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EIA iNSWMA May 11, 2009 Paul Eger, Commissioner Minnesota Pollution Control Agency 520 LaFayette Rd North St. Paul, MN 55155 Dear Commissioner Eger: The National Solid Wastes Association (NSWMA) has reviewed the Draft Report, "Analysis of Waste Collection Service Arrangements", prepared for the Minnesota Pollution Control Agency by Foth Infrastructure and Environment, and respectfully submits the following summary of our comments in bold below. Summary Presentation of NSWMA Comments: I. The Foth Report goes well beyond its original scope as discussed by MPCA with NSWMA prior to its development. The attempted examination and comparison of rates charged to customers within various waste system types detracts from the environmential goals we are all trying to achieve II. The report fails to use a scientific approach in data collection and analysis, and in survey development and administration. The report author acknowledges these shortcomings but nevertheless, goes on to draw unsubstantiated conclusions about achieving higher recycling rates and what appear to be large reductions in GHG emissions. (See Attachments 1 and 3) III. The report fails to put the very small GHG emissions reductions gained from organized collection into the bigger climate change picture. It becomes very clear, when presented in this context, that there are very minimal gains to be made from a GHG perspective with implementation of organized collection. (See Attachment 2) Detailed Discussion of NSWMA Comments: Scope of the Report: In May 2008, members of NSWMA were involved in early discussions with MPCA management on the development of this report. Through those discussions, it was determined that the MPCA stakeholder process would focus as an extension of the Minnesota Climate Change Advisory Group (MCCAG) process and that this report would gather information on solid waste systems from a Greenhouse Gas (GHG) perspective. Instead, the report goes well beyond its initial charge by researching costs to consumers and rate comparisons in various waste system scenarios, by different waste hauling businesses in different communities. We believe the presentation and comparisons of rate information go beyond the environmental charge of this report and beyond the statutory responsibilities of the MPCA. Report Methodologies: The author discredits the work throughout the document by citing the lack of scientific approach and lack of random sampling. NSWMA agrees with this assessment and cites a general lack of rigor with methodologies used in examining rates and system costs, road wear and tear, and in determining fuel use and Greenhouse Gas (GHG) emissions. In many cases, the report then goes on to draw conclusions that advocate organized collection as a means to decreasing costs for consumers, increasing recycling rates, decreasing road wear and tear, and reducing GHG emissions. These are completely unfounded, unsubstantiated conclusions that are not supported by the data collected and field studies used in this report. (See Attachment 1 for more detailed comments) Relative Cost/Benefit of Organized Collection from an Environmental Perspective: The methodology used in arriving at GHG emissions reductions gained through organized collection is poor and even if the data and analysis were sound, the calculated reduction of 6,000 metric tons of CO2e is very small in relation to the overall climate change goals of the Minnesota Climate Change Advisory Group (MCCAG).