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There are a lot of surprises in a new state report about solid waste, including the fact that other states are shipping tens of thousands of tons of trash to our landfills because it’s cheaper here, but perhaps the most surprising thing is that it really shouldn’t surprise us at all.

“In some weird way, China has done us a favor” by upending the world’s recycling markets, said Karen Ebel, a state representative who chaired the legislative committee that wrote the report. “It has pointed out the warts, if you will, in what’s going on here. We really need to wake up and take some action.”

A big part of that action, the report recommended, should be a kind that isn’t popular in New Hampshire: spending more on state government.

“Through a process of budget cuts, the department within the Solid Waste Management bureau that used to be involved in community assistance, recycling, that sort of thing – basically it has gone away,” said Ebel, a Democrat from New London. “If you don’t have a (Department of Environmental Services) that’s really working on what the heck we’re going to do with the solid waste in our state, you leave the municipalities floundering, trying to figure it all out in a global market.”

Municipalities, which under state law are responsible for disposing of waste, are floundering because the cost of recycling has soared since China stopped accepting most of it in 2018. Many cities and towns have curtailed or even ended their recycling programs, sending material to landfills or incinerators instead. The resulting outcry helped prompt the creation of the Committee to Study Recycling Streams and Solid Waste Management in New Hampshire, made up of three state representatives and Sen. David Watters, D-Dover. It held 14 meetings and took testimony from “over 50” individuals, businesses and government entities, and quickly realized that figuring out what to do with empty soda bottles, used cardboard and garbage is part of a very large, very complicated issue.

“The thing about this is it affects everybody. It affects business, government, it affects individuals. There’s nobody who doesn’t use things that ultimately will generate some waste. It’s just a universal issue and something that we really need to do a better job of dealing with,” Ebel said.

The 27-page report can be read online at

Were state goals met?

In 1990, the state Legislature set a goal of keeping 40% of the waste generated in the state from going to landfills by the year 2000. That’s an admirable goal, but it turns that nobody knows if it was accomplished because nobody keeps track of how much waste is generated in the first place.

“Calculating the percentage of solid waste diverted is inherently difficult in that it includes source reduction which involves changes made in the manufacture of products. (Department of Environmental Services) does not regulate at the point of manufacture, but rather at the solid waste facilities which it permits. … DES does not know, in part due to this issue, what our current diversion rate is and so the level of success in achieving the 40% diversion goal is unknown,” the report says.

Instead, the committee recommends that the state adopt a more measurable goal: Cutting the amount that is put into landfills. The committee supported a minimum of 25% disposal reduction by 2030 and 45% reduction by 2050.

That cutback would help a major concern: Where to put future trash.

Out-of-state trash

New Hampshire trash that isn’t recycled ends up in only a few places. The state has three private landfills that take trash from anywhere – the huge Turnkey facility in Rochester and large dumps in the towns of Bethlehem and Success – as well as three limited-service landfills in Nashua, Lebanon and Conway, plus the Wheelabrator incinerator in Concord.

The unlimited landfills have between 2 and 8 years of capacity left, according to the report, but it is proving extremely difficult to expand them or create new ones, as is shown by the ongoing battle in the towns of Bethlehem and Dalton over a proposed expansion of Casella’s landfill. The controversy over PFAS “forever chemicals” in the liquid that leaches out of the Turnkey landfill – and probably all other landfills, since PFAS chemicals are widely used – is just one of the environmental concerns that gives communities pause.

If we can’t expand landfills, we can make them last longer by reducing the amount of trash thrown into them. This has long been one of the arguments for recycling. But the report points out a complication: Half the material in New Hampshire’s three big private landfills comes from out of state.

In 2018, in fact, almost two-thirds of the trash arriving at the Turnkey landfill was from outside New Hampshire: 919,000 tons from out of state compared to 570,000 tons from inside the state.

The city-specific dumps and the Wheelabrator trash-to-energy plant take in much less out-of-state waste, usually less than 10 percent of the total by weight, according to the report.

Federal interstate commerce laws mean we can’t discriminate against out-of-state trash but the report says New Hampshire indirectly welcomes it. We are the only state in the region that doesn’t charge an extra per-ton “disposal fee,” which sometimes makes it cheaper to truck trash across the border rather than dump it closer to where it’s generated. Such a fee could be used to pay for government services that could help communities deal better with waste.

“Surrounding states have also instituted certain disposal bans at landfills, such as on food waste and construction and demolition debris. The Northeast Resources Council provided a comprehensive, eye-opening list of regional disposal bans in its testimony,” the report said. “This makes New Hampshire’s commercial landfills, with no such bans, a more attractive disposal option for waste that has been banned in that state. Additionally, other states, such as Massachusetts, have closed landfills, making New Hampshire a cheaper, nearby alternative for landfill disposal.”


One suggestion for reducing the amount of trash sent to landfills, the report said, is for towns and cities to institute pay-as-you-throw programs, which charge per bag of trash picked up by municipalities, “to reduce property taxes and to decrease what is landfilled and incinerated.” Concord’s purple bag program for curbside pickup is an example, but such efforts can be unpopular and have been rejected at some town meetings.

Another suggestion is to focus on food waste, an often-overlooked aspect of trash. The EPA has estimated that more than one-fifth of the nation’s waste is discarded food, more than any other single type of item.

The report, which notes that the state already bans the landfilling of leaf and yard waste, recommends both that the Department of Environmental Services improve composting regulations relating to food waste, paying particular attention to the problem of composting meat and dairy products, which usually have to be handled separately. “Recognizing the staffing challenges this presents, the Legislature should require the Bureau to send proposed, revised composting rules to the Joint Legislative Committee on Administrative Rules no later than September 30, 2020.”

Food composting is relatively rare in New Hampshire. A Hanover business that collected compost from Upper Valley towns expanded to Concord in 2018 but quickly shut down. Vermont is the forefront of this issue and is in the midst of a years-long program that will require virtually no food waste be placed in landfills, but such government mandates are unlikely to happen in New Hampshire.

Glass and plastic

The big complication is that waste is made of many different materials that require very different approaches.

Glass, for example, can easily be crushed and used in place of gravel for many road projects. The Northeast Resource Recovery Association, a multi-state industry group for recyclers, does this already and is expanding the program.

But the committee report notes obstacles: “The use of the material in private construction requires a professional engineer’s or architect’s approval, as required by DES’s current Certified Waste Derived Product specification,” which slows down its use. Further, “the state Department of Transportation requires that the product be more finely crushed (to 3/8 inch) before it can be used on a state road project.” The NRRA crushes glass to one inch, so it can’t be used on the biggest projects unless equipment or regulations change.

Then there’s plastic, which comes in a wide variety of types, many of which either cannot be recycled or cost too much to break down. Many products combine more than one type of plastic, making it almost impossible to recycle them.

The EPA estimates that in 2015 only 9% of plastic, by weight, was actually recycled in this country – and that was before China stopped buying our waste to use as raw material.

Realistically, the report says, the only solution is to use less plastic, which would require controversial actions like bans or fees for certain products such as plastic bags in supermarkets. Not doing this could have a boomerang effect, the report says: “Other states in the region are taking action to decrease plastics. … This may mean more plastics being sent to New Hampshire for disposal.”

Market solutions?

The report points to a pair of long-term things that state government could do to start tackling the problems.

One is education – letting people know that tossing everything into a recycling bin doesn’t cut pollution or taxpayer costs for waste disposal as much as many have been led to believe. Generating less waste in the first place is key, emphasizing the reduce and reuse portions of the “reduce, reuse, recycle” slogan.

Another step is to help coordinate marketing and development, figuring out uses for waste materials and helping businesses take advantage of them.

The report notes that a Chinese firm, Nine Dragons, has purchased a closed Maine paper mill and plans to use it to recycle paper or cardboard, and that “domestic plastic recycling plants are also starting to come online.”

“New Hampshire could work with entrepreneurs to develop such businesses and become an incubator for solid waste recycling and reduction innovation. … There are also opportunities related to the development of anaerobic digesters and better uses for biogas in the creation of electricity. Business opportunities also exist for developing and promoting sustainable packaging,” it says.

Overall, Ebel said, a sweeping problem like waste requires sweeping solutions that involve many different actors at once.

“We should try to coordinate the people coming up with ideas for marketing and packaging, with the people who produce the packaging, with the people who are charged with receiving the waste and do something with it – they need to work together,” she said.

After all, the report points out, the problem and the costs are already here. “Society generates a vast amount of refuse of a mind-boggling variety. Virtually everyone, directly or indirectly, pays for private or public waste management services to deal with their garbage.”

“We continue to produce untold, arguably inexcusable, amounts of waste that is increasingly difficult and expensive to handle. Our state must adjust its laws and programs to reflect the new economic, environmental and public health realities of solid waste management. This will take commitment, foresight, collaboration and funding.”

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