contributes to one

of the following results: 1) the release of a hazardous substance, or pollutant or contaminant; 2)

pollution of water; 3) air pollution; or 4) a significant threat to the safe or efficient operation of a solid

waste facility. The four conditions are further defined in Minn. Stat. § 115A.03, subd. 24a.

Processing

Describes the treatment of waste after collection and before disposal. Processing includes, but is not

limited to, reduction, storage, separation, exchange, resource recovery, physical, chemical, or biological

modification and transfer from one waste facility to another (Minn. Stat. § 115A.03, subd. 25 and

473.848, subd. 5.

Recycling

The process of collecting and preparing recyclable materials and reusing the materials in their original

form or using them in manufacturing processes that do not cause the destruction of recyclable materials

in a manner that precludes further use. (Minn. Stat. § 115A.03, subd. 25b)

Recycling facility

A facility at which materials are prepared for reuse in their original form or for use in manufacturing

processes that do not cause the destruction of the materials in a manner that precludes further use.

(Minn. Stat. § 115A.03, subd. 25c)

Recyclable materials

Materials that are separated from mixed municipal solid waste for the purpose of recycling or

composting, including paper, glass, plastics, metals, automobile oil, batteries, source-separated

compostable materials, and sole source food waste streams that are managed through biodegradative

processes. Refuse-derived fuel or other material that is destroyed by incineration is not a recyclable

material. (Minn. Stat. § 115A.03, subd. 25a)

Refuse-derived fuel

A product resulting from the processing of MMSW in a manner that reduces the quantity of

noncombustible material present in the waste, reduces the size of waste components through shredding

or other mechanical means, and produces a fuel suitable for combustion in existing or new solid fuel-

fired boilers. (Minn. Stat. § 115A.03, subd. 25d)

Residuals

Waste materials left after recovery of recyclables and/or the physical, chemical, or biological processing

of wastes.

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Resource recovery

The reclamation for sale, use, or reuse of materials, substances, energy, or other products contained

within or derived from waste. (Minn. Stat. § 115A.03, subd. 27)

Resource recovery facility

A waste facility established and used primarily for resource recovery, including related and appurtenant

facilities such as transmission facilities and transfer stations primarily serving the resource recovery

facility. (Minn. Stat. § 115A.03, subd. 28)

Reusable

Most items can be reused even if the original design was intended for single use, making a reuse

definition more difficult. However, this also makes it more important for programming to clarify number

of reuses necessary (e.g., grant programs for swapping single-use items for reusables or ordinance

requiring reusables for all dine-in food service). Recently, reusable programming and policy has been

focusing on food service ware, food packaging, and personal product packaging. These are three main

elements defining “reusable” for these types of scenarios:  

•  Durable design – as previously noted, most items can be reused regardless of the original

intent. Programs and policies must indicate how durable (i.e., number of reuses to break even

with the life cycle impacts of a single-use alternative) an item needs to be considered

“reusable”  

•  Actual reuse (returns and/or refills) – more resources go into manufacturing a more durable,

reusable item, so actual reuse is needed to offset those impacts. This typically means ensuring a

system is in place for individuals to personally refill the item or return it to be refilled or used

again. Programs and policies must specify an expectation for how this system will be designed,

funded, serviced, and operated long-term.  

• Non-toxic materials – while there are clear benefits of reusable items and systems, it is critical

to test, monitor, and restrict harmful chemicals to limit human and environmental exposures.

Often programs and policies emphasize reuse to reduce waste generation or climate impacts

from manufacturing and overlook toxicity considerations.  

Reuse

The continued use, repair, or repurposing of items or materials which extends the life of resources and

decreases the demand for new production. Continued use can include resale (e.g., thrift stores), sharing

(e.g., clothing swaps without a financial exchange), or rental (e.g., formal wear rental). When

repurposing an item or material, it is in the current form of the product without drastic modifications –

this is the main difference between reuse and recycling.

Secondary materials

The marketable or usable products derived from solid or hazardous waste through processing or

separation.

Solid waste

Garbage, refuse, or sludge from a water supply treatment plant or air contaminants treatment facilities,

and other discarded waste materials and sludges, in solid, semisolid, liquid, or contained gaseous form,

resulting from industrial, commercial, mining, and agricultural operations, and from community

activities, but does not include hazardous waste; animal waste used as fertilizer; earthen fill, boulders,

rock; sewage sludge; solid or dissolved materials in domestic sewage or other common pollutants in

water sources, such as silt, dissolved or suspended solids in industrial wastewater effluents or discharges

which are point sources subject to permits under section 402 of the federal Water Pollution Control Act;

as amended, dissolved materials in irrigation return flows; or source, special nuclear, or by-product

materials as defined by The Atomic Energy Act of 1954, as amended. (Minn. Stat. § 116.06, subd. 22)

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Solid waste management

The systematic administration of activities that provide for the collection, separation, storage,

transportation, transfer, processing, treatment, and disposal of solid waste.

Source separation

Separation of recyclable or compostable materials by the waste generator prior to collection.

Source reduction (see also waste reduction)

An activity that prevents generation of waste or the inclusion of toxic materials in waste, including:

(1) reusing a product in its original form; (2) increasing the life span of a product; (2) reducing material

used in production or packaging, or changing procurement, consumption, or waste generation habits to

result in smaller quantities or lower toxicity of waste generated. (Minn. Stat. § 115A.03, subd. 36b)

Storage

Containment of solid or hazardous waste, in an approved manner, after generation and before

collection, for ultimate recovery or disposal.

Sustainable materials management

Describes an approach to serving human needs by using/reusing resources most productively and

sustainably throughout their life cycles, generally minimizing the amount of materials involved and all

the associated environmental impacts (Source: EPA). SMM focuses on the best use and management of

materials based on how they impact the environment throughout their life cycle. SMM considers the

impacts of extracting raw materials, scarcity of materials, product design, product use, and reuse.

Transfer station

An intermediate waste facility in which waste collected from any source is temporarily deposited to

await transportation to another waste facility. (Minn. Stat. § 115A.03, subd. 33)

Unprocessed mixed municipal solid waste (Unprocessed MMSW)

For the purpose of Minn. Stat. § 473.848, waste is "unprocessed" if it has not, after collection and before

disposal, undergone separation of materials for resource recovery through recycling, incineration for

energy production, production and use of refuse-derived fuel, composting, or any combination of these

processes so that the weight of the waste remaining that must be disposed of in a mixed municipal solid

waste disposal facility is not more than 35% of the weight before processing, on an annual average.

Waste flow designation

A requirement by a waste management district or county that all or any portion of the mixed municipal

solid waste that is generated within its boundaries or any service area thereof be delivered to a

processing or disposal facility identified by the district or county. (Minn. Stat. § 115A.81, subd. 2)

Waste facility

All property real or personal, including negative and positive easements and water and air rights, which

is or may be needed or useful for the processing or disposal of waste, except property used for the

collection of the waste and property used primarily for the manufacture of scrap metal or paper. Waste

facility includes, but is not limited to, transfer stations, processing facilities, and disposal sites and

facilities. (Minn. Stat. § 115A.03, subd. 35)

Waste management

Activities that are intended to affect or control the generation of waste and activities which provide for

or control the collection, processing, and disposal of wastes. (Minn. Stat. § 115A.03, subd. 36)

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Waste reduction (see also source reduction)

An activity that prevents generation of waste or the inclusion of toxic materials in waste, including:

(1) reusing a product in its original form; (2) increasing the life span of a product; (2) reducing material

used in production or packaging, or changing procurement, consumption, or waste generation habits to

result in smaller quantities or lower toxicity of waste generated. (Minn. Stat. § 115A.03, subd. 36b)

Yard waste

Garden wastes, leaves, lawn cuttings, weeds, shrub, and tree waste, and prunings. (Minn. Stat. §

115A.03, subd. 38)

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Appendix F: Metro Policy Plan MMSW forecast

Forecasted MMSW using per capita MMSW generation using a

combination of ARIMA and baseline forecasting methods.

Data sources

Mixed Municipal Solid Waste (MMSW) Tonnage

All forecasts use tonnage information provided by the counties from their MMSW Certification reports

and SCORE reports. Additional work has been done by the MPCA and the counties to ensure these

sources are aligned.

Population

Population estimates and forecasts come from the Minnesota State Demographic Center at the

Department of Administration. Additional interpolation has been performed on the forecasts to achieve

annual values versus 5-year values. If there is no Population estimate available for a given year, the

forecast value is used instead.

2020 Population values are sourced from the U.S. Census.

Alternative forecast assumptions

Assumptions for the alternative forecast regarding the amount of diversion of Recycling and Organics

from MMSW were sourced from the counties and compiled by the MPCA into a consistent format and

applied to the MPCA’s forecasted MMSW generation rate.

Methodology

Forecast assumptions

Below is the summary of assumptions used for the MPP forecast:

• Ramsey and Washington counties are combined into one entity due to difficulty in splitting out

their WTE and their joint powers agreement

• Metro counties will achieve the 75% recycling rate as laid out in Minn. Stat. § 115A.551 by 2030

• Using the baseline rate for traditional recyclables and organics, increased recycling and

organics diversion will be assumed at a constant rate until the 75% recycling rate is

achieved in 2030.

• Total compliance with Restriction on Disposal (ROD) is assumed

• Capacities for the WTE facilities serving the TCMA provided in Table 12.

• If there is additional capacity at a given WTE facility, that capacity will be used by all

available MMSW in the TCMA regardless of originating county

• Landfilling is assumed to be a minimum of 5% given the need to manage non-processibles, bulky

items at WTE facilities and residuals and rejects from recycling and composting facilities.

• Baseline is the last year of observable data since the latest year of data represent the best data

available to the counties and their current education and diversion practices.

• The continued operation of HERC is assumed. While the Hennepin County board has instructed

staff to develop a plan with HERC closing sometime in the 2028-2040 timeframe, it is currently

not clear if that timeline will be met or when within that timeframe the facility would come

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offline. If HERC closes during the planning period, the MMSW would be managed via landfilling.

The Metro Policy Plan (MPP) is updated every 6 years and a new forecast is developed with each

iteration. MPCA will have a better understanding of the future of HERC during the development

of the next MPP.

Forecast models

Each county was modeled separately using an Auto-regressive Integrated Moving Average (ARIMA)

model on population corrected MMSW tonnage (per capita generation) from 2010 to 2020.

Recycling and Organics was forecasted using a baseline per capita generation (2020) – the tons of

traditional recyclables generated per person and the tons of organics generated per person. As the

population increases, new residents will have access to the same infrastructure, education, and benefits

that current residents do thus increased population will not increase the current per capita generation

but will increase total tonnage.

WTE capacity

Hennepin County is the sole provider of MMSW to the HERC facility while Ramsey and Washington split

the capacity of the Ramsey-Washington Energy Center. Each of these facilities is assumed to be at

capacity due to ROD compliance.

Dakota County will continue to send MMSW to the Red Wing processing facility, estimating 10,000 tons

in 2020 and 13,000 tons in all subsequent years.

Table 12. Annual capacity (in tons) for the WTE facilities servicing the TCMA.

Facility

Annual Capacity (in Tons)

HERC

365,000

Ramsey-Washington Energy Center

450,000

City of Red Wing

13,000

Total landfill tonnage

The amount of material estimated to go to landfills is determined by the MMSW forecast created by the

MPCA and is the amount remaining after additional diversion is removed from the MMSW and the

amount dedicated to WTE is subtracted, as shown in Equation 1.

Equation 1. Calculation for landfill tonnage using MMSW forecast, additional diversion assumptions, and WTE

capacity

Landfill=MMSW−(Additional Diversion+WTE)Landfill=MMSW−(Additional Diversion+WTE)

Results

The per capita generation point estimate was multiplied by the forecasted population change for each

county and management method to provide the total MMSW.

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Figure 16. Reported and forecasted TCMA MMSW collection methods amounts in tons

Table 13. Total TCMA MMSW forecast by management method

Year

Landfill

WTE

Recycling

Organics

Total

MSW

Total

MMSW

Recycling

Rate

2010

917,472

785,506

620,069

127,879

2,450,926

1,702,979

31%

2011

810,443

842,273

627,884

130,010

2,410,610

1,652,716

31%

2012

739,152

901,721

715,089

134,292

2,490,254

1,640,873

34%

2013

713,741

908,636

660,166

150,980

2,433,523

1,622,377

33%

2014

728,970

978,326

813,580

275,574

2,796,450

1,707,296

39%

2015

767,491

931,415

778,092

341,745

2,818,743

1,698,906

40%

2016

799,435

897,494

836,135

452,956

2,986,020

1,696,929

43%

2017

834,315

942,536

1,004,251

479,283

3,260,385

1,776,852

46%

2018

785,118

951,181

1,091,967

502,906

3,331,173

1,736,299

48%

2019

1,028,517

710,286

1,036,330

511,934

3,287,068

1,738,803

47%

2020

1,023,749

678,239

1,041,423

549,135

3,292,546

1,701,987

48%

2021

825,124

821,000

1,118,619

590,477

3,355,219

1,809,433

51%

2022

750,682

821,000

1,188,683

627,698

3,388,064

1,720,145

54%

2023

674,392

821,000

1,259,825

665,492

3,420,710

1,612,238

56%

2024

596,250

821,000

1,332,017

703,843

3,453,110

1,503,892

59%

2025

516,260

821,000

1,405,232

742,737

3,485,229

1,395,014

62%

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Year

Landfill

WTE

Recycling

Organics

Total

MSW

Total

MMSW

Recycling

Rate

2026

434,457

821,000

1,479,466

782,172

3,517,095

1,285,592

64%

2027

350,828

821,000

1,554,665

822,118

3,548,611

1,175,605

67%

2028

265,388

821,000

1,630,789

862,556

3,579,733

1,065,079

70%

2029

180,521

818,633

1,707,795

903,462

3,610,411

954,059

72%

2030

182,030

728,122

1,785,643

944,814

3,640,609

842,609

75%

2031

183,515

734,060

1,800,245

952,479

3,670,298

842,970

75%

2032

184,973

739,892

1,814,588

960,006

3,699,459

843,113

75%

2033

186,404

745,615

1,828,665

967,391

3,728,075

843,036

75%

2034

187,807

751,230

1,842,477

974,635

3,756,150

842,739

75%

2035

189,184

756,737

1,856,024

981,738

3,783,683

842,225

75%

2036

190,534

762,137

1,869,311

988,703

3,810,684

841,497

75%

2037

191,858

767,433

1,882,342

995,531

3,837,165

840,562

75%

2038

193,157

772,628

1,895,128

1,002,229

3,863,142

839,423

75%

2039

194,432

777,726

1,907,674

1,008,799

3,888,632

838,089

75%

2040

195,683

782,731

1,919,992

1,015,248

3,913,653

836,565

75%

2041

196,911

787,646

1,932,092

1,021,580

3,938,229

834,858

75%

2042

198,120

792,479

1,943,990

1,027,805

3,962,393

832,977

75%

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

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Appendix G: Strategy table

Table 14. Strategy table with point values and interested parties

Code

Number

Strategy Type

Optional

Point Value

Interested Parties

1

Increase compliance with Hauler reporting per

Minn. Stat. § 115A.93.

Required

haulers, industry, county

staff

2 Provide required county reporting. Required county s taff

3

Requi re was te compos iti on s tudy at least once every

5 years at all landfills that are located within your

c

ounty.

Required landfill operators

4

Improve recycling data collection at businesses

within the county.

Optional 7 county staff, businesses

5 Require waste composition study at all landfills. S

tate-l ed MPCA

6

Develop appropriate and consistent waste reporting

systems to measure all waste.

State-l ed MPCA

7

Continue to explore options for growing the agency’s

LCA data, modeling, and resources to better support

c

ounties in measuring and tracking environmental

and human health impacts.

State-l ed MPCA

8

Continue to engage with counties in the development

of an environmental target that better accounts for

a

nd incentivizes programming and actions higher on

the hierarchy.

State-l ed MPCA

9

Participate in an annual joint commissioner/staff

meeti ng on s ol i d waste.

Required county s taff and board

10 Commit to standardized outreach and education. Required

county s taff, MRFs ,

res i dents

11

Engage in efficient and value-added infrastructure

planning.

Required

county s taff, SW faci l ity

operators

12

Develop contingency plans for large facility

closures to reduce landfill reliance

Required

county s taff, SW faci l ity

operators

13

Provi de grants for or access to s oftware that can

track food was te.

Required

county s taff, restaurants,

cafeteri a s

14

Establish partnerships between food rescue

organizations and restaurants/stores to increase

f

ood res cue.

Required

county staff, food rescue

orgs, restaurants, grocery

st

ores

15

Launch bi-annual sustainable consumption

chal l enges for res i dents .

Required county staff, residents

16

Implement a formal county sustainable purchasing

policy using MPCA guidance.

Required county staff, vendors

17

Participate in Responsible Public Purchasing

Council meeti ngs.

Required county s taff, MPCA

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Code

Number

Strategy Type

Optional

Point Value

Interested Parties

18

Work with health inspectors to educate restaurants

and other establishments that have excess prepared

food to donate.

Optional 7

county staff, health dept,

restaurants and other food

producers/s

purveyors

19

Offer grants or rebates for organizations to transition

to reusa bl e food and beverage s ervi ce ware.

Required

county s taff, restaurants ,

organizations serving food

20 Offer grants for source reduction, reuse, and repair. Required

county staff, repair and reuse

businesses

21 Impl ement a green meeti ng pol icy. Required county s taff

22

Implement a county policy encouraging all county

and city-led events and food providers use reusable

food and bevera ge servi ce ware.

Optional 6 county s taff

23

Adopt an ordinance with a mandatory consumer

charge or ban for single-use items.

Optional 9 county s taff, restaurants

24

Join and/or actively participate in a reuse network,

like Reuse Minnesota, to provide county and city staff

with learning opportunities to broaden their reuse

experti s e.

Optional

6 county s taff

25

Establish a Repair Ambassador program, like the

Recycler/Composters (RCAs) Ambassador programs. 

Optional 7 county staff, residents

26

Establish a reuse location for residential drop-off

and pick-up.

Optional 7 county staff, residents

27

Establish a curbside set-out day to allow residents to

set out us ed i tems for reus e.

Optional 7

county staff, residents, reuse

businesses

28

Develop standardized guidance and methodology for

tracking source reduction and reuse activities and

their resulting benefits.

State-l ed

MPCA

29

Research and pursue financial strategies to best

incentivize source reduction and reuse, such as

grants and loans.

State-l ed MPCA

30

Collect recyclables, organics, and trash on the same

day.

Required

county staff, residents,

haulers

31 Collect recycling weekly by 2030. Optional 7

county staff, residents,

haulers

32

Pair the option of bi-weekly trash collection with

weekly recycling and organics collection.

Optional 7

county staff, residents,

haulers

33

Contract for residential recycling and organics by

2030.

Optional 7

county staff, residents,

haulers

34 Contract for residential MMSW collection by 2030. Optional 7

county staff, residents,

haulers

35

Recruit a minimum of 12 commercial businesses a

year to recycl e at l ea st three materi al s from thei r

operations and promote the environmental and

res ource benefi ts .

Required county staff, businesses

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

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Code

Number

Strategy Type

Optional

Point Value

Interested Parties

36

Establish mandatory pre-processing of waste

at resource recovery facilities and landfills by

2030.

Required

haulers, landfill operators,

trans fer stati on operators

37

Provide assistance to multi-family properties

to improve recycling (4 or more units with

shared walls

Required county staff, property managers

38

Assist with tracking commercial recycling self-

hauling activities.

Sta te-l ed MPCA

39

Support and invest in new facilities and retain

proces s ors of recycl ed materi a l for end

markets.

Sta te-l ed MPCA

40

Make residential curbside organics collection

available in cities with a population greater

than 5,000 by 2030.

Required county staff, residents, haulers

41

Expand backyard composting outreach and

res ources for res i dents.

Required county staff, residents

42

Requi re management of organi cs from l a rge

commercial food generators by 2033.

Required

county staff, commercial food

generators

43

Establish additional organics recycling drop-

off sites.

Optional 7 county staff, residents

44

Standardize the role of compostable products

in organics recycling programs by 2025.

Sta te-l ed MPCA

45

Develop plans to prevent and manage wood

waste in each county and throughout the

regi on.

Required

county staff, yard waste

proces s ors , tree care and

landscaping operators

46

Promote exis ting programs that use EAB-

effected wood for furniture, home goods,

flooring, and other purposes.

Required

county staff, local artisans and

producers of wood products

47

Composting and mulching operations must

continue to be supported.

Required

county staff, composting and

mulching operators

48

Update ordinances that address wood

burning.

Optional 4 county staff, county board

49

Develop and distribute EAB tree care education

programs for privately owned land.

Optional 8 county staff, residents

50

Incenti vi ze tree trea tment a s a cos t-effecti ve

strategy to extend the life of as h trees and to

reduce the vol ume of wood was te generated

over the next 20 years .

Optional 8

county staff, residents,

arborists

51

Allow assessments on property taxes to

spread the cos t of tree care over a mul ti -year

ti meframe.

Optional 9

county staff, residents,

arborists

52

Expand composting and mulching capacity

beyond existing markets.

Optional 5 county staff, industry

53

Support development of systems that use wood

fuel .

Optional 4 county staff, industry

54

MPCA will continue state agency coordination

to address wood waste.

Sta te-l ed MPCA, DNR, MDA

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Code

Number

Strategy Type

Optional

Point Value

Interested Parties

55

Require food-derived compost in county

construction and landscaping projects.

Required county staff, industry

56

Find new outlets to increase food to animal

operations.

Optional 7

county staff, farmers,

restaurants

57

Develop a process for gathering the information

necess ary to make ti mel i er and cons i s tent pol i cy

decisions.

State-l ed MPCA

58

Counties must continue to support the

impl ementati on of Mi nn. Stat. § 473.848 Restri ction

on Disposal.

Required

county staff, industry, facility

operators

59

Implement additional fees to better account for the

externalities of land disposal.

Optional 4 county staff, industry

60

Participate with the Product Stewardship

Committee under the Solid Waste Administrators

Ass oci ati on (SWAA).

Required county staff

61

Encoura ge retai l ers to i ncrea s e cons umer

awareness of responsible end-of-life handling for

products containing lithium-ion batteries.

Required

county staff, retail store

operators

62

Continue participation in the reciprocal use

agreement for HHW col l ecti on s i tes.

Required county staff, HHW s ites

63

Partner with cities to increase participation in

HHW collection.

Required county staff, HHW s ites

64

Host monthly drop-off sites in locations other than

a permanent HHW si te.

Optional 8 county staff, HHW s ites

65

Implement the use of a Building Material

Management Plan.

Required

county staff, builders and

contractors

66

Prior to demolition of county-owned buildings,

requi re that SMM strategi es are cons idered.

Optional 7 county staff

67 Host a building material collection event or swap. Optional 8 county staff, residents

68

Provide financial assistance to offset the

additional cost of building deconstruction, used

building material installation, and/or structural

movi ng.

Optional 8

county staff, residents, builders

and contractors

69 Provide deconstruction training. Optional 8

county staff, builders and

contractors

70

Annually host or aid with home and building repair

and refurbishment trainings.

Optional 8

county staff, builders and

contractors, resi dents

71

Use purchasing guidelines to require

environmental product declaration (EPD) for

concrete.

Optional 7 county staff

72 Study waste classification practices. State-l ed MPCA

73

Propose changes to B3 guidelines to strengthen

deconstruction requirements.

State-l ed MPCA

74

Incentivize deconstruction over landfilling MMSW

and demolition debris.

State-l ed MPCA

75

Lead Sustainable Building Group (SBG)

devel opments.

State-l ed MPCA

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

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Appendix H: Air Toxic and Cumulative Impact Rules

Proposed changes to certain rules will be applicable to HERC. These rules apply only to air quality

permits in certain geographic areas of Minnesota. Option B registration permits are exempt from these

rules.

Minn. Stat. § 116.065 requires MPCA to adopt rules to implement and govern cumulative impacts

analysis in Environmental Justice areas in 7 county metro and cities of Duluth and Rochester. The Notice

of Intent to Adopt (NOIA) must be published in the State Register by May 2026. The Cumulative Impacts

Analysis Rule will be applicable to facilities with air permits located in or within one mile of an

environmental justice area in the TCMA and cities of Duluth and Rochester. HERC will be subjected to

Cumulative Impacts Analysis rule once adopted due to its location in an EJ area within Hennepin County

and its Part 70 permit. The MPCA may require a Cumulative Impacts assessment, if a petition requesting

that a cumulative analysis be conducted by at least 100 individuals who reside or own property in the

environmental justice area impacted by the facility and is supported by material evidence that

demonstrates a potential adverse cumulative impact. More detail can be found on the MPCA website.

Cumulative impacts | Minnesota Pollution Control Agency (state.mn.us)

The Air Toxics Regulations Rule will be applicable to facilities with air permits located in the TCMA. Three

years after adopting rules, the MPCA is required amend existing air quality permits to conform to the

rules. This applies even if the case there is no pending permit action. HERC will be subjected to this rule

once adopted due to its location within Hennepin County and its Part 70 permit. The MPCA must

establish testing, monitoring, reporting, record-keeping, and inspection requirements for facilities that

reflect: 

1. The different risks to human health and the environment posed by the specific air toxics and

amounts emitted by a facility, such that facilities posing greater risks are required to provide more

frequent evidence of permit compliance, including but not limited to performance tests, agency

inspections, and reporting; 

2. The facility's record of compliance with air toxics emission limits and other permit conditions; and 

3. Any exposure of residents of an environmental justice area to the facility's air toxics emissions.

More information can be found on the MPCA website.

Air toxics emissions reporting | Minnesota

Pollution Control Agency (state.mn.us)

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Appendix I: Public Comments and Responses

Name Affiliation Comment Response

Ally Sutherland

City of Inver

Grove Heights

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Source separation is the best way to recover materials and to ensure the highest value of those materials. However, despite our best efforts, human behavior is unpredictable. Preprocessing is the process of pulling recyclables out of mixed waste and it

can recover additional recyclables, especially metals. The cost of collection is the primary driver of cost to residents, but historically tip fees have not been the driver for cost. The plan has been modified to extend the timeline to allow facilities time to plan

the best preprocessing system. The Minnesota Legislature passed a sweeping bill to address and prohibit PFAS in consumer products. The Minnesota Attorney General reached an $850 million settlement with 3M. For more information about this, visit

https://3msettlement.state.mn.us/. All past and present research can be found on this page. This language will reduce the amount of PFAS entering landfills. To address landfill leachate, the MPCA is addressing PFAS through our solid waste and

wastewater programs. MPCA is also reviewing newly published research on landfill leachate. The plan prioritizes waste reduction, reuse, and recycling as the most important things we can do. These all minimize the amount of waste going to disposal.

These activities are funded by the solid waste management tax and landfill fees. A clear and consistent process for MPCA's issuance of CON to landfills statewide is now reflected in the plan.

Aaron

Rosenblum

Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Thank you for your feedback.

Akira Yano Resident

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The 5% waste reduction goal references the total generation of waste. Despite our best efforts, consumption influences waste generation. To truly be successful in waste reduction, upstream policies must be put into place by the Minnesota Legislature

that result in fewer materials being generated. The 75% goal is determined by state statute as the disposal avoidance goal and MPCA intends to aggressively push for improvement in all areas that are feasible. The plan includes required strategies for

counties to reduce and divert food waste, launch bi-annual sustainable consumption challenges for residents, and to implement a formal county sustainable purchasing policy. There are also strategies to support reuse and repair through volunteer

program, outreach, and grants. Thank you for your feedback.

Albert (Shane)

McCaffrey

Resident

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Metro counties will develop solid waste plans of their own based on this plan. This plan includes strategies to address organics recycling, multi-family, and education.

Alex Burns Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. The 5% waste reduction goal references the total generation of waste. Despite our best efforts, consumption influences waste

generation. To truly be successful in waste reduction, upstream policies must be put into place by the Minnesota Legislature that result in fewer materials being generated. The 75% goal is determined by state statute as the disposal avoidance goal and

MPCA intends to aggressively push for improvement in all areas that are feasible. The plan includes required strategies for counties to reduce and divert food waste, launch bi-annual sustainable consumption challenges for residents, and to implement a

formal county sustainable purchasing policy. There are also strategies to support reuse and repair through volunteer program, outreach, and grants. Thank you for your feedback.

Alice Brandt Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Thank you for your feedback.

Amanda

Koehler

Resident

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Compostable single-use is a better option than conventional single-use. However, reuse is the best option. The plan calls for residential curbside organics collection to be required region-wide in cities greater than 5,000. MPCA agrees that it must be more

convenient for people to participate in greater numbers. Chickens are not officially considered a solid waste management method, but the additional avenue for food waste management for residents is intriguing.

Amy Sheldon Resident

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Curbside collection of textiles has been discontinued by municipal programs due to the exposure to weather. Textiles must be dry and clean for both reuse and recycling. The Secondary Materials and Recycled Textiles (SMART) Association estimates that

about half of new clothing end up donated. Of the clothing that is donated, about 20% are sold in reuse outlets, 25% are shipped overseas, 50% are used as absorbants/rags/stuffing, and about 5% head to landfills or WTE facilities. That means that over

half of all textiles end up in the garbage. For a material to be recycled, it needs to be used to create a new product. Fast fashion has resulted in an onslaught of low-quality textiles that have no reuse nor recycling value. Durable textiles made from natural

fibers and extending the life via proper care and repair can help reduce personal impact. Minnesota Statute 115A.151 applies to most commercial buildings. Those that contract waste service for 4 cubic yards or more per week are required to recycle at

least three materials types. Resident education is addressed in this plan with a strategy that calls for a commitment to standardized outreach and education. We agree that the messaging reaching residents should be easy to understand. Piecemeal efforts

by counties, cities, haulers, and other organizations are rarely collaboratively developed and therefore can lead to confusion over what materials can be recycled or composted. Assuring a consistent message from those within the solid waste system

would help bring clarity to the users of the system. The plan calls for residential curbside organics collection to be required region-wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater

numbers. The plan requires counties to standardized outreach and education. This will address the concern that different terms are used throughout the metro and will help to address confusion. Waste reduction in construction and remodeling projects

will require many solutions. The state doesn’t currently have requirements for construction and remodeling material management. However, there are several waste reduction initiatives and an increase in reuse activities. Removing barriers to buying,

selling and donation of surplus materials benefits us all.

Andrea Siegel Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Counties are required to complete an environmental justice review when developing their solid waste plans. The requirements are

laid out in Appendix B. With the addition of multi-family strategies in the plan, we believe this supports a solid waste system that strives for fair treatment and meaningful involvement of all people. The plan has been amended to allow for counties to

propose optional strategies. We encourage all our metro counties to propose strategies that would directly address environmental justice. The plan includes required strategies for counties to reduce and divert food waste, launch bi-annual sustainable

consumption challenges for residents, and to implement a formal county sustainable purchasing policy. There are also strategies to support reuse and repair through volunteer program, outreach, and grants. The 5% waste reduction goal references the

total generation of waste. Despite our best efforts, consumption influences waste generation. To truly be successful in waste reduction, upstream policies must be put into place by the Minnesota Legislature that result in fewer materials being generated.

The 75% goal is determined by state statute as the disposal avoidance goal and MPCA intends to aggressively push for improvement in all areas that are feasible. Thank you for your feedback.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Amy Sklar Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Thank you for your feedback.

Andrea Sit Resident

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This plan requires residential curbside organics collection to be region-wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater numbers. The plan includes education requirements that should help

create more informed residents. Minnesota has some of the best recycling rates in the nation. There are many systems and requirements in place that assure the materials in resident bins are routed to their intended place. MN statute 115A.95 does not

allow for haulers to deliver source-separated recyclable materials to a disposal facility unless the MPCA determines that no other recycling options are available. Except for litter in waterways, it's highly unlikely that any plastic waste from Minnesota ends

up in the ocean. County environmental centers and household hazardous waste drop sites are wonderful resources for managing materials safely and to their highest use. The plan has been revised to require counties to promote these sites to residents.

Andrea Tauer Resident

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Curbside collection of textiles has been discontinued by municipal programs due to the exposure to weather. Textiles must be dry and clean for both reuse and recycling. The Secondary Materials and Recycled Textiles (SMART) Association estimates that

about half of new clothing end up donated. Of the clothing that is donated, about 20% are sold in reuse outlets, 25% are shipped overseas, 50% are used as absorbants/rags/stuffing, and about 5% head to landfills or WTE facilities. That means that over

half of all textiles end up in the garbage. For a material to be recycled, it needs to be used to create a new product. Fast fashion has resulted in an onslaught of low-quality textiles that have no reuse nor recycling value. Durable textiles made from natural

fibers and extending the life via proper care and repair can help reduce personal impact.

Andrew Coyne City of Stillwater

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MPCA is working in collaboration with DNR and local governments to create a cohesive plan for wood waste management. The plan has been modified to be inclusive of other tree disease issues, such as Oak Wilt. Wood waste is expected to increase and

will require collaboration to find upstream solutions. Planning will be required to avoid open burning.

Andy Healy

ARCA Recycling,

Inc.

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Appliances at the end of their useful life contain many valuable materials—like steel—that can be recycled. There are also many concerning components, like refrigerants, that need to be managed properly to avoid harm to human health and the

environment. MPCA will continue to value appliance recycling and recovery as playing a very important role in solid waste management. MPCA received funding in the last Legislative session for various grants that will be utilized to make address waste

issues and climate change reduction.

Ann Hanson Resident

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Due to difficultly with sorting at recyclng centers, black plastic has nearly no market value for recycling. For a material to be recycled, it needs to be used to create a new product. Fast fashion has resulted in an onslaught of low-quality textiles that have no

reuse nor recycling value. Durable textiles made from natural fibers and extending the life via proper care and repair can help reduce personal impact. Removing barriers for participation was our original intent and we received great feedback on changes

to further our progress. Legislative action will be needed to create accountability for those producing waste through product design.

Beverly Mears Resident

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All of the 7-county metro environmental centers and household hazardous waste (HHW) drop-off sites are open to residents of any metro county. Many materials are collected for free, but some require a collection fee. The plan also includes a strategy to

expand mobile collection of HHW, which would provide residents with more convenient access.

Bill Keegan

Dem-Con

Companies

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Minnesota has an existing rechargeable battery law. MPCA's Solid Waste Policy Report to the Minnesota Legislature recommends updates to address the full scope of the lithium battery issue. The MPCA is working with partners on legislative proposals to

improve the collection and recycling of batteries. A strategy has been added to the plan to implement education programs on proper battery management. Creating safe storage spaces that minimize fire risks at waste facilities is challenging. Thank you for

the feedback on Appendix D. You provided many valid points, which were considered when revising the plan. A clear and consistent process for MPCA's issuance of CON to landfills statewide is now reflected in the plan. Source separation is the best way

to recover materials and to ensure the highest value of those materials. However, despite our best efforts, human behavior is unpredictable. Preprocessing can recover additional recyclables, especially metals. The cost of collection is the primary driver of

cost to residents and historically tip fees have not been the driver for cost. The strategy's timeline has been extended.

Blaine

McKeever

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Retail drop off is far from ideal, but is currently the best option for plastic film recycling. We can encourage retailers to monitor their collection bins more closely to optimize collection efforts.

Bobby Stewart

Highland

Sanitation

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Tax breaks and credits are outside of the scope and authority of the plan. The authority of this plan extends to counties in the metro area. Strategies are included to encourage the development of reuse markets and programs. The Recycling Association of

MN has a Recycling Education Toolkit available on their website that has signage and messaging available for use. https://recycleminnesota.org/rec-toolbox/ The strategy for single-use containers has been revised in response to multiple comments. Yard

waste and SSO mixed together is undesirable for most compost facilities. Effective composting requires the proper ratio of carbon and nitrogen sources. Co-collection of these materials make it difficult to achieve a consistent ratio. However, if compost

facilities and haulers can work together to ensure co-collection works effectively, it would be worth exploring as an option.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Bonnie Matter Resident

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This plan does not have authority to make changes like eliminating plastic bags. However, there is an optional strategy for counties to adopt an ordinance with a consumer charge or ban on disposable single-use items, which is open for a county to

interpret as including plastic shopping bags. Convenience is a critical component of success. The plan includes a strategy that would expand curbside collection of organics recycling to all cities with a population of 5,000 or greater. Restaurants cannot

place orders directly in customers own containers, but you may bring your containers to restaurants for leftovers. The plan also includes a requirement for counties to provide financial assistance to organizations for transitioning to reusable foodware

options. This plan seeks to address and divert unnecessary food waste through strategies that provide access to tracking software, partnering with health inspectors to identify diversion and prevention, and establishing partnerships between food rescue

organizations and the businesses that create it. Some manufacturers produce packaging-free products. The strategies in this plan can encourage a shift toward that direction, but we will need more manufacturers to reduce packaging and residents to

support these changes. Reducing waste at the source provides the greatest environmental benefit. Legislative action will be necessary to require manufacturers to participate. This plan does not have authority to standardize packaging, but does call for

standardized outreach and education on recycling.

Brad Hanzel Carver County

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The composting rule changes adopted in 2015 prioritized environmental protection and sought to allow flexibility in compost operations. To expand organics capacity in the region, composters have advocated for the agency to prioritize market

development for compost. Additionally, pushing for the expansion of collection programs signals to existing and future operators that there will be material for them to manage. Focusing on these two strategies will support market conditions that can

help meet the regions capacity needs. The plan calls for residential curbside organics collection to be required region-wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater numbers. MPCA will

continue to enforce MN Stat. 473.848, which requires WTE energy facilities to operate at full capacity. It is understood that some counties will supply more waste to those facilities than others. It is also understood that some counties will not be able to

meet the total percentage laid out in the Metro Policy Plan. However, it should be noted that MPCA expects counties to support the existing infrastructure when possible as well as continue to implement strategies to avoid land disposal as much as

possible. MPCA will defer to the expertise of counties to propose variations to strategies that will work for their residents and haulers. The plan has been amended to allow counties to provide alternative strategies. For required strategies, proposals must

achieve comparable objectives. For optional strategies, counties should work with their PCA solid waste planner to determine the point value of the alternative strategy. MPCA acknowledges that data submittal prior to a license renewal may be

challenging. This appears in the plan as a best practice to ensure hauler compliance. Carver County may follow the other best practices, which can be effective too. We appreciate that the county understands the value of quality hauler data. Interested

parties have raised many concerns about the undue burden weekly recycling would have on their operations. Accordingly, this now appears in the plan as an optional strategy. This strategy can make collection frequency more convenient for residents but

is cost prohibitive and would further exacerbate the driver shortage. Providing additional bins at no cost could achieve the same objective as weekly collection without the added emissions from extra truck routes. The strategy to pair trash and recycling

collection has been made optional to address similar hauler concerns. MPCA is working in collaboration with DNR and local governments to create a cohesive plan for wood waste management. The plan has been modified to be inclusive of other tree

disease issues, such as Oak Wilt. MPCA has requested and received funding to work on wood waste projects which will also include developing markets. Implementing the strategy for county-owned buildings was the original intent of this strategy. The

plan has been edited for clarity. Thank you for your valuable feedback.

Bridget Diep Resident

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Enforcement of 115A.93 Subd 3(c) assures that haulers do not imposing a greater charge on residents who recycle than on residents who do not recycle, which includes organics recycling. Minn. Stat. § 115A.151 requires businesses to collect a minimum of

three materials for recycling. The plan calls for residential curbside organics collection to be required region-wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater numbers.

Caleb Werth Resident

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Compostable single-use is a better option than conventional single-use that cannot be recycled, but reuse is the best option. MPCA will look to counties to interpret or adjust this strategy to achieve the best outcome given their resources and residents.

The strategy has been edited to incorporate the successful and vetted aspects of the Minneapolis ordinance. Many county environmental centers have incorporated reuse areas or plan to in the future. We encourage every metro county to provide this

service. Resident education is addressed in this plan with a strategy that calls for a commitment to standardized outreach and education. We agree that the messaging reaching residents should be easy to understand. Piecemeal efforts by counties, cities,

haulers, and other organizations are rarely collaboratively developed and therefore can lead to confusion over what materials can be recycled or composted. Assuring a consistent message from those within the solid waste system would help bring clarity

to the users of the system. The plan includes a required strategy to offer grants for waste reduction, reuse, and repair. Reuse businesses may be eligible for this funding.

Calla Martin Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. The optional strategies for sustainable building and deconstruction have high point values, which should incentivize counties to

incorporate them in their plans. Extended producer responsibility laws have been shown to be a very effective tool to achieve the following, provided the right incentives and requirements are included in the EPR legal framework: Influence manufacturer

design to improve recyclability, repair, and reuse; Reduce material use and toxicity; Improve recovery for reuse, repair, and recycling; Help create a sustainable and circular economy for the materials and products covered by specific EPR requirements;

Manufacturers and others along the product chain share in the financial and physical responsibility for collection, reuse, and recycling of products at the end of their useful lives. This includes the role for consumers that must be responsible for ensuring

that end-of-life products get into the collection system that’s provided. This is the overarching plan for the metro area. Counties have flexibility to choose optional strategies that they can effectively implement. In order for Minnesota to utilize this type of

program, the Minnesota Legislature would have to create new laws with requirements for manufacturers and other parties that have a role in the cycle of commerce for the products and materials in question.

Carmela

Giardina

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Recycling refund legislation is very successful at increasing the collection of beverage containers. States with recycling refund often have capture rates greater than 80% for those materials that are covered by the redemption fee. MPCA does not have the

authority to require this type of legislation through this plan, because it would take action by the Minnesota Legislature to enact that requirement on beverage manufacturers. The plan calls for residential curbside organics collection to be required region-

wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater numbers. The types of materials collected in curbside collection programs are determined by the recycling market. If there is an end-use

for an additional material that could be collected in a quantity great enough to support an economically viable market, the industry will implement it.

Carolyn

Majkrzak

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Thank you for the feedback.

Cassie Lefeber Resident

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Due to the varied resources of metro counties, we believe requiring these strategies would place an undue burden on county staff at this time. Impactful optional strategies carry a high point value, which should provide a strong incentive for counties with

the appropriate resources to successfully implement. The plan includes a reuse section with several strategies to address barriers and expand reuse access. Drop-off events hosted by the counties are popular with residents, but these events have been

shown to be very expensive and time intensive for county staff to plan and execute. Advertising a special collection day at the existing permanent sites could have a similar impact to raise community awareness, perhaps outside of regular hours.

Convenience is a critical component of success for organics recycling. The plan includes a strategy that would expand curbside collection of organics recycling to all cities with a population of 5,000 or greater. The plan includes a strategy for the

management of organics recycling from large commercial food generators by 2030. It was optional in the draft and has been changed to required. MPCA has been working with the Departments of Agriculture and Health to create content for inspectors to

educate licensed facilities about financial assistance, donation, and opportunities to reduce wasted food. The plan has been revised to include the MPCA’s commitment to continue work with partner agencies on improved food rescue and prevention

efforts. A strategy encouraging county engagement with health inspectors in individual county plans will remain in the plan to help accelerate adoption of the practice but will not be required.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Chris Kostik Resident

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Interested parties have raised many concerns about the undue burden weekly recycling would have on their operations. Accordingly, this now appears in the plan as an optional strategy with an alternative option to provide extra bins at no cost. The

single-use container fee is an optional strategy that counties may choose to add to their plans. We will look to the counties to select an approach that will best serve the needs of their residents. Counties will be required to offer grants or rebates for

organizations to transition to reusable food and beverage service ware. Restrictions like a bag ban should be determined through county and/or city ordinances. The most effective way to reduce waste is to not create it in the first place. Compostable

single-use products are a better option than conventional single-use products that cannot be recycled, but reuse is the best option. Extended producer responsibility (EPR) laws have been shown to be a very effective tool to achieve the following, provided

the right incentives and requirements are included in the EPR legal framework: Influence manufacturer design to improve recyclability, repair, and reuse; Reduce material use and toxicity; Improve recovery for reuse, repair, and recycling; Help create a

sustainable and circular economy for the materials and products covered by specific EPR requirements; Manufacturers and others along the product chain share in the financial and physical responsibility for collection, reuse, and recycling of products at

the end of their useful lives. This includes the role for consumers that must be responsible for ensuring that end-of-life products get into the collection system that’s provided. For us to utilize this type of program, the Minnesota Legislature would have to

create new laws with requirements for manufacturers and other parties that have a role in the cycle of commerce for the products and materials in question. Packaging: The Partnership on Waste and Energy—which includes Hennepin, Ramsey, and

Washington counties—are working on issues raised by MPP commenters regarding the need to address quantities, types, and management of packaging materials. EPR can provide a better pathway for compostable packaging to be collected and directed

to a commercial composting facility. EPR can require proper labeling for reuse, recycling, or composting.

Chris Long Resident

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The plan prioritizes reuse strategies. Reducing the amount of material being managed in the solid waste system provides the greatest environmental benefit.

Chris McConn

Minnesota

Resource

Recovery

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MPCA supports the waste hierarchy and values the role of waste-to-energy in the system. We appreciate MRRA's alignment with the agency's stance. Due to the unfolding events in Hennepin County and many comments of concern about the continued

operation of the Hennepin Energy Recovery Center, we have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of WTE and landfills and acknowledgement of the possible closure

that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental justice impacts. MPCA supports minimizing disposal options of WTE

and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Extended producer responsibility (EPR) laws have been shown to be a very effective tool to achieve the following, provided the

right incentives and requirements are included in the EPR legal framework: Influence manufacturer design to improve recyclability, repair, and reuse; Reduce material use and toxicity; Improve recovery for reuse, repair, and recycling; Help create a

sustainable and circular economy for the materials and products covered by specific EPR requirements; Manufacturers and others along the product chain share in the financial and physical responsibility for collection, reuse, and recycling of products at

the end of their useful lives. This includes the role for consumers that must be responsible for ensuring that end-of-life products get into the collection system that’s provided. For us to utilize this type of program, the Minnesota Legislature would have to

create new laws with requirements for manufacturers and other parties that have a role in the cycle of commerce for the products and materials in question. The Partnership on Waste and Energy—which includes Hennepin, Ramsey, and Washington

counties—are working on issues raised by MPP commenters regarding the need to address quantities, types, and management of packaging materials. EPR can provide a better pathway for compostable packaging to be collected and directed to a

commercial composting facility. EPR can require proper labeling for reuse, recycling, or composting. Thank you for your support and valuable feedback.

Christine

Popowski

Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Thank you for your feedback.

Chris Roloff Resident

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The reciprocal use agreement among the metro counties allows residents of any metro county to use any of the 7-metro county environmental centers and HHW sites. The single-use container fee is an optional strategy that counties may choose to add to

their plans. We will look to the counties to select an approach that will best serve the needs of their residents.

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Carbon capture and storage (CCS) is a theoretical idea that has not been tested in real world applications. Additional research is needed to confirm that it can be implemented at a scalable level. MPCA would potentially support demonstration research

projects to investigate CCS. Landfills and compost facilities are open for use over many years. During this time any collected organic material would be exposed to precipitation and the atmosphere allowing for the generation of decomposition gases.

Introducing large quantities of salt into a landfill would increase the risk of groundwater contamination. Composting and anerobic digestion provide benefits beyond the disposal of waste such as creating mulch for reuse or electricity generation. CCS

would only be used as a disposal method and therefore would be lower on the solid waste hierarchy. The referenced articles discuss agro-sequestration using various crops specifically chosen for the carbon capture potential. The heterogenous nature of

human generated organics used in composting may impact the feasibility of using CCS.

Claire

Graupmann

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Resident education is addressed in that plan with a strategy that calls for a commitment to standardized outreach and education. We agree that the messaging reaching residents should be easy to understand. Piecemeal efforts by counties, cities, haulers,

and other organizations are rarely collaboratively developed and can lead to confusion over what materials can be recycled or composted. Assuring a consistent message from those within the solid waste system would help bring clarity to the users of the

system. The plan includes many waste reduction strategies. The plan requires counties to standardized outreach and education. Using consistent terms throughout the metro should help to reduce confusion.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Commissioner

Liz Workman,

Board Chair

Dakota County

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Appendix G now includes a column identifying interested parties expected to be impacted by each strategy in the Metro Policy Plan. Based on comments received, its clear that the MPCA needs to play a role in creating regional consistency. As the leading

state agency, MPCA is committed to coordinating and facilitating regional meetings to discuss solid waste issues. The plan has been modified to clarify the role that MPCA will play. If a county and the MPCA have conflicting compliance rates, that

demonstrates a need to collaborate and identify the source of this anomaly. If the MPCA has an outdated license list from the county, this could be the source of the discrepancy. Implementing this strategy for county owned buildings was the intent of this

strategy. The plan has been edited for clarity. Interested parties have raised many concerns about the undue burden weekly recycling would have on their operations. Accordingly, this now appears in the plan as an optional strategy. MPCA is working in

collaboration with DNR and local governments to create a cohesive plan for wood waste management. The plan has been modified to be inclusive of other tree disease issues, such as Oak Wilt. Wood waste is expected to increase and will require

collaboration to find upstream solutions. Planning will be required to avoid open burning. The plan has been revised to include a state-led strategy aimed at inter-agency coordination. MPCA promotes the use of compost to MNDOT and enterprise wide.

Food-derived compost requirements in some metro counties and cities has bolstered markets. The region's food waste can have a beneficial use in metro construction projects. MPCA must promote robust markets for compost. One avenue is through

partnerships with other state agencies. However, the MNDOT specification may not be the right tool for a statewide market development strategy for food-derived compost. In much of Greater Minnesota, food-derived compost is not established.

Facilities and compost sites may be remote. Current MNDOT specifications do allow for use of food-derived compost. However, requiring only food-derived compost statewide is not currently feasible. The volume of compost used under MNDOT

specifications exceeds the supply of food-derived compost. Additionally, some projects are located far from sources of food-derived compost. These statewide specifications must be achievable through a variety of feedstocks. MPCA will continue to

enforce MN Stat. 473.848, which requires WTE energy facilities to operate at full capacity. It is understood that some counties will supply more waste to those facilities than others. It is also understood that some counties will not be able to meet the total

percentage laid out in the Metro Policy Plan. However, it should be noted that MPCA expects counties to support the existing infrastructure when possible. The MPCA also has many strategies that expect counties to move materials up the hierarchy via

reuse, recycling, and composting whether they have access to WTE or not. Source separation is the best way to recover materials and to ensure the highest value of those materials. However, despite our best efforts, human behavior is unpredictable.

Preprocessing can recover additional recyclables, especially metals. The cost of collection is the primary driver of cost to residents, but historically tip fees have not been the driver for cost. The plan has been modified to extend the timeline in order to

allow facilities more time to plan. The metro forecast was developed as described in the methodology included within Appendix F. Organics and recycling tonnages were calculated based on needed benchmarks to achieve the 75% recycling goal by 2030.

Capacity has historically expanded as programs have come online and as needed. Organics processors (i.e., compost sites and anerobic digestion facilities) are only likely to make the necessary investments in expanding their capacity if/when they have

assurances that materials will be available to be managed. New capacity could come from a variety of sources, including already announced expansions, the initiation of operations at already permitted sites, management of organics at facilities outside

the metro region and/or the development of new sites. The forecast is a more useful planning tool in its current format than it would be if it were to reflect an estimate of new capacity that may not accurately reflect real capacity in 2025. The MPCA is

generally supportive of adequately funding programs at a state, county, and city-level. Legislative changes are outside the scope of the plan. The plan provides a waste forecast of anticipated generation. Waste reduction is determined by comparing

forecasted population growth with documented solid waste generation data. Ideally, the strategies proposed throughout the plan result in future reported generation rates as less than forecasted. The vast number of strategies creates a wide range of

possible systems/programs. It wouldn't be possible to estimate costs for all outcomes. It is expected that metro counties consider costs of implementation as they select strategies for their County Solid Waste Plans. MPCA will allow counties to

recommend alternative strategies that will be approved by MPCA on a case-by-case basis. The standardized education strategy has been edited to address your concern.

Connor

Stratton

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MPCA is committed to addressing the GHG contributions the solid waste system produces. This plan seeks to hold counties accountable for assuring meaningful effort is being put forth into the greatest impact reduction activities, like source reduction.

MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Thank you for your feedback.

Cora Preston Resident

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Ramsey County will soon roll out curbside pick-up for food scraps: https://www.ramseycounty.us/residents/recycling-waste/collection-sites/food-scraps. Making this an easier option for residents should increase participation and divert more food waste

from landfills. An optional strategy that counties may choose to add to their plans would require a fee on takeout containers. We will look to the counties to plan for an approach that will best serve the needs of their residents. There is flexibility in how

counties fulfill this strategy and also to better align with the waste heirarchy, which values recycling over composting. Interested parties have raised many concerns about the undue burden weekly recycling would have on their operations. Accordingly,

this now appears in the plan as an optional strategy. Piecemeal efforts by counties, cities, haulers, and other organizations are rarely collaboratively developed and therefore can lead to confusion over what materials can be recycled or composted.

Assuring a consistent message from those within the solid waste system would help bring clarity to the users of the system.

Corissa

Nohrenberg

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A required strategy calls for expanded backyard composting outreach and resources for residents. Those resources would provide guidance and materials for residents to set up their own backyard compost. Encouraging a reduction in paper marketing

materials is a great source reduction idea. Recycling is exempt from the solid waste management tax, so a tax break is already in place. The State and counties could do a better job of making this clear to residents. The cost of curbside collection is outside

of the scope of this plan. Haulers establish the costs for service. The Minnesota Department of Corrections (DOC) work release program is something materials recovery facilities (MRFs) have historically used. However, this practice was interrupted during

the COVID-19 pandemic due to both safety concerns as well as limited availability of incarcerated workers at MRFs.

Curt Wynkoop Resident

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An analysis of existing data shows that higher participation rates are realized with single-sort recycling than historical rates with multiple streams. Switching from one bin to 5-6 different types in bags or containers would be very difficult. Additionally,

workers now use hydraulic systems to empty rolling carts. Under the old system, workers had to physically empty 5-6 different bags or containers into different compartments in the truck. This resulted in injuries that are now avoidable through the

simplified single-stream system.

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The MPCA has a responsibility to assure the solid waste system is equitable and does not create an undue burden on any community in the Twin Cities Metro Area.

Dagny

Heimisdottir

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The plan calls for residential curbside organics collection to be required region-wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater numbers.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Dale Lutz Resident

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Thank you for sharing the information about CCC for WTE facilities. MPCA is aware of carbon capture technology and the Minnesota Resource Recovery Association is exploring partnerships with carbon capture technology for WTE facilities located in

MN. Carbon captured in MN could be deep well injected into bedrock as close as North Dakota, but there are some technical hurdles to cross prior to that, most notably the pipeline infrastructure to get the CO2 transported efficiently. Solving climate

change will require a wide range of creative solutions and CCC could be one of the tools.

Daniel

Rosenblum

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Extended producer responsibility laws have been shown to be a very effective tool to achieve the following, provided the right incentives and requirements are included in the EPR legal framework: Influence manufacturer design to improve recyclability,

repair, and reuse; Reduce material use and toxicity; Improve recovery for reuse, repair, and recycling; Help create a sustainable and circular economy for the materials and products covered by specific EPR requirements; Manufacturers and others along

the product chain share in the financial and physical responsibility for collection, reuse, and recycling of products at the end of their useful lives. This includes the role for consumers that must be responsible for ensuring that end-of-life products get into

the collection system that’s provided. For us to utilize this type of program, the Minnesota Legislature would have to create new laws with requirements for manufacturers and other parties that have a role in the cycle of commerce for the products and

materials in question. The Partnership on Waste and Energy—which includes Hennepin, Ramsey, and Washington counties—are working on issues raised by MPP commenters regarding the need to address quantities, types, and management of packaging

materials. EPR can provide a better pathway for compostable packaging to be collected and directed to a commercial composting facility. EPR can require proper labeling for reuse, recycling, or composting. MPCA received many comments of concern

about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of WTE and landfills and acknowledgement of

the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental justice impacts. MPCA supports minimizing

disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this document. Air quality impacts will be addressed as

part of the cumulative air impact rule-making effort that is underway. This plan seeks to manage waste to its highest and best use.

Deb Leibel Resident

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Organized collection systems provide many overall benefits to residents, if implemented properly. Establishment of an organized collection system is a local decision and therefore, this strategy will remain optional. The plan calls for residential curbside

organics collection to be required region-wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater numbers.

Delaney Welle Resident

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Convenience is a critical component of success. A required strategy in the plan expands curbside collection of organics recycling to all cities with a population greater than 5,000. MPCA agrees that it must be more convenient for people to participate in

greater numbers. Counties are able to pursue the implementation of an ordinance to tax single-use items. Restrictions like a bag ban should be determined through county and/or city ordinances. Education must be a priority to improve our system. In

addition, different types of education are important to reach different people. The plan calls for robust education in all seven metro counties.

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Minnesota Statute 115A.93 Subd. 3 prohibits haulers from imposing a greater charge on residents who recycle than on residents who do not recycle. The initial draft of this plan explored the feasibility of weekly recycling collection, which was determined

to cause an undue burden on the haulers without evidence of an increase in collection of recyclable materials.

Diane

Ballentine

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Compostable single-use products are a better option than conventional single-use products, but reuse is the best option.

Diane Edson Resident

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Contamination is a serious issue plaguing the recycling stream. Penalizing violators would be difficult to enforce. The plan focuses on education strategies to mitigate the issue. Interested parties have raised many concerns about the undue burden weekly

recycling would have on their operations. Accordingly, this now appears in the plan as an optional strategy. Recycling refund legislation is very successful at increasing the collection of beverage containers. States with recycling refund often have capture

rates greater than 80% for materials covered by the redemption fee. MPCA does not have the authority to require this type of legislation through this plan. This would require action by the Minnesota Legislature to enact a requirement on beverage

manufacturers. The plan includes a strategy for the management of organics recycling from large commercial food generators by 2030. It was optional in the draft and has been changed to required, based on public comments.

Dick Evans Resident

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The plan calls for residential curbside organics collection to be required region-wide in cities greater than 5,000. MPCA agrees that it must be more convenient for people to participate in greater numbers.

don nelson Resident

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Compostable single-use products are a better option than conventional single-use products that cannot be recycled, but reuse is the best option. The plan requires expansion of curbside organics collection to a greater number of households. Terracycle

can fill the gaps in collection of materials that cannot be diverted/processed at a traditional recycling facility. Reducing or eliminating these materials is best. For unavoidable waste, it's a great option to assure these materials stay out of landfills and WTE

facilities.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Donna Lindberg Resident

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Educational requirements appear throughout the plan. School districts are required to collect and recycle at least three types of recyclables in their schools, although contamination of the recyclables can be a challenge. Curbside collection of organics

recycling is a requirement in the plan.

Doug Gurian-

Sherman

MN EJ Table and

MCEA

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MPCA used up-to-date peer-reviewed science as a basis for the recommendations in this report. The strategies of this plan have merit for reducing waste generation and disposal. We acknowledge that some are more effective and impactful than others.

State statute backs the waste hierarchy, and the plan has a strong emphasis on the top of the hierarchy to reduce waste to the extent possible. MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery

Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin

County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the

plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is

underway. The objectives of the plan show that we are attempting to increase traditional recycling by 20%, organics by 11% and to reduce overall waste generation by 5%. If the Metro area can successfully achieve these objectives, the solid waste system

will generate far fewer greenhouse gases.

Doug Heuer Resident

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Reducing waste is a keystone theme in this plan. Replacing single-use containers with reusable containers is an effective way to reduce waste. We encourage counties to address solutions to reduce reliance on single-use waste through several optional

strategies.

Douglas

Carnival

McGrann Shea

Carnival

Straughn &

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Interested parties have raised many concerns about the undue burden weekly recycling would have on their operations. Accordingly, this now appears in the plan as an optional strategy. The MPCA is tasked with enforcing state law as written. MPCA

continues to support the 75% recycling goal. We have and will continue to support a greater emphasis on waste prevention and reuse because of their increased benefits. MPCA continually reviews goals and requirements for ways they can be improved

or revised and recommend revisions as appropriate. Source separation is the best way to recover materials and to ensure the highest value of those materials. However, despite our best efforts, human behavior is unpredictable. Preprocessing can recover

additional recyclables, especially metals. The cost of collection is the primary driver of cost to residents, but historically tip fees have not been the driver for cost. The plan has been modified to extend the timeline. MPCA acknowledges that an additional

cost may not change human behavior, but these added costs could provide resources to fund programs that can focus on alternatives to disposal. It is the intention of the MPCA that the tax/fee would be utilized by the county to reinvest in education and

alternatives to disposal. The vast number of strategies creates a wide range of possible systems/programs. It wouldn't be possible to estimate costs for all outcomes. It is expected that metro counties consider costs of implementation as they select

strategies for their County Solid Waste Plans. Minnesota has a rechargeable battery law. Updates to the law are needed to address the full scope of the lithium battery issue. The MPCA is working with partners on legislative proposals to improve the

collection and recycling of batteries. A strategy has been added to the plan to implement education programs on proper battery management. Creating safe storage spaces that minimize fire risks at waste facilities is challenging. Minnesota Statute

473.149 Subd 3 (b) states that revisions to the plan are exempt from rulemaking. The statute also puts in a robust public comment and engagement process that guides the MPCA in development of the Metro Policy Plan. The plan states that required

strategies must be included in county plans in order for approval by MPCA pursuant to MN Stat 473.803. Only those criteria and standards as laid out in Appendix D are required of facilities. Required strategies in the body of the plan are requirements that

counties must include in their solid waste plans. County plans set policies and goals. Counties are expected to implement their plans, which may require the introduction of ordinances.

Drew

Hatzenbihler

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Greater Minnesota CON is currently identified in rule. Issuance of CON is not done for a set number of years, but rather for the volume of waste anticipated for a set amount of time. Time-based CON is challenging, because it requires long-term forecasts

that must account for uncertainty. When landfill capacity is constrained, MPCA and the affected facilities must coordinate to ensure that there is no disruption to the system that results in illegal dumping of waste.

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Thank you for your feedback.

Elizabeth

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Recycling refund legislation is very successful at increasing the collection of beverage containers. States with recycling refund often have capture rates greater than 80% for those materials that are covered by the redemption fee. MPCA does not have the

authority to require this type of legislation through this plan, because it would take action by the Minnesota Legislature to enact that requirement on beverage manufacturers.

Elizabeth

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Universally-sized collection bins are the best option for hauler safety. If other accomodations could ease your burden, that may be feedback you can share with your city officials.

Elizabeth

Shvedenko

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Curbside organics recycling pickup programs play an important role in solid waste diversion.

Elke

Zimmermann

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Contract for residential recycling and organics by 2030 is an optional strategy in the plan. Organized collection has numerous benefits and can lower costs for all types of service (i.e., MSW, recycling, organics) to residents of a community. Resident

education is addressed in this plan with a strategy that calls for a commitment to standardized outreach and education. We agree that the messaging reaching residents should be easy to understand. Piecemeal efforts by counties, cities, haulers, and other

organizations are rarely collaboratively developed and therefore can lead to confusion over what materials can be recycled or composted. Assuring a consistent message from those within the solid waste system would help bring clarity to the users of the

system. The draft plan did not include strategies for multi-family housing. Strategies for multi-family recycling, organics recycling, and reduction have been added to the final plan. The plan includes a strategy to establish a curbside set-out day to allow

residents to set out used items for reuse. This should lead counties to eliminate prohibitive ordinances and policies.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Emily Barker

Minnesota

Reusables

Coalition

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A strategy requiring counties to establish their own green meeting policy now appears in the plan. In response to comments received from cities and counties, the strategy for reusables at county events will remain optional. Compostable single-use

products are a better option than conventional single-use products that cannot be recycled, but reuse is the best option. MPCA will look to counties to interpret or adjust this strategy to achieve the best outcome given their resources and residents. The

strategy has been edited to incorporate the successful and vetted aspects of the Minneapolis ordinance. MPCA received funding in the last legislative session for grants that will address waste issues and climate change reduction. Quality tracking of

materials is the key to successful solid waste management. Measuring our successes and failures allows us to advance the system in a meaningful, data-based way. The plan has been amended to allow counties to provide alternative strategies. For

required strategies, proposals must achieve comparible objectives. For optional strategies, counties should work with their PCA solid waste planner to determine the point value of the alternative strategy. This state-led strategy is a brief description of the

complex work PCA staff will continue to focus on.

Emily Beltt Resident

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Ramsey County will soon roll out curbside pick-up for food scraps: https://www.ramseycounty.us/residents/recycling-waste/collection-sites/food-scraps. Making this an easier option for residents should increase participation and divert more food waste

from landfills.

Emma Marlar Resident

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts.MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Thank you for your feedback.

Eric Brace Resident

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Convenience is a critical component of success. The plan includes a strategy that would expand curbside collection of organics recycling to all cities with a population of 5,000 or greater. The most effective way to reduce waste is to not create it in the first

place. Compostable single-use products are a better option than conventional single-use products that cannot be recycled, but reuse is the best option. The plan requires expansion of curbside organics collection to a greater number of households. Making

a new product emits greenhouse gases that contribute to climate change and requires a lot of materials and energy - raw materials must be extracted from the earth, and the product must be fabricated then transported to wherever it will be sold. As a

result, reduction and reuse are the most effective ways you can save natural resources, protect the environment and save money.

Erin Oakley Resident

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The most effective way to reduce waste is to not create it in the first place. Making a new product emits greenhouse gases that contribute to climate change and requires a lot of materials and energy—raw materials must be extracted from the earth, and

the product must be fabricated then transported to wherever it will be sold. As a result, reduction and reuse are the most effective ways you can save natural resources, protect the environment, and save money. The plan includes many strategies

targeted at improving diversion of businesses.

Evan

Mulholland

MN EJ Table and

MCEA

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MPCA received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of

WTE and landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental

justice impacts. MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this

document. Air quality impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. Decentralized waste management is an interesting concept. In many ways, this plan is pushing for strategies that do just that. By

prioritizing waste reduction, reuse, recycling, and composting over disposal methods, the idea of moving material into decentralized management is in this plan. The plan contains strategies to diversify our end markets for recycling, compost, and wood

waste. When it comes to diversifying trash outlets, MPCA would be receptive to discussing what those options could be that also are protective of the environment. The Metro Policy Plan will not be including a HERC shut down by 2025 scenario. At the

time of publication, Hennepin County is in the process of developing a plan to close HERC between 2028 and 2040. CON for land disposal facilities is not contingent on the Metro Plan having that scenario published. CON needs are evaluated as need

arises, and landfills can expand without a forecast that states that it’s needed if conditions in the region are substantially different than the time that the forecast was developed. Forecasts for non-MSW were inadvertently omitted from the draft plan.

Non-MSW forecasts, including ash estimates, have been added. Waste-to-energy facilities reduce waste volume by about 75%, greatly reducing the amount of space needed for land disposal. Additionally, ash is homogeneous and chemically-stable, which

reduces some of the risks of land disposal. The 5% waste reduction goal references the total generation of waste. Despite our best efforts, consumption influences waste generation. To truly be successful in waste reduction, upstream policies must be put

into place by the Minnesota Legislature that result in fewer materials being generated. The 75% goal is determined by state statute as the disposal avoidance goal and MPCA intends to aggressively push for improvement in all areas that are feasible. The

draft plan did not include strategies for multi-family housing. Strategies for multi-family recycling, organics recycling, and reduction have been added to the final plan.

Frank

Hornstein

Minnesota

Legislature

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Forecasts for non-MSW were inadvertently omitted from the draft plan. Non-MSW forecasts, including ash estimates, have been added. Waste-to-energy facilities reduce waste volume by about 75%, greatly reducing the amount of space needed for land

disposal. Additionally, ash is homogeneous and chemically-stable, which reduces some of the risks of land disposal.

MPCA uses the Metro Policy Plan cycle to increase the expectations for county plans by requiring additional items for them to include. In addition, in previous cycles, MPCA has met with underperforming counties to work with them to see better results.

MPCA intends to await the response of the counties in their solid waste plans. We have the authority to approve or deny plans and will work to enforce this statute within our authority in order to continue to push the region toward the 75% goal. MPCA

received many comments of concern about the continued operation of the Hennepin Energy Recovery Center. We have re-examined our approach to the waste-to-energy (WTE) section of the plan. Changes include a comparison of the impacts of WTE and

landfills and acknowledgement of the possible closure that will be determined by the Hennepin County Board. It is critical to ensure that large infrastructure decisions are being made with consideration to environmental and environmental justice impacts.

MPCA supports minimizing disposal options of WTE and landfill as much as possible and the plan focuses on waste reduction, recycling, and composting to meet the 75% goal. Cumulative air impacts are outside of the scope of this document. Air quality

impacts will be addressed as part of the cumulative air impact rule-making effort that is underway. MPCA is supportive of significantly reducing the burning of fossil fuels by 2040. The challenge for the waste management sector is that data indicates that

landfills generate greater amounts of greenhouse gases than WTE facilities do because of the methane generated. Well intended policy can create unintended consequences. MPCA agrees that we need to consider the best ways to reduce emissions from

combusting certain materials. For example, the ban on mercury in batteries had a huge impact on reducing mercury emissions from WTE facilities. The Hennepin County Board passed a resolution requiring that county staff develop a plan to close HERC

between 2028 and 2040. It is clear to MPCA that Hennepin County is taking the intent from the Minnesota Legislature seriously and MPCA does not feel the need to interject into their on-going process.

G R Resident

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Extended producer responsibility laws have been shown to be a very effective tool to achieve the following, provided the right incentives and requirements are included in the EPR legal framework: Influence manufacturer design to improve recyclability,

repair, and reuse; Reduce material use and toxicity; Improve recovery for reuse, repair, and recycling; Help create a sustainable and circular economy for the materials and products covered by specific EPR requirements; Manufacturers and others along

the product chain share in the financial and physical responsibility for collection, reuse, and recycling of products at the end of their useful lives. This includes the role for consumers that must be responsible for ensuring that end-of-life products get into

the collection system that’s provided. For us to utilize this type of program, the Minnesota Legislature would have to create new laws with requirements for manufacturers and other parties that have a role in the cycle of commerce for the products and

materials in question. The Partnership on Waste and Energy—which includes Hennepin, Ramsey, and Washington counties—are working on issues raised by MPP commenters regarding the need to address quantities, types, and management of packaging

materials. EPR can provide a better pathway for compostable packaging to be collected and directed to a commercial composting facility. EPR can require proper labeling for reuse, recycling, or composting.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Gael Zembal Resident

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Interested parties have raised many concerns about the undue burden weekly recycling would have on their operations. Accordingly, this now appears in the plan as an optional strategy. One strategy in the plan encourages donation of excess food from

restaurants and grocery stores with the help of health inspectors. Resident education is addressed in that plan with a strategy that calls for a commitment to standardized outreach and education. We agree that the messaging reaching residents should be

easy to understand. Piecemeal efforts by counties, cities, haulers, and other organizations are rarely collaboratively developed and therefore can lead to confusion over what materials can be recycled or composted. Assuring a consistent message from

those within the solid waste system would help bring clarity to the users of the system. The Minnesota State Legislature has enacted rules to maintain the integrity of the recycling system. MN Statute 115A.95 was written to ensure that once material is

collected for recycling, it must be taken to a recycling processing facility or end market. This law prohibits material that is collected as recycling from being taken to a landfill and ensures that material collected for recycling is indeed being recycled. In

addition, Minnesota imposes a solid waste tax on every ton of solid waste disposed. Counties also impose a separate solid waste tax if material is disposed of in their county. Minnesota does not tax material that is taken to a recycling processing facility.

This makes recycling cheaper than disposal. In the 1990’s private companies and the public sector made investments in the recycling system to make recycling more desirable. When overseas markets closed their borders to recyclable materials in 2017,

Minnesota companies made even more investments to make sure material was clean and ready for end markets. Cleaner material and fewer contaminates in bales of recyclable material mean companies will buy Minnesota’s recyclable material over

others and at a better price. Minnesota has good, stable end markets for recyclable materials because of the investments made over the last 30+ years. Recycling is important to Minnesota’s local economy. Overall, recycling helps support nearly 78,000

jobs in Minnesota. Over 330 manufactures in Minnesota use recycled material in their products. There is a strategy in the plan for counties to expand backyard composting outreach and resources. Placing a backyard compost pile at least 20 feet away

from habitable buildings is widely accepted as a measure to mitigate the associated risks. This is an optional strategy that counties may choose to add to their plans. The strategy requires the adoption of an ordinance with a mandatory consumer charge

for take out containers.

Gerald Stiff Resident

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Education is addressed throughout the plan and plays a very important role in the success of a functional solid waste system. Your county, city, and hauler are all great resources for learning how to best dispose or find a new use for a waste or material.

H McCrillis Resident

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Black plastics are not recyclable due to limitations of the sorting equipment at recycling facilities. The optical sorter cannot read the resin type. Elimination of black plastic in packaging would be more beneficial than recycling it.

Hannibal Hayes Resident

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MPCA is working in collaboration with DNR and local governments to create a cohesive plan for wood waste management. The plan has been modified to be inclusive of other tree disease issues, such as Oak Wilt. Wood waste is expected to increase and

will require collaboration to find upstream solutions. Planning will be required to avoid open burning.

Heidi Blum Resident

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The draft plan did not include strategies for multi-family housing. Strategies for multi-family recycling, organics recycling, and reduction have been added to the final plan based on comments like yours.

Helen M

Carrillo

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Preventing contamination through education is less costly and more effective than establishing a penalty system with compliance officers.

ivy Booth Resident

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The plan includes a strategy for the management of organics recycling from large commercial food generators by 2030. The point value of this strategy has been raised to reflect the impactfulness of the strategy and recognize the amount of work required

of county staff to accomplish it. Thanks for your support of this impactful strategy.

J Forman Resident

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Compostable single-use products are a better option than conventional single-use products, but reuse is the best option. Replacing single-use containers with reusable containers is an effective way to reduce waste. We encourage counties to address

solutions to reduce reliance on single-use waste through several optional strategies.

Jacquelyn

Chlebeck

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Thank you for the feedback. The plan includes education strategies that the counties will execute. A visit to a solid waste facility can be exceptionally enlightening.

Jake

Heidelberger

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Ramsey County will soon roll out curbside pick-up for food scraps: https://www.ramseycounty.us/residents/recycling-waste/collection-sites/food-scraps. Making this an easier option for residents should increase participation and divert more food waste

from landfills.

Metropolitan Solid Waste Management Policy Plan 2022-2042 • January 2024 Minnesota Pollution Control Agency

Name Affiliation Comment Response

Jane Dow Resident

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