The Transfer Station Siting Controversy

As the closure of landfills creates the need for more transfer stations, controversy is brewing over some proposed sites.

The growing number of transfer stations is a result of federal and state environmental regulations, which closed thousands of small, substandard landfills and replaced them with larger, more environmentally sound landfills. Coupled with a growing national recycling rate, there now are less than 2,900 municipal solid waste (MSW) landfills, down from more than 20,000 in the late 1970s.

Because many new landfills serve large geographic or metropolitan areas, transfer stations have become necessary to haul trash economically. Typically built in several surrounding locations, transfer stations help to consolidate loads before trash is hauled to a regional landfill. Whether stations are proposed in urban, suburban or rural areas, siting controversies are inevitable.

On one side is the claim that transfer stations and other waste disposal facilities are sited disproportionately in low-income and minority neighborhoods [See "Is Justice Served?" page 166]. These complaints spurred the U.S. Environmental Protection Agency (EPA), Washington, D.C., to create in 1998 the National Environmental Justice Advisory Council (NEJAC), a 25-member committee that researches environmental issues.

NEJAC has raised concerns about the clustering of transfer stations in low-income, minority communities in New York City, particularly proposed transfer stations that are being planned to accommodate trash after the Fresh Kills landfill closes.

As a result, NEJAC has formed the Waste Transfer Station Working Group, which is holding a series of fact-finding sessions to determine whether new transfer station regulations are needed.

The group's first session was held in Brooklyn, N.Y., in November 1998, and the second session was in Washington, D.C., in February 1999. The group is expected to present a report to the EPA with its findings and recommendations, which may include a call for federal transfer station regulations.

Richard Peluso, professional engineer and senior vice president of Emcon, San Mateo, Calif., a national environmental services firm, represented the National Solid Wastes Management Association (NSWMA), Washington, D.C., at the first two sessions and testified before the NEJAC committee about the importance of transfer stations and how and why they are sited.

Without transfer stations, substantially more packer trucks would make trips to landfills and incinerators, thus increasing fuel consumption, transportation emissions and trips needed to transfer garbage to final disposal, he said. Using bigger trucks that are designed for highway driving to haul the trash instead of using heavy, more operationally expensive packer trucks has economic benefits and keeps roads safer, he said.

When siting a transfer station, a municipality or company first looks for locations zoned for transfer stations, Peluso says. The site must be large enough to handle the design requirements for the daily waste volume and to allow for quick truck unloading times. Sites also must have easy access to local utilities. In most cases, these are industrial areas.

Next, local transportation infrastructure is analyzed, including accessibility to the interstate or limited access highways and local transportation patterns, Peluso says. The best sites are streets designated as commercial routes. NSWMA avoids sites where morning or evening rush hour traffic creates transportation bottlenecks.

The quality and cost of transportation routes determine whether the trash will be shipped by truck, train or barge, Peluso says. Trucking generally is the least expensive way to transport solid waste, especially for shorter distances. Hauling by rail or barge requires larger amounts of trash to be hauled longer distances to reach economies of scale.

NSWMA members also fit transfer stations into their host neighborhood, Peluso says. Facility operators will design a transfer station with noise and odor controls, landscaping and a pleasant exterior design.

Peluso says transfer stations are heavily regulated by state and local permitting requirements, zoning and other rules. But these regulations differ among the 50 states. Generally speaking, state regulations include siting, operation, design and financial assurance requirements. A transfer station may need additional approvals and permits such as:

* Zoning board requirements;

* Planning board approval, including compliance with city or county master plans;

* Building department permits;

* Erosion and sediment control plans from the soil and water conservation district;

* Solid waste facility permits from the state solid waste management agency;

* An air emissions permit from the state environmental agency; and

* A National Pollution Discharge Elimination System (NPDES) permit from the EPA.

With extensive state and local requirements, siting a transfer station is an expensive and time-consuming process, Peluso says. It has yet to be determined whether differences between state permitting requirements are a burden on solid waste management companies that operate transfer stations in multiple states. "The differences in local requirements for transfer stations probably reflect unique geographical circumstances," he says.

According to Peluso, the NSWMA will work with the EPA to prepare guidelines for transfer stations, including siting. He added that NSWMA believes enforcement actions need to be taken against those transfer stations that operate without having received site or permit approvals.

At the Working Group's February session, Ernie Ruckert, a senior engineer at Emcon, provided follow-up testimony on technical aspects of marine transfer stations. Ruckert focused on best management practices and siting, transportation and regulatory requirements for these more specialized transfer stations. He noted the unique nature of these facilities as opposed to land-based transfer stations and the additional regulatory requirements they must follow, including construction permits from the Army Corps of Engineers along or within navigable waterways and a coastal zone consistency determination from state or federal environmental agencies.