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NSWMA Comments Page: 2 From a truck emissions standpoint, the Foth report estimates that a reduction of 6,000 metric tons of CO2e could be achieved through organized collection. This represents a minimal emissions reduction of .004 % of the total GHG emissions generated in the state annually. (See the pie chart in Attachment 2 for a relative comparison.) The Foth report also cannot draw the conclusion that higher recycling rates are achieved through organized collection because the data supporting this claim covers a timeframe of only one year, draws from a small sample, does not differentiate between dual sort and single sort programs, and the increased recycling may be due to a variety of other factors other than organized collection. Further, the minor differences in tonnage clearly do not warrant the report recommendation for organized collection. Nevertheless, the report repeatedly advocates for organized collection as a means to achieving higher recycling rates and leaps to the conclusion that an additional 32,000 metric tons of CO2e would be reduced in the Twin Cities Area (Page 66 of the report) through higher recycling rates due to organized collection. These reductions would be minor in comparison to the overall reduction that could be achieved if we focused our resources on getting residents and businesses to reduce the amount of waste they generate (20,000,000 metric tons of CO2e reduced) and recycle more material from the waste stream (45,000,000 metric tons of CO2e reduced). Even if this were an accurate conclusion, the resulting emissions reduction from increased recycling is .022% of the total GHG emissions generated in the state annually. Concluding Comments: The question then becomes, why advocate for organized collection and at what cost do cities organize collection, resulting in increased administrative, regulatory and enforcement costs, for the small benefit in terms of GHG emissions reduction gained? There is no evidence supporting the claim that organized collection results in higher recycling rates and, the GHG reductions estimated by Foth are unsubstantiated. It is perplexing, that the high level conversation held at the MCCAG that resulted in goals for the entire transportation sector has now turned into an effort to target a relatively small contributor to the overall climate change picture, for very little gain. Lastly, although we respect the diversity of opinions on solid waste issues, we continue to be frustrated by the indifference to the history of the private sector's efforts and role in developing the waste and recycling collection systems in Minnesota. As an industry, we have invested millions of dollars towards the development of the recycling system and have been major contributors to achieving the state's high recycling rate. Our industry has taken the initiative to explore alternative fuels and emissions reduction technologies and provides jobs that contribute to the state economy. The waste industry in Minnesota fully recognizes that our trucks generate emissions and contribute a small percentage to the overall 18% of emissions generated by all diesel trucks. And, we fully recognize the need for all of the trucking industry to work towards reducing GHG emissions in the state. For that reason, past members of the NSWMA have participated in Project Green Fleet, retrofitting our trucks for emissions reduction purposes and we have initiated discussion with the Minnesota Environmental Initiative (MEI) as a potential candidate for further work in this area. Members of NSWMA have anti -idling policies, daily pre and post trip inspections to ensure optimum engine performance, and routing software to ensure maximum fuel efficiency. Our industry has taken measures to protect the environment because the competitive marketplace has driven innovation and value. Each of us tries to be the best service provider in order to stay in the business, and that means that we compete to be leaders on issues that our customers and the marketplace demand. In Minnesota, that means the waste industry must give serious consideration to environmental issues and our business decisions reflect a balance amongst environmental considerations, priorities and cost. Our industry delivers the best possible value to our customers in terms of service, environmental protection and price. It is concerning that this report fails to acknowledge that the loss of the open market system will stifle innovation, reduce the 1163 E. Odgen Avenue, Suite 705, PMB 313, Naperville, IL 60563 800-679-6269 630-848-1101 630-848-1102 fx www.nswma.org