Mr. Nork (NH Solid Waste Management Bureau), I have read the subject draft plan for Solid Waste Management in NH, and it ignores the elephant in the room. Please give me a moment to explain.
The Introduction to the plan states, in part: “As mandated under RSA 149-M:29, the purpose of this plan is to set out goals, strategies and actions to:
- Reduce generation of solid waste through source reduction.
- Increase diversion of waste from disposal.
- Achieve the state’s solid waste disposal reduction goal established in RSA 149-M:2.”
This plan, however, does nothing to address the nearly million tons of solid waste generated by sources in other states, nor diverting that solid waste from disposal in New Hampshire.
Table 1 on page 6 clearly shows that only just over half of the solid waste disposed in New Hampshire from 2018 to 2020 was generated by the residents of our state!
I’m sure that you and the Bureau are well aware of the fact that 2.7 of the 5.9 million tons of Solid Waste disposed in New Hampshire came from other States. In fact the plan states in the last sentence on page 5: “Legislators and members of the public have expressed significant concern about the receipt and disposal of out-of-state waste in New Hampshire.”
Why, then, are there no Goals, Strategies, or Actions that address reducing the amount of solid waste accepted from other states to be disposed in New Hampshire?
Frankly, Goal Number 1 should be reworded to REDUCE THE QUANTITY OF SOLID WASTE GENERATED DISPOSED. And Action 1.1 should be to introduce legislation that reduces the amount of solid waste accepted from other states and disposed in New Hampshire to 0 tons in a reasonable time. (Doing so by 2050 would, in itself, meet the 45% reduction goal stated in the first paragraph in Section II.)
The plan goes on to Goal Number 3: “MAXIMIZE THE DIVERSION OF…SOLID WASTE”, yet still makes no mention of diverting solid waste accepted from other states TO other states, instead of New Hampshire landfills, public or private. Doing so will go a long way to supporting Goal Number 4: “ENSURE ADEQUATE CAPACITY FOR MANAGEMENT OF NEW HAMPSHIRE-GENERATED WASTE”. In fact, it will greatly increase the life of the active New Hampshire landfills. (Wouldn’t raising the tipping fee for out of state solid waste, perhaps with a State Tax serve two purposes? Reduce out of state Solid Waste and increase State revenue.)
These comments are not intended to reduce the importance or significance of the need for Granite Staters to reduce the amount of solid waste that we generate. Nor are they intended to ease the heavy lifting that comes with our responsibility to minimize our foot print on this beautiful land that we have inherited. It simply notes that we Granite Staters should not be doing the lifting for those in other states who shirk their responsibility to manage their waste and who care little about our beautiful state lands.
Given the knowledge that I am not “the brightest bulb in the pack”, I am sure that many individuals have raised this point before, yet apparently no one has taken any action. What is it that prevents the Bureau, this Plan, the General Court, our Executive Council, and our Governor from noticing and addressing the elephant? My last suggestion is that the Bureau take the time to answer that question in the Introduction to the plan and the “Public Outreach, Education, and Technical Assistance Action(s) associated with the aforementioned Goals 1,3,& 4. We deserve education and outreach why can’t we ask and force other states to keep, manage, and dispose of their own trash!
Respectfully submitted,
Subject: Public Comment on Draft New Hampshire Solid Waste Management Plan to be published October 1, 2022.
Solid Waste Management Bureau
Attn: Mr. Michael Nork
P.O. Box 95
Concord, NH 03302-0095
