SWMP Comments
Solid Waste Management Plan: Comments
The Bureau of Solid Waste (BSW) received 768 comments between January 25th and April 24th 2023. Comments were made on multiple platforms, including email, Konveio (a platform that allows you to add comments directly on the draft) and testimony at Draft Public Review Meetings. All feedback was thoughtfully reviewed, compiled, and analyzed for common themes and priorities to update the Solid Waste Management Plan (SWMP).
Comment Stats and Downloads:
30% Draft Stage
Comments were collected between January 25 and February 2, 2023.
| Platform | #Comments |
|---|---|
| Konveio | 27 |
| 8 | |
| 1/17/23 Department of Planning Comprehensive Plan Mini-Conference Breakout Session | 11 |
| Total | 46 |
30% Draft Comments
60% Draft Stage:
Comments were collected between February and March 1, 2023.
| Platform | #Comments |
|---|---|
| Konveio | 89 |
| 14 | |
| 2/22/23 Public Meeting (testimony & chat) | 26 |
| Total | 129 |
60% Draft Comments
90% Draft Stage:
Comments were collected between February 28 and March 23, 2023.
| Platform | #Comments |
|---|---|
| Konveio | 42 |
| 94 | |
| 3/13/23 Public Meeting (testimony & chat) | 21 |
| Total | 157 |
90% Draft Comments
99% Draft Stage:
Final Draft Stage
Comments were collected between March 24 and April 24, 2023
| Platform | #Comments |
|---|---|
| Konveio | 104 |
| 14 | |
| 3/27/23 Public Meeting (testimony & chat) | 48 |
| Total | 166 |
99% Draft Comments
Draft Stages Combined:
Comments were collected between March 23 and April 24, 2023
| Platform | #Comments |
|---|---|
| Konveio | 458 |
| 182 | |
| Public Meetings | 128 |
| Total | 768 |
All Draft Comments
Comment Categories: Most comments fell into eight categories: program, legislation/code, education/outreach, environmental/equity concern, organics, infrastructure, administrative, and other. BSW has provided responses to common comments within those categories below.
| PROGRAM: new or different solid waste management programs | |
| Comment Topic | Response |
| Return to weekly recycling | Returning to weekly recycling is a priority for BSW and the SWMP outlines a return to weekly recycling through increased funding and rightsizing of routes, equipment and personnel (5.4.1- Curbside Collection of Mixed Refuse). |
| Implement the bridge strategy in the Fair Development Plan for Zero Waste endorsed by the City Council. The plan outlines diverting 184,000 tons of material over a two-year period with full City commitment. | BSW recognizes the ambition and thought that has been put into the bridge strategy for the zero-waste plan. Some of the strategies listed have been included in the SWMP, like expanded transfer capacity, expanded recycling and composting programs, and extensive education and outreach campaigns. However, full commitment from the City necessitates an assessment of the funding mechanisms for solid waste, which has been described in section 5.1.2. |
| Dual stream recycling | The current recycling plan of action focuses on restoring weekly single stream recycling, increasing recycling participation and decreasing contamination. However, BSW is open to exploring the costs and benefits of dual stream recycling and expanding the recycling program in the future to include additional source separated streams. |
| Curbside composting | A plan for expanding the existing organics program in a stepwise manner from residential and farmers’ market drop-off centers to food scrap pick up from public schools, City government offices, and residents (pilot) is described in the Plan of Action for Organics Management. (5.2.2- Organics) |
| Expand and incentivize recycling and reuse market development | The SWMP outlines a plan to incentivize the growth of local recycling markets by advocating for green procurement processes for the City and by holding market development workshops between local businesses that use recycled materials and local recyclers. Other activities described, such as exploring public private partnerships, will also lead to recycling market growth. The City also plans to host fix-it, repair and reuse workshops to encourage reuse and repair.(5.2.1 Single Stream Recyclables, 5.2.4 Bulk Waste) |
| Expand home compost programs | BSW plans to expand support for home composting by holding workshops and developing educational materials that encourage sustainable resource management behavior shifts, including home composting workshops. (5.2.2 Organics) |
| Financial commitment to economic development funds via development bonds | BSW will explore development bonds along with the other funding mechanisms as part of a Solid Waste Funding Assessment outlined in section 5.1.2 |
| Glass recycling at Residential Drop-Off Center(s) | BSW will explore a glass separation pilot program at residential drop-off centers (5.3- Residential Drop-Off Centers) |
| Long haul waste shipping program: truck vs train | The City will explore costs and benefits for long haul waste disposal methods to create a long-term disposal plan. Some methods that BSW will consider include rail, long-haul trucking, and regional partnership options (5.5.3 Long-haul disposal plan) |
| Mattress recycling program | BSW will be implementing a mattress recycling program by contracting with a private recycling company to recycle residential mattresses collected at the residential drop-off facility at the landfill and discourage disposal of mattresses at QRL (5.2.5- Other Diversion Programs) |
| Public space smart compost bins | More research and funding is needed to move forward with public compost receptacles to ensure public health standards and routine maintenance standards are managed properly. BSW will consider this input for future investment. |
| Public school waste diversion services and programs. | The plan outlines several waste diversion initiatives for schools including deploying outreach and education to improve recycling and organics diversion habits and establishing school gardens at public schools to encourage on-site gardening and composting. (5.2.2 Organics) |
| Compost Christmas trees | The Plan outlines improving Christmas tree recycling by partnering with non-profits and local farmers to divert whole Christmas trees for shoreline restoration or goat feed (5.2.5-Other Diversion Programs) |
| Subsidized costs for public school solid waste services | The SWMP outlines plans to support public schools waste diversion programs including providing education and outreach resources, supporting school farms that will encourage composting, expanding food scrap pick up to schools and continuing recycling pick up at schools. However, beyond providing food scrap and recycling pick up the plan does not specify subsidies for public school solid waste services. (5.2.2 Organics) |
| Textile recycling | The SWMP includes a plan to participate in textile recycling through the contract available with the Northeast Maryland Waste Disposal Authority. (5.2.5 Other Diversion Programs) |
| Increase commercial food waste diversion goals | For this regulatory plan goals were pulled from other existing City planning documents. The commercial food waste diversion goal was pulled from the Baltimore Food Waste and Recovery Strategy. BSW will work with the Office of Sustainability to update these goals. |
| Yard waste composting | BSW will explore and develop incentive programs to support and encourage development of yard waste reuse facilities, including wood pellet energy and biochar production (5.2.2 Organics). |
| ADMINISTRATIVE: administrative changes, actions and improvements (i.e., data management, planning, budgeting) | |
| Comment Topic | Response |
| Transparency around recycling rates, recycling contamination, markets recyclables are sent to, percent/tonnage sent to markets, City contracts, where waste and recycling is exported. | The plan of action includes assessing effective ways to improve transparency around recycling (5.2.1 Single Stream Recyclables) |
| Increase staffing at transfer stations | BSW is assessing the need for increased staff at new and existing transfer stations. |
| Improve 311 request response times | BSW tracks and analyzes 311 request service response times and is continually working on improving. Studies to determine funding, staffing, and equipment needs are included in the plan for operations across BSW. Ensuring the correct staffing levels in special services, bulk waste, and property management operations should improve 311 request response times. |
| Review RFP standards to improve contractor performance, services and reporting requirements. Specifically, MRF contracts. | The City plans to revise its contract policies to ensure that checks and balances are in place to guarantee optimal performance, health and equity standards for contracted service providers and private partnerships (5.1.2 Potential Funding Mechanisms). Additionally, the City plans to review and update contract policies and standards for issuing requests for proposals (5.2.1 Single Stream Recyclables). And lastly, the City of Baltimore intends to require MRFs and other disposal contractors to report on end markets for materials to improve reporting (5.2.1 Single Stream Recyclables). |
| Develop community/labor standards to ensure development and operation is consistent with environmental justice development principles | The City plans to work with the labor unions that represent the DPW workforce to improve pay, benefits, retention and working conditions for all DPW employees. |
| Improve Drop-off Center accessibility | Section 5.3.1 outlines a multi-faceted plan for Drop-Off Center improvements including improving accessibility. |
| Create emergency/contingency plans for incinerator closing | Various management scenarios for this emergency were described in the task reports for Less Waste, Better Baltimore. A summary of these recommendations will be included in the final draft of the SWMP. |
| Coordinate at state level to limit plastic tolerance in state | The City plans to support legislation and programs related to plastic limitation and diversion at the state level. (Section 5.2.1) |
| INFRASTRUCTURE: suggestions for new or improved solid waste management infrastructure | |
| Comment Topic | Response |
| Compost center within the city | The City intends to construct (or facilitate construction of) in-city organics processing capacity taking a decentralized and incremental approach, in which several, small-scale composting facilities would be constructed on an as-needed basis (Section 5.6.3) |
| Resource recovery center(s) where residents and small haulers can drop off a full range of products for reuse and attend educational programs. | The City will determine infrastructure priorities (in-city and regionally) for constructing a resource recovery park, reuse and repair clinics. (Section 5.3 Residential Drop Off Centers) |
| Local or regional glass recycling infrastructure | The City is interested in conducting pilot glass diversion initiatives and investigating partnerships with existing glass recycling facilities within the region. In addition, the City of Baltimore will confer with its recycling contractors to see what upgrades or changes are needed in the collection or processing of recyclables to facilitate more responsible glass recycling. (Section 5.3.1) |
| Mini MRFs | The plan proposes a phased, decentralized approach for building mini MRFs (section 5.6.2 Proposed Mini-MRFs) however, the City is also exploring whether regional partnerships will support the development of larger, more centralized and efficient MRFs for regional processing. |
| EDUCATION AND OUTREACH: strategies related to communicating, collaborating, and educating residents | |
| Comment Topic | Response |
| Increase outreach and education efforts for recycling, community cleanliness, illegal dumping and food waste reduction. | Every sub-section in section 5 outlines a comprehensive plan to expand education and outreach to residents, businesses, schools, and community groups. Initiatives include community-engaged seminars to gather data on residents’ barriers and motivations to waste diversion activities, developing a zero-waste coalition to gather stakeholders from multiple sectors to collaborate with the City on priorities for services in the City and a community-based social marketing campaign to inspire social norms, social diffusion and public pledges. |
| Provide incentives for residents and businesses for keeping neighborhoods clean, recycling and organics diversion. | Every sub-section in section 5 outlines a comprehensive plan to expand education and outreach to residents, businesses, schools, and community groups. Initiatives include community-engaged seminars to gather data on residents’ barriers and motivations to waste diversion activities, developing a zero-waste coalition to gather stakeholders from multiple sectors to collaborate with the City on priorities for services in the City and a community-based social marketing campaign to inspire social norms, social diffusion and public pledges. |
| Increase community partnerships for waste diversion and solid waste initiatives | Every sub-section in section 5 outlines a comprehensive plan to expand education and outreach to residents, businesses, schools, and community groups. Initiatives include community-engaged seminars to gather data on residents’ barriers and motivations to waste diversion activities, developing a zero-waste coalition to gather stakeholders from multiple sectors to collaborate with the City on priorities for services in the City and a community-based social marketing campaign to inspire social norms, social diffusion and public pledges. |
| LEGISLATION/CODE: change or adoption of laws related to solid waste management | |
| Comment Topic | Response |
| Ban plastic-to-fuel and other burn facilities | BSW would like to assess the environmental and health impacts of all future waste disposal options to ensure that decisions are made on the foundation of social and environmental equity and justice. |
| Create more nuance in types of plastics recycled/collected and recycled | Improving the recycling program is a priority for BSW. Creating more nuance in communications and materials recycled is feedback that has been incorporated into section 5.2.1. BSW also plans to improve terms and conditions of contracted services to ensure that recyclables tonnages and destinations are being reported accurately. (5.2.1 Single Stream Recyclables) |
| Retain industrial zoned buildings for use by local manufacturers | This is a great suggestion. While it is not directly related to the SWMP, we have noted this for future conversations with planning and zoning colleagues. |
| 25% set aside for local small businesses and agencies for recycling and organics collection | Recently DPW started a new program to make it easier for small businesses to do business with the City: https://publicworks.baltimorecity.gov/smallbusinessdevelopment. We hope that this initiative can lead to more progressive policies like small business set asides. |
| Deconstruction initiatives | The SWMP includes a comprehensive C & D reuse and diversion plan that includes supporting: a City-mandated deconstruction policy, a City mandate on source separation of recyclable materials, a City-wide policy to prioritize use of recycled materials in construction and repair projects, and a City-wide policy to support architectural salvage programs. (5.2.3 Construction and Demolition Debris). In addition, the City is in conversation with the Council about the REBUILD Act. |
| Improve transparency on the amount of waste Win Waste incinerates that comes from outside the City. | Baltimore City introduced a reporting bill in the 2023 General Assembly that would require haulers to report the tonnages and sources of waste incinerated, however the bill did not make it through. BSW will continue to explore avenues to increase transparency in the private and public solid waste system. |
| Ban single use plastics | The Plan includes supporting local and state legislation banning single use plastics (5.2.1 Single Stream Recyclables) |
| Code: -expanded polystyrene ban -modified plastic bag ban to eliminate 4 mil thickness standards for film plastic bags -deconstruction mandates for commercial buildings -revise code to eliminate barriers for waste diversion initiatives in inspection and food safety code |
These are excellent recommendations. Many of these have made it into Section 5 Plan of Action recommendations. |
| Legislation: -Rebuild Act -Renewable Energy Act -Right to Repair Legislation -Bottle bills -Take-back programs for hard to recycle materials |
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| ENVIRONMENTAL/EQUITY CONCERN: concerns, changes or actions related to environmental or public health inequities | |
| Comment Topic | Response |
| Aerobic composting over anaerobic digestion for environmental benefits | Aerobic composting for processing the City’s organic waste will be the first choice of action for its environmental and health benefits. |
| Do not renew contract with BRESCO/shut down BRESCO/ prohibit BRESCO from accepting waste outside of the City | WIN Waste is a private company and conducts their affairs as such. There may be other avenues to disincentivize accepting waste from outside the City which BSW will consider. In order to transition away from antiquated waste management strategies like landfilling and incineration, the City of Baltimore and private industry need to create the infrastructure that will facilitate the reuse, repair and diversion of the City’s waste. We are hopeful that we will see significant progress in this direction during the SWMP planning period. More details can be found in Section 5. |
| Other toxins such as heavy metals, dioxins and PFAs should be considered in emissions | DPW will work to coordinate with the Office of Sustainability in monitoring additional toxins that contribute to environmental pollution and emissions. |
| Chemical recycling concerns | BSW would like to assess the environmental and health impacts of all future waste disposal options to ensure that decisions are made on the foundation of social and environmental equity and justice. |
| ORGANICS: actions and improvements regarding organics diversion | |
| Comment Topic | Response |
| Improving accessibility of existing collection locations | These suggestions are a priority for BSW. There are recommendations in section 5 about expanded drop-off locations and pilot residential collection programs. |
| Separate yard waste and trash collection | |
| More community composting | |
| OTHER: didn’t fit into other categories | |
| Comment Topic | Response |
| Goals should be measurable | All goals found in the SWMP are detailed in other City plans listed in section 1.1.2. More nuance on the goals can be found in the original plans from which they were taken. |
| Who is responsible for executing the plan? | The plan contains actions for DPW, other City agencies, the private sector, residents and businesses. |
| We need step by step goals and a concrete timeline to move away from incineration. | Diversifying solid waste management strategies and maximizing source reduction, reuse and diversion are a priority for DPW. In order to consider alternatives to both incineration and landfilling, DPW will need to assess the resources, funding, and regional strategy to develop alternative methods and infrastructure for waste management. These precursory actions are detailed throughout section 5 of the SWMP. |
| Is Baltimore’s recycling getting recycled? | Yes, Waste Management does recycle the City’s residential recycling materials and sell baled goods to end markets for reuse. |
| What are the limiting factors to reaching the 35% recycling mandate? | Limiting factors include the staffing shortages that have limited services to bi-weekly recycling, funding for adequate outreach strategies, and funding for infrastructure upgrades or development to facilitate the diversion of more recyclable goods. Creating local infrastructure to facilitate the diversion of organics and C&D materials would greatly improve the City’s ability to meet the 30% mandate. In addition, there is legislation that currently requires private sector and multi-family dwellings to recycle, but there is no enforcement mechanism to ensure compliance. All of these challenges have been addressed in sections 4 and 5 of the SWMP. |
| Is it possible to do this type of planning within the current budget or will this lead to an increase in bills? | DPW is exploring various funding mechanisms detailed in section 5.1.2. |