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SWIRP ­ Draft Management Strategies The following potential management strategies have been prepared as the next step in the County’s ongoing project to develop a Solid Waste Integrated Plan (SWIRP) that targets Class III solid waste, including construction and demolition debris (C&D). At this stage, these items are not necessarily recommendations but are being used to foster a discussion among stakeholders and to help to refine subsequent recommendations. _____________________________________________________________________________________ 1) Improve reporting requirements to track generation and recycling/disposal of Class III waste through building permits, haulers, and/or destination facility data. The current system of landfills and MRFs reporting to the state is not sufficient in terms of helping the County to understand the quantity of materials generated inside and outside of the County. Improve reporting on the generation, recycling and disposal of Class III and C&D waste through: 
Use of the building permit process and/or C&D ordinance to require all private developers, construction and demolition contractors, and/or others generating Class III and C&D materials to report the quantities diverted and disposed to the County upon completion of projects in a format approved by the County. This could require development of a more elaborate data tracking system in coordination with the building permit process. 
Requirement that all registered C&D waste haulers submit annual reports to the County on the amount of C&D materials collected by material type, the destination to which each of those materials were taken, and the amount of diversion documented to have been achieved at each of those facilities. 
Working to improve current requirement that some destination facilities report to the County annually on Class III and C&D tonnages received and origin of material. The County should implement reporting improvements regardless of whether a C&D ordinance requiring recycling for C&D projects is adopted (i.e. Strategy #2). _____________________________________________________________________________________ 2) Job Site Construction and Demolition Debris Diversion Plan Adopt and implement a C&D diversion ordinance that includes the requirement to prepare a diversion plan and divert a certain percentage of materials from construction and demolition projects (e.g. 50% of all materials; or 75% of inerts such as asphalt, brick, concrete, dirt, fines, rock, sand, soil and stone, and 50% of remainder). Diversion could include options like deconstruction or the careful disassembly of buildings components for reuse, the reuse of recovered materials onsite or offsite, offsite recycling, or perhaps even waste‐to‐
energy. HDR Engineering, Inc. 1 SOLID
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A Diversion Plan would be submitted with projects requiring a Building Permit. As a local (land use) ordinance, the reporting on the implementation of the Diversion Plan would be required prior to issuance of the Certificate of Occupancy. A deposit could be required to be paid at the time of permit issuance based on the size and scope of the project. All or part of the deposit could be refunded on a pro‐rated basis once evidence of diversion is submitted to the County. Alternatively, the County could require the permit holder to pay a prorated non‐compliance fee if minimum diversion thresholds are not met during the course of the project. Review fees, forfeited deposits, and non‐compliance fees could be used to fund the program. The County should actively publicize the ordinance and its overall plan for C&D debris diversion and allow time for end markets and infrastructure to develop. _____________________________________________________________________________________ 3) C&D Pre‐Processing Prior to Disposal Adopt and implement a C&D diversion ordinance that requires pre‐processing prior to disposal. This strategy was recommended by FDEP in its 2010 report to the 2010 Florida Legislature and subsequently adopted as amendments to Florida Statute 403. One consideration of the FS language is the provision of a not well defined “extent economically feasible” clause. A local ordinance should mirror the Florida Statute and FAC Rules while clarifying the criteria that will be used at the local level for determining whether pre‐processing is required or not. Potential approaches include defining general thresholds for economic feasibility (e.g. remaining facility capacity and expected life) and requiring facilities to submit documentation to the County regarding the feasibility or infeasibility of pre‐processing. In addition, minimum percentages of materials would be required to be diverted during pre‐processing. For example: 25% total; or 75% of metals and 55% of concrete. Affected facilities would be allowed an adjustment/implementation period of a year or two to reach these minimum diversion requirements, with less aggressive interim goals to be met during the adjustment implementation period (i.e. must be diverting 10% of total tonnage by the end of year one and 25% of total tonnage by the end of year two). Accounting for the potential of a site receiving pre‐processed loads may either require additional record keeping or simply reflecting this as a lower overall minimum diversion rate. The County should actively publicize the C&D pre‐processing requirements and its overall plan for C&D debris diversion and allow time for end markets and infrastructure to develop. _____________________________________________________________________________________ 4) Landfill Ban for certain types of C&D materials Establish an Ordinance that “bans” the disposal of certain types of materials. Identify materials with sufficient recycling potential (such as asphalt, brick, concrete, cardboard, and wood) and establish maximum allowable percentages of components in loads tipped at landfills. For example, loads must contain less than a specified number of tons or a specified percentage of a particular material; otherwise it must be diverted for segregation and recycling prior to disposal. This could be accomplished in a stepped approach, starting with a material like concrete that is already being recycled by many, then adding metals for which there are good markets, and later adding other materials that there may be less HDR Engineering, Inc. 2 SOLID
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demand for. This would need to be a cooperative effort between the County and local municipalities, and would require State and regional support. The intent of the ban would be to encourage the recycling or composting of “banned” materials and to encourage facilities to create incentives for haulers/waste producers to remove the “banned”/recyclable materials from the waste stream. The County could require facility operators to develop a plan showing that they will not dispose of waste that is commingled with too much of the “banned” substances by processing for recycling onsite or offsite. Elements to be addressed in the plan are similar to the spotting already performed for unauthorized waste: 
Monitoring of all incoming loads 
Comprehensive inspection of certain loads 
Response to failed loads o Notice to the sender o Records kept on failed loads greater than a certain size o Loads rejected (unless facility recycles the banned materials) o Facility may fine hauler or provide incentives Facilities would have the option to either set up a recycling program for the banned materials received at their facility, or create incentives for haulers/waste generators to separate recyclables prior to delivery to the facility. Such incentives could include fines for violations, rewards for cooperation, and/or rejection of non‐compliant loads. Facilities that do not comply with the ban and their submitted plan could be fined by the County. The County should actively publicize the landfill ban on selected C&D materials and its overall plan for C&D debris diversion and allow time for end markets and infrastructure to develop. _____________________________________________________________________________________ 5) Building Contractor Education Develop educational information and outreach methods to inform contractors of alternatives to landfill disposal of their C&D waste. Contractor education programs typically aim to illustrate the environmental and economic value of C&D recycling to contractors and provide them with information on local resources and alternatives, with the goal of encouraging a change in their thinking and behavior related to C&D reuse and recycling. Examples of possible topics to be covered include: green building practices focused on waste reduction, deconstruction, on‐site source separation, recycling at mixed waste or C&D processing facilities, and information regarding any local C&D ordinances, resources, or incentive programs. The County could provide resources regarding how to conduct a detailed building inventory to assess the initial feasibility of deconstruction. Provide education and resources on the process for planning, permitting, and contracting related to deconstruction projects, and the marketing of recovered materials resulting from the project. The County could also provide building contractors with worksheets to assist with diversion cost‐benefit analysis, to assist them in determining whether on‐site source separation is economically feasible. HDR Engineering, Inc. 3 SOLID
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Information should also be provided to contractors regarding area haulers and/or facilities that are already doing significant pre‐processing and diversion. _____________________________________________________________________________________ 6) C&D Disposal Surcharge (Community Host Fee) Enact a surcharge for landfill disposal of C&D debris and use the proceeds to support waste diversion and public education efforts. Funds could be utilized to support other strategies for implementation, such as developing data gathering and reporting mechanisms (i.e. database and links to building permit applications). This would be most effective as a cooperative effort with local municipalities in order to be consistent throughout the County, and pool resources for funding consistent public education efforts. _____________________________________________________________________________________ 7) Adopt C&D diversion policies and procedures that strongly encourage the diversion of C&D materials. Policies would be in the form of an informal advisory document or a program that strongly encourages the diversion of C&D materials, but would not provide the kind of enforcement mechanism that an ordinance would provide. It would simply express a preference on the part of the County that C&D waste be diverted for reuse or recycling wherever feasible. The purpose of such a policy is to encourage C&D diversion without actually requiring it. This can be a viable alternative to an ordinance when a jurisdiction does not have the time and resources necessary to fully implement an ordinance. It can also be used as a "stepping stone", moving toward an ordinance requiring diversion. Procedures that would encourage diversion of C&D materials could include: 
Structural and/or financial incentives for green building o
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Reduce permitting hurdles for recycling facilities to the extent possible, while maintaining the necessary controls needed by the County. o
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For example, the County currently offers expedited review/permitting processes for green building projects. Other incentives that could be implemented should be evaluated. Make the permitting process easier to encourage recycling facilities. Two task forces in the county – general permitting and environmental permitting – are already working on this. Encourage local end use intermediates markets. o
Work with local economic development groups such as the Metro Orlando Economic Development Coalition to bring these types of businesses to the area. _____________________________________________________________________________________ 8) Establish a C&D recycling incentive program for waste haulers. Establish a C&D recycling incentive program for waste haulers that would encourage them to increase diversion of C&D material. This could be accomplished through modifications to existing licensing procedures with the C&D waste haulers in the County, and providing incentives for C&D diversion HDR Engineering, Inc. 4 SOLID
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through commensurate license fee decreases or rebates (or establish disincentives with commensurate fee increases for disposal versus recycling of C&D waste). This approach would require annual reporting on the part of the haulers. Another option would be to provide rebates to haulers or contractors for the delivery of C&D material to recycling facilities. Under such a program, levels of recyclables delivered to recycling facilities would be documented and communicated to the County which would issue the rebates. Rebate programs are typically voluntary. In order to provide rebate funding, this Strategy would need to be coupled with a revenue generating Strategy. _____________________________________________________________________________________ Other Strategies It should be noted that as part of this project many potential strategies have already been evaluated at a high level. Some of these strategies have been combined in some form with those that appear on this list. Other strategies were in effect ranked low and don’t appear on this list because of poor potential for success, difficulties in implementation, inconsistencies with the Guiding Principles, low anticipated outcomes in achieving the Goals of this project, etc. _____________________________________________________________________________________ For additional information on the SWIRP project please contact: Orange County Environmental Protection Division David Bromfield [email protected] 407‐836‐1527 HDR Engineering, Inc. Allison Trulock [email protected] 407‐420‐4166 Acknowledgment: “This material is based upon work supported by the Department of Energy under Award Number(s) DE‐EE0000791.” Disclaimer: “This report was prepared as an account of work sponsored by an agency of the United States Government. Neither the United States Government nor any agency thereof, nor any of their employees, makes any warranty, express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately owned rights. Reference herein to any specific commercial product, process, or service by trade name, trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, or favoring by the United States Government or any agency thereof. The views and opinions of authors expressed herein do not necessarily state or reflect those of the United States Government or any agency thereof.” HDR Engineering, Inc. 5