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TRIBAL DECISION
MAKER'S GUIDE
TO SOLID WASTE
MANAGEMENT
WASTE
MANAGEMENT
IN INDIAN COUNTRY
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TRIBAL DECISION-
MAKERS'GUIDE
TO SOLID WASTE
MANAGEMENT
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Contents
Chapter 1. Introduction 1
The Solid Waste Dilemma 1
Making Solid Waste Management a Priority 2
Goals of This Guide 3
Chapter 2. Developing Solid Waste Management Plans 5
What Is a Solid Waste Management Plan? 5
Reasons To Develop a Solid Waste Management Plan 6
Getting Started 8
Steps in Developing a Solid Waste Management Plan 9
Conducting a Waste Stream Analysis 14
Chapter Highlights 17
Resources 18
Chapter 3. Developing, Implementing, and Enforcing Solid
Waste Codes, Laws, and Regulations 19
Developing a Solid Waste Management Code 20
Implementing a Solid Waste Management Code 26
Enforcing a Solid Waste Management Code 30
Chapter Highlights 31
Resources 31
Chapter 4. Solid Waste Collection and Disposal Programs 33
Getting Started 33
Collection Options 34
Transfer and Disposal Options 38
Addressing Open and Illegal Dumps 48
Chapter Highlights 51
Resources 51
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Chapter 5. Waste Reduction, Buying Recycled, and Manufacturing
with Recovered Materials 53
Why Tribes Set Up Waste Reduction Programs 53
Setting Up a Materials Collection Program 54
Beyond Recycling: Source Reduction, Reuse, and Composting 58
Buying Recycled Products and Manufacturing with Recovered Materials 61
Manufacturing with Recovered Materials 64
Chapter Highlights 64
Resources 64
Chapter 6. Public Education and Community Outreach 67
Designing an Effective Education Program 67
Sample Educational Tools 71
Instituting the Community Education Program 75
Sample Educational Program: Illegal Dumping 77
Chapter Highlights 79
Resources 79
Chapter 7. Funding Your Solid Waste Management Program 81
Major Program Costs 81
Sources of Funding 82
Finding Out About Funding Opportunities 86
Building Strong Relationships 88
Chapter Highlights 89
Resources 90
Acronyms List 93
Appendix A. Glossary 95
Appendix B. Tribal Information Sources and Contacts 99
Appendix C. Sample Public Education Tools Used by Tribes 107
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Chapter 1. Introduction
The Solid Waste Dilemma
What is the best way to manage
solid waste? This is a question
that many Native American
tribes and Alaskan Native villages face
today. Tribes in rural areas face illegal dump-
ing issues. Alaskan Native villages struggle
to find cost-effective and safe alternatives to
open dumps. Tires, appliances, furniture, car
batteries, and abandoned cars litter many
reservations. Backyard burning of household
waste pollutes the air and poisons fish and
wildlife. This guide is designed to help tribes
and villages to find solutions to these prob-
lems, improve existing systems, and develop
effective solid waste management programs.
The types of solid waste management pro-
grams being run by tribes and Native villages
are varied and diverse, ranging from simple,
one-step disposal programs to complex man-
agement programs intertwining recycling,
composting, and disposal. Some tribes have
sophisticated recyclables collection and mar-
keting programs, others run landfills or trans-
fer stations on the reservation, while still
others are struggling to clean up and close
open dumps or determine the best way to
dispose of bulky items and other trash litter-
ing the reservation.
In the past, tribal members and Alaskan
Native villagers have disposed of their waste
in open pits or by burning it, with few envi-
ronmental or health impacts. Due to changes
in the types and volumes of waste generated
today, however, these practices are no longer
safe or effective ways to manage waste. The
increase in plastics and other synthetic mate-
rials in our waste stream, in addition to the
growth in sheer volume of waste, makes
backyard burning and open dumping danger-
ous to human health and the environment.
Public health and environmental concerns
include an increased incidence of disease,
food and drinking water contamination, and
air pollution.
Open dumps can attract young children and
pets. Children playing in or rummaging
through open dumps can be hurt by sharp
objects. They also can come in contact with
toxic materials or contagious pathogens,
which can lead to gastroenteritis; skin rashes
and infections; or eye, nose, and ear infec-
tions. Open dumps also attract pests such as
insects, rats, dogs, bears, birds, and raccoons
that can spread disease or physically injure
people. Chemicals and bacteria from these
dumps can run off into rivers and lakes, con-
taminating drinking water sources and fish
and game. Native Americans and Alaskan
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Native villagers dependent upon fish and
game for subsistence living are especially vul-
nerable to illness resulting from open dump
contamination.
Burning waste in barrels, boxes, or open pits
releases dangerous chemicals into the atmos-
phere that are inhaled immediately or settle
on plants and bodies of water, entering the
food chain. Air pollutants released by back-
yard burning include dioxins, fine particulate
matter, carbon monoxide, nitrogen oxides,
polycyclic aromatic hydrocarbons (PAHs),
volatile organic compounds (VOCs), and
hydrogen chloride. The ash residue from
burning also can contain dangerous levels of
toxic heavy metals, such as mercury, lead,
chromium, and arsenic, which can contami-
nate water or enter the food chain.
The impacts of improper solid waste man-
agement go beyond these health and envi-
ronmental problems. Open dumps degrade
the land by destroying fish and wildlife habi-
tats. Many tribes and villages depend on
these natural resources for economic and cul-
tural survival. In the Pacific Northwest, for
example, salmon are central to many tribes'
social, spiritual, and economic livelihoods.
Open dumping and burning can further
threaten these species. Open dumping also
degrades natural resources, such as timber,
agriculture land, and recreational areas. In
some cases, open dumping even infringes
upon or threatens culturally or spiritually sig-
nificant lands.
Making Solid Waste
Management a Priority
Solid waste management touches all aspects
of tribal and village life—public health,
environmental quality, economic develop-
ment and prosperity, community pride and
identity, tribal culture, and land stewardship.
But tribes often have limited resources.
Equally important competing interests, such
as education, physical and mental health,
employment, and economic development,
often take precedence over solid waste and
exhaust tribal funds.
Even when tribal environmental and natural
resource divisions obtain funds, solid waste
management concerns often are seen as sec-
ondary to drinking water and water quality
concerns. Many tribal solid waste managers
An illegal dump site on
the Seminole Nation
of Oklahoma's
reservation.
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have to make the case to their tribal councils
and communities that solid waste manage-
ment is an issue that warrants attention and
adequate funding. The managers who are
successful are those who are able to demon-
strate the extent of the problem and show
how it is integrally connected to the commu-
nity's other concerns. In some cases, making
solid waste a tribal priority reaps financial
benefits, too. In order to obtain Indian
Health Service (IHS) Sanitation Deficiency
System funding for a solid waste related proj-
ect, for example, a tribe often must designate
solid waste management as its number-one
priority.
Goals of This Guide
Each tribe is unique, with its own history,
culture, financial situation, and geographic
location. But even though tribes have their
own separate identities, they share common
problems. The primary objective of the Tribal
Decision-Makers' Guide to Solid Waste
Management is to provide a variety of options
and technical assistance solutions to help
tribes and Alaskan Native villages protect
their environment and the health of their
members. To achieve this goal, the guide rec-
ommends developing and implementing an
integrated solid waste management (ISWM)
program.
No two ISWM programs will be exactly alike
due to the differing geography, demograph-
ics, financial situation, and culture of each
tribe and Alaskan Native village. While the
specifics of each program will likely vary,
every successful integrated solid waste man-
agement program will possess five fundamen-
tal components. These five components form
the core of any integrated solid waste man-
agement program:
Solid Waste Management Plan — A
solid waste management plan is the
foundation of any ISWM program.
Solid Waste Codes, Ordinances, or
Regulations — Codes, ordinances, and
regulations provide the legal justification
for your ISWM and the authority to
ensure compliance.
Enforcement Mechanisms — Solid
waste codes, ordinances, and regulations
are only effective if they are consistently
and equitably enforced.
The same site after
cleanup.
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Viable Solid Waste Disposal Options —
Proper solid waste management and dis-
posal mechanisms ensure that your tribe
or village's waste ends up in a licensed,
certified, or permitted landfill or munici-
pal solid waste incinerator and not an
open dump.
Community Outreach and Education
— Community outreach and education
promote understanding, support, and
participation in your ISWM program.
While reuse, recycling, composting, and
waste prevention/source reduction are other
important components of an ISWM pro-
gram, they are not sufficient to ensure proper
solid waste management in the absence of
the core components. Incorporating these
other components into a well planned and
implemented core program can only increase
the effectiveness of your ISWM program, but
you must have the core program to ensure
success.
To help tribal leaders and decision-makers
clarify their solid waste goals and objectives
and assess management options, the guide is
divided into six sections, each focusing on a
different component of an ISWM program.
These sections include:
• Developing Solid Waste Management
Plans: Describes why a tribe or village
would want to develop a solid waste
management plan, what the plan should
include, and where to get help in devel-
oping the plan. The chapter also
includes links to solid waste manage-
ment plans drafted and used by individ-
ual tribes.
• Developing, Implementing, and
Enforcing Solid Waste Codes, Laws,
and Regulations: Describes and provides
examples of how to develop, implement,
and enforce solid waste codes. Provides
examples of actual regulatory language
used by other tribes and villages, numer-
ous examples of effective enforcement
strategies and practices, and information
on working within the federal regulatory
framework.
• Solid Waste Collection and Disposal
Programs: Outlines and describes sever-
al waste collection and disposal options.
Also discusses strategies to control illegal
dumping and close open dumps.
• Waste Reduction, Buying Recycled,
and Manufacturing with Recovered
Materials: Discusses reasons for develop-
ing source reduction, recycling, compost-
ing and buy-recycled programs and how
to start these programs, as well as infor-
mation on manufacturing with recovered
materials. Provides numerous examples
of tribes and Alaskan Native villages
with successful programs.
• Public Education and Community
Outreach: Discusses approaches to
developing and instituting an effective
community outreach and education pro-
gram. Provides different examples of ini-
tiatives aimed at children, adults, and
tribal and village leaders.
• Funding Your Solid Waste Management
Program: Provides tips for identifying
grants and loans and ways to improve
your grant applications. Also discusses
different internal sources for funding
your program.
Incorporated throughout the guide are exam-
ples of tribes and villages finding solutions to
solid waste problems through creativity, flexi-
bility, and perseverance. The case studies and
examples also demonstrate the benefits of
forming partnerships and collaborating with
other tribes, villages, neighboring counties,
and state and federal agencies. These stories
illustrate that while creating an effective
solid waste management program is often a
challenging endeavor, success is possible.
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Chapter 2. Developing Solid Waste
Management Plans
Solid waste management plans offer a
host of benefits for tribes and Alaskan
Native villages. Through the prepara-
tion of these plans, you can assess your cur-
rent and future waste management needs, set
priorities, and allocate resources accordingly.
Working through these issues can help you
ensure your waste management system offers
the highest level of protection to the health
of tribal members and the natural environ-
ment. This chapter explains the purpose of
solid waste management plans and the steps
involved in developing these plans. It also
includes references to solid waste manage-
ment plans that tribes have already devel-
oped and are successfully implementing.
Throughout this chapter, several publica-
tions are cited or referenced. For a complete
listing of these documents and specific order-
ing information, refer to the Resources sec-
tion at the end of this chapter.
What Is a Solid Waste
Management Plan?
A solid waste management plan is simply a
document developed by a tribe or Alaskan
Native village that outlines how the tribe or
Native village will reduce, manage, and dis-
pose of its solid waste. A solid waste manage-
"Solid waste management is an evolving pro-
gram in which planners try one strategy, and, if
they are unsuccessful, change and try another."
-Laura Weber,
Director of Solid Waste Management,
St. Regis Mohawk Tribe
ment plan will assist and guide your tribe or
village in developing and implementing its
solid waste management program by estab-
lishing what actions need to be taken and
setting the criteria for decision-making.
A basic solid waste management plan typi-
cally includes:
• A profile of the tribal community.
• The goals and objectives of the plan.
• An overview of the existing solid waste
management program.
• Solid waste management alternatives,
along with a discussion of the issues and
uncertainties associated with each alter-
native.
• The selected alternative, implementa-
tion measures, and potential funding
sources.
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• Any solid waste codes that need to be
developed.
Reasons To Develop a Solid
Waste Management Plan
Planning is the first step in designing or
improving a solid waste management system.
A solid waste management plan will help
your tribe take institutional, social, financial,
economic, technical, and environmental fac-
tors into consideration as it manages its
waste stream.
A solid waste management plan is a practical
document that can help guide your commu-
nity's solid waste management efforts. It can
help you:
• Define and understand current waste
management practices and the system in
place.
• Identify problems and deficiencies with
the current system.
• Identify opportunities for improvement
in the current system.
• Set priorities for action to address prob-
lems and affect improvement.
• Measure progress toward implementing
actions.
• Identify the resources needed and devel-
op budgets and schedules.
• Revisit and modify priorities as the plan
develops.
A solid waste management plan also can sup-
port proposals for solid waste management
grants. Government agencies that provide
financial assistance to tribal communities for
solid waste management place a high priority
on good planning to support a grant proposal.
Agencies involved in funding tribal solid
waste management projects often prefer that
a tribe complete a solid waste management
plan as a prerequisite for grant applications
related to solid waste handling facilities or
closing open dumps. In addition, tribes can
ask for funding for a project that is a step
toward solving, but does not completely
solve, a solid waste problem. For example, an
agency might be more likely to fund clean up
and closure of an open dump site if the tribe
offers a plan addressing the waste currently
being generated, such as taking waste off site
to an approved facility. See Chapter 7 for
more information on grants and other fund-
ing sources.
Determining the Scope of the Solid
Waste Management Plan
Several factors help determine the scope of a
solid waste management plan, including
available funding and technical expertise.
You might not have the resources on hand to
develop a comprehensive plan initially, but
starting a plan is still useful. Solid waste
management plans are living documents that
can be revisited and revised.
Your initial plan can describe existing waste
management practices, identify existing sys-
tem limitations and opportunities for
improvement, and delineate a plan of action
to address these limitations and make
improvements. If it is well thought out and
effectively describes your tribe's priorities,
goals, and plans, this initial plan will be suf-
ficient to support your requests for funding
future activities.
The Hannahville Indian Community in north-
ern Michigan prepared an initial plan present-
ing basic information about the tribe and its
solid waste needs, including a description of
the reservation's location and geography, exist-
ing conditions, a brief waste stream analysis, an
evaluation of the tribal solid waste manage-
ment program, and a 3-year action plan. The
Washington-based Spokane Tribe of Indians'
solid waste management plan also presents
basic information and includes details on regu-
latory requirements and landfill closure.
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Figure 1 illustrates all of the steps in the
comprehensive solid waste management
planning process, from planning to imple-
mentation. This diagram can help you see
where you are in the process and determine
the path you need to take.
Developing Long-Term and Short-Term
Goals
Solid waste management is a complex puzzle
with many pieces, and it is easy to get side-
tracked in your planning process. Developing
goals will help guide your solid waste manage-
ment planning and keep you focused on your
priorities. Goals also can help you set targets
by which your tribe can measure progress.
A good way to determine your goals is to
develop a list of your tribe's values and what
you want to accomplish. Look for problems
that require solutions, and actively solicit
input from the tribe, including tribal mem-
bers. Typical considerations related to solid
waste management are:
• Protecting tribal members' health and
safety.
• Protecting the natural environment.
• Complying with federal and tribal laws.
• Protecting and conserving natural and
cultural tribal resources.
• Contributing to the economic develop-
ment of the tribe.
Figure 1. Comprehensive Integrated Solid Waste Management Planning Process
Evaluate the Waste
Management System
How can you make adjustments or improve or
expand solid waste management services?
Identify Needs
-Wfiat types of wasEe""—-.
are currently generated
and in what quantities?
Review Existing System
Where are the uncontrolled dumps located? How is
waste\urrently managed?
Implement the Plan
When will you begin to conduct new or
additional solid waste management activities?
Education
Review Existing Regulations
Are the existing laws adequate for ISWM?
Develop the Integrated Solid
Waste Management Plan
How will you finance building of facilities,
obtain equipment, and hire and train workers?
Public Participation
Outreach
Organize Decision-Making
Framework
Who will make the decisions?
Compare Options
Which activities are the most cost-effective?
Are they affordable in the long-run?
Establish Objectives
What are your short- and long-term goals?
Identify Potential
'•Components- "
Which waste management activities
(e.g., waste prevention, recycling,
disposal) will help you achieve your
objectives?
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For each problem or proposed improvement
you identify, develop a goal statement. For
example, if the community has a problem
with uncontrolled open dumping that is
impacting the natural environment, a typical
goal statement could be: Control open
dumping as necessary to protect the environ-
ment and tribal resources. One action relat-
ed to this goal could be developing and
enforcing regulations that prohibit open
dumping. The tribe would measure success
by how much open dumping decreases.
The Gila River Indian Community in
Arizona identified illegal open dumping as a
goal to address. The community added a pro-
vision about illegal dumping to its Solid
Waste Management Ordinance and held a
workshop for tribal officials to discuss how to
enforce the provision and delegate enforce-
ment responsibility. The community also
maps dump sites and categorizes them into
three levels of risk so it can focus its limited
resources on sites that pose the most severe
health threats. The tribe measures its success
by the reduction in the number of illegal
dump sites in the community.
Key Decisions To Be Made on Basis of
Plan
The solid waste management plan will pro-
vide information and guidance you need to
make critical waste management decisions,
such as whether you need a transfer station
for exporting solid waste or need to construct
a landfill on your reservation. The plan also
can help your tribe focus on solid waste man-
agement enhancements, including waste pre-
vention, materials reuse, recycling, and
household hazardous waste management.
Key decisions your tribe can address in the
planning process include:
• How important is waste reduction, as a
priority, compared with other solid waste
management priorities?
• What opportunities exist for waste
reduction?
• Which materials can be recycled?
• What type of waste and recyclables col-
lection system can the tribe use?
• What type of disposal system can the
tribe use?
• What will the present/future costs of the
waste management program be?
• What resources does the tribe need to
implement its solid waste management
plan?
• What resources are available to the tribe?
Getting Started
Before your tribe starts drafting its solid
waste management plan, you should consider
a few key parameters that will provide a
framework around which planning can take
place. These include:
• Defining the planning area.
• Identifying the regulatory entities within
the planning area.
• Establishing planning periods.
• Developing a community education and
outreach plan to solicit public input.
Defining the Planning Area
A natural planning area for tribal communi-
ties or nations is defined by the reservation
boundary. Some tribes will have a contiguous
boundary, while other tribes will have more
of a "checkerboard" boundary, whereby some
areas of the reservation are not directly con-
nected to other areas. At minimum, the
planning area should reflect the extent of
the area serviced by the current solid waste
management program.
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Identifying the Regulatory Entities
Within the Planning Area
Regulatory entities will include tribal envi-
ronmental programs and the other tribal pro-
grams that handle solid waste. Include not
only the entities actively managing your
solid waste, but also departments that might
be able to contribute resources, such as the
road department for construction equipment,
and those that can assist with regulatory
development and implementation. Also con-
sider community, county, state, and federal
agencies. Tribes might fall under more than
one state regulatory entity. Look for opportu-
nities to pool resources and share informa-
tion and costs.
Establishing Planning Periods
Determine the time period your plan will
cover. Typically, a solid waste management
plan will cover 20 years, with 5-year review
intervals. Longer terms may be needed to
site and construct new facilities. Siting,
designing, permitting, and constructing a
new landfill may take 10 years, while it may
take 3 years to design and construct a recy-
cling facility. Regardless of the planning
period, the tribe should build a regular
review interval into the plan. Review periods
let planners incorporate new regulations,
changes in waste generation rates, or experi-
ence gained from operating the solid waste
management program.
Developing a Community Education
and Outreach Plan To Solicit Public
Input
The backbone of waste management plan-
ning is public involvement, participation,
and cooperation. The planner can compile
data, estimate costs, and develop lists of
potential sites and solid waste management
options; however, the choices and positive
changes must ultimately come from within
the tribal community. Tribal education and
outreach is a continuous process that
includes a variety of activities, such as dis-
tributing newsletters, sponsoring open hous-
es, mailing fact sheets, conducting
community surveys, and distributing infor-
mation through advisory groups and commit-
tees, public meetings, interviews, and
workshops. For more information on devel-
oping an education and outreach campaign,
refer to Chapter 6.
Steps in Developing a Solid
Waste Management Plan
Solid waste management planning is specific
to each tribe. The lack of technical or finan-
cial resources needed to develop a solid
waste management plan can be a drawback
for many tribes. Available resources can vary
greatly from one tribe to another—every
tribe comes into the planning process at a
different place. Some tribes have access to
landfills but are considering implementing
source reduction and recycling programs to
reduce disposal costs. Others need to close
open dumps, which often requires imple-
menting new waste management practices
such as finding an appropriate facility for dis-
carding waste before the dump can be closed.
The following steps outline the general
process required to develop your solid waste
management plan. As you go through this
process, remember to stay focused on your
goals. You might wish to revisit and modify
your goals as you develop a better under-
standing of your situation.
Step 1: Develop a Profile of the
Planning Area.
Compile information on the population,
number of households, and estimated growth
rate of your tribe. This can include informa-
tion on any planned economic development.
The tribe can use this information to esti-
mate the present and future waste stream.
Information on climate, geology, and natural
resources also is important to have when you
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are siting waste handling facilities.
Identifying transportation routes, distances
to potential recycling markets, distance to
solid waste (Subtitle D) landfills and other
disposal sites, and infrastructure needs will
help you when you are developing cost esti-
mates for waste management activities. The
Hannahville Indian Reservation in northern
Michigan, for example, is composed of 13
separate parcels of land, so its plan identifies
the location of the parcels and their proximi-
ty to the nearest highway and landfill.
Step 2: Define the Solid Waste
Generators Within the Planning Area.
Examine all of the residential, commercial,
and municipal solid waste (MSW) genera-
tors in your planning area (e.g., homes, tribal
government buildings, schools, restaurants,
casinos, health care facilities). Also, deter-
mine whether you will have to handle solid
waste from illegal dumping sites. The St.
Regis Mohawk Tribe in New York identified
100 businesses in the community. Time con-
straints limited the number of waste audits
the tribe could conduct, so the tribe took a
representative approach—classifying busi-
nesses into different categories and selecting
10 percent of the businesses in each category
for a waste audit.
Step 3: Identify Existing Waste
Management Practices Within the
Planning Area.
Where is waste going now? Are individuals
or community organizations reusing or recy-
cling products or materials? Identify any sig-
nificant amounts of waste entering and
leaving the reservation. Don't forget to
include waste left from illegal dumping or lit-
ter. Many tribal members use burn barrels
and backyard dumps for waste disposal; your
community outreach program can help you
identify this portion of your waste stream.
Step 4: Conduct a Waste
Assessment/Waste Audit.
Characterizing the solid waste requiring man-
agement in your tribal community is the back-
bone of the whole planning process. The St.
Regis Mohawk Tribe in New York used vol-
ume-based estimates to determine the waste
generated by the residential and commercial
sectors. Using information from both the waste
collectors and generators, along with visual
inspections of waste materials, the tribe quanti-
fied the waste composition. Your tribe might
need to determine the quantity and composi-
tion of your waste to evaluate your options and
estimate their costs. Quantity information can
include both the weight and volume of your
waste, and a composition analysis can tell you
what products and materials make up your
waste stream. If incineration is an option, you
also will need to estimate the energy content of
your waste stream to ensure you are generating
sufficient waste for effective burning.
Information on your waste is collected through
a process called a waste stream analysis, dis-
cussed later in this chapter.
Step 5: Estimate Future Waste
Generation Quantities.
Estimate future waste quantities using the
projected growth information you gathered
in Step 1 for the established planning period.
These are the quantities that will be used to
size facilities and estimate long-term waste
management costs.
Step 6: Develop Waste Handling
Options.
Once you have a good picture of your cur-
rent situation, start looking at the waste
management options available. What per-
centage of discards can be prevented, reused,
reduced, or recycled? How will you dispose of
everything else? Does the tribe collect resi-
dents' discarded materials, or will members
have to take them to a transfer station or
disposal facility? A discussion of source
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Example of Estimating Future Waste Generation Quantities
The Makah Tribe of Indians in Neah Bay, Washington, had a population of 1,500 in 2002, with an estimated
population growth rate of 1.1 percent per year. The planning period is 20 years, and the waste generation
rate is 3.7 pounds per person per day (determined through an actual waste stream assessment by the tribe)
for the 20-year period.
To determine how much waste it would generate in 2002, the tribe made the following calculation:
Equation 1: (population) x (waste generation rate) x (number of days per year) •*• (number of pounds per
ton)
(1,500 people) x (3.7 Ibs/person • day) x (365 days/year) - 1 ton/2,000 Ibs = 1,013 tons/year
Rounding up, the tribe estimated it would generate approximately 1,020 tons of solid waste in 2002.
Based on a constant growth rate of 1.1 percent per year and using a simple compound interest equation,
the Makah Tribe's population will be approximately 1,866 in 2022
Equation 2: P(1 + r) T where: P = initial population = 1,500 people
r = percent growth rate/100= 1.1/100 or 0.011
T = years= 20 years
1,500(1 + 0.011 )20 = 1,866 people
Using Equation 1 again, the tribe calculate that these 1,866 people will generate 1,260 tons of waste during
the year.
(1,866 people) x (3.7 Ibs/person • day) x
(365 days/year) - 1 ton/2,000 Ibs =
1,260 tons/year
The easiest way to determine the total
amount of waste generated over this 20-
year period is to set up a spreadsheet,
similar to the one depicted in Figure 2,
that tracks the tribe's population and
waste generated increases year by year.
Summing the annual waste generated
amounts from 2003 through 2022 shows
that a total of 22,802 tons of waste will
be generated during this time period.
Using these projected waste quantities in
its planning process, the Makah Tribe
would know that a transfer station would
need to be large enough to accommo-
date the 1,260 tons of waste expected in
2022, while a landfill would need to be
large enough to hold the 22,802 tons
generated during this 20-year period.
Figure 2. Population and Waste Generation
Spreadsheet
Year Population Annual Waste
Generation (Tons)
2002 (base year)
2003 (year 1)
2004 (year 2)
2005 (year 3)
1,500
1,517
1,537
1,554
1,013
1,024
1,037
1,049
2020 (year 1 8)
2021 (year 19)
2022 (year 20)
20-year Total
1,830
1,847
1,866
—
1,235
1,247
1,260
22,802
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reduction, recycling, and composting is pre-
sented in Chapter 5. Waste collection and
disposal options are presented in Chapter 4.
Step 7: Identify Existing Regional
Programs or Infrastructure That the
Planning Area Might Use.
When evaluating the potential benefits of
developing or participating in regional pro-
grams, the following questions should be
answered: Where is the closest permitted
landfill? Do other tribes in your region
export their waste? Is there an opportunity to
combine your efforts and share certain
resources? What types of collection and dis-
posal programs does the county or state cur-
rently run? Does the county or state hold
annual household hazardous waste collection
events near your tribe?
Planners and managers involved in solid
waste management usually find that it is ben-
eficial to participate in regional solid waste
advisory committees or work groups to gain
an understanding of how others are dealing
with their challenges. Often, tribes involved
in regional partnerships can use their
increased size and associated bargaining power
to gain economic advantages. In the Prince
William Sound regions of Alaska, for exam-
ple, seven Native villages and two Alaska
Native Claims Settlement Act corporations
have formed the Nunagpet/Chugachmiut
Environmental Consortium. This coalition
covers all aspects of environmental protection
for the region, supporting solid waste manage-
ment and recycling efforts. Most recycling
revenue is used to cover transportation costs;
it takes the commitment of the member vil-
lages to keep the program viable.
Step 8: Develop Costs for Waste
Handling Options.
Once a tribe has compiled information on
the quantity and composition of its waste
stream, planners and managers can develop
options and associated costs for solid waste
handling and disposal. Cost estimates should
include both capital costs and operation and
maintenance costs for the facilities for each
option. Capital costs include costs to design
and construct new facilities and purchase
equipment. Operation and maintenance
costs are those necessary for the day-to-day
operation of the solid waste management sys-
tem and include employee salaries, employee
benefits, utility costs, equipment fuel, equip-
ment maintenance, and other expenses relat-
ed to handling and disposing of the materials
in the waste stream.
Step 9: Compare Options Based on
Criteria Defined by the Tribe.
Look to your goals to help you develop the
criteria for comparing options, and prioritize
your criteria. Some common criteria include:
• Environmental impacts
• Relative cost
• Potential to create jobs in the tribe
• Operation and maintenance challenges
• Regulatory requirements
• Degree of tribal control
• Cost of closure, post-closure care, and
financial assurance for municipal landfills
The Metlakatla Indian Community, a com-
munity of 1,600 residents located on the
Annette Islands Reserve in southeast Alaska,
developed a solid waste management plan in
1999 with funding from an EPA grant. The
community had to address many of the issues
faced by tribes today, including its remote
location, open dumping, lack of infrastruc-
ture, and competing environmental con-
cerns. The plan includes the results of a
waste stream analysis, a discussion of solid
waste management options and costs, and a
list of the criteria used to evaluate sites for
waste handling facilities.
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When and How To Use a Consultant
Most tribes and Alaskan Native villages have found that they do not need a consultant to develop their solid
waste management plans. Tribes and Native villages already possess or are able to obtain most of the infor-
mation needed for developing a plan. Additional information and resources are available to tribes and
Native villages free of charge through federal agencies such as EPA, other tribes and villages, tribal and
regional associations, or state environmental agencies.
Some tribes and villages have hired consultants to help them develop solid waste management plans. These
consultants helped organize the planning process, provided technical assistance, facilitated planning ses-
sions, and in some cases, wrote the plan. While consultants often do have expertise in developing plans in
general, they still do not have as much expertise and knowledge of your tribe or village as a tribal member
does. The consensus among many tribes and Alaskan Native villages is that tribes and villages possess
enough expertise and knowledge and have access to enough free resources to develop a basic solid waste
management plan without hiring outside consultants.
When the time comes to implement your solid waste management plan, you might find that obtaining the
help of a consultant is necessary. Designing and building a landfill, transfer station, or recycling center, for
example, will require the expertise of a trained and certified engineer. If your tribe or village does not have
this expertise in-house, hiring a consultant is one method of obtaining it. Contacting IMS or your state envi-
ronmental agency and asking the agency to provide an engineer is another potential option.
To find a qualified consultant, contact your regional EPA office, IMS, or the Bureau of Indian Affairs (BIA).
These agencies can usually provide the names of several consultants that offer professional engineering and
consulting services to tribes. Another place to look is in tribal newspapers and publications, such Indian
Times, Indian Country Today, or American Indian Report. You can also check with other tribes and villages to
ask for references and recommendations for consultants they have worked with in the past.
Before hiring a consultant, ask for a statement of qualifications and references from former clients. If it is a
large project, or if it is being performed through an EPA grant, a formal award process might be necessary.
This involves fully describing your technical need, advertising the requirement, and requesting and reviewing
several consultants' technical and cost proposals. These need to specifically state what, where, when, and
how the work will be done. The technical proposal needs to address past performance, including references
from clients. Always check their references.
The Alaska Native Health Board's (ANHB) Solid Waste Management & Planning for Rural Communities in
Alaska provides helpful tips on using consultants effectively while maintaining control over your solid waste
management decisions. Some of these tips include:
Only ask a consultant to prepare parts of your solid waste management plan that no one else in your
community or agency can do for you, or to provide technical/engineering expertise that you can not
provide internally.
Have a get-acquainted meeting. Make sure the consultant understands your needs and exactly what you
want.
Encourage the consultant to ask questions about your community; this will ensure that you receive a
plan or design that meets your tribe or village's specific needs and situation.
Ask your consultant for suggestions, and carefully weigh the advice. Accept advice, not direction.
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Conducting a Waste Stream
Analysis
"Know your waste stream. A waste assessment
provides information about potential recycling
opportunities and helps you choose a transfer
station design."
-Calvin Murphy,
Eastern Band of Cherokee Indians
As discussed in Step 4, conducting a waste
stream analysis or audit will lay the founda-
tion for your planning process. A waste
stream analysis helps estimate the amount of
solid waste generated within a planning area.
The process involves compiling reliable
information on the types and quantities of
solid waste being generated. The weight or
volume of materials and products that enter
the waste stream are measured before any
recycling, composting, burning, or landfilling
takes place. For example, in 2001 the U.S.
waste generation rate was 4.4 pounds of dis-
cards per person per day. In rural areas, how-
ever, the generation rate is commonly lower.
The St. Regis Mohawk Tribe, for example,
determined its waste generation rate to be
1.5 pounds per person per day. Conversely,
Alaskan Native villages tend to be above the
national average. According the Alaskan
Native Health Board's Solid Waste
Management & Planning for Rural
Communities in Alaska, the average Alaskan
generates 6 pounds of waste per day. The
Tribal Association of Solid Waste and
Emergency Response (TASWER) and the
Solid Waste Association of North America's
(SWANA) joint training course guide,
Developing and Implementing Integrated Solid
Waste Management Systems for Tribal Nations,
provides several approaches to estimating
tribal waste generation rates.
A waste stream analysis will give you the
information you need to answer questions
such as: How much of your waste can be
recycled? and, What percentage will require
disposal? It gives your tribe the data it needs
to develop an effective solid waste manage-
ment plan.
Purpose and Outcome of a Waste
Stream Analysis
What solid waste management goals has your
tribe developed during the planning process?
A tribe's goals dictate the information and
accuracy needed in a waste stream analysis.
A tribe that is interested in the economic
benefits of recycling might want to deter-
mine the quantities of higher-valued materi-
als (such as aluminum cans) it generates. On
the other hand, a tribe that is interested in
preserving landfill space might need to know
the quantities of all materials it generates
that it can reduce. Source reduction and
landfill projects require knowledge of gross
waste volumes. Recycling and waste-to-ener-
gy programs require knowledge of the quanti-
ty and composition of wastes, not only for
value of the material, but also for sizing stor-
age and handling areas.
The Eastern Band of Cherokee Indians in
North Carolina conducted a weight-based
waste assessment. The tribe's Public Utilities
Department randomly selected 212 houses
and several businesses to participate in the
study. Department staff visited each partici-
pant to obtain consent and explain study
procedures. For a specified period of time,
participants placed all of their solid waste and
recyclable materials in special garbage bags.
At the end of the study period, department
staff collected the bags and separated the
waste by hand, weighing paper, food scraps,
and glass separately. The tribe used the waste
assessment data to estimate its waste genera-
tion rates and identify recycling opportuni-
ties. For example, the study revealed that
homes and businesses generate large quanti-
ties of cardboard. The tribe found a market to
sell its recovered cardboard to make money
-------
to support other, less profitable,
recycling activities.
Methods of Conducting
Waste Stream Analysis
Two basic approaches a tribe can
use to analyze its waste stream are
1) desktop estimates and 2) field
surveys. The desktop estimate
uses existing data to quantify the
amount of waste generated. A
desktop estimate will provide a
first-cut estimate. Existing data
can come from your state, or a
nearby county, city, or tribe. Table
1 provides the average densities of
common waste categories that
might also prove useful in making
initial estimates. Many tribes use
the EPA national generation rate
and characterization data for their
first-cut estimate. Visit the EPA
Web page for the most current
update of Municipal Solid Waste In
the United States: Facts and
Figures. Keep in mind, however,
that tribes and other communities
in rural areas often generate less
waste per capita than the amount
reflected in EPA's numbers. For
example, for 2001, EPA reports
the per capita waste generation
rate to be 4.4 pounds per person
per day, while the Makah Tribe of
Indians, referenced earlier in this
chapter reported a rate of 3.7
pounds per person per day in
waste generation. Conducting a
field survey will provide you with
more tribal-specific data.
Desktop estimates can use an
average generation rate or a more
sector-specific generation rate.
Both approaches use generation
rate (pounds per person per day)
multiplied by population (number
Table 1. Average Waste Densities
Waste Type
Density of uncompacted
waste (pounds/yard3)
General household waste (organic and
inorganic wastes including food wastes,
paper, cardboard, plastics, textiles, rubber,
leather, wood, aluminum, tin, other metal,
glass, dirt, and ashes)
Uncompacted
Compacted
Large metal scrap (depending on
metal type)
Mixed wood, plastic, metal waste
Miscellaneous plastics
Commercial waste
(uncompacted)
Special wastes
Tires (non-shredded)
Furniture (large, e.g., couches, armchairs)
Refrigerator
Other appliances (white goods)
Automobiles
Yard and agricultural wastes
Yard trimmings (e.g., tree
trimmings, brush, leaves)
Grass clippings
Agricultural wastes (mixed)
Dead animals
Fruit or vegetable waste
Construction and Demolition Debris
Wood (unstacked)
Broken concrete
Mixed construction
Mixed demolition
(non-combustible)
Mixed demolition
(combustible)
150-300
500-1,000
750-3,000
150-300
70-120
300-600
45-110
75-400
160-280
230-340
1,000-5,000 Ibs/vehicle
100-300
500-1,000
675-1265
605
605
180-350 (well stacked
wood is 2 to 4 times larger)
2,020-3,035
305-605
1,685-2,695
505-675
Source: TASWER and SWANA. Developing and Implementing Integrated Solid Waste
Management Systems for Tribes. Spring 2003, pp. 41 & 66.
-------
of residents or employees). Using generation
rates from a community of similar size will
improve the reliability of the estimate. The
sector estimate uses generation rates for differ-
ent generators, then combines the data to
derive the total generation rate. EPA's Waste
Prevention, Recycling, and Composting Options:
Lessons from 30 Communities lists waste gener-
ation rates for 30 urban, suburban, and rural
communities discussed in the report. Your
tribe might be able to use one of these genera-
tion rates from a similar size community for a
desktop estimate.
The Spokane Tribe of Indians in
Washington state used desktop methods to
estimate its volume and tonnage of waste.
The Tribal Solid Waste Program did not
keep track of the waste managed through its
collection and landfill services. The tribe
derived estimates using a combination of
state-wide averages, observations by the col-
lection employee, billing records for com-
mercial accounts, and general demographic
data. The tribe developed separate estimates
for the waste stream from the collection
service, the commercial accounts, and the
commercial accounts not serviced by collec-
tion. Then they combined these three esti-
mates for a reservation-wide estimate.
Field surveys can help you obtain a more
accurate measure of your waste stream.
Three tasks are required to develop reliable
data—planning, execution, and data analy-
sis. The importance of planning cannot be
overemphasized. Planning considerations
include determining what type and how
much waste is generated in the area and
what equipment and personnel are available,
and calculating bias factors.
Several approaches are available for execut-
ing the field survey. One is a field weighing
program, where tribal staff or contractors
weigh all vehicles entering the landfill, or a
randomly selected subset. The other is a field
composition study, where tribal staff deter-
mines the composition of the waste stream
by sorting and weighing individual compo-
nents. A brief overview of the steps to per-
form a field waste sort follows:
1. Obtain a guide on how to perform a field
waste sort and talk to other tribes that
have performed a waste sort.
2. Decide whether you want to conduct the
waste sort in-house, using tribal staff, or
whether you want to hire an outside
contractor.
3. Define the waste categories to be sam-
pled. Based on your tribal community's
goals, select the components you will use
for the field sampling.
4. Select containers for the waste compo-
nents. Make sure containers are of a
manageable size for weighing. A 55-gal-
lon container filled with glass can weigh
between 200 and 500 pounds. The size
and weight capacity of the scale you will
be using also will influence your con-
tainer choices.
5. Determine the number of samples and
the physical sizes of the samples.
Consider the following factors: the con-
sistency of the waste stream, the amount
of solid waste delivered to a facility by
the different generators, and the number
of vehicles delivering solid waste to the
facility each day. Sampling 10 percent of
the vehicles using the facility (daily or
weekly) is a good guide.
6. Arrange for a crew and set up the equip-
ment.
7. Sort and weigh the waste, recording
weight on category forms.
8. Compile and analyze the data.
Estimating Composition and Quantity of Solid
Waste Generation, by the National
Environmental Training Center for Small
Communities, provides technical guidance
-------
for performing a waste stream analysis. The
guide has worksheets and checklists for both
desktop and field surveys. For a less technical
approach, consult Counting Your Community's
Trash. This two-page fact sheet provides an
overview for small communities on how to
calculate the materials in the residential
waste stream.
The St. Regis Mohawk Tribe Environment
Division's Solid Waste Handbook provides
examples of two different approaches to field
surveys. Appendix B of the Solid Waste
Handbook describes in detail how the St.
Regis Mohawk Tribe performed a volume
based waste audit, while the Eastern Band of
Cherokee Indians in North Carolina per-
formed a weighted-based audit. The Solid
Waste Handbook also provides a link to a
waste audit manual.
Potential Bias Factors
Accounting for potential bias factors that
can affect the estimates of waste generation
rates is important. Seasonal variations
account for most of the potential bias. The
quantity of waste generated in any area will
vary from month to month. Lack of yard
trimmings in the winter months reduces the
amount of residential waste. Retail wastes
are higher during peak sales periods like
Christmas. School-related wastes decrease
during the summer. Tourism causes varia-
tions in population and types of waste,
which impacts waste generation. Work force
fluctuations affect population and also waste
types and quantities generated. Subsistence
activities can generate specific types of waste
only at certain times of the year.
To help control potential bias factors caused
by the increased population during tourist
season, the Eastern Band of Cherokee
Indians, for example, conducted its waste sort
twice, once during the height of tourism sea-
son and once during the tourism low point.
The St. Regis Mohawk Tribe collecting waste as a part of its waste stream
analysis.
Chapter Highlights
• Prepare a solid waste management plan
as the first step in developing a solid
waste management program. It is the
foundation upon which you will build
your tribe or village's program.
• Use your solid waste management plan
to define, prioritize, and focus your tribe
or village's solid waste management
goals.
• Conduct a waste stream analysis to
understand the types and amounts of
waste your tribe or village generates.
• Complete your solid waste management
plan before applying for federal solid
waste grants. Many grant programs place
a premium on having a solid waste man-
agement plan—for a few it is even a pre-
requisite.
• Revisit and update your solid waste man-
agement plan as your program develops
and as your tribe or village's solid waste-
related goals change.
-------
Resources
EPA's Decision-Maker's Guide to Solid Waste
Management, Second Edition (EPA530-R-95-
023), available on EPA's Web site at
or by contacting the RCRA Call
Center at 800 424-9346.
EPA's Solid Waste Management: A Local
Chalknge with Global Impacts (EPA530-F-02-
026), available on EPA's Web site at
or by contacting the RCRA
Call Center at 800 424-9346.
EPA's Waste Prevention, Recycling, and
Composting Options: Lessons from 30
Communities (EPA530- R-92-015), available
on EPA's Web site at
or by contacting the RCRA Call Center at
800 424-9346.
Estimating Composition and Quantity of Solid
Waste Generation, by the National
Environmental Training Center for Small
Communities. Available by calling 800 624-
8301 or through the Center at .
Counting Your Community's Trash, available
on the Web at .
St. Regis Mohawk Tribe-Environment
Division's Soiid Waste Handbook available at
.
Developing and Implementing Integrated Solid
Waste Management Systems for Tribal Nations:
A Training Course Prepared by the Tribal
Association for Solid Waste and Emergency
Response (TASWER) and the Solid Waste
Association of North America (SWANA),
Spring 2003. Contact TASWER
or SWANA
for more information.
Soiid Waste Management & Planning for Rural
Communities in Alaska: Community Resource
Guide & Planning Workbook, Draft 2003. By
the Alaskan Native Health Board. Contact
your ANHB contact for more information.
7 Generations: Addressing Village
Environmental Issues for the Future
Generations of Rural Alaska, March 1999,
available on the Web at .
Regular updates of Municipal Solid Waste In
the United States: Facts and Figures, available
on EPA's Web site at .
Soiid Waste Disposal Facility Criteria
(EPA530-R-93-017), November 1993, avail-
able on EPA's Web site at or by contacting the
RCRA Call Center at 800 424-9346.
Sample Solid Waste Management Plans
The Inter Tribal Council of Arizona, Inc.,
Model Tribal Solid Waste Management Code,
available on the Web at , includes
information on how the tribe developed its
solid waste management plan.
Solid Waste Management Plan for the
Hannahville Indian Community, available
on the Web at .
Description of the Metlakatla Community
Integrated Waste Management Plan, avail-
able on the Web at
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Chapter 3. Developing,
Implementing, and Enforcing
Solid Waste Codes, Laws, and
Regulations
A number of tribes and Alaskan
Native villages have adopted codes,
laws, or regulations to address solid
waste management issues. Some have well-
established regulatory programs they are
actively implementing and enforcing. The
majority of tribes, however, currently have
no, or very limited, formal solid waste regula-
tions. Most tribes are aware of the value of
solid waste management codes, laws, and
regulations but have lacked the financial
resources to develop and implement them.
Today, many tribes are at the point of con-
sidering whether developing a solid waste
regulatory program is a feasible or desirable
approach for addressing their waste manage-
ment needs.
Your tribe or village might want to develop
solid waste management codes, ordinances,
or regulations for a number of reasons. These
might include promoting tribal waste man-
agement goals, protecting public health and
the environment, or protecting natural
resources. Solid waste codes are a formal
legal method of promoting or preventing
behaviors, such as recycling or open dump-
ing respectively. One thing to consider when
developing your codes is if voluntary waste
management standards are sufficient to meet
your tribe's needs, or if formal regulations are
necessary. Also, consider which waste man-
agement issues will always need a code, such
as preventing open dumping, and which
issues might change over time, such as recy-
cling standards.
In contrast to many federal and state waste
management programs, many tribes rely pri-
marily on non-regulatory measures and use
regulatory measures as a last resort. This chap-
ter can help you determine whether a regula-
tory, non-regulatory, or combination approach
will best meet your solid waste management
needs. Because many tribes are still in the
process of considering whether to develop
solid waste codes and regulations, the empha-
sis of this chapter is on these early stages.
Establishing a tribal solid waste regulatory
program typically involves three main steps:
1) code development, 2) implementation,
and 3) enforcement. This chapter addresses
each of these steps and suggests issues to
consider at each stage.
Examples of language from several tribes'
solid waste codes are interspersed throughout
this chapter. Complete reference and order-
ing information for these and additional trib-
al codes, model code templates, and other
guidance documents are included in the
Resources section at the end of this chapter.
-------
Developing a Solid Waste
Management Code
When developing a solid waste management
code, you might identify the need for a regu-
latory program, define the scope of regula-
tions, and draft the regulations. Some tribes
have the resources to develop a comprehen-
sive solid waste code. If your tribe is limited
by funding, staffing, or time and is unable to
develop and adopt comprehensive solid
waste regulations, developing codes or regu-
lations that address a single priority issue, or
a few select issues, might be a more viable
approach. The number, complexity, and
importance of waste management issues can
differ significantly among tribes, and there-
fore the approach taken in developing a reg-
ulatory program will vary from tribe to tribe.
Identifying and Prioritizing Waste
Management Issues
The first step in determining the type of regu-
latory approach that best meets your needs is
identifying and prioritizing your tribe's waste
management issues. The tribal community,
staff, and governing body all can help identify
and prioritize key issues. Government officials
and residents in surrounding jurisdictions that
share common waste management concerns
also might be involved. Although specific
issues and priorities are likely to differ among
tribes and Alaskan Native villages, they share
a number of waste management concerns,
including:
• Open dumping
• Cleanup and closure of open dumps
• Open burning
• Abandoned vehicles and vehicle-related
wastes
• Abandoned large appliances/white goods
• Construction and demolition waste
• Facility siting and permitting
Open Dumping
Open dumping refers to the depositing of
solid waste anywhere (on land or in water)
other than an approved solid waste facility.
This practice is one of the most prevalent
waste management concerns for tribes, and
most tribal solid waste codes include a prohi-
bition against open (or "wildcat") dumping.
Open dumps can leak hazardous leachate
into the groundwater and streams, contami-
nating drinking water supplies or negatively
affecting commercial or subsistence fishing.
In areas with high amounts of rainfall, this
leaching process can happen quickly. Also,
open dumps attract scavenging wild animals
and insects that spread disease.
To address the problem of open dumping on
tribal lands, the Fallon Paiute-Shoshone
Tribe of Nevada adopted an Open Dump
Ordinance, with the following purpose:
"The tribe is enacting this ordinance to provide a
process and standards for the prevention of open
dumps within tribal lands or adjacent bound-
aries. The tribe is compelled to act because of
the threat open dumps pose to the environment,
health, safety, and economic security of the tribe
and its members. In particular, open dumps
present a significant threat to the quality of
groundwater and surface water resources. In
order to protect the tribe's limited natural
resources, the tribe is required to address the
threat posed by open dumps through the exercise
of its inherent sovereign power and constitutional
authority to protect and preserve the tribal
health, safety, welfare, customs and traditions,
lands and environment."
Cleanup and Closure of Open Dumps
Even when a tribe eliminates open dumping,
the wastes that remain at historic open dump
sites can continue to adversely impact tribal
health and resources. To prevent this, your
tribe can develop a solid waste management
regulation that addresses environmental
-------
standards for cleaning up and closing an
open dump site.
A Waste Management Ordinance adopted
by the Metlakatla Indian Community in
Alaska directed the community's
Environmental Office to develop regulations
for cleanup and closure of open dumps, ille-
gal disposal sites, and other contaminated
sites on the Annette Islands Reserve in
Southeast Alaska. The Metlakatla Indian
Community Council subsequently developed
and approved these regulations, which serve
as the basis for ongoing cleanups conducted
by various federal agencies.
Open Burning
Open burning refers to the burning of solid
wastes in a simple container or pile. In some
areas, waste burning occurs at relatively
large open dump sites, and in other areas it
occurs on a much smaller scale, such as in
backyard burn barrels. Some tribal codes
include a prohibition on all open burning,
while others allow open burning of specific
wastes, such as yard trimmings, agricultural
waste, or wood construction debris. Open
burning of solid waste at municipal solid
waste management facilities is prohibited by
the Resource Conservation and Recovery
Act (RCRA) (see 40 CFR Parts 258.24(b)
and 257.3-1) except in limited cases. Many
states and counties prohibit the burning of
household trash on private property as well.
Open burning increases community exposure
to pollutants that can have an adverse
impact on human health and the environ-
ment. Smoke from open burning can exacer-
bate existing respiratory conditions, such as
asthma and emphysema. Children, the elder-
ly, and individuals with other preexisting res-
piratory conditions are especially vulnerable
to these effects. Open burning also can
spread toxins throughout the atmosphere,
onto land and water and into the food chain.
Hazardous pollutants released by open burn-
£'f^*"" ^^•jtiSTiii " «™^™-~
«gn «*3J__4t 'IwlHHBSBr- > "*" " <""
Before and after photographs of an illegal dump on the White Earth Band of
Chippewa's land.
ing of waste include dioxins, particulate mat-
ter (fine particles), lead, mercury, sulfur
dioxide, nitrous oxides, and hexachloroben-
zene and other volatile organic compounds
(VOCs) (many of which are known carcino-
gens). Because the remaining ash can con-
tain dangerous levels of toxic metals such as
mercury, lead, arsenic, and chromium, care
should be taken in disposing of the ash.
The Walker River Paiute Tribe in Nevada
drafted a Solid Waste Burning Prohibition
-------
Backyard burning of
household waste in
burn barrels is a prob-
lem nationwide, not
just in Indian country.
Ordinance to address the problem of burning
solid waste in open dumps and at other sites
within the exterior boundaries of the Walker
River Indian Reservation. The tribe deemed
development of this ordinance necessary
"because of the particular threat the burning
of solid waste poses to the environment, eco-
nomic security, health, and welfare of the
Walker River Paiute Tribe, its members, and
all residents of the reservation," and also
because "burning solid waste in the open
dumps and at other sites located on the reser-
vation presents a significant threat to the
quality of the air resource on the reservation."
Abandoned Vehicles and Vehicle-
Wastes
Abandoned vehicles and vehicle parts are
such a prevalent waste management concern
for many tribes that they are specifically
included in the definition of solid waste in
many tribal codes, as well as in some state
and municipal codes. In addition to the
vehicles themselves, vehicle-related wastes
(including tires, batteries, used oil, and
antifreeze) might be a concern.
Most of the health and environmental haz-
ards related to tire disposal are caused by
long-standing stockpiles of tires. Air pockets
in tires provide convenient habitats for
rodents. They also hold water, which pro-
vides an ideal breeding ground for mosqui-
toes that transmit infectious diseases.
Stockpiled tires also pose fire hazards.
Burning stockpiles are difficult to extinguish,
because air pockets trap oxygen that feeds
the flames. When they burn, tires emit a
noxious black smoke. The remaining oils
Abandoned vehicle and parts in Kokhanok Village (Alaska).
22
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and soot can run off and contaminate
groundwater.
The Open Dump Ordinance adopted by the
Fallon Paiute-Shoshone Tribe in Nevada
expressly prohibits the dumping of "used
motor vehicle tires, motor vehicle batteries,
motor vehicle oils or fluids." The Cheyenne
River Sioux Tribe, located in South Dakota,
has established specific service fees for col-
lecting and disposing of automobiles, pickup
trucks, utility trailers, and trucks according
to a fee schedule in the tribe's Solid Waste
Ordinance.
Abandoned Large Appliances/White
Goods
Your tribe might find it needs codes or regu-
lations to address disposal of large appliances
and white goods. If not disposed of properly,
large appliances can easily become eyesores
in your community. The Stockbridge-
Munsee Nation of the Mohican Band in
Wisconsin has a Tribal Solid Waste
Management Ordinance that specifically
states that discarded appliances are not
accepted for collecting, and their disposal is
the responsibility of the owners. Other
tribes, such as the Eastern Band of Cherokee
Indians and Jicarilla Apache Nation accept
white goods at their transfer stations for
scrap metal recycling.
Construction and Demolition Debris
Several tribes have experienced difficulties
in managing construction and demolition
(C&D) debris. The size and weight of these
wastes makes their disposal with normal
household waste very expensive. Since C&D
debris typically contains inert materials such
as concrete, brick, asphalt, and non-haz-
ardous materials such as wood, sheetrock, or
plaster, it can be disposed in special C&D, or
inert waste, landfills. Since these landfills
typically do not need to be lined, tipping
fees are much lower than at a Subtitle D-
White goods recycling pile at the Kokhanok Village (Alaska) landfill.
compliant landfill. Several tribes have estab-
lished management standards, either formal-
ly through codes or informally through other
policy mechanisms, to manage C&D debris
separately.
The Assiniboine and Sioux Nations of the
Fort Peck Reservation in Montana, for
example, were having troubles with private
contractors filling up roll-off containers at
their five household waste drop-off sites. Fort
Peck's Operations and Maintenance (O&M)
Department was stuck paying high tipping
fees at a municipal landfill to dispose of this
C&D debris. Going through its Public
Works Committee Board, O&M received
authorization to manage C&D debris sepa-
rately in designated containers and request
that contractors rent dumpsters directly from
O&M. Separating its C&D debris from its
municipal waste allowed O&M to ship the
C&D debris to a C&D landfill with much
lower tipping fees.
Facility Siting and Permitting
Some tribes choose to locate solid waste
facilities, such as landfills or transfer stations,
on tribal lands. When appropriate, tribal reg-
ulations might include criteria for siting, per-
mitting, and operating these facilities. An
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ordinance adopted by the Cheyenne River
Sioux Tribe in South Dakota designates the
Cheyenne River Sanitary Landfill for tempo-
rary or permanent disposal of garbage and
waste materials in the community of Eagle
Butte. Additionally, the Rosebud Sioux Tribe
of South Dakota has adopted landfill loca-
tion, design, and operation standards as part
of its Solid Waste Code.
After you have identified and prioritized the
important waste management issues for your
tribe, you will need to decide whether you
want to address any or all of these issues
through codes or regulations. Involving trib-
al members at this stage is critical to ensur-
ing that the issues identified as needing some
form of regulation are truly the issues impor-
tant to the tribe.
Public involvement at this step also will help
you understand how a regulatory program
will potentially affect and benefit tribal
members. Tribal members are much more
likely to respect and follow tribal ordinances
when the tribe has gone through an open
and fair adoption process. Tribal members'
involvement at this stage also will help staff
draft regulations that are consistent with and
promote tribal cultural values and traditions.
Ensuring Consistency and Coordination
with Federal Regulatory Programs
Tribal governments, as well as the federal gov-
ernment, are responsible for regulating the
environment and protecting the health, wel-
fare, and resources of tribal members on reser-
vations and other tribal lands. In carrying out
these responsibilities, some tribes have devel-
oped waste management regulations as a part
of their inherent sovereign authority. Once
you identify and prioritize your tribe's waste
management issues, you can identify what fed-
eral regulatory programs are already in effect to
address your tribe's waste management con-
cerns and how developing tribal regulations
can build upon those existing programs.
The primary federal law governing solid
waste is the Resource Conservation and
Recovery Act (RCRA). Enacted by
Congress in 1976, RCRA's main goals are to
protect human health and the environment
from the potential hazards of waste disposal,
conserve energy and natural resources,
reduce the amount of waste generated, and
ensure that wastes are managed in an envi-
ronmentally sound manner. One approach to
developing your solid waste regulations is to
write them in a manner that is consistent
and coordinates with federal regulations.
The Lac du Flambeau Tribe of Wisconsin, for
example, uses compliance with the federal
RCRA regulations as a requirement for
issuance of a solid waste facility permit under
its Solid Waste Code.
Another approach to developing your solid
waste codes and regulations is to write them
so that they are consistent with your tribe's
culture. The St. Regis Mohawk Tribe in New
York wrote its solid waste codes from the
tribe's cultural perspective to help tribal
members better understand and relate to the
issues. For example, the St. Regis Mohawk
Tribe's Solid Waste Management Code uses
education as its first and primary enforce-
ment tool, resorting to fines or penalties only
as a last recourse.
Waste management practices that directly or
indirectly impact groundwater, surface water,
and air resources on tribal lands also can be
subject to federal regulatory requirements. In
addition to a tribe's inherent regulatory
authority, certain federal regulatory programs,
including the Clean Water Act, the Clean
Air Act, and the Safe Drinking Water Act
also are applicable to tribes. Until tribes apply
for and are authorized to operate a regulatory
program under these statutes, EPA is responsi-
ble for implementing federal regulations on
tribal lands. Whether or not your tribe pur-
sues authorization under any of these regula-
tory programs, opportunities exist for your
tribe to receive financial assistance, technical
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Descriptions of major federal environ-
mental regulations can be found in the
glossary of this guide.
assistance, or cooperative enforcement that
can help you in your efforts to address impacts
from waste management. For more informa-
tion on financing your waste management
program, refer to Chapter 7.
Drafting Tribal Codes
Although tribal regulations differ significant-
ly from one another in their scope and com-
plexity, they generally include the following
elements:
• Purpose and Scope
The purpose and scope of the codes typi-
cally discuss why the tribe developed the
regulations, who is subject to the regula-
tions, where the regulations apply, and
what activities are covered by the regu-
lations.
• Definitions
This section of the code will define
terms that are important in understand-
ing, implementing, and enforcing the
regulations.
• Program Requirements, Procedures, or
Standards
Program requirements, procedures, and
standards typically describe how the
tribe will carry out regulations and might
include waste management procedures,
permitting and operating requirements,
and prohibitions.
• Enforcement
The enforcement section typically
includes a schedule of fees or penalties
for violating the requirements contained
in the regulations and might include
other enforcement mechanisms and
authorities.
• Administration
This element typically identifies the
responsibilities and procedures for imple-
menting, revising, and/or updating the
regulations.
The Rosebud Sioux Tribe of South Dakota
adopted a Solid Waste Code with the follow-
ing statement of purpose:
I. Provide environmental and health standards
for the collection and disposal of solid waste;
2. Prohibit future open dumping and littering
of waste on the reservation and eliminate
unhealthy, unsightly, and indiscriminate dis-
posal or placement of solid waste; and
3. Inform and educate persons living on the
reservation of the need to participate fully
in efforts to manage solid waste genera-
tion, transportation, and disposal on the
reservation.
The Fort McDowell Yavapai Community of
Arizona adopted a Waste Ordinance as part
of its Environmental Code for the following
purposes:
I. Promote the health and safety of tribal
members and all other persons within the
exterior boundaries of the nation and other
lands within the jurisdiction of the tribe;
2. Promote the cultural, social and economic
stability of residential, agricultural, com-
mercial, industrial, forest, riparian, and
environmentally sensitive lands within the
nation and other lands within the jurisdic-
tion of the tribe;
3. Contribute to the protection of the historical
and cultural values and traditions of the
tribe, the nation as a permanent tribal
homeland, and the aboriginal character of
the nation;
4 • Minimize air, water and land impacts from
solid and hazardous waste pollution, includ-
ing contamination of the tribe's aquifers,
-------
groundwater, surface waters, drinking water
supplies, and all other natural resources;
5. Enhance standard of living, quality of life,
welfare and well being of all persons within
the exterior boundaries of the nation and
other lands within the jurisdiction of the
tribe;
6. Provide and promote tribal environmental
protection and services within the nation,
and to regulate environmental activities
under principles of tribal sovereignty; and
7. Implement, regulate, and enforce environ-
mental standards and criteria, orders and
permit conditions, and laws and regulations
under the ordinance, for the sanitary stor-
age, collection, transportation, and disposal
of all solid waste within the exterior bound-
aries of the nation and other lands within
the jurisdiction of the tribe.
Implementing a Solid Waste
Management Code
Once your tribe drafts and adopts codes or
regulations, your next step is to implement
them. To effectively implement a regulatory
program, tribal members will need to under-
stand the specific requirements of the regula-
tions, as well as why it is important to follow
the regulations. They should understand the
benefits of compliance and the consequences
of non-compliance. For more information on
developing a tribal solid waste management
education and outreach strategy, refer to
Chapter 6.
The two areas of regulatory program imple-
mentation discussed in this section are:
• Supporting and sustaining the regulatory
program.
• Coordinating the regulatory program
with other, non-regulatory waste man-
agement efforts
Supporting and Sustaining a Regulatory
Program
Developing, implementing, and sustaining a
successful regulatory program requires not
only financial and technical resources, but
also might require approval from tribal mem-
bers. Coordination with local or state gov-
ernments often is important as well.
Financial Support
Determining how to adequately fund a long-
term regulatory program can be a major chal-
lenge for tribes. You might need to
determine if you will fund the program
through internal sources, such as by charging
user fees at solid waste facilities or by assess-
ing penalties for violating solid waste regula-
tions. Additionally, outside funding sources
might support and sustain the costs of pro-
gram development. You might use some
combination of funding sources to set up a
regulatory program that meets your tribe's
needs and goals over the long term.
Unfortunately, lack of adequate funding
often is the primary limiting factor in a
tribe's ability to develop and implement reg-
ulatory, as well as non-regulatory, waste man-
agement programs. Your tribe can consider
the anticipated cost of developing and
implementing regulations, and its ability to
support those costs, when determining the
best regulatory approach. Your tribe also will
need to consider the costs associated with
building or using a landfill, transfer station,
or other facility. For more information on
funding a solid waste management program,
refer to Chapter 7.
Technical Support
In addition to financial support, technical
support—including access to regulatory,
technological, and economic guidance—will
help your tribe develop, implement, and sus-
tain its regulatory program. Technical
resources are available via the Internet or
-------
other electronic formats (such as CD-ROM),
in hard copy, or through access to technical
assistance and expertise. Other potential
sources of technical support include federal,
state, or local agency staff; other tribes; tribal
organizations; consultants; or other waste
management organizations.
Tribes wanting to start up an integrated
waste management program should consider
three important elements of success: 1) rec-
ognizing their solid waste problems, 2)
obtaining public support, and 3) being open
to technical assistance from outside sources.
The Bois Forte Band of Chippewa in
Minnesota has successfully partnered with
local, state, and federal government agen-
cies, along with a nonprofit organization and
a local university, to restore and preserve the
tribal environment. In the early 1990s, EPA
released regulations requiring that tribes and
municipalities close all open dumps. The
Bois Forte Band of Chippewa, IHS, and BIA
set up a task force to determine the next
steps. Working with IHS and BIA, and with
money from a 3-year grant from EPA, the
Bois Forte Band developed and implemented
an aggressive solid waste management plan
that called for the closure of existing dumps,
development of waste management infra-
structure, and significant reductions in the
volume of the solid waste stream. To date,
the Boise Forte Band has built two transfer
stations and a demolition landfill and is
planning a composting facility.
Public Support
The ability to successfully develop and
implement waste management regulations
depends on the willing compliance of tribal
members. Even a well-funded regulatory pro-
gram might not be successful if it does not
receive support and approval from tribal
members. For this reason, you might consid-
er involving tribal members in all of the
development and implementation phases of
the regulatory program. Regulations are more
likely to have tribal support when their
development process is open and inclusive
and when everyone understands that their
purpose is to promote tribal goals and values
and to protect the health and resources of
the tribe.
As a part of its public outreach efforts, the
Solid Waste Department of the White
Mountain Apache Tribe of Arizona pro-
duced a brochure that includes excerpts from
the tribe's solid waste code, the curbside
pickup schedule, a hotline number for
reporting illegal dumping, a picture of an
illegal dump site, and a reminder list for
proper waste disposal. The department dis-
tributed a copy to each resident through the
reservation's post offices.
Intergovernmental Support
Waste management issues often are regional,
and successfully implementing a new tribal
regulation might require coordinating tribal
regulatory programs with other local, state,
or regional regulatory programs.
Coordinating a Regulatory Program
with Other Non-Regulatory Programs
Successful waste management efforts can
include both regulatory and non-regulatory
programs. Non-regulatory programs are based
on the idea that if tribal members under-
stand how to manage their waste and the
health and environmental impacts of
improper disposal, and if affordable options
are widely available, then they will manage
solid waste in a manner that protects tribal
health and resources.
Focused regulatory measures are important
tools that can help tribes when non-regula-
tory measures alone are not effective. To be
most effective and efficient, your tribe can
coordinate regulatory measures with non-
regulatory measures to the maximum extent
possible. Codes and regulations might focus
on identifying actions or practices that your
-------
tribe wants to strictly regulate or prohibit,
such as open dumping, open burning, or dis-
posal of hazardous wastes. Non-regulatory
programs can provide the means, incentives,
and options for meeting those requirements.
When developing codes and regulations,
consider how regulatory and non-regulatory
programs can complement each other. The
following examples illustrate how tribes can
set up complementary regulatory and non-
regulatory programs.
Recyc//ng
You can coordinate waste management regu-
lations with a recycling program by mandat-
ing certain practices, such as: separating
recyclables from waste to facilitate recycling
efforts; prohibiting disposal of certain recy-
clable materials; requiring businesses and
institutions to prepare recycling plans;
encouraging recycling through regulatory
initiatives such as buy recycled initiatives; or
setting a voluntary goals to reach a certain
recycling rate.
Composting
You can coordinate waste management regula-
tions with various voluntary composting
options. You can set prohibitions or limita-
tions on the disposal of certain waste materi-
als, such as yard trimmings, that can be
composted in available facilities.
Source Reduction
Some tribes have coordinated waste manage-
ment regulations with existing tribal solid
waste source reduction efforts. The Campo
Band of Mission Indians of California recog-
nized in the Campo Indian Reservation Solid
Waste Management Code of 1990 that:
"Methods of solid waste management
emphasizing source reduction, recovery, and
recycling of all solid waste are essential to
the long-range preservation of the health,
safety, and well being of the public, to the
economic productivity of the Campo Band
and the state of California, to the environ-
mental quality of the reservation and the
state of California, and to the conservation
of natural resources."
Public information can support source reduc-
tion efforts. These might focus on tribal gov-
ernment procurement and purchasing
requirements, promoting the use of recycled
paper or double-sided copying, or goals for
reducing generation of solid waste by a par-
ticular year.
Household Hazardous Waste Collection
You can coordinate regulations with non-
regulatory efforts to remove household haz-
ardous waste—including paint, batteries,
used oil, pesticides, and cleaning products—
from the waste stream.
The Metlakatla Indian Community of the
Annette Islands Reserve in Alaska adopted a
Waste Management Ordinance in 1999 that
requires safe disposal of household hazardous
waste. In conjunction with its regulatory
efforts, the community held a household haz-
ardous waste collection event designed to
attract as many residents as possible, to make
them aware of the new regulations, provide
advice on safe household hazardous waste
characterization and handling procedures,
identify non-hazardous substitutes for corn-
Household hazardous waste collection at the
Pueblo of Santa Clara's transfer station.
-j^j' „, -i „•;,•,;«:, ,'••.'fit".;
-------
mon hazardous household products, and
remove as much existing household hazardous
waste as possible from the waste stream.
The implementation provisions of many
existing tribal regulations include prohibi-
tions on certain activities, such as open
dumping or open burning of solid waste.
They also might include planning require-
ments, performance standards, design criteria,
identification of acceptable waste manage-
ment practices, and numerous other provi-
sions for implementing regulatory programs.
Though implementation provisions can vary
significantly depending on the scope, com-
plexity, and number of issues addressed, pro-
hibitions are among the most common
methods for implementing tribal regulations.
The Campo Band of Mission Indians of
California adopted a Solid Waste
Management Code in 1990 that includes the
following language prohibiting open dumping:
"In order to protect the limited land, air, and
water resources of the reservation from irre-
mediable hazardous pollution and to protect
the health, safety, and welfare of all residents
of the reservations and surrounding commu-
nities, disposal of solid waste in any open
dump is expressly prohibited within the
exterior boundaries of the reservation."
The Solid Waste Disposal Ordinance of the
Manzanita Tribe of Kumeyaay Indians in
California contains the following prohibitions:
a. No person shall dispose, release, discharge,
or conduct open dumping or open burning
of any solid waste on the Manzanita Indian
Reservation except as provided in this ordi-
nance.
b. No person shall generate, store, transfer,
transport, treat, discharge, release or dispose
of a hazardous waste through the conduct of
any business on the Manzanita Indian
Reservation, except as permitted under
RCRA and/or this ordinance.
c. No operator, owner, agent, or employee of
any business, industry or facility within the
exterior boundaries of the Manzanita Indian
Reservation shall dispose, or cause to be dis-
posed, any solid waste in the waste recepta-
cles of any other business, industry, facility
or residential premises.
The Open Dump Ordinance adopted by the
Fallon Paiute-Shoshone Tribe in Nevada
includes the following prohibition:
Pueblo of Santa Clara's hazardous waste storage area at its transfer station.
"No person shall
dump on any public
reservation lands the
following, which
includes, but is not
limited to, any rub-
bish, swill, refuse,
cans, bottles, paper,
vegetable matter, car-
cass of any dead ani-
mal, trash, used
motor vehicle tires,
motor vehicle batter-
ies, motor vehicle
oils or fluids, sewage,
-------
sludge, garbage or other toxic and hazardous
wastes."
Enforcing a Solid Waste
Management Code
Once you have developed and adopted codes
or regulations and implemented the regula-
tory program, you will need to enforce your
requirements. To be most effective, regulato-
ry enforcement should focus on the highest
priority issues. Identifying these issues will be
most effective if the public is involved.
Enforcement provisions in existing tribal
regulations vary widely. Following are a few
examples of these provisions.
The Gila River Indian Community (GRIG)
in Arizona designed an illegal dumping
enforcement program that combines partner-
ships with continual publicity to achieve
results. The community's Solid Waste
Ordinance allows law enforcement officials
to confiscate vehicles involved in illegal
dumping incidents and assess a fine. Vehicle
impoundment increases the chance that an
illegal dumper, whether or not he/she resides
on the reservation, will appear in court later.
Police, prosecutors, and judges established a
system to make the impoundment process
run smoothly. The community uses an out-
side company to impound vehicles.
GRIC's Department of Environmental
Quality (DEQ) supplied tribal rangers and
police officers with a map of dump sites to
target patrolling efforts. Gila River rangers
do their best to patrol reservation borders
and illegal dumping hot spots. They perform
routine patrols, conduct stakeouts at night,
and respond to illegal dumping reports from
residents. As a result, the community is hav-
ing more success catching and prosecuting
illegal dumpers. In one case, a waste material
pumper truck driver was caught discharging
waste into an irrigation canal next to the
Gila River. The driver received a citation for
trespassing on community land, and the
company received an illegal dumping cita-
tion. The company, DEQ, and the tribal
prosecutor reached a settlement in tribal
court under which the company had to clean
the contaminated soil and pay an $8,302
penalty to the community. DEQ developed a
press release on the case and distributed it to
local newspapers.
The Hannahville Indian Community in
Michigan has rules and regulations for solid
waste disposal that provide the following
enforcement provisions:
a. Under the direction of the Tribal Council
and the Health Board, the Solid Waste
Administrator (Health Administrator) and
all tribal law enforcement and conservation
enforcement personnel are empowered to
enforce these rules and regulations.
b. Actions for violations may be heard in tribal
court by conservation citation, summons
and complaint, or criminal warrant.
c. Violation of any provision of these rules and
regulations may be punished or remedied by
a civil fine or forfeiture not to exceed
$1,000. Each day of any continuing viola-
tion may be charged as a separate violation.
The Open Dump Ordinance adopted by the
Fallon Paiute-Shoshone Tribe in Nevada
includes the following provision for viola-
tions of tribal requirements:
If found guilty of any violations of this Ordinance
the Civil Penalties will be as foUows:
Accidental and Unintentional Acts:
A fine not to exceed $10,000 per day, plus
the costs of clean up to restore the site to its
near original state.
Intentional Acts:
First Offense:
A fine not to exceed $25,000 per day, plus
the costs of clean up to restore the site to its
near original state.
Second Offense:
-------
A fine not to exceed $50,000 per day, plus
the cost of clean-up to restore the site to its
near original state, plus imprisonment for a
minimum I-year term.
Chapter Highlights
• Develop and tailor a regulatory approach
to solid waste that meets your tribe or
village's specific needs.
• Identify which portions of your solid
waste program require codes and what
the scope of these codes should be (i.e.,
comprehensive versus targeted).
• Educate community members on the
purpose and meaning of your solid waste
codes. Understanding leads to accept-
ance and compliance.
• Enforce your codes consistently and
equitably. Regulations are only as effec-
tive as their enforcement.
• Adequately fund enforcement.
Resources
The full titles of codes cited in this chapter,
as well as additional tribal codes, are provid-
ed below. Some codes are not currently
available on the Web. To request a copy of
these codes, refer to Appendix B for the
tribe's contact information.
Issue-Based Codes
• Campo Band of Mission Indians
(California) Solid Waste Management
Code of 1990. This code focuses primari-
ly on the issues of open dumping and
open burning. Download a Word Perfect
version from this Web site: .
• Walker River Paiute Tribe (Nevada)
Draft Solid Waste Burning Prohibition
Ordinance. This code focuses on the
issue of open burning of solid waste.
• Metlakatla Indian Community (Alaska)
Cleanup and Closure Guidelines for
Open Dumps. These regulations focus
on the standards and procedures for the
cleanup of open dumps.
• Cheyenne River Sioux Tribe (South
Dakota) Solid Waste Ordinance #33.
This ordinance is focused on the siting
of a sanitary landfill facility.
Comprehensive Codes
• Rules And Regulations Providing
Standards For Solid Waste Disposal for
the Hannahville Indian Community's
(Michigan) Solid Waste Management
Plan.
• Lac Du Flambeau Tribal (Wisconsin)
Solid Waste Code. WordPerfect file
accessible at
-------
• The St. Regis Mohawk Tribe's Solid
Waste Management Code is available at
< www. srmtenv.org/swcode .pdf >
Model Code Templates
• The following Web site: , includes
sample or model codes that were not
developed for any specific tribe or
nation, but were intended to be used by
tribal governments as a starting point
that can be built upon, modified, and
adapted according to the needs and cus-
toms of each individual tribe. The
majority of these sample codes provide
options and commentaries for tribes to
consider in evaluating and adapting the
code to meet their specific needs.
• The Inter Tribal Council of Arizona,
Inc. Model Tribal Solid Waste
Management Code, available on the
Web at .
• The National Indian Justice Center
Model Tribal Solid Waste Ordinance.
Contact at 707 579-5507 or on the Web
at .
Other References
• Tribal Waste journal: Respect Our
Resources: Stop Illegal Dumping. Issue 1.
EPA Solid Waste and Emergency
Response. EPA530-N-02-001. May
2002.
Bois Forte Chippewa and Outside
Agencies Band Together for Integrated
Waste Management. Waste
Management in Indian Country.
.
Solid Waste Management Planning for
Rural Communities in Alaska: Community
Resource Guide and Planning Workbook.
Available from the Alaska Native
Health Board in 2004.
Tribal Leaders Are Key to Reducing
Backyard Burning. EPA530-F-03-016.
August 2003. .
Reducing Backyard Burning in Indian
Country. EPA530-F-03-017. August
2003. .
EPA's construction and demolition
debris Web site .
EPA's Management of Scrap Tires Web
site .
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Chapter 4. Solid Waste Collection
and Disposal Programs
A key component of a strong tribal
solid waste management program is
setting up a collection and disposal
system that is compatible with the needs of
your tribe or village. Through careful plan-
ning, you can ensure that your system will
effectively manage your waste stream, safe-
guard tribal members' health, and protect the
environment. Many tribes have found that
developing convenient and affordable waste
collection and disposal alternatives is the
most effective way to stop illegal dumping.
This chapter explores the benefits and costs
of different waste collection and disposal
options for everyday household waste, as well
as construction and demolition debris and
hazardous waste. It includes case studies and
tables that weigh various options in terms of
criteria that are important to tribes. All
materials referenced or cited in this chapter
are included in the Resources section at the
end of this chapter. This chapter also illus-
trates the key elements of a comprehensive
illegal dumping prevention program—site
maintenance and controls, community out-
reach and involvement, targeted enforce-
ment, and measurement.
Getting Started
"Everyone has different goals and needs. Do a
feasibility study to know your needs."
~Merlin Tafoya, Sr., Executive Director of Public Works
Division, Jicarilla Apache Nation
Each tribe has a unique history, culture,
financial situation, and geographic location.
These key factors all will play a role in deter-
mining the collection and disposal options
that are right for your tribe. Each tribe also
generates a variety of types of waste in its
waste stream, depending on its size, geo-
graphic location, and the activities taking
place in the tribe. Waste assessments can
help you develop a collection and disposal
system that matches your particular waste
types and generation rate. They also can
help you decide whether or not to collect
recyclable materials; compost organic wastes;
or develop a management system for house-
hold hazardous waste, bulky items, and con-
struction and demolition debris. The Spirit
Lake Tribe in North Dakota conducted a
waste sort to determine waste composition
and volume before starting its waste collec-
tion program. See Chapter 2 for more exam-
-------
pies of other tribes' experiences and informa-
tion on waste stream analyses.
Decisions about what materials to collect, as
well as how to collect, transport, and ulti-
mately dispose of them, are all interrelated.
Whether you are starting a solid waste man-
agement program or enhancing an existing
system, thinking through the entire collec-
tion and disposal process will help guarantee
your program's success.
Collection Options
There are three basic collection systems:
• Drop-off sites
• Direct access to transfer stations
• Curbside collection
Table 2 compares some of the capital costs
associated with drop-off sites and curbside
collections systems in rural areas.
Drop-off Sites and Direct Access to
Transfer Stations
Drop-off sites are centrally located facilities
with containers where tribal members
deposit their waste. Some tribes also facili-
tate direct access to transfer stations so tribal
members can take their trash to these larger
facilities themselves. These collection
options are less convenient for residents than
curbside collection but keep collection costs
down for the tribe. Tribes can own and oper-
ate these facilities or make arrangements
with neighboring communities to use their
facilities.
The Bois Forte Band has drop-off boxes at
two locations on its northern Minnesota
reservation. Through an agreement with the
tribe, St. Louis County owns the drop-off
boxes and collects trash and recyclables from
the tribe.
Table 2. Estimated Waste Collection Capital Costs
Waste Drop-off Sites
Curbside Collection
Site development
Household solid waste
Other solid waste
$3,000-4,000
$30,000-40,000
$30,000-40,000
8 cubic yard drop-off container
(e.g., green box)
30-cubic-yard front loading packer/
collection truck
$4,000-5,000 each
$100,000-110,000
N/A
Large plastic container (< 90 gallons)
40-cubic-yard roll-off container
(for bulky items and C&D)
N/A
$3,000-5,000
$50
$3,000-5,000
$40,000-60,000
Other equipment
$25,000-30,000
Maintenance shop (optional)
$40,000-50,000
$40,000-50,000
Transfer station
$200,000-400,000
N/A
Source: TASWER and SWANA. Developing and Implementing Integrated Solid Waste Management Systems for Tribes, Spring
2003, p. 50.
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Recyclables collection containers used by the St. Regis Mohawk Tribe.
Members of the Red Cliff Tribe of
Wisconsin take their trash directly to a trib-
ally owned transfer station. The tribe funds
transfer station operations through a Pay-
As-You-Throw (PAYT) program. Tribal
members must bring their trash to the trans-
fer station in special trash bags that they can
purchase from the tribe. The PAYT system
encourages residents to reduce the solid
waste they dispose of, as members must pur-
chase more trash bags to throw away larger
volumes of trash.
Curbside Collection
You can customize a waste collection pro-
gram to fit your tribe's or village's specific
needs. With curbside collection programs,
tribal members can deposit their trash in
containers right outside their homes, and
haulers pick it up and take it away for dis-
posal. This system is more convenient for
residents, but more expensive than other
types of collection programs because it has
higher transportation and labor costs.
Transportation costs can add up quickly
when collection trucks serve rural communi-
ties where residences are spread out over a
large area.
One tribe that runs a
curbside collection
program is the
Jicarilla Apache
Nation in New
Mexico, which pro-
vides free, weekly
waste collection to
all residents. The
nation owns two 14-
cubic-yard capacity
compactor vehicles.
The vehicles collect
and transport the
waste to a tribally
owned and operated
transfer station that
handles 12 to 16 tons
of waste per day.
Combining Collection Options
Some tribes find that a combination of col-
lection options works best. The Assiniboine
and Sioux Nations of Fort Peck Reservation
in Montana show that tribes can incorporate
elements of several waste collection options
The St. Regis Mohawk Tribe's curbside collection program in action.
-------
into a successful program. The reservation's
population extends across six towns in Valley
and Roosevelt Counties, and residents in the
towns have adopted varied collection sys-
tems. The Assiniboine and Sioux Nations
obtained funding from the Department of
Housing and Urban Development (HUD)
and IHS to build roll-off sites for five of the
towns. Residential and business customers
pay a monthly permit fee to dispose of waste
at these sites. The nations' Operations and
Maintenance (O&M) Department hauls
waste from two of the sites to a landfill in
Roosevelt County, where they pay a tipping
fee. The nations pay for a private trucking
company to haul waste from the other sites
to a landfill in Valley County. Valley County
charges a flat fee for using the landfill, based
on the county population.
Table 3. Estimated Annual Operating
Costs for Solid Waste Management
Systems*
Labor:
Administration
Other
Benefits
Vehicles:
Maintenance
Fuel
Roll-off containers
Contingency
$10 per hour
$5-7 per hour
30% of salary
$0.20-0.35 per mile
$0.10-0.20 per mile
$100-300 each load
$10,000-30,000 per year
*ln addition, there will be annual capital costs for items such
as household containers (5-year average life expectancy),
roll-off containers (10-year life expectancy), buildings (25-
year life expectancy), or collection trucks (150,000 miles life
expectancy).
Source: TASWER and SWANA. Developing and Implementing Integrated
Solid Waste Management Systems for Tribes, Spring 2003, p. 52.
The Fort Peck Reservation also pays a pri-
vate trucking company to collect materials at
the curbside in two of the towns on the
reservation. O&M charges residential cus-
tomers a monthly fee—currently $14, which
is added to residents' utility bills—to support
curbside collection service. This option
worked for Fort Peck because the tribes
solicited input from members before imple-
menting the plan and gave members a
choice. Before O&M instituted a rate
change, the tribes held a public hearing and
asked residents if they would prefer to use a
roll-off container or pay a higher collection
fee. Residents in one town decided to pay
the higher fee. Residents in another decided
to use the roll-off container, but later agreed
to pay the higher fee.
Outside Factors Affecting Collection
Options
Tribal collection can be affected by factors
outside the scope of the tribe's control.
Winter weather can make rural curbside col-
lection impractical in some areas, particular-
ly for Alaskan Native villages, which can be
covered in snow and ice the majority of the
year. The Alaskan Native Village of Kipnuk
uses all-terrain vehicles to collect trash from
residents twice a week during the summer.
During the long winter, regular waste pickup
is not possible and trash can accumulate in
the village. The Kipnuk Traditional Council
decided to address the problem by building
10 wooden sleds outfitted with trash dump-
sters. During the winter, the sleds rest in the
village near the honey bucket stations.
Periodically, community members use snow
machines (i.e., snowmobiles) to move the
sleds out of the village to the landfill.
Collecting Recyclables and Special
Wastes
Planning a waste collection system also
should include consideration of how to man-
age recyclable materials and special wastes.
-------
Collecting recyclables will be feasible for
some tribes and can offer benefits such as
lowering disposal costs, preserving resources,
supplying the tribe with manufacturing feed-
stocks and materials such as compost, and
generating revenue. Other tribes, however,
might find that collecting recyclables is
infeasible or too expensive, especially if they
are located far from processing centers and
markets. For more information on tribal
recycling issues and resources, refer to
Chapter 5.
Your tribe also should plan for proper man-
agement of special wastes—including used
oil, tires, white goods, bulky goods, house-
hold hazardous waste, and construction and
demolition debris. If disposed of improperly,
these materials can be unsightly and even
pose health threats to tribal members. They
also can contaminate the tribe's waste stream
and disrupt collection and disposal activities.
Following you will find examples of how a
variety of tribes manage special wastes.
• Employees at the Jicarilla Apache
Nation's transfer station in Arizona
screen waste for contaminants, such as
tires and household hazardous waste, to
make sure they are removed from the
general waste stream and are disposed of
appropriately. To help prevent contami-
nation, you can educate your community
members about proper disposal practices
for these materials and develop programs
to ensure their safe management.
• Some tribes designate specific collection
depots for special wastes. The Alabama-
Coushatta Tribe of Texas encourages resi-
dents to bring used tires and oil to a local
auto shop that accepts them for a small
fee. The tribe also contracts with a local
salvage yard that hauls away bulky items
that contain metal for free. Tribal mem-
bers simply place these items in a desig-
nated location at the transfer station.
Scrap metal recycling pile at the Eastern Band of Cherokee Indians' transfer
station.
• The White Mountain Apache in
Arizona took a different approach. The
tribe hosts an annual "Clean Your House
Day" to give tribal members an opportu-
nity to dispose of large bulky items. The
tribal Public Works Department sets out
large bins at different locations on the
reservation, and residents can drop off
their items without having to pay a spe-
cial disposal fee.
• In Minnesota, the Red Lake Band of
Chippewa co-locates permanent household
hazardous waste collection containers at its
solid waste drop-off sites, while the Fond
du Lac Band of Lake Superior Chippewa
hosts household hazardous waste collection
events. In addition, high school students
have conducted a thermometer exchange
on Fond du Lac Reservation to safely
remove mercury-containing thermometers
from the community.
• For many tribes, construction and demo-
lition debris comprises a significant por-
tion of the solid waste stream. The Fort
Peck Tribes of Montana had problems
with contractors placing bulky construc-
tion and demolition debris in tribal roll-
off bins. The bins filled up quickly,
-------
forcing the tribes to pay thousands of dol-
lars in landfill tipping fees. To address this
issue, the tribes decided to manage con-
struction and demolition debris separately
from MSW. The Fort Peck Operation and
Maintenance Department now rents con-
struction and demolition debris dumpsters
to contractors and transports their waste
to a special C&D debris landfill.
• Special wastes can be particularly prob-
lematic for remote Alaskan Native vil-
lages, since transporting the wastes to an
appropriate management facility is diffi-
cult. For this reason, the Native Village
of Barrow-Inupiat Traditional
Government has taken an active
approach to educating the Inupiat peo-
ple about safe storage and disposal of
household hazardous wastes. The Inupiat
Traditional Government identified the
kinds of potentially hazardous wastes
being produced in the community and
then used the local radio and television
networks to reach out to members with
information about safe management.
• The Onondaga Nation in New York
decided to make household hazardous
waste disposal a priority. The nation
hosts household hazardous waste collec-
tion events twice a year to educate the
tribal community about proper disposal
practices. In addition, the tribe provides
public access to a household hazardous
waste collection compartment at the
transfer station. Tribal members can
bring their household hazardous waste to
the transfer station 24 hours a day, 7 days
a week. The transfer station also includes
a storage container for car batteries.
Transfer and Disposal Options
Where does solid waste go after it is collect-
ed from residents? Reviewed below are four
major transfer and disposal options for tribes:
• Using a transfer station or landfill locat-
ed off the reservation
• Building a transfer station on the reser-
vation
• Building a landfill on the reservation
• Disposing of construction and demoli-
tion debris and hazardous waste
Using a Transfer Station or Landfill
Located Off the Reservation
For some tribes, outsourcing—contracting
with a public- or private-sector facility to
manage discards—is a temporary or perma-
nent waste management solution. Tribes can
hire private haulers or contract with local
waste management districts to provide service
for reservation residents. For tribes that are
building a transfer station or landfill, there
often is a gap between the time that a tribe
closes its open dumps and opens a new trans-
fer station or landfill. If residents do not have
a convenient and affordable waste disposal
alternative in the meantime, they might
resort to illegal dumping. Your tribe can work
with a private hauler or local government to
provide residents with curbside collection
service or access to a designated drop-off site
at a nearby transfer station or landfill.
Another example of outsourcing is seen on
Fond du Lac Reservation in Minnesota.
When the Fond du Lac Band of Chippewa
began to close its open dumps, illegal dump-
ing problems increased. The tribe recognized
the need to provide residents with conven-
ient and affordable waste disposal alterna-
tives and allowed private waste haulers to
offer curbside collection. Private haulers now
pick up waste and carry it off of the reserva-
tion. They charge reasonable rates, encour-
aging proper waste disposal. Working with
private haulers, the tribe facilitated waste
removal for residents without spending tribal
funds on a transfer station or landfill. The
tribe is studying the feasibility of tribally
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Table 4. Weighing Waste Collection Options
Criteria Important to Tribes
Collection
Options
Cost-Effective
Cost-Effective for
Tribe
Affordable for
Community Members
Convenience for
Community
Members
Minimizes Litter,
Odor, Dust, Noise,
and Vermin
Potential for
Source Reduction
and Recycling
Curbside
Collection
(Individual
household or
shared with
neighbors)
• Cost-effective if paid for by
tribal members through
fees.
•Tribally operated service
can lower costs, but
requires investment in
collection vehicle and staff.
•Typically costs more than
drop-off sites or transfer
stations.
•Tribal subsidies can make
it affordable for
community members.
• Community participation
increases as disposal
options become more
affordable.
• Extremely convenient for
community members.
• Minimal effort to place
trash outside of a home
or business for collection.
• Fosters high participation
rates and reduces illegal
dumping incidents.
• Waste is stored outside
for a short time before
it is collected, reducing
litter, odor, and vermin
problems.
• Noise and dust from
collection vehicles are
limited.
• Convenience encourages
recycling.
• Combining with PAYT
waste disposal creates
incentive for recycling.
• Requires separate
containers and
possibly separate
collection vehicles.
• Co-mingled recyclables
need to be sorted before
sale to processors.
Drop-off Sites
• Costs the tribe less to
transport waste to transfer
stations or landfills from
consolidation points (drop-
off sites) than from
individual homes and
businesses.
• If not subsidized, tribal
members will pay more
for curbside collection
than to use drop-off sites
or transfer stations.
• Direct access to a single,
centrally located transfer
station is less expensive
than consolidating and
transporting materials
from multiple drop-off
sites.
• Less convenient than
curbside pickup service,
but more convenient
than direct access to
transfer stations.
• Convenience increases
with multiple drop-off
sites.
• As convenience
increases, participation
increases and illegal
dumping decreases.
• Storing large
quantities of waste at
one site for more than
a few hours can
produce litter, odor,
and vermin problems.
• Litter can accumulate
if sites are not cleaned
frequently.
• Staffing, fencing, or
enclosing sites
minimizes these
problems.
• Appropriate site
selection can minimize
noise and dust impacts.
• Requires separate
collection bins, but this
eliminates need to sort
recyclables before sale
to processors.
• Providing free recycling
with PAYT waste
disposal creates
incentive to recycle.
• Convenience dependent
upon number of sites,
locations, and hours of
operation.
• Can arrange for
direct pickup from
sites by processors.
Direct Access • If the tribe does not
to Transfer operate its own transfer
Station station, it can enter an
agreement with a
surrounding town or
county.
•Tribe can compensate
surrounding town or county •
for direct access to a transfer
station off the reservation.
• Collection costs go up if
tribe compensates town or
county from tribal coffers.
Tribe can reduce the
tipping fees or solid waste
fees it charges tribal
members.
Tribe does not have to
pay for transportation to
a consolidation point.
Although these costs are
not reflected in the
tipping fees or solid
waste fees, tribal
members absorb them.
Not convenient if transfer
station is located far
away from the tribal
members who will be
using it.
• Storing large quantities
of waste at one site for
more than a few hours
can produce litter, odor, •
and vermin problems.
• Litter may accumulate
if sites are not cleaned
frequently.
• Staffing, fencing, or
enclosing sites minimizes
these problems.
• Appropriate site
selection can minimize
noise and dust impacts.
Requires separate area
and containers for
recyclables.
Combining free
recycling with PAYT
waste disposal creates
incentive to recycle.
Can sort to reduce
contamination, bale for
easier handling, or store
at facility until find
acceptable market price.
-------
operated waste hauling services but mean-
while continues to move the waste directly
to an off-reservation facility.
Finally, some tribes view outsourcing as a
long-term solution. For example, the
Assiniboine and Sioux Nations of Fort Peck
Reservation in Montana annually pay Valley
County $75 per household for residents in the
county to use its landfill. The nations pay for
a private trucking company to perform curb-
side collection in Frazer, which lies in Valley
County. The trucking company hauls house-
hold waste directly to the Valley County
landfill. Some tribes also own or operate their
own trucks and haul waste to a landfill locat-
ed off of the reservation. An advantage of this
approach is that the tribe retains flexibility. It
also incurs minimal liability compared to
owning and operating a landfill on site. The
tribe also avoids the need to budget for clo-
sure and post-closure care of the landfill.
Closure consists of either capping the landfill
or removing the waste and any other contam-
inated soils or structures. Post-closure care
typically includes groundwater and landfill gas
(i.e., methane) monitoring and maintenance
of the final cover.
Building a Transfer Station on the
Reservation
"It is important to know how much you are
generating and what you are generating when
you choose a transfer station design."
-Laura Weber,
Director of Solid Waste Management,
St. Regis Mohawk Tribe
Some tribes find, after studying the alterna-
tives, that collecting and managing their
waste on site is safer and more economical. If
such issues are important to your tribe, then
you might consider building a transfer station
on your reservation. A transfer station is a
facility where waste materials are taken from
smaller collection vehicles and placed in larg-
er vehicles for transport to their ultimate site
of disposal—often a landfill. Although these
transfer station facilities require funds for con-
struction, they might lower your waste man-
agement costs over the long term. Typically,
transfer stations are less expensive than land-
fills because they require less money for con-
struction, operation and maintenance, and do
not require the expensive closure and post-
closure care that landfills do. Table 5 presents
construction and equipment cost and the
expected life for the common structures and
equipment used at a transfer station.
In addition, your tribe might build a transfer
station rather than a landfill because you do
not generate very much waste. Consider,
however, that when a tribe builds a facility
on the reservation, it still does not have
total control over costs, availability of
trained personnel, and markets for recovered
materials. Some tribes prefer to delegate, or
contract out, solid waste services to reliable
companies, finding that they save money
and the waste is easier to manage that way.
Transfer stations can be designed for versatili-
ty, to accept anywhere from 1 ton of waste
per week to several hundred tons of waste per
day. Communities use waste assessments to
estimate waste generation rates and properly
Collection truck dumping waste at the Eastern
Band of Cherokee Indians' transfer station.
-------
Table 5. Transfer Station Construction and Equipment Costs and Life
Expectancy*
Item
Ramp and retaining wall
Building
Fencing—Chain link (installed)
Rolling gate (Chain link)
Fencing—Wood (installed)
Crushed rock
Concrete (6 inches deep, no labor)
Concrete (4 inches deep, no labor)
Asphalt (7 inches deep, no labor)
Stabilization (8 inches deep)
Dumpster (6-8 cubic yards)
Roll-off boxes, 40 cubic yards, open top
Roll-off boxes, 42 cubic yards, closed top
Stationary compactor, 2 cubic yards
Roll-off truck with hoist
Yard waste chipper
Cost Life (years)
varies with size 25
$42 per square foot 25
$10 per linear foot 20-30
$400 each 20-30
$9 per linear foot 15
$10,760 per acre ($2.25 per square yard) 5
$46,750 per acre ($9.50 per square yard) 25
$31,540 per acre ($6.50 per square yard) 25
$62,610 per acre ($13 per square yard) 10-15
$16,940 per acre ($3.50 per square yard) 10-15
$450-600 5
$3,200-5,000 10
$4,250-6,400 10
$6,000-9,000 10
$60,000-83,000 10
$20,000-25,000 10
* These costs are provided as reasonable examples. The total cost can vary from a few thousand dollars to more than $100,000.
Source: TASWER and SWANA. Developing and Implementing Integrated Solid Waste Management Systems for Tribes, Spring
2003, p. 76.
size transfer stations. Each of the tribes high-
lighted below chose to build a different type
of transfer station.
Small Roll-off Site Solves Onondaga
Nation's Waste Management Dilemma
Sovereignty and community size were major
factors in the New York-based Onondaga
Nation's decision to construct a small transfer
station on the reservation. The community's
low waste generation rate and reluctance to
rely on grants or loans for construction
helped tribal leaders rule out building a land-
fill or large transfer station. The nation
decided to build a small, low-maintenance
transfer station and worked with a private
waste management company to develop a
construction and operation plan.
Tribal leaders agreed to build the new trans-
fer station near an old open dump site on
uninhabited land between three highways.
The transfer station consists of a concrete
surface with two roll-off bins—one for
household waste and one for recyclable
-------
An example of the self-contained modular waste storage units used by the
St. Regis Mohawk Tribe.
materials—inside a chain link fence with a
gate. The first bin has a compactor powered
by a hydraulic pump which is housed in a
small adjacent shelter. Onondaga Nation's
contractor hauls away the roll-off bin of
compacted trash at least once a week.
The transfer station is only open to
Onondaga Nation members. Initially, resi-
dents from surrounding counties used the
transfer station to avoid paying tipping fees in
their own towns. To address this problem, the
tribe hired attendants to staff the collection
site continually. The attendants also monitor
roll-off bins and remove tires, household haz-
ardous waste, and other unacceptable materi-
als to minimize contamination.
Self-Contained Modular System a Perfect Fit
for the St. Regis Mohawk Tribe
During the 1990s, residents of the St. Regis
Mohawk Tribe in New York were seeking
alternative waste management options. At
the time, private waste haulers provided
curbside collection services for a fee.
Residents felt the fee was too high and
voiced their concerns to the Tribal Council
and Environmental Division. A solid waste
management feasibility study revealed that
most residents wanted a tribally owned and
operated waste disposal facility. The
Environmental Division built upon this pub-
lic sentiment and used it to help gain Tribal
Council support for a transfer station. One
effective tool in convincing Tribal Council
members of the need for such as facility was
showing them pictures of existing open
dumps on the reservation and explaining
how a new transfer station could eliminate
such sites.
The Environmental Division conducted a
waste audit and determined that the commu-
nity generates between 6 and 7 tons of waste
each day, half of which could be recycled.
The tribe decided that its moderate waste
generation rate did not warrant building a
large transfer station. At the same time, out-
door roll-off containers were a poor option
because they would fill up with ice during
the harsh winter months. In addition, roll-
off bin compactors sometimes fail in the win-
ter. In search of a creative solution,
Environmental Division staff and Tribal
Council members visited other tribal facili-
ties and trade shows. At one trade show, the
tribe discovered self-contained, modular
waste storage units.
The tribe purchased two 53-cubic-yard mod-
ular waste storage units, designed to with-
stand harsh outdoor conditions for years.
Each unit is an enclosed waste collection
container that is leak-, fire-, and animal-
proof. Residents can access the unit manual-
ly by opening a side door. A door on top of
the unit is larger and must be opened
hydraulically. The tribe purchased a collec-
tion truck for curbside pickup service that
can open the top door of the unit using its
hydraulic system. The tribe ships its waste
from the modular units to a landfill off of the
reservation. The tribe also uses four 6-cubic-
yard modular containers for collecting recy-
clable materials at its transfer station. These
units are emptied regularly by a truck with a
-------
hydraulic lift system. By diverting recyclable
materials from its waste stream, the tribe
hopes to keep disposal costs down.
The storage units required more start-up
funds than a roll-off site, but less than a large
transfer station. The St. Regis Mohawk Tribe
obtained grants from IHS, HUD, and the
U.S. Department of Agriculture (USDA) to
build the transfer station. The tribe's use of
federal funds added steps to the design and
construction process—the National
Environmental Protection Act requires any
federal construction project to provide an
environmental impact statement, including
projects using federal grants. In addition,
contractors must demonstrate that they meet
federal bonding requirements. Some federal
agencies place additional requirements on
the use of their funds. For example, USDA's
Rural Utility Service required the St. Regis
Mohawk Tribe to work closely with a USDA
engineer during the design phase. The
USDA engineer had to sign off on any
change to the original construction plan.
large Transfer Station Spells Success for
Eastern Band of Cherokee Indians
In 1991, the Eastern Band of Cherokee
Indians in North Carolina realized that it
would have to close the reservation's landfill
because it failed to meet the new Resource
Conservation and Recovery Act (RCRA)
Subtitle D regulations. Tribal members
searched for a solid waste solution that
would accommodate future community
growth, including a planned gaming facility.
The tribe decided to build a transfer station
capable of handling 300 tons of waste per
day. The tribe constructed the transfer sta-
tion with its own waste in mind, but the
facility also is large enough to handle waste
from towns outside the reservation.
A large transfer station can bring traffic,
noise, odors, debris, and animals to an area.
To minimize impacts on the community, the
Scale house at the entrance to the Eastern Band of Cherokee Indians' trans-
fer station.
tribe chose to site the transfer station next to
the old landfill, where tribal members were
accustomed to bringing their waste. The
tribe already owned the property, and the
tribal council quickly approved the location.
At the Eastern Band of Cherokee Indians'
transfer station, a scale for weighing trucks is
located at the entrance. Trucks enter the
transfer building and dump their loads onto a
tipping floor. A front-end loader then pushes
the waste into a trailer that sits on a truck
one level below. Before leaving the facility,
transfer station operators check to make sure
that the truck does not exceed the 20 to 21
tons of waste limit set by state and federal
transportation regulations. The waste is then
hauled to a landfill in South Carolina, where
the tribe pays tipping/disposal fees.
Building a Landfill on the Reservation
Finally, a tribe might decide to site a landfill
on the reservation. An onsite landfill can be
a technically and economically feasible
option for a tribe under certain circum-
stances, such as if the tribe is located far
from available waste management facilities
-------
The Alaskan Native
Village of Klawock's
solid waste landfill.
or generates enough waste to make an onsite
facility viable. An important factor to
remember when making this decision is that
costs for a Subtitle D compliant landfill
include not only construction and operation
and maintenance, but also closure and post-
closure care expenses.
Many tribes, however, have decided that
landfills require too much land, funding,
maintenance, and waste volume to be a
viable waste management option. It often is
difficult to find enough land on the reserva-
tion to build a landfill. In addition, tribal
members often object to siting a landfill
close to their homes or businesses.
In 1991, the federal government developed
more stringent design, construction, operation,
and closure criteria for landfills under RCRA
Subtitle D. These criteria protect health, safe-
ty, and the environment but can make it diffi-
cult to control landfill costs. Regulations
require that all landfills include a composite
liner (a flexible membrane liner above a layer
of compacted clay). Other federal require-
ments that lower risks, but increase costs,
include leachate collection systems, groundwa-
ter monitoring, and landfill gas management.
Building an economically viable small landfill
that meets these requirements can be a chal-
lenge, and most tribes do not generate enough
waste to make building a large landfill worth
the cost and effort. In their joint training,
TASWER and SWANA estimate that the
typical cost of construction per acre of landfill
space is between $150,000 and $250,000. At
these costs, TASWER and SWANA believe
that tribes generating less than 100 tons of
waste per day will find building and operating
a Subtitle D compliant landfill is not an eco-
nomically feasible option.
The federal government recognizes that
small, unlined landfills are the only viable
waste management option for some commu-
nities, including tribes. Consequently, it cre-
ated two exemptions—one for small
communities in cold regions and one for
small communities in dry regions. Alaskan
Native villages, for example, can be exempt
from the federal landfill design and ground-
water monitoring requirements if they can-
not access a regional waste management
facility for several months. These villages
qualify for the exemption if they generate
less than 20 tons of waste daily and experi-
ence an annual interruption of at least 3
consecutive months of surface transportation
because of snowfall.
Some tribes in the Southwest also can be
exempt from federal landfill requirements.
Tribes qualify for the exemption if they gen-
erate less than 20 tons of waste daily, have
no practical waste management alternative,
and are located in an area that receives 25
inches or less precipitation annually.
Though most tribes do not qualify for the
exemptions listed above, they can apply to
EPA for site-specific flexibility. If a tribe can
demonstrate that its landfill will adequately
protect human health, safety, and the envi-
ronment without a composite liner or
groundwater monitoring, it can apply for site-
specific flexibility or exemption from the fed-
eral requirements. Several tribes, including
the Oglala Sioux Tribe of the Pine Ridge
-------
Reservation in South Dakota, have taken
advantage of this exemption to lower their
landfill construction and operation costs.
Landfill Completes Waste Management
Strategy for Pine Ridge Reservation
In 1994, members of the Oglala Sioux Tribe
(OST) met with representatives from
SWANA and the state of Nebraska to dis-
cuss hauling trash from Pine Ridge
Reservation, located in South Dakota, to a
state landfill in Nebraska. Based upon this
meeting, the OST decided that operating a
transfer station would be too expensive
because the state landfill was too far away. A
full-scale, Subtitle D landfill seemed to be
the best solution because the tribe wanted to
retain complete control of its waste and tip-
ping fees. The tribe acquired a $561,000
grant from EPA to plan a landfill and bale
building (a building where waste is compact-
ed into bales).
The OST applied for site-specific flexibility
and asked the federal government to waive
the composite liner requirement. Pine Ridge
Reservation contains very dense clay soils,
and the tribe demonstrated that the clay per-
forms the equivalent role of an engineered
composite liner and would prevent liquids
from leaching out of the landfill into the
reservation's groundwater supply. EPA grant-
ed the Oglala Sioux a waiver.
Environmental Protection Program staff
worked closely with regional representatives
from each federal agency to fill out grant
applications and obtain funding for the proj-
ect. The tribal council placed solid waste at
the top of its Sanitation Deficiency System
priority list. Consequently, IHS awarded the
tribe $724,000 for landfill construction. The
tribe also received $1.2 million from USDA's
Rural Development Service.
Disposing of Construction and
Demolition Debris and Hazardous
Waste
Managing construction and demolition
(C&D) debris presents a major challenge for
many tribes. C&D debris includes concrete,
asphalt, wood, metals, gypsum wallboard
(sheet rock), and roofing generated from the
construction, renovation, or demolition of
structures (e.g., buildings, roads, bridges).
Some tribes and states include land clearing
debris such as stumps, rocks, and dirt in this
category of waste. Most C&D debris is classi-
fied as nonhazardous and therefore can be
managed with normal waste and disposed of
in an MSW landfill.
Due to the size and weight of much of this
debris, co-managing C&D debris with MSW
can be cost prohibitive. Many tribes have
found that managing C&D debris separately
is the most cost-effective approach. Since
C&D debris materials are typically inert,
many states have established special criteria
for C&D debris landfills. Siting, design, con-
struction, operation, monitoring, and closure
of landfills containing nonhazardous C&D
debris are still regulated under RCRA
Subtitle D (see 40 CFR part 257), but many
of the requirements are much less restrictive
than those for MSW landfills.
One major difference for C&D debris land-
fills is that in most cases they do not require
a liner or groundwater monitoring systems.
Cover requirements typically are less strin-
gent as well. Air emissions from C&D debris
landfills are generally not a concern either,
since C&D debris does not contain large
volumes of putrescible organic matter that
produce landfill gas (methane). If gypsum
wallboard is present in C&D debris, howev-
er, the landfill might produce hydrogen sul-
fide, with its distinctive rotten-egg odor,
particularly if moisture is introduced into the
waste. Tribes operating landfills that manage
large amounts of these materials might need
to install gas control systems to reduce odors.
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Table 6. Weighing Your Waste Disposal Options
Disposal
Option
Outsourcing:
Using a transfer
station or landfill
located off the
reservation
Building a
transfer station
Building a
landfill
Building a
C&D debris
landfill
Short-Term
Startup Costs
Low. No funds
required for
planning or
construction.
Moderate. Tribe
must obtain
funding for
transfer station
equipment.
Building a transfer
station costs less
than building a
landfill.
High. Even if
tribe obtains a
waiver from
some federal
requirements,
costs can be
high.
Low to moderate.
Need to acquire
adequate land
and do minor
excavation to
prepare site. If
liner or
monitoring
systems are
required, cost
will increase.
Long-Term
Operation/
Maintenance Costs
Low. No equipment for
the tribe to maintain.
Moderate. Requires
continuous funding
for operation and
maintenance.
High. Unless tribe
obtains a waiver from
some federal
requirements, it is
expensive to operate
and maintain a landfill
both while open and
after closure.
Moderate. Requires
operation and
maintenance funding.
If need to maintain
liner and monitoring
systems, costs will
increase.
Costs for
Individual
Tribal Members
Low to High. Tribe
has no control over
transfer station or
landfill tipping fees,
unless it has a long-
term contract.
Low to Moderate.
Tribe sets disposal
rates for residents;
however, tribe is
subject to tipping
fee increases
because it transports
trash to a landfill
or incinerator.
Low to High. Tribe
dictates disposal
rates for residents.
If the landfill is
expensive to
operate and
maintain, then
higher rates might
be needed.
Low to moderate.
Tribe establishes
disposal rates.
Increases in
operating costs will
affect disposal rates.
Minimizes
Controversy
Over Siting
Tribe does not
have to site a
transfer station or
landfill on tribal
land.
Requires less
space and is
easier to site
than a landfill.
Residents
sometimes
object to siting a
transfer station
close to their
community.
Minimizes
Liability
The town, county,
state, or company
that operates the
facility is liable for
any health and
environmental
problems.
Tribe liable for any
problems that
might occur at the
transfer station.
People may leave
hazardous waste
or start fires at
small, un-staffed
transfer stations.
Typically, residents Tribe assumes
object to siting a
landfill near their
community.
Requires so
much space that
it is difficult to
find enough land
to build one.
Requires
significant
amount of space.
Residents might
object to siting
near their
community (but
should be less
opposition than
msw landfill).
liability for
problems
associated with
the landfill during
both active life and
the post-closure
care period.
Tribe assumes
liability for
problems
associated with
the landfill during
both active life and
the post-closure
care period.
Minimizes Litter,
Odor, Dust,
Noise, and Vermin
Outsourcing reduces potential
health, environmental, and
aesthetic problems associated
with storing large quantities of
waste in a single location on
the reservation.
Trucks entering and leaving
can produce dust and noise.
Waste can produce foul odors
and attract vermin. Tribes can
reduce these problems by
paving nearby roads and
building an enclosed facility
and fencing the site.
Building the landfill and
disposing waste on a daily
basis produces dust, noise,
odors, and litter. It also attracts
birds, animals, and vermin.
Paving nearby roads and
covering waste at the end of
each day prevents some of
these problems.
Dust and noise can be a
problem. Odors and vermin
typically not a problem. Litter
is not a likely problem, but
could be some wind-blown
paper materials.
-------
Funding a Collection and Disposal Program
After choosing a waste collection and disposal option, your tribe must figure out how to finance it. A variety
of financing mechanisms are available to your tribe:
Subsidizing the program from the tribal general fund.
The Gila River Indian Community in Arizona subsidizes curbside collection by public works to make
waste disposal cheap and convenient for tribal members.
Charging residents a flat fee.
The Fort Peck Tribes in Montana charge residents $15 per month to use tribal roll-off sites. Community
members drop off their trash at a few bins scattered throughout the reservation. The tribes are consider-
ing switching to a Pay-As-You-Throw system. The Shoshone-Paiute Tribes of Duck Valley, which straddles
land in Idaho and Nevada, charges residents a solid waste fee, which appears on their monthly electrical
bills.
Asking residents to work directly with a private hauler or local government.
Members of the Delaware Nation in Oklahoma pay a private hauler for curbside collection.
Instituting a Pay-As-You-Throw (PAYT) program.
Communities with PAYT programs charge residents for solid waste collection based on the amount they
throw away, creating a direct economic incentive to recycle more and to generate less waste. The St.
Regis Mohawk Tribe of New York charges residents based on how much they throw out. Under this
PAYT program, tribal members purchase 30-gallon blue disposal bags from the tribe. The blue bags are
picked up weekly by the tribe.
For more information on financing a tribal solid waste management program, refer to Chapter 7.
If your tribe decides to build and operate a
C&D debris landfill, you can finance the
operation in several ways. One approach is
to charge a flat fee per load of C&D debris
dumped. Another approach is to create a
"pay-as-you-use" system where by tribal
members are charged per pound of material
disposed. Using this type of per weight sys-
tem will require a scale house and an atten-
dant at the landfill entrance. A simple
method of operation is to weigh incoming
vehicles and then weigh them again on the
way out. The hauler would pay based on the
difference in the two weight measurements.
Some C&D debris may be classified as haz-
ardous waste because it contains hazardous
materials, such as lead or chromium, or has
been contaminated by other hazardous
waste. Hazardous C&D debris must be dis-
posed of in a hazardous waste landfill. Other
Tribal members cleaning up an open dump on the White Earth Band of
Chippewa's reservation.
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•**• ,. •< , .V •'<•"•".•,, :•„, •.'„ -: ; ' / ' • - ' "" , ' '••<-.,•';.*•";
•', , !'•••'.,'f," • •„ ";,.'• , <- -.,',-,--i.':''(•''•'i-*1^'';.'1"^
Before and after photographs of an open dump cleaned and restored by the
Shosone-Paiute Tribes of Duck Valley.
toxic materials, such as asbestos and poly-
chlorinated biphenyls (PCBs), must also be
managed in accordance with federal regula-
tions, as spelled out by the Toxic Substances
Control Act (TSCA).
Increased new home construction on the
Bois Forte Band of the Minnesota Chippewa
Tribe reservation, coupled with the demoli-
tion or refurbishing of old buildings, necessi-
tated the development of a landfill for C&D
debris. IHS helped the tribe locate and
design a 25,000-cubic-yard landfill based on
federal and state regulations. In addition to
providing disposal for C&D debris, the land-
fill, which opened in 1998, generates income
from disposal charges levied on building con-
tractors.
Table 6 summarizes how the four disposal
options—1) using a transfer station or land-
fill located off of the reservation, 2) building
a transfer station, 3) building a landfill, and
4) building a C&D debris landfill—measure
up to several criteria that are important to
tribes.
Addressing Open
Dumps
For years, Native American communities
used open dumps, burn pits, and burn barrels
to dispose of their waste. In 1991, the federal
government passed regulations making open
dumping illegal. Many open dumps attract
vermin, contain materials that are dangerous
to curious children or wildlife, pose a fire
threat, contaminate surface water and
groundwater supplies, and interrupt natural
drainage patterns. Burning waste in pits,
piles, or barrels releases smoke containing
pollutants harmful to human health and the
environment. Open burning of waste has
been illegal since the passage of the Resource
Recovery and Conservation Act of 1976.
Tribes are closing open dumps and banning
open burning to protect both the health of
their members and the environment. Many
tribes, however, continue to experience ille-
gal dumping problems, even after they set up
new collection and disposal programs. To suc-
cessfully deal with the problem, tribes need
to adopt a multifaceted approach to illegal
dumping prevention that includes site main-
tenance and controls, community outreach
and involvement, targeted enforcement, and
measurement. The examples included below
illustrate the four components of a strong
illegal dumping prevention program.
-------
The Lac Courte Oreilles Chippewa Tribe's no
dumping signs help deter illegal dumpers.
Site Maintenance and Controls
Site maintenance and controls include plan-
ning and implementing cleanup projects and
maintaining cleaned sites to prevent contin-
ued illegal dumping. Proper planning is often a
decisive factor in determining the degree of
success of an open dump cleanup effort. In
addition to securing the proper
equipment and labor, you will
need to arrange for the trans-
portation and disposal of the
removed waste.
On the Cherry Lake Road
cleanup project at the White
Earth Band of Chippewa in
Minnesota, the tribe hired a
contractor that used heavy
equipment to clean up large
items, and hired local resi-
dents to pick up remaining
items by hand. Other tribes
have partnered with local
governments or worked with
IHS and BIA staff to clean
up sites. For example, the Pawnee Nation in
Oklahoma partnered with BIA to clean up
most of its open dump sites. The Seminole
Nation of Oklahoma also works with neigh-
boring Seminole County to clean up illegal
dump sites.
Once cleanup is complete, signs, lighting,
barriers to limit access, and landscaping can
be used to keep a site clean and discourage
future dumping at the site. The Red Lake
Band of Chippewa in Minnesota post "No
Dumping" signs at cleaned areas that state
illegal dumping is punishable by fine and
cite the tribal resolution banning illegal
dumping. The Wyandotte Nation in
Oklahoma installed a fence at one cleaned
dump site to limit access and prevent future
dumping. At the Cherry Lake Road cleanup,
the White Earth Band of Chippewa planted
more than 1,000 trees donated by the state
to beautify the area and discourage illegal
dumping.
Community Outreach and involvement
Educating community members about waste
reduction, recycling, and proper waste dis-
posal can help limit future illegal dumping
Burning waste at the Kokhanok Village (Alaska) landfill.
-------
incidents. Tribal members are more likely to
support solid waste management programs if
they understand the new waste disposal
options and the dangers of open and illegal
dumping. To educate tribal members about
proper waste disposal, the Keweenaw Bay
Indian Community in Michigan developed
an illegal dumping pamphlet that details the
environmental problems associated with ille-
gal dumping and directs residents to proper
waste disposal facilities. The tribe distributes
the pamphlet in public buildings on the
reservation and at public events such as the
annual pow-wow.
Targeted Enforcement
The foundation of any enforcement program
is strong and clearly worded solid waste
codes or ordinances. Codes or ordinances
prohibiting open dumping typically include
some sort of penalty or consequence for the
illegal dumper. Some penalties used by tribes
include fines, collecting the cost of cleanup,
community service, or vehicle impound-
ments. Some tribes, such as the Seminole
Nation of Oklahoma, give an illegal dumper
the opportunity to clean up the mess before
a citation is issued.
For a code or ordinance to be effective, it
must be enforced consistently and equitably.
The Gila River Indian Community of
Arizona developed an aggressive strategy to
deter illegal dumping. Under the tribe's Solid
Waste Ordinance, tribal rangers and police
officers can fine illegal dumpers up to
$10,000. Law enforcement officials also have
the power to confiscate vehicles involved in
illegal dumping incidents. A strong enforce-
ment program can be a powerful illegal
dumping deterrent.
One difficulty many tribes experience when
attempting to enforce illegal dumping ordi-
nances is the inability to prosecute non-trib-
al members for illegal acts. Checkerboard
land patterns and Indian lands being sur-
rounded by multiple jurisdictions further
complicates enforcement issues. A few tribes,
such as the Pawnee Nation in Oklahoma,
have worked out mutually beneficial
enforcement agreements with their neigh-
boring communities. Under agreements with
Pawnee and Payne Counties, tribal rangers
and the Pawnee Environmental Regulatory
Commission share enforcement and prosecu-
tion duties with the Pawnee and Payne
County courts.
Measurement
Measurement is the final component of a
multifaceted illegal dumping program.
Measurement can help build community
support by quantifying cleanup and closure
success. It also can help justify program
spending to tribal leaders. The Pawnee
Nation Department of Environmental
Conservation and Safety in Oklahoma per-
forms a yearly site assessment to identify
dump sites. In 1996, department staff identi-
fied 40 illegal dumping sites on the reserva-
tion. The most recent assessment shows that
only four illegal dump sites remain.
EPA Region 5 created the IDEA (Illegal
Dumping Economic Assessment) Cost
Estimating Model to assess and measure the
costs of illegal dumping activities. The
model allows tribes to compare the cost of
different cleanup methods, equipment
investments, and surveillance and preven-
tion techniques. Tribes can apply the model
to a single dump site, specific groups of sites,
or all of the sites on a reservation.
Most tribal members will stop using burn
barrels and open dumps if their tribe pro-
vides convenient and affordable waste dis-
posal alternatives. Members of the
Alabama-Coushatta Tribe of Texas stopped
using burn pits when the tribe built and pro-
moted its new transfer station. The tribe sub-
sidizes disposal costs for members who bring
their waste to the transfer station. The
-------
White Earth Band of Chippewa in
Minnesota started a tribal curbside collec-
tion service for residents to discourage illegal
dumping. The tribe collects a small fee from
households that subscribe to this service.
Residents that can not afford to pay this fee
use one of five small drop-off sites for a
smaller fee. These collection options have
contributed to the success of White Earth's
illegal dumping prevention program.
Chapter Highlights
• Understand your tribe or village's waste
stream and collection and disposal needs.
• Design your collection and disposal pro-
grams to meet your tribe or village's spe-
cific needs (including political and
cultural needs) and that are in line with
your financial and technical resources.
• Involve community members in the deci-
sion-making process, especially when
deciding services or siting a facility.
• Provide convenient and affordable alter-
natives to open dumping, and educate
community members on their proper use.
• Use a multifaceted approach to open
dump clean up and control.
Resources
These three EPA publications (available at
the Web sites listed below or by contacting
the RCRA Call Center at 800 424-9346)
provide detailed guidance on transfer station
design, siting, construction, operation, and
maintenance:
• Tribal Waste journal: "Against All Odds:
Transfer Station Triumphs" (EPA530-N-
02-002), May 2003, .
• Waste Transfer Stations: A Manual for
Decision-Making (EPA530-R-02-002)
.
• Waste Transfer Stations: Involved Citizens
Make the Difference (EPA530-K-01-003)
.
• EPA's Criteria for Solid Waste Disposal
Facilities: A Guide for Owners/Operators
(EPA530-SW-91-089), summarizes the
major requirements of the federal munic-
ipal solid waste landfill regulations.
Available on the Web at or by contacting the RCRA
Call Center at 800 424-9346.
• EPA's Safer Disposal for Solid Waste: The
Federal Regulations for Landfills (EPA530-
SW-91-092), summarizes the federal
municipal solid waste landfill regula-
tions. Available on the Web at
or by
contacting the RCRA Call Center at
800 424-9346
Code of Federal Regulations, Title 40, Part
258 (40 CFR Part 258)—Criteria for
Municipal Solid Waste Landfills, available on
the Web at .
EPA's Site-Specific Flexibility Requests for
Municipal Solid Waste Landfills in Indian
Country Draft Guidance (EPA530-R-97-016),
helps tribes apply for site-specific flexibility.
Available on the Web at or by contacting the RCRA Call
Center at 800 424-9346.
EPA's Seminar Publication: Design, Operation,
and Closure of Municipal Solid Waste Landfills
(EPA625-R-94-008), available from the
National Service Center for Environmental
Publications at .
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EPA Region 5 has the Illegal Dumping
Prevention Guidebook and information on
the IDEA (Illegal Dumping Economic
Assessment) cost estimating model. Contact
the EPA Region 5 Illegal Dumping
Prevention Project at 312 886-7598.
EPA's Tribal Waste Journal, "Respect Our
Resources: Prevent Illegal Dumping"
(EPA530-N-02-001), includes additional
case studies and is available on the Web at
or by contacting the
RCRA Call Center at 800 424-9346.
The Bureau of Indian Affair's (BIA) Manual
for Assessment of Open Dumping on Indian
Lands: Site Closure and Maintenance, avail-
able from your regional BIA representative.
The Central Council of Tlingit and Haida
Indian Tribes' A Guide to Closing Solid Waste
Disposal Sites in Alaska Villages. Available on
the Web at .
The following periodicals provide articles
and reviews of innovative and successful
waste collection and disposal strategies, prac-
tices, and technologies. Advertisements in
these periodicals also contain information on
new technologies, collection and disposal
equipment, and engineering and consulting
services that can help you meet your tribe or
village's solid waste management needs.
• MSW Management — Phone: 805 682-1300
Fax: 805 682-0200 Mailing address:
Forester Communications, Inc, P.O. Box
3100, Santa Barbara, CA 93130
• Resource Recycling — Phone: 503 233-1305
Fax: 503 233-1356 Mailing address:
Resource Recycling, P.O. Box 42270,
Portland, OR 97242-0270 E-mail:
info@resource-recycling.com
Waste Age —
Phone: 866 505-7173 Fax: 402 293-0741
Mailing address: Waste Age, 2104
Harvell Circle, Bellevue, NE 68005 E-
mail: wecs@pbsub.com
Waste News — Phone: 800-678-9595
or 313-446-0450 Fax: 313-446-6777
Mailing address: Waste News, 1725
Merriman Road, Akron, Ohio 44313 E-
mail: subs@crain.com
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Chapter 5. Waste Reduction,
Buying Recycled, and
Manufacturing with Recovered
Materials
ncorporating waste reduction activities,
buying products that contain recycled
materials, and manufacturing your own
products with recovered materials are all
activities that can enhance your tribe's solid
waste management program and offer sub-
stantial benefits in life quality and econom-
ics. These activities reduce the amount of
waste requiring disposal and help conserve
and protect natural resources.
This chapter will review tools that your tribe
can use to start or expand residential and
commercial waste reduction programs and
businesses on the reservation. The case stud-
ies highlighted throughout this chapter illus-
trate both the challenges encountered by
tribes in setting up these programs and the
significant benefits that you can achieve.
Complete reference and ordering informa-
tion for all materials cited in this chapter are
provided in the Resources section at the end
of this chapter.
Why Tribes Set Up Waste
Reduction Programs
Native American tribes and Alaskan Native
villages have a long-held tradition of land
and resource stewardship. The story of the
Acoma Pueblo pot demonstrates the role
that recycling has played in this tribe's cul-
ture. Pueblo Indian women crafted pots out
of clay, which lasted for years. When the
pots eventually broke, they were not thrown
away. Rather, the broken pots were crushed
to a fine clay powder. Tribal members soaked
the powder to soften it to a workable clay
consistency and used the "recovered" clay to
make new pots.
Source reduction, recycling, and
composting all fit under the umbrella of
"waste reduction" activities.
Tribes today have taken the simple concept
of waste reduction and applied it in new
ways. Many tribes are now running successful
recycling programs on their reservations.
Recycling and composting divert materials
from the waste stream and reduce disposal
costs. These potentially valuable materials
also can supply your tribe with manufactur-
ing feedstocks, which can lead to business
development and job creation. Starting and
expanding businesses on the reservation
offers members enhanced flexibility for fami-
ly and cultural activities, generates income,
and contributes to the tribe or village's eco-
nomic health and development. Source
-------
Eastern Band of
Cherokee Indians'
recyclables manage-
ment area.
reduction activities, including purchasing
durable, long-lasting goods and seeking prod-
ucts and packaging that are as free of toxins
as possible, can help your tribe or village
reduce both the amount and toxicity of the
waste it generates, so you save money
through avoided purchasing and waste man-
agement costs.
Through recyclables collection programs,
some tribes have gathered materials to make
new products for the tribe or to sell to other
communities. Through composting pro-
grams, tribes can make a soil amendment
product they can use on farms and gardens
to help plants grow and thrive. Through
source reduction programs, tribes can pro-
tect health by using less toxic materials and
save money by purchasing fewer products.
You can focus on one aspect of waste reduc-
tion or combine elements from a variety of
resource conservation programs. Numerous
examples of tribal source reduction, reuse,
recycling, purchasing, and recovered materi-
als manufacturing
programs are featured
throughout this
chapter.
Setting Up a
Materials
Collection
Program
You can set up a vari-
ety of recyclable
materials collection
programs. Your tribe
can design a residen-
tial recycling program
to collect and process
recovered materials
generated by tribal
residents and busi-
nesses and market
these materials to end
users.
Before you set up a tribal recycling program,
you will want to determine:
• What materials are in your waste stream,
and which of these should you recycle?
• What markets exist for collected materi-
als?
• What type of collection program best
suits the community?
• What will the program cost, and how
will it be funded?
• Who will collect the materials, and where
can you take the collected materials?
• Who will staff the recycling program?
• How can you encourage residents to par-
ticipate in the recycling program?
What Materials in Your Waste Stream
Should You Recycle?
When developing a waste reduction pro-
gram, the first step is to determine what type
of discards your tribe or village is generating
and in what quantity. A waste characteriza-
tion study will help you determine the waste
stream composition by identifying waste
types and volumes, existing waste manage-
ment practices (e.g., reuse, recycling, dispos-
al), and associated costs. It will help identify
which portions of the waste stream you can
effectively recycle, reduce, or eliminate all
together.
For example, the Quechan Indian Tribe in
Arizona monitored its waste stream composi-
tion and found that paper products made up
the bulk of the waste discarded in landfills.
Using these findings, the Quechan Tribe set
waste reduction goals and priorities based on
the specific materials that were being gener-
ated and thrown away. Once you have this
information, you can identify the extent to
which each element in the waste stream can
be recovered and recycled. For more infor-
-------
mation on conducting a solid waste stream
analysis, refer to Chapter 2.
What Markets Exist for Collected
Materials?
After your tribe has analyzed its waste
stream, you can decide what materials to tar-
get for recycling. Typically, you will want to
recycle materials that members generate in
large quantities for which there also is a local
market or some sort of end use. Of the paper
products generated by the Quechan Tribe,
office paper appeared to be the most mar-
ketable material because it was very clean,
although the paper varied in color and quali-
ty. The Quechan Tribe contacted potential
collectors and buyers, but found none were
interested in the office paper. The tribe then
pursued the idea of recycling the paper itself
and established a papermaking business that
would not only use the recycled office paper,
but also create jobs and generate income for
the tribe.
What Type of Collection Program Best
Suits the Community?
Various types of collection programs you can
consider include:
• Drop-off centers for recyclables
• Buy-back centers
• Curbside recycling programs
• Special collection events
Drop-off Centers for Recyclables
Drop-off facilities for recyclables work best
when they are located in centralized areas
that members of the tribe can access easily.
They are often found in locations that tribal
members frequent, such as grocery stores or
shopping areas, tribe-sponsored sites, transfer
stations, or residential areas. The Zuni
Pueblo Tribe of New Mexico set up nine
recyclables collection centers in areas fre-
quented by tribal residents and established a
processing and marketing system for the
materials it collected. At drop-off centers,
you can use labeled bins or containers to col-
lect a wide range of recovered materials,
from newspapers and cardboard to glass, alu-
minum, and steel containers. The Zuni
Pueblo takes the plastic, newsprint, alu-
minum, and glass the tribe collects to nearby
processing centers. For widely dispersed pop-
ulations, a drop-off center might be the most
economically feasible option for collecting
recyclable materials.
Buy-Back Centers
Buy-back centers are commercial operations
that pay tribal members for recovered mate-
rials. They can include scrap metal dealers,
aluminum can centers, or paper dealers.
Generally, buy-back centers collect materials
that have a high market value.
Although few tribes are currently making use
of buy-back centers, they remain feasible
options in some areas. For example, tribes
located in one of the 10 states with a bottle
bill container redemption program can
receive a refund of 5 to 10 cents for alu-
minum beer and soda containers at a local
buy-back center. The Shoshone-Paiute
The Eastern Band of
Cherokee Indians
bale its recyclables to
reduce transportation
costs and simplify
handling.
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Tribes of the Duck Valley Reservation in
Idaho and Nevada, for example, pays resi-
dents for aluminum cans brought to its trans-
fer station for recycling. Other tribes are
looking toward establishing their own buy-
back centers on their reservations.
Curbside Recycling Programs
Collecting recyclable materials at the curb-
side is most convenient for residents and
thus can lead to higher recovery rates.
Curbside collection also is a more expensive
collection option, as the tribe has to pay
workers to collect the materials and purchase
and maintain trucks and other equipment to
transport the materials to a recovery facility.
In spite of these costs, some tribes have
found curbside collection is worth the price.
The Confederated Tribes of the Umatilla
Indian Reservation, for example, collected
nearly 40 tons of corrugated cardboard,
paper, and steel for recycling in 2001
through its curbside collection program and
centrally located collection bins. The rela-
tive ease of curbside collection for tribal
members is helping the tribe work toward its
35 percent recycling goal.
Special Collection Events
To collect more recyclables, you also might
institute special recycling events in conjunc-
tion with curbside or drop-off collection pro-
grams. These events can include special
recovery days for large items or household
hazardous waste. The Fort Peck Reservation
in northern Montana holds an "Annual
Spring Cleanup Week," during which almost
everyone on the reservation mobilizes to
pick up litter, remove junk cars and furni-
ture, and properly dispose of recyclables and
waste. The tribes also use the cleanup, which
prepares the reservation for tourist season, as
an event to bring the community together.
When examining the various collection
options, consider which system is likely to
work best in your area. Factors that might
impact your collection option choice include
your tribe's population density, the availabili-
ty and distance to markets for recovered
materials, what transportation options are
available, the volume of materials residents
generate, how interested tribal residents are
in recycling, and whether appropriate fund-
ing and staff are available to work on the
recyclable collection program. For more
information on tribal collection options,
refer to Chapter 4, and for information on
revenue from recycling, refer to Chapter 7.
What Will the Program Cost, and How
Will It Be Funded?
Recycling programs, like waste collection
and disposal programs, cost money to set up
and run. The amount of funding your tribe
has available will affect the type of collec-
tion program you implement. You might be
limited by how much tribal members are
willing to pay for recyclables collection serv-
ices. In addition, if a tribe is located in a
remote area or has a small population, the
economic feasibility of the recycling program
might be limited, especially given other trib-
al concerns. When weighing the costs and
benefits of a recycling program, you might
want to consider the extent to which you
can build support for and encourage program
participation.
The major costs of a tribal recycling program
are capital costs to set up the program, and
operation and maintenance costs to keep the
program running, such as new equipment
purchases and staff salaries. Money to pay for
these expenses can come from user fees, trib-
al general funds, and some federal and state
grants and loans.
Grants and loans are good tools to help a
tribe get a recycling program off the ground.
After receiving a grant from the Oregon
Department of Environmental Quality and
providing matching funds of their own, the
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Confederated Tribes of the Warm Springs
Reservation in Oregon started a recycling
program on the reservation. Since receiving
the funding, the tribes were able to expand
from an aluminum can-only recycling system
to recycling a greater variety of materials and
reducing the amount of materials sent to the
landfill. Many federal grants have limitations
on how their money can be spent. Many
grants, for example, can not be spent on pro-
gram operation and maintenance. For this
reason grants might be a good source of
startup funding, but should not be relied
upon for program maintenance. For more
information on financing a recycling pro-
gram, including sources of grants and funds,
refer to Chapter 7.
Who Will Collect the Materials, and
Where Can You Take the Collected
Materials?
While developing the technical aspects of
the recyclables collection system, you might
want to evaluate the role your tribal govern-
ment and private waste management compa-
nies play. Some tribal leaders might decide
that tribal government should handle all
aspects of recyclables collection, while others
might advocate contracting with a private
hauler. You might be able to obtain collec-
tion services at a lower cost by bidding out
services to different private companies. The
Fond du Lac Band of Lake Superior
Chippewa in Minnesota hired several private
waste haulers to collect waste for the tribe.
The tribe also has studied the feasibility of
tribally operated waste hauling services.
If your reservation is very large, you might
issue separate contracts to private companies
for different geographic regions. If any near-
by tribal or non-tribal communities are inter-
ested in recyclables collection services, you
can work with these communities to provide
recyclables collection services on a regional
basis. Regional collection systems are partic-
ularly cost-effective if several small tribal
communities located close to each other can
use the same collection or disposal site.
How Can You Encourage Residents to
Participate in the Recycling Program?
If the program is new for the tribe, then con-
vincing tribal members to practice recycling
habits might take time. The success of a
recycling program will depend on early com-
munity involvement, followed by continuing
educational efforts. Start by showing mem-
bers how a recycling program can benefit the
tribe. Gauge members' interest in recycling
and their concerns about how a recycling
program will work. Being responsive to
members' input and providing clear informa-
tion will go a long way toward ensuring a
program's success.
One of the best ways to ensure strong partic-
ipation in your tribal recycling program is by
introducing recycling to schools. Not only
can schools serve as focal points for collec-
tion, but they also can instill a recycling
ethic in children. The children, in turn, will
take the recycling message home, encourag-
ing parents and other tribal elders to partici-
pate in tribal recycling events. When the
Nez Perce Tribe of Idaho received a grant
from USDA to fund a tribal recycling pro-
gram, one of its first steps was to go to the
schools. The Lapwai grade school was desig-
nated as a recyclables drop-off center.
Educators worked with fifth and sixth
graders to teach them about recycling and
instituted a Saturday afternoon class cover-
ing various environmental issues for elemen-
tary schoolchildren. The tribe invited
professionals from natural resources fields to
teach the children about environmental
conservation. Chapter 6 has more informa-
tion about setting up a recycling educational
program for tribal members.
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Beyond Recycling: Source
Reduction, Reuse, and
Composting
Because recycling is now entrenched in
many states and communities across the
nation, it is often the first waste reduction
effort considered by tribes. There are, how-
ever, many other ways for tribes and Alaskan
Native villages to practice waste reduction.
Many of these activities are simple to imple-
ment and do not require large amounts of
funding or a complex infrastructure.
What You Can Do To Reduce Waste
Use less toxic products.
Call direct mailers to remove your name from their mail-
ing lists.
Make duplex copies and print on both sides of the paper.
Reuse scrap paper as message pads or sketch pads for
children.
Use canvas bags in place of plastic or paper shopping
bags.
Reduce the use of chemical fertilizers on your plants.
Join EPA's WasteWise Program for more ideas
.
Source Reduction/Reuse Programs
Source reduction and reuse activities can help
reduce your tribe's waste management expens-
es by avoiding the costs associated with col-
lecting, transporting, processing, and disposing
of discards. Source reduction and reuse pro-
grams, which include materials exchanges and
backyard composting, also conserve resources,
such as water and energy, and reduce pollu-
tion, including greenhouse gases that con-
tribute to global climate change. Source
reduction also can help reduce the toxicity of
a tribe's waste stream by discouraging use of
products containing toxic materials, such as
cleaning products and pesticides.
Source reduction activities are an important
part of the Mohegan Tribe's waste manage-
ment program. In 1997, the Connecticut-
based tribe established an integrated waste
management program for the Mohegan Sun
Casino and the tribal government. The pro-
gram emphasizes source reduction activities,
along with recycling, over waste disposal
options. The tribe practices water-conserving
irrigation methods and uses native rather
than ornamental plants in landscaping.
Native plants are well adapted to their envi-
ronment, which means they require less
water, fertilizers, and pesticides for their
maintenance. The tribe also has minimized
its chemical use, switching to less toxic prod-
ucts where possible.
A number of resources are available to tribes
that can help them in their source reduction
efforts. Smith River Rancheria in California
joined EPA's WasteWise Program in 2001
and began implementing source reduction
activities immediately. The tribe's reception-
ist returns unwanted direct mail solicitations
and calls or writes to companies requesting
removal from mailing lists. Posters in the
tribal office remind staff about the duplex
printer feature, and tribal council members
and office staff copy meeting minutes and
other documents on both sides of the paper.
Reuse also can be a good alternative to dis-
posal for those materials for which recycling
markets are located far away. In the isolated
village of Kotzebue, Alaska, several business-
es and organizations collect scrap office
paper. Every few weeks, the businesses deliv-
er this paper to tribal schools, local daycare
centers, and children's homes for reuse.
The severe weather conditions in Alaska also
have led to creative source reduction and
reuse activities. In Galena Village, Alaska,
winds blew hundreds of white plastic shop-
ping bags around the community, which
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became entangled in nearby trees, clung to
the frozen tundra, or choked and entangled
local wildlife. The Tribal Council passed a
resolution prohibiting the three local stores
from using plastic shopping bags. At first, the
store owners were apprehensive about the
ordinance, wanting to know what alterna-
tives would be available to them. The coun-
cil worked with store owners to identify
alternatives, such as brown paper and
reusable canvas bags, and explained the envi-
ronmental benefits. Once they found alterna-
tives, local merchants accepted the change.
Source reduction and reuse practices can be
easy for your tribe to adopt. Tribal members of
the Blue Lake Rancheria Tribe in California
also practice source reduction and reuse by
using the double-sided copier function when-
ever possible and using the back side of once-
used paper for drafts. These simple activities
have helped the tribe save money by cutting
down the amount of paper purchased.
Materials Exchange Programs
A materials exchange is a reuse program that
offers a market for buying and selling
reusable and recyclable commodities.
Materials exchange programs help tribes
redirect unwanted materials to potential
users. Materials can be offered for free or for
a price, typically below the market value of
the goods or materials being offered. Tribal
members that contribute materials for sale or
donation save time and money by not hav-
ing to dispose of the unwanted materials,
and purchasers benefit by obtaining goods or
materials at no cost or for a nominal fee.
Examples of materials exchanges that tribes
use include:
• Reuse centers, secondhand stores, or flea
markets where residents donate or sell
unwanted goods to others.
• Physical warehouses that advertise avail-
able commodities through catalogs.
• Computer listings or Web sites that con-
nect buyers and sellers.
• Informal word-of-mouth communications.
Many tribes schedule events or set up tempo-
rary or permanent reuse centers where tribal
residents can donate products and materials
that they no longer need. The collected
materials are then made available to tribal
schools, senior centers, or other tribal resi-
dents. Some tribes establish and run second-
hand stores or swap meets, where residents
can donate or sell their used materials
instead of throwing them away.
The Pine Ridge Oglala Sioux Tribe holds
regular "swap days." Tribal members bring
items they no longer want to a central loca-
tion, where they swap or sell them to each
other in a flea market-like setting. The
Oneida Tribe of Indians in Wisconsin has
found it beneficial to hold a week-long
clothing and household item exchange. In
one week, tribal members donated 770
pounds of clothing and 1,300 pounds of mis-
cellaneous household items for reuse by
other members of the tribe. At the end of
the week, the tribe transported leftover items
to other reservations in the state.
The Alaska Materials Exchange (AME) is an
information clearinghouse to help Alaskan
businesses reuse products and materials and
find alternatives to throwing valuable materi-
als into local landfills. Through quarterly cat-
alogs, AME lists surplus and unwanted
material from one company that others can
use. The materials exchange is a service of
the state Department of Environmental
Conservation in cooperation with BP
Exploration and ARCO Alaska, Inc. Since
1994, AME has saved Alaskan businesses
more than $1.4 million in disposal costs.
Currently, AME has more than 100 listings
and a subscriber list of 2,500 organizations.
Tribes where the majority of residents have
access to computers also might want to set
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up a computer network or brochure listing
materials that tribal members or businesses
no longer want that other members of the
tribe could use. Materials listed can include
manufacturing or construction materials,
such as wood, textiles, or concrete. Tribal
members also may choose to list appliances,
office or home furnishings, or computers in
their materials exchange.
Tribes do not need high-tech capabilities to
put a materials exchange program in place.
The Confederated Tribes of the Umatilla
Indian Reservation
in Oregon maintain a
more informal mate-
rials exchange pro-
gram. The tribal
government opera-
tions manager e-
mails tribal
employees when resi-
dents bring in used
items to exchange.
The tribal employees
then inform commu-
nity members that
items are available
for reuse.
Composting
Programs
Composting is the
controlled decompo-
sition of organic
materials, such as
leaves, grass, and
food scraps, by
microorganisms. The
result of this decom-
position process is
compost: a crumbly,
earthy-smelling, soil-
like material. Your
tribe can use compost
material in its gar-
dens and other land-
scaping applications or sell it to individuals
or businesses outside the tribe for a profit.
Two types of composting programs you can
set up include:
• Residential backyard composting programs
• Community composting facilities
In a residential backyard composting pro-
gram, tribal members leave cut grass clip-
pings on their lawn and collect other yard
trimmings and gather them into a backyard
mulch pile. You can teach members how to
Eastern Band of Cherokee Indians' composting operations. Top: windrow
turner aerates the piles to increase decomposition. Bottom: watering the
piles helps maintain the proper moisture levels.
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compost and can offer composting bins to
residents to encourage the practice. The
Oneida Tribe of Indians in Wisconsin sells
backyard composting bins to residents to
promote backyard composting among mem-
bers and also teaches adult education classes
on backyard composting. Through practicing
backyard composting, residents will have less
trash to dispose of and will gain a soil
amendment product that will improve the
consistency of the soil in their own gardens.
If your tribe chooses to establish a communi-
ty composting facility, residents can leave
yard trimmings at the curbside for collection
or drop them off at a designated site. Factors
you might consider when selecting a drop-off
site are similar to those for choosing a recy-
clables drop-off site, including convenience
for tribal members and low impact of odors,
dust, or noise on tribal members. You will
need to train and hire staff to run your facili-
ty. One factor that contributed to the success
of the Eastern Band of Cherokee Indians'
pilot casino composting program in North
Carolina was integrating the composting
process into employee training and routine
procedures at the casino. The tribe also hired
an additional employee to handle some of
the composting responsibilities.
You can use the compost you produce for
landscaping projects on your reservation. If
you control and document the composition
and nutrient content, then you can sell its
compost to farms, nurseries, or greenhouses
in the area and use the profits to fund other
tribal activities.
Tribal and village businesses also can partici-
pate in composting programs, with the added
benefit that they will contribute larger quan-
tities of materials. Sitka Tribal Enterprises in
Alaska designed a composting program to
produce marketable products from organic
wastes of Alaskan industries. Aerated, turned
windrows produce high-quality, nutrient-
rich, organic, soil-like compost from fish and
timber wastes. The result is certified organic
products, such as potting soil and transplant
mix, from Alaska's own land and water. The
project has provided jobs for village residents
and serves as a model for other Alaskan
Native communities.
Buying Recycled Products and
Manufacturing with Recovered
Materials
Materials collected through recycling and
composting programs need to be made into
products in order for the recycling process to
be considered "complete." More and more
products are now available that have been
made from recycled materials. Buying these
products on an individual and tribal level
can help support the demand for these mate-
rials in the marketplace and thereby enhance
the viability of tribal recycling programs.
Additionally, some tribes themselves have
been successful in "closing the recycling
loop" by establishing their own businesses to
use the materials they collect. These busi-
nesses, in turn, provide both revenues and
jobs for tribal members.
Buy-Recycled Programs
For most of the products that tribal employ-
ees and residents purchase, there probably is
The Eastern Band of
Cherokee Indians use
a tub grinder to chop
branches and brush for
composting.
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Tribal Business Waste Reduction Programs: Targeting Hotels and Casinos
Approximately 400 hotels, motels, and resorts and 200 casinos and bingo halls are located in Indian country.
These facilities generate a tremendous amount of solid waste, from food scraps, glass containers, and metal
cans to plastics, paper, and cardboard. Tribal hotel and casino operators can prevent waste when purchasing
supplies and food, serving customers, and cleaning guest rooms, and many have found these actions also
have the economic benefit of reducing purchasing costs and disposal fees.
The Eastern Band of Cherokee Indians in western North Carolina started a pilot project to compost food
scraps from its casino and three restaurants after they opened in 1997. The tribe collects more than 1,200
pounds of food scraps each day from the casino and restaurants for composting. The tribe sells the final
compost product to landscapers, nurseries, and homes both on and off the reservation.
The Lac du Flambeau Band of Lake Superior Chippewa Indians developed a pilot waste reduction program
for the Lake of the Torches Casino on its reservation in north-central Wisconsin. Initially, the tribe undertook
a waste characterization study to determine its waste stream composition. The tribe found that cardboard
made up 70 percent of the waste stream by weight, and food and paper was another 12 percent. The tribe
has three goals: reduce the amount of waste generated; reuse rather than discard items; and recycle as
much of the remaining waste stream as possible. The tribe met with several challenges while developing its
waste reduction program. The casino struggled to reduce cardboard waste, since most of the cardboard
came from packaging sent by outside suppliers, so it reused many of these boxes internally to avoid recy-
cling or landfilling them. The casino worked with its hauler to collect and weigh recyclables regularly and
document their destination. In addition, the casino instructed employees how to prepare and separate recy-
clables to the hauler's specifications. The tribe's waste reduction plan included purchasing supplies in bulk
to reduce packaging waste; using washable rather than disposable dinnerware and utensils; and, replacing
individually bottled cleaning supplies with a central housekeeping supply station stocked with nonhazardous
cleaners purchased in bulk.
The Grand Traverse Band of Ottawa and Chippewa Indians in Michigan wanted to teach its hotel, casino,
and restaurant managers how to recycle, prevent waste, and buy recycled-content products. Tribal environ-
mental department staff worked with businesses to insert waste reduction education into new employee
welcome packets. The tribe also reduced waste during hotel renovation projects by donating old furniture
and fixtures to residents and local businesses.
a recycled-content alternative. Recycled-
content products not only are typically of
the same quality as products made from vir-
gin materials, but they also can cost less
money. Buying recycled sends a message to
manufacturers that recycled products are in
demand, which helps ensure that the materi-
als the tribe is recovering are being put to
good use. When tribal members buy recycled
products, they help expand the markets for
recovered materials. Tribal businesses that
manufacture products from recovered materi-
als can provide jobs for tribal members and
revitalize local economies.
Setting Up a Buy-Recycled Program
Tribal governments purchase everything
from office paper to construction materials.
You can set a positive example for your
members by instituting a buy-recycled pro-
gram. Key elements to setting up a buy-recy-
cled program can include:
• Setting purchasing specifications to
include recycled content
• Establishing recycled-content standards
• Giving preference to recycled products
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Set Purchasing Specifications To Include
Recycled Content
Tribal purchasing officials can review product
and service specifications or policies to iden-
tify and eliminate any provisions that require
the use of virgin-content products or that
exclude the use of recycled-content products.
Smith River Rancheria in California, which
purchases recycled-content copier paper, cal-
endars, pencils, envelopes, and file folders,
conducted a purchasing audit. This audit
identifies the products the tribe is purchasing
that are made from virgin materials and helps
it find recycled-content alternatives.
Establish Recycled-Content Standards
Many government agencies have established
voluntary or mandatory minimum recycled-
content standards that apply to their own
purchases of certain goods and materials.
Your tribe can use these standards as a guide
in developing your own standards.
Guidelines can vary on the minimum per-
centage of recycled materials required in spe-
cific products. For instance, the recycling
coordinator for the Confederated Tribes of
the Umatilla Indian Reservation in Oregon
asked the tribal purchasing department "to
make every effort" to purchase recycled-con-
tent products where possible.
The purchasing department for the
Confederated Tribes of the Umatilla seeks
out vendors that sell recycled-content prod-
ucts. In 2001, for example, the tribe pur-
chased one thousand 100-percent recycled
content toner cartridges and other recycled
content items including paper, boxes, pallets,
drums for storing hazardous materials, and
totes. "At first, [purchasers] were hesitant to
buy recycled content products because they
were concerned about quality," said Teddi
Bronson, recycling coordinator for the tribe.
"But after purchasing recycled products, they
realized they were as good as the products
they purchased before."
Closing the Loop
The recycling symbol has three chasing arrows. T"\
Each arrow represents one step in the recycling \ |
loop.
The first arrow is the collection step. This is when you put
your recyclable materials into your curbside recycling bin
or take it to a local drop-off center. The collected materi-
als then can be taken or sold to a manufacturing facility.
The manufacturing process is the second arrow in the
recycling symbol. The recyclable materials are converted
into new products and shipped to stores.
The third arrow represents the step where the consumer
purchases products made with recycled content.
When you "buy recycled," you close the recycling loop.
Give Preference to Recycled Products
With current technologies and scales of pro-
duction, some recycled-content products cost
more than their virgin competitors.
Eventually, prices for recycled products
might be competitive with prices of products
made from virgin materials, but until then,
recycling activities can be supported by price
preferences for recycled-content products. A
typical price preference can cost out recy-
cled-content products at 5 to 10 percent
lower cost than comparable virgin products.
Even without price preferences in place, trib-
al recycling coordinators are finding that
businesses and residents are still buying recy-
cled, once they are educated about it. "Our
tribal members buy recycled because it pro-
tects the environment," Bronson said. "That
is the benefit they see to buying recycled."
Your tribe also can establish buy-recycled
cooperatives with other, neighboring tribes,
local governments, or organizations. The
Grand Traverse Band of Ottawa and
Chippewa Indians, for instance, partnered
with two neighboring tribes so that they
could increase their purchasing power to
encourage the production and sale of recy-
-------
cled-content products. To set up such a
cooperative, tribal leaders/purchasing agents
can contact neighboring tribes, determine
what purchases they have in common, and
agree to purchase these products in recycled-
content from a vendor that can supply the
highest-quality recycled-content product at
the best price.
Manufacturing with Recovered
Materials
Some tribes, like the Hopi Tribe in Arizona,
have found new business opportunities and
helped create jobs for residents through man-
ufacturing with recovered materials. The
tribe's unemployment rate had often caused
residents to seek jobs as far away as Phoenix,
more than 200 miles from the reservation.
The tribe received an Inter-Tribal Council of
Arizona grant to fund solid waste manage-
ment planning on the reservation.
Gentle Rain Designs, organized under the
Hopi Foundation, a local organization with a
mission to "foster self-reliance, self-sufficien-
cy, and a sense of pride," in tribal members,
received a $16,000 startup grant from the
Arizona Department of Commerce. Gentle
Rain Designs creates and sells garments fea-
turing cultural designs, made of fabric pro-
duced from recycled polyethylene
terephthalate (PET) from 2-liter soda bot-
tles. Tribal members expanded production to
include fleece jackets and vests. Tribal mem-
bers employed by this operation have the
freedom to work out of their homes and set
their own schedules. In addition, the Gentle
Rain Designs workers generate products that
not only serve to artistically preserve Hopi
culture, but also, thanks to their recycled
content, help to preserve the environment.
Gentle Rain Designs has successfully market-
ed its business in outdoor industry trade mag-
azines and at Native American events, art
shows, outdoor retailer shows, and other
recycled products trade shows. In addition,
the company has expanded its partnerships,
receiving support from the Grand Canyon
Trust, the First Nations Development
Institute, and Arizona Community
Foundation. "When you demonstrate ability,
organizations come looking for you," said
Mike Puhuyesva, director of solid waste for
the Hopi Tribe. "You no longer have to go
out and seek money with grant proposals; it
comes in."
Chapter Highlights
• Use waste assessment results to identify
potential for recycling and opportunities
for source reduction, or composting.
• Identify markets or end users for recy-
clables, compost, and other exchange-
able materials.
• Use community outreach and education
to educate and energize tribal members
about your tribe or village's waste reduc-
tion programs and increase participation.
• Buy recycled-content products to close
the recycling loop.
• Manufacture with recovered materials to
stimulate markets for recyclables, create
jobs, and generate revenue.
Resources
A variety of additional resources are avail-
able to help tribes reduce, recycle, compost,
purchase recycled products or manufacture
with recovered materials:
Publications
EPA's Recycling Guide for Native American
Nations (EPA530-K-95-006), provides infor-
mation for tribes developing recycling pro-
grams. Available on the Web at or by contacting the RCRA/
Call Center at 800 424-9346.
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EPA's Waste Prevention, Recycling, and
Composting Options: Lessons from 30
Communities (EPA530- C-01-002) highlights
the actual operating experience of 30 diverse
communities. The report is available on the
Collection of Solid Waste Resources CD free
of charge from the National Service Center
for Environmental Publications at 800 490-
9189. Information for ordering by mail or fax
is available at .
A Native American Agenda for Action: Solid
Waste Management in the 1990s, published by
EPA Region 6, describes the scope of the
solid waste problem in Native American
communities and offers solutions. To order a
copy, contact EPA Region 6 at 214 665-6760.
EPA's Source Reduction Program Potential
Manual (EPA530-R-97-002), describes six
source reduction options (grasscycling, home
composting, clothing reuse, office paper
reduction, converting to multi-use pallets,
and paper towel reduction) to help solid
waste managers determine the potential
impacts of source reduction on their solid
waste program. Available on the Web at
or by contacting the
RCRA Call Center at 800 424- 9346.
EPA's Composting Yard Trimmings and
Municipal Solid Waste (EPA530-R-94-003),
examines planning, siting, designing, and
operating composting facilities. Available on
the Web at or by contacting the RCRA
Call Center at 800 424-9346.
EPA's Waste Reduction Tips for Hotels and
Casinos in Indian Country (EPA530-F-00-
007), shows how tribes can set up a waste
reduction program on tribal casinos and
highlights successful tribal programs.
Available on the Web at
or by contacting the RCRA Call Center at
800 424-9346.
EPA's Business Guide for Reducing Solid Waste
(EPA530-K-92-004), provides instructions
for performing a waste audit — useful for
businesses and governmental organizations
establishing a waste reduction program.
Available on the Web at or by contact-
ing the RCRA Call Center at 800 424-9346.
EPA's Climate Change and Waste: Reducing
Waste Can Make a Difference (EPA530-E-03-
002), explains how preventing waste and
recycling can help reduce emissions of green
house gases that cause climate change.
Available on the Web at or by contact-
ing the RCRA Call Center at 800 424-9346.
Download the Alaska Materials Exchange
Catalogue at , or
for more information contact the
Compliance Assistance Office in Anchorage
at 907 269-7586.
Periodicals
The following periodicals provide informa-
tion on innovative and successful waste
reduction practices and strategies.
• BioCycle — Phone:
610 967-4135 Mailing address: The JG
Press, Inc., 419 State Avenue, Emmaus,
PA 18049 E-mail: biocycle@jgpress.com
• MSW Management — Phone: 805 682-1300 Fax:
805 682-0200 Mailing address: Forester
Communications, Inc, P.O. Box 3100,
Santa Barbara, CA 93130
• Resource Recycling — Phone: 503 233-1305
Fax: 503 233-1356 Mailing address:
Resource Recycling, P.O. Box 42270,
Portland, OR 97242-0270 E-mail:
info@resource-recycling.com
-------
• Waste Age —
Phone: 866 505-7173 Fax: 402 293-0741
Mailing address: Waste Age, 2104
Harvell Circle, Bellevue, NE 68005 E-
mail: wecs@pbsub.com
• Waste News — Phone: 800-678-9595
or 313-446-0450 Fax: 313-446-6777
Mailing address: Waste News, 1725
Merriman Road, Akron, Ohio 44313 E-
mail: subs@crain.com
Web Sites
Environmentally Preferable Purchasing:
EPA's
Environmentally Preferable Purchasing Web
site has links to contracts that federal agen-
cies have set up to purchase specific recy-
cled-content products.
Energy Star: EPA's
EnergyStar Program promotes the use of
energy-efficient products and services.
EnergyStar can help tribes, businesses, and
consumers find energy-efficient solutions,
including tools to help measure current ener-
gy performance and estimate potential for
improvement.
EPA's Comprehensive Procurement
Guidelines (CPG): The
CPG Program promotes federal purchase of
recycled-content products. The CPG Web
site includes information on the CPG and
EPA's Recovered Materials Advisory Notices
(RMANs) that can recommend recycled-
content levels for CPG items to tribes.
EPA's WasteWise Program: WasteWise is a free, voluntary,
EPA program through which tribes and
Alaskan Native villages, communities, and
organizations can work to eliminate waste,
benefitting their bottom line and the envi-
ronment. The WasteWise program can help
partners design their own solid waste reduc-
tion programs tailored to their needs.
Department of Energy's Federal Energy
Management Program (FEMP):
FEMP works to
reduce the cost and environmental impact of
the federal government by advancing energy
efficiency and water conservation, promoting
the use of distributed and renewable energy,
and improving utility management decisions
at federal sites. Interested tribes can use this
resource as well.
Resource Conservation Alliance (RCA):
RCA's mission
is to protect natural forests and other ecolog-
ically important systems through market-
and commodity-based conservation strate-
gies, including reduced consumption and
increased recycling, redesign, and resource
diversification. The RCA list of Web links of
EPP programs including federal, state, local,
and green building programs that tribes can
learn from.
50 Ways to Save the Environment:
This Web site covers
activities that people can do in their home,
car, and yard; at work; and when they are
shopping to protect the environment.
Web sites that connect buyers and
sellers of recovered materials:
• Recyclers' World:
• Used Building Materials Exchange:
• Resource Exchange Network for
Eliminating Waste (RENEW):
• RecycleXchange:
• Washtenaw County Materials Exchange:
-------
Chapter 6. Public Education and
Community Outreach
Public education and community out-
reach are integral parts of any tribal
solid waste management program.
Well planned education and outreach initia-
tives can help generate understanding and
support for waste management issues in your
tribe. They also can be used to teach resi-
dents how to comply with waste manage-
ment and recycling activities to the overall
benefit of the tribe.
This chapter describes steps a tribe or
Alaskan Native village can take to design an
effective education program. Examples of
tribal education efforts are provided through-
out the chapter. Additionally, the chapter
presents strategies for crafting an education
program specifically designed to decrease
illegal dumping and use of burn barrels.
Appendix C includes sample public educa-
tion tools tribes have used. The Resources
section at the end of this chapter provides
complete reference and ordering information
for the documents cited in this chapter, in
addition to other outreach and education-
related resources.
Designing an Effective
Education Program
Designing an effective public education cam-
paign requires both funding and expertise.
As described in this chapter, you can often
find creative, low-cost ways to accomplish
your education goals, even if you have a
small staff or a limited budget. The main
steps to consider in designing an effective
education program are:
• Identifying your goals and audiences
• Crafting a clear and useful message
• Choosing an outreach method
• Creating incentives and deterrents
Working through these steps does not need
to be time- or resource-intensive. In fact, you
probably have considered some of these
issues already. But thinking through these
steps in a methodical way can help ensure
that your resources are well spent and your
program has an impact. For additional tech-
nical assistance, consider contacting the
tribes whose educational programs are high-
lighted in this chapter for their advice. For
financial assistance, refer to Chapter 7 for
ideas on getting the funding and other
-------
resources necessary to implement public edu-
cation efforts.
Identify Your Goals and Audiences
Before you begin an educational campaign, it
is useful to clearly identify your outreach goals,
keeping in mind your overall solid waste man-
agement program objectives. For example, if
an overarching goal of your waste manage-
ment program is to reduce illegal dumping on
the reservation, the objective of your outreach
might be to: 1 ) educate tribal members about
the causes and effects of illegal dumping, 2)
encourage tribal members to change behavior
The White Earth Band of Chippewa distribute calendars as part of its out-
reach program.
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1 ',/7f?V,"'=^f-
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WHITE EARTH N«FL'RAL RESOURCES
2001
to avoid illegal dumping, and 3) encourage
tribal members to report any incidents of ille-
gal dumping that they witness.
Your outreach goals are closely linked to,
and often define, your target audience.
Depending on your goals, you might be
directing your message to any or all of the
following sectors of the tribal population:
illegal dumpers, schoolchildren, tribal offices
that produce waste, tribal businesses and
industries, or other individuals. You might
also need to reach audiences beyond the
reservation— for example, illegal dumpers
that are not tribal members.
In some cases, you also might need to direct
your efforts towards the tribal staff responsi-
ble for implementing waste management
laws and programs. Education can help
ensure that staff fully understand their role
and what is being asked of tribal members
under a program.
Craft a Clear and Useful Message
Once you have defined your goals and target
audiences, consider the specific messages you
want to impart to achieve your objectives.
Messages are simply the ideas or information
you want to communicate. They should be
clear, concise statements that can be repeat-
ed every time you communicate. Generally,
you do not want to overwhelm your audi-
ence with too much information, so you
might limit yourself to three or four simple
messages, using language that speaks to the
audience.
To craft effective messages, you might ask
yourself the following questions:
• Why are you interested in educating the
tribal community?
tribal community?
• What does the tribal community need
know?
to
•<«.«, v,,» ,,„,! I
What would you like tribal members to
do?
-------
• What other information can you provide
that might act as an incentive or deter-
rent that will encourage tribal members
to do what you would like them to do?
As you develop your messages, keep in mind
your target audiences and how they will per-
ceive and respond to your messages.
Consider such issues as:
• What are their core values?
• How do they process information?
• What motivates them to take action?
In addition, consider any factors that could
influence how receptive your target audi-
ences will likely be to your information. For
example, will they bring preconceived
notions to the issue? Are there historical or
tribal sensitivities surrounding the issue? Are
there greater priorities or competing chan-
nels of information that could detract or
undermine your messages? Keep in mind that
you will likely need to tailor your message so
that it appeals to different audiences.
As you are developing messages, remember
that it is important to teach tribal members
why new laws and new programs are in place
and why they need to handle and dispose of
their waste in a particular way. When tribal
members understand why certain waste man-
agement practices are bad for public health,
the environment, and wildlife, for example,
they are more likely to handle their waste
differently.
Without this type of explanation, residents
might be more resistant to change. For
example, tribal members might be more like-
ly to stop burning trash if they learn that the
pollution from burning is bad for their
health. Similarly, they might be more likely
to stop illegal dumping if they learn that the
pollution created by open dumps can con-
taminate the water they drink or poison the
fish they eat.
^ ,, I .(' M.\, t " I I K l TV I Ulill
Examples of outreach brochures from the Southern Ute Indian Tribe and
Jicarilla Apache Nation.
Choose an Outreach Method
The next step is to determine the best way
to get your message to your target audiences.
You might already have a clear sense of the
preferred information dissemination chan-
nels in your tribe. For example, perhaps your
tribal newsletter is widely read or a particular
radio station is popular. If you want input on
your audience's preferences, you can hold
informal discussions with tribal members or
perhaps convene a focus group of representa-
tives of different segments of the tribal com-
munity, including business leaders, residents,
teachers, and government officials.
Consider more than one method for convey-
ing your information. Your outreach messages
-------
are likely to have more impact if they are
heard more than once. You might do an ini-
tial outreach campaign using flyers, for exam-
ple, and then follow up with an article in the
tribal newsletter a couple of months later.
As you are considering the many options for
distributing your message, consider the tribe's
budget, staff availability, and the technical
requirements of your options. When possi-
ble, consider ways to use existing tribal com-
munity outreach programs and tools to get
your messages to your audiences. Frequently,
tribes will not have to create their educa-
tional materials from scratch. Many existing
educational resources are available from
other tribes, nonprofit organizations, and
non-tribal governments. Often, these materi-
als can be used as-is or modified to fit your
needs. See Appendix C for ideas.
If you do need to create outreach products
specifically for your program, consider cre-
ative and low-cost ways of producing these
items. For example, if you need a poster
explaining what materials are accepted at
your transfer station, think about sponsoring
a poster contest in the school system. If you
need 300 flyers for your new recycling pro-
gram, consider a barter with a local printer.
For example, the printer might donate its
services in return for placing an advertise-
ment for its business on the back of the flyer.
When designing any outreach products for
your educational program, always consider
ways to incorporate elements of your tribal
culture to help tribal members feel a connec-
tion to the program.
Create Incentives and Deterrents
In addition to using specific outreach tools
to convey your message, consider other
avenues for delivering your message that are
likely to create incentives (or, in some cases,
deterrents) for action. For example, some
educators highlight the endorsement and
support they receive from respected tribal
officials or elders to increase the credibility
of the messages they distribute. When lead-
ers from the Tribal Council or Reservation
Business Committee deliver messages about
proper waste management and respect for
the land, they can have a powerful influence
on the members, creating an incentive for
them to listen to your message. In addition,
tribal leaders can ask tribal agencies to get
involved, mobilize community support, and
leverage funding and other resources.
You can create incentives to manage waste
properly through public recognition of waste
management "champions" or by sharing suc-
cess stories with the tribal community; for
example, efforts that helped increase tribal
recycling rates. Another good incentive is to
remind tribal members of the values and
ethics that are important to the tribal com-
munity (for example, protecting the Earth
and considering future generations), since
these are values that can encourage them to
manage waste properly.
The Red Cliff Tribe in Wisconsin signifi-
cantly reduced backyard burning on its reser-
vation through a voluntary incentive
program that gives residents a chance to turn
in their burn barrel and receive $20 worth of
trash bags. The bags encourage tribal mem-
bers to take their discards to the tribe's trans-
fer station. When residents turn in their
burn barrels, they sign a pledge acknowledg-
ing that they understand that burning trash
in barrels causes harmful pollution. Program
participants receive a certificate, along with
10 free trash bags.
Creating deterrents also helps discourage
illegal activities that can harm public health
and the environment. Publicizing new laws
and associated penalties or publicizing suc-
cessful convictions of illegal dumpers and
levied fines can deter illegal dumping. The
Seminole Nation in Oklahoma publishes
newspaper articles on the consequences of
breaking tribal waste management laws, lists
-------
the names of the responsible parties, and
offers rewards for information leading to
convictions.
Sample Educational Tools
Education can take a variety of forms,
including written materials (e.g., fact sheets,
newsletters, articles, flyers, inserts, question
and answer pieces); visual materials (e.g., sig-
nage, posters, slides, charts, Web sites); and
events (e.g., meetings, community forums,
and workshops). The following are some
real-life examples of tribal public education
efforts.
Signage
Signs placed in strategic locations are a low-
cost, low-effort way of educating tribal mem-
bers about various waste management
options or regulations. They are particularly
useful for no dumping and anti-litter cam-
paigns. They also are effective when posted
at transfer stations and recycling facilities to
clearly explain what materials are accepted.
• The Red Lake Band of Chippewa in
Minnesota strategically posted more
than 25 "No Dumping" signs at accesses
to off-road areas and other potential ille-
gal dumping locations. The signs state
that dumping is prohibited and punish-
able by a fine. They also include the per-
tinent tribal resolution number. The
tribe keeps litter away from the "No
Dumping" signs to give the message cre-
dence.
Other Written Materials
(Inserts/Fiyers/Articies)
Inserts and flyers are another low-cost
method of spreading information. By devel-
oping a simple message and distributing it to
tribal residents, the tribal leaders can impart
information about waste management pro-
grams. Additionally, putting certain informa-
tion in writing (e.g., materials accepted for
recycling, household hazardous waste collec-
tion dates) is useful because tribal members
can keep and refer to the information
received.
• The Resource Management Division of
the Fond du Lac Band in Minnesota
periodically inserts its Environmental
Program Newsletter in the tribal news-
paper, to reach a large number of resi-
dents at a low cost.
• The San Carlos Apache Tribe
Environmental Protection Agency in
Arizona mailed a flyer to all tribal mem-
bers to tell them about the tribe's new
transfer station, its rates, and items it
accepts. The head of the agency also
writes articles on waste management
issues for the local newspaper.
Door-to-Door Campaigns
Door-to-door campaigns are beneficial
because tribal educators can talk directly to
tribal members. A door-to-door campaign
can be more time-consuming and labor-
intensive than other education options, but
The Lac Courte Oreilles1 transfer station sign lists the hours of operation and
types of waste accepted.
-------
it can be invaluable in reaching people,
especially in situations where rules or laws
have changed, or where you anticipate resist-
ance to a new program. A door-to-door cam-
paign also lets you hear directly what issues
are important to tribal members and what
questions or concerns they have. It also has
an added benefit of enabling you to track
every individual that you reach, thereby
helping you gauge the effectiveness of your
program (see section on "Carrying Out
Top: entries in the Klawock Cooperative Association's (Alaska) Trash Art con-
test held during its 2003 Earth Day Celebration. Bottom: Trashion Show win-
ners from the Klawock Cooperative Association's (Alaska) 2003 Earth Day
Celebration.
Program Measurement Activities" later in
this chapter for more information).
• The Alabama-Coushatta Tribe of Texas
had opened a transfer station and cov-
ered all disposal costs for its members as
an incentive for proper disposal. But
tribal members continued to use burn
pits and other illegal disposal methods.
Consequently, the tribe's Solid Waste
Department conducted an aggressive
door-to-door campaign explaining the
dangers of illegal dumping and the bene-
fits of using the transfer station. Transfer
station use grew as awareness increased.
• The Fond du Lac Band of Chippewa in
Minnesota organized a door-to-door
mercury thermometer exchange for
ninth and tenth graders to teach them
about household hazardous waste dispos-
al issues. The students went to private
residences with non-mercury thermome-
ters and exchanged them for mercury
thermometers.
Outreach to Schools
Some tribal leaders focus outreach initiatives
on schools, teaching children about solid
waste, why it is an important issue, and how
to safely and effectively manage waste. These
campaigns are conducted with the hope that
the children will teach their family what
they learn in school, take personal responsi-
bility for the waste they generate, and con-
tinue to manage waste properly as adults.
Because children will ultimately be the deci-
sion-makers for the tribe, teaching personal
responsibility for solid waste early on can
only benefit your tribe in later years.
• The director of the White Mountain
Apache Tribe's Solid Waste Department
in Arizona visits area schools to deliver
educational programs on waste manage-
ment issues. Sixth graders learn how to
conduct waste assessments, fourth and
fifth graders play environmental education
-------
games, and the youngest students use col-
oring books to familiarize themselves with
basic waste management concepts.
• The St. Regis Mohawk Tribe
Environment Division in New York
sponsored a series of cartoons, Kwis and
Tiio: Solid Waste Management on the
'Rez, to increase awareness of proper
solid waste management practices and to
illustrate how disposal practices impact
the environment.
• The Red Lake Band of Chippewa
Indians in Minnesota helped students at
the tribe's high school produce an edu-
cational video on illegal dumping on the
reservation. Not only did the students
who made the video get to learn first-
hand about illegal dumping, but the
video served to educate others as well.
• The Fond du Lac Band's Natural
Resources Division in Minnesota
obtained a resolution from the
Reservation Business Committee in sup-
port of its illegal dumping prevention
program. The division brought the reso-
lution to the tribe's Ojibwe High School
and Fond du Lac Elementary School and
asked the schools to participate in an
Earth Day cleanup. School administra-
tors and teachers worked with the stu-
dents to clean up and adopt the road in
front of the school.
• The Pawnee Nation in Oklahoma creat-
ed the Pawnee Environmental
Education Center to educate students in
tribal and local non-tribal communities
about waste management and other
environmental issues.
Meetings and Community Events
Another way of getting your message out is
through meetings and community events.
You might decide to organize a special meet-
ing to communicate your information or
make a presentation as part of a regularly
scheduled tribal meeting. Meetings enable
you to talk directly with your target audi-
ence, offering the benefit of two-way interac-
tion. Educators have a forum for
communicating their messages and informa-
tion, while also hearing their audience's
issues and concerns.
You also can hold an event, such as a com-
munity cleanup, a household hazardous
waste collection day, or a children's poster
contest, where the winner is publicly recog-
nized. Events can be fun, interesting, memo-
rable, and effective in getting your message
out. It might be useful to turn a 1-day activi-
ty into an annual or monthly event to pro-
mote your message.
• At community events, the
Environmental Office of the Seminole
Nation in Oklahoma sets up a booth to
distribute educational materials. The
director of the Environmental Office
also discusses current waste management
issues in a weekly tribal radio program.
• The Lac Courte Oreilles Conservation
Department of the Lac Courte Oreilles
Chippewa Tribe in Wisconsin delivers
Children learn about recycling at the Klawock Cooperative Association's
(Alaska) Earth Day Celebration.
-------
presentations at the regular Community
Circle meetings in each of the tribe's 23
villages.
• The Delaware Nation of Oklahoma's
"Adopt a Highway" program enlists
interested tribal community groups and
residents in removing trash from an
adopted stretch of highway four times
each year.
Workshops/Training
Workshops and training sessions are valuable
ways to educate your audience about a new
program, policy, or waste management
option. These sessions can provide a hands-
on learning experience for participants, as
well as an opportunity to ask questions or try
out new techniques.
• The Gila River Indian Community in
south-central Arizona held a workshop
to educate its target audience—tribal
officials and representatives—about the
illegal dumping provision of the tribe's
Solid Waste Ordinance and how to
enforce it. The workshop was attended
by a councilman, the Police Chief and
police officers, tribal rangers, a prosecu-
tor from the Law Office, the Chief Judge
and Assistant Judge, a livestock officer,
and representatives from the
Department of Transportation,
Emergency Management, and Public
Works. Through the workshop, tribal
Table 7. Comparing Tribal Outreach Methods
Method Investment of Time/Labor Monetary Cost
Signage
Inserts/Flyers/
Articles
Door-to-Door
Campaigns
Outreach to
Schools
Meetings and
Community
Events
Workshops/
Training
Low. Develop message for
sign and set up at sites.
Low. Develop message for
flyer and distribute.
Medium-High. Canvassers
must dedicate afternoons/
evenings over a set period
of time to promote message.
Medium-High. Dependent
on size of event(s), activities
planned.
Medium-High. Dependent
on size of event(s), activities
planned.
Medium-High. Dependent
on size of workshop, training
activities planned.
Low-Medium. Dependent
on the quality of the signs
(temporary or permanent).
Low. Paper, printing/
photocopying, labor.
Low-Medium. If volunteers
agree to canvass, costs will
stay down.
Medium-High. Dependent
on size of event(s), activities
planned, materials needed.
Medium-High. Dependent on
size of event(s), activities
planned, materials needed.
Medium-High. Dependent on
size of workshop, training
activities planned, materials
needed.
Effectiveness
Low-Medium. Tribal members
will have to read and respond
to signs.
Low-Medium. Message must be
compelling to tribal members so
they read and remember it.
Medium-High. Talk to residents
one-on-one to address their
concerns. But the size of the
audience may be limited.
High. Potentially large audience;
reaches children and their
families; fun events can help
residents find favor with your
message.
High. Potentially large/diverse
audience; fun or memorable
activities can draw residents to
your message.
High. Provide specific training
to audience, address their
questions and concerns. Helpful
when introducing new programs.
-------
Implementing a Hazardous Waste Education Program
The Native Village of Barrow-lnupiat Traditional Government in Alaska is developing
an environmental protection program to properly address the release, or threat of
release, of hazardous waste into the environment that might jeopardize human health
and natural resources. The environmental program has taken an active approach to
ensure the Inupiat people have substantial involvement in the environmental policy
decisions that impact the entire village—its people and resources.
Activities under the grant include:
Signing a Tribal Environmental Agreement between the tribe and EPA.
Developing ordinances and regulations at the municipal and tribal level.
Developing and implementing a hazardous waste and toxic material information-
al program with the North Slope Borough School District to identify common
household hazardous waste and other toxic materials; identify municipal toxic
and hazardous waste to initiate proper handling, storage, and disposal; and dis-
seminate the information through local radio and television networks.
Working with the agencies responsible for proper closure of the Barrow Landfill
(which contains hazardous waste).
Working with the U.S. Department of Defense to address hazardous waste
impacts in the North Slope Borough area.
law enforcement officials saw the bene-
fits of partnering with the community's
Department of Environmental Quality
on cases involving businesses that were
dumping waste illegally. At the close of
the workshop, the participants had
agreed to coordinate with the tribe's
public information office to issue press
releases about enforcement actions.
Instituting the Community
Education Program
Education and outreach programs are not
complete once materials have been distrib-
uted—educational programs are continual
and constantly evolving to meet the needs of
tribal members. Many solid waste manage-
ment programs are long term and require sus-
tained education and training. In addition,
tribal members will likely have questions
about new programs and policies that may
not be completely addressed through your
initial outreach. Many solid waste programs
also need to go through an adjustment
process before they run smoothly, and educa-
tion will be needed to help guide tribal
members through these changes.
For these reasons, once you have an out-
reach program in place, it is important to
take steps to:
• Address comments and complaints
• Sustain and adjust your education pro-
gram
• Carry out program measurement activi-
ties
Addressing Comments and Complaints
When developing your educational initia-
tives, it is important to anticipate questions
that tribal members will have so that they
can be addressed early on (e.g., hours of
-------
operation at the transfer station, what mate-
rials are or are not accepted for recycling).
But it is sometimes impossible to anticipate
every question or complaint a member will
have about a new program or policy.
You might need to develop additional educa-
tional materials after your initial outreach to
address unanswered community concerns.
You also might need to establish additional
or ongoing avenues for communication. One
strategy is to designate an educator— per-
haps a volunteer— who has been involved
in the waste management program to field
questions and comments during program
implementation and after the program starts.
Tribal members will become more informed
and better equipped to follow waste manage-
ment rules and regulations when they have a
resource to turn to with their questions.
Ultimately, responding to public inquiries
and continually refining your program in
response to comments will make your waste
management program stronger and more
accepted by the community.
Adjusting and Maintaining Your
Education Program
It is important to note that both your solid
waste management program and your educa-
tional initiatives might go through adjust-
ments as they are implemented. For example,
you might find that procedures for sorting
recyclables need to change to make the pro-
gram more efficient, or that you need to
revise your transfer station hours of operation
to better serve the tribe. As changes like
these are made to a program, additional com-
munication with your tribe will be necessary.
You also might find that your educational
initiatives need fine tuning. Sometimes mes-
sages do not resonate with the target audi-
ence and are not as successful as anticipated
in achieving the desired response. Similarly,
a particular outreach method, like a
brochure, might turn out to be ineffective in
reaching your audience. In these cases, you
may have a clear sense how to respond to
improve your program, or you might consider
formal testing of your message or materials
(e.g., by surveying your audience or holding
focus groups) or informal testing (e.g., asking
your friends, family, and colleagues for their
reactions) to get a "reality check" before pro-
ceeding further.
Carrying Out Program Measurement
Activities
Sometimes it is difficult to tell whether your
education program is having its intended
effect. To determine the effectiveness of
community education efforts, you can carry
out measurement activities. First, consider
what would be helpful to measure. Things
you might want to measure could include:
• Have incidents of illegal dumping gone
down?
• Are more tribal members using the
transfer station?
• How much trash, by weight and volume,
are you collecting now?
• What do residents think and say about
the tribe's education program?
By measuring the effects of the tribe's waste
management program, you will be better able
to decide whether you need to carry out
more education efforts or change your educa-
tion approach.
Measurement is important because it can
help you get to the root of persistent prob-
lems. For example, if your measurement
efforts show that illegal dumping public edu-
cation efforts have not been effective, you
might decide to ask residents why they keep
dumping trash illegally. They might tell you
something important, and you can adjust
your waste management program accordingly
to make sure it is effective. Even after the
Fond du Lac Band of Chippewa in Minnesota
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closed its open dumps and private waste
haulers began to service the community,
charging reasonable monthly fees for curbside
pickup, many residents continued to dump
their trash illegally in remote areas and near
old open dump sites. One obstacle to pro-
gram implementation was a lack of awareness
among tribal members about the environ-
mental and health effects of illegal dumping.
Consequently, the tribe's Resource
Management Division distributed illegal
dumping information at an annual health fair
and other local events and publicized the
risks associated with illegal dumping in the
tribal newspaper.
Sample Educational Program:
Illegal Dumping
The remainder of this chapter makes use of
the recommendations provided earlier to
help you create a community education pro-
gram focused on stopping illegal dumping.
As discussed earlier in this guide, laws and
codes that prohibit illegal dumping and
penalize lawbreakers are an essential part of a
tribe's strategy to stop illegal dumping.
Public education is another critical compo-
nent of any effort to stop illegal dumping.
Setting Goals
The first step is to establish the goals for
your educational program. The ultimate goal
of your education program might be to
encourage people to change their behavior
to reduce or eliminate illegal dumping. In
order to reach this overarching goal, you
might want your educational initiatives to
accomplish the following:
• Communicate why illegal dumping is
bad for tribal members' health and the
environment, including wildlife.
• Inform tribal members what illegal
dumping codes or regulations the tribe
has established and the penalties for
breaking the law.
• Explain alternative waste disposal
options, such as a nearby transfer station
and recycling center.
It is important to realize that behavioral
change will not happen overnight. Patience
and persistence is important on your part. In
the past, dumping trash in the woods was a
common practice in some areas. Today, those
who continue to dump in the woods are
unaware that many materials contain toxic
or environmentally harmful components.
Often, these illegal dumpers are unaware of
the environmental and health implications
of their actions. They might need to hear
why illegal dumping is harmful more than
once before they change their ways. It also is
important to remember that some illegal
dumpers might not be able to afford or have
access to current waste disposal options.
Therefore, your education program will need
to communicate to tribal members what
waste disposal alternatives are available.
Understanding Your Audience and
Crafting Messages
One of the challenges in addressing illegal
dumping is identifying your target audience.
The first step is determining who is dumping
illegally. Investigating existing illegal dump
sites can help you find clues. For example,
most illegal dump sites within the Gila River
Indian Community in Arizona are located
along the reservation border, indicating that
most of the illegal dumpers probably come
from outside the community. Armed with
this information, the Gila River Department
of Environmental Quality designed an out-
reach campaign that extends beyond the
borders of the reservation.
The next step is to identify the unique char-
acteristics of your illegal dumpers, and tailor
outreach efforts accordingly. For example,
because the counties surrounding the Gila
-------
River Indian Community have a large popu-
lation of Spanish speakers, the Gila River
Department of Environmental Quality rec-
ognized the need for new "No Illegal
Dumping" signs with an international sym-
bol for "no dumping."
Knowing why individuals are dumping ille-
gally also can help make your outreach cam-
paign more effective. Again, illegal dump
sites might contain clues. Dump sites that
consist primarily of household trash might
indicate that current waste disposal options
are too costly or inconvenient. Dump sites
located next to closed dumps or burn pits
might indicate that habit is driving the prob-
lem. Informal conversations with community
members also can expose the reasons behind
illegal dumping.
After identifying who is responsible for ille-
gal dumping, expand your audience to
include people who can influence the behav-
ior of the illegal dumpers. Educate people
who can pass on information and maximize
the message's impact. For example, if habit is
driving illegal dumping, educate children
and tribal leaders about the problem. When
these groups explain the dangers of illegal
dumping, the community tends to listen.
If you distribute your educational materials
and find that some members still continue to
dump their waste illegally, then you might
want to try one-on-one visits with the unco-
operative citizens. The Onondaga Nation
used this approach with the few households
that refused to recycle and continued to
dump illegally. These one-on-one household
visits were successful in convincing these
hold-outs to use the nation's transfer station.
Outreach Methods
After identifying your audience and deter-
mining your message, consider a variety of
outreach methods. For example, in addition
to posting "No Dumping" signs, the
Keweenaw Bay Indian Community in
Michigan produced a pamphlet detailing the
environmental problems associated with ille-
gal dumping. The pamphlet also instructs
community members to report illegal dump-
ing and educates them about proper waste
disposal methods. The community distributes
the pamphlet at public events and includes it
with hunting and fishing license applications.
Cleanup events can encourage tribal mem-
bers to report illegal dumping incidents and
assist with future cleanup efforts. The White
Mountain Apache Environmental Planning
Office in Arizona used the "Adopt a
Highway" program to catalyze community
interest in its illegal dumping prevention
program. The Solid Waste Department con-
tacted residents and tribal businesses to
locate volunteers to collect garbage, and the
tribal Environmental Planning Office pro-
vided trash bags. At a day-long event, com-
munity members picked up trash discarded
along many of the reservation's highways.
Measuring Success
Measuring the success of your outreach and
educational program can be difficult but
extremely useful as an assessment and plan-
ning tool. Measuring the number of tribal
members who received your materials or
message is fairly simple. You can determine
the number of tribal members who attended
workshops or community events or the num-
ber of households contacts via door-to-door
campaigns, as well as determine how many
educational brochures, flyers, and other
materials you distributed.
Measurement also can help you identify the
most effective outreach and education meth-
ods to help you plan future initiatives. The
Alabama-Coushatta Tribe in Texas, for
example, determined that it reached 60 per-
cent of the households on the reservation
through its door-to-door illegal dumping
education campaign. Prior outreach efforts,
such as presentations at public meetings,
-------
were measured to have lower effectiveness
due to poor turnout at these meetings.
Measuring the success of your outreach and
educational program in changing tribal
members' thinking or behavior can be more
difficult, but several tribes have done so suc-
cessfully. The Alabama-Coushatta Tribe
measures the success of its outreach efforts by
tracking the increase in the number of tribal
residents using the tribe's transfer station
after the door-to-door campaign. The
Pawnee Nation in Oklahoma measured its
outreach success by tracking the number of
phone calls the Pawnee Environmental
Education Center received after it opened.
The number of calls to the tribal
Department of Environmental Conservation
and Safety reporting illegal dumping activi-
ties shot up after the center opened. The
tribe attributed this to the increased aware-
ness created by the tribe's outreach materials,
not an increase in actual incidents.
Chapter Highlights
• Clearly identify your target audience,
goals, and message.
• Select the outreach method(s) that most
effectively delivers your message to your
intended audience.
• Tailor your message to each audience by
speaking in terms and the level of com-
plexity that they will understand.
• Use your language and culture to help
tribal members understand and accept
your message.
• Work with the children in your tribe or
village through the schools and youth
groups, clubs, or organizations.
• Be responsive to community feedback
and continually modify your methods
and message to address community con-
cerns and changing program goals.
Resources
EPA's A Collection of Solid Waste Resources
(EPA530-C-01-002) contains publications
on hazardous and non-hazardous waste top-
ics. The CD is available from the National
Service Center for Environmental
Publications at 800 490-9189 or on the Web
at .
EPA's Let's Reduce and Recycle: Curriculum for
Solid Waste Awareness (EPA530-SW-90-005)
educates young people about the problems
associated with solid waste. Available on the
"A Collection of Solid Waste Resources" CD.
What a Waste! A Teacher's Resource for
Integrating the Solid Waste Crisis into the
Classroom is targeted to elementary school
students in grades 3-6 and adaptable for
other grades. Available through the
Southwest Connecticut Regional Recycling
Committee at 800 455-9571.
A-way with Waste, available on the Web at
, presents integrated waste man-
agement concepts affecting land, air, and
water to promote awareness, attitudes, and
actions to solve waste management problems
at home, in school and in the community.
Pollution Prevention and Cultural Preservation
in Native American Communities: An
Educational Tool Kit for Tribal Colleges, pro-
duced by Montana State University
Extension Service under a grant from EPA.
It includes a student handbook, an educa-
tional guide, transparencies, worksheets, a
test, and evaluations. For more information,
contact Montana Pollution Prevention
Program, Phone: 888 687- 6872, or 406 994-
3451, or on the Web at .
Environmental Protection Native American
Lands: A Cultural Approach to Integrated
Environmental Studies. Grades 1-12, Second
Edition, a 52-lesson curriculum for grades 1
-------
through 12 produced by the Center for
Indian Community Development at
Humboldt State University, under a grant
from EPA. For more information, contact
the Center for Indian Community
Development, Humboldt State University,
Phone: 707 826-3711, or on the Web at
.
Examples of existing community education
materials are available at EPA's "Waste
Management in Indian Country" Web site at
. Case studies
describe community education efforts carried
out by tribes, some of which are featured in
this chapter. The Web site also has tribal-
focused curricula for students at
.
The St. Regis Mohawk Tribe Environment
Division in New York developed a series of
cartoons called Kwis and Tiio: Solid Waste
Management on the 'Rez, available on the
Web at .
Developing and Implementing Integrated Solid
Waste Management Systems for Tribal Nations:
A Training Course Prepared by the Tribal
Association for Solid Waste and Emergency
Response (TASWER) and the Solid Waste
Association of North America (SWANA),
Spring 2003. Contact TASWER
or SWANA
for more information.
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Chapter 7. Funding Your Solid
Waste Management Program
For many Native American tribes and
Alaskan Native villages, securing pro-
gram funding is the most difficult solid
waste management challenge they face.
Every step in developing, implementing, and
maintaining a solid waste management pro-
gram requires funding. Most tribes, unfortu-
nately, do not have the economic base to
fully support these programs. This chapter
will address the major costs associated with
solid waste management, funding sources
and opportunities, and ways to build strong
relationships to acquire needed funds. The
Resources section at the end of this chapter
provides ordering information for several
funding-related resources available to tribes
and Alaskan Native villages. This section
also provides brief descriptions of some of
the primary federal grant programs for which
tribes and Alaskan Native villages are eligi-
ble (including contact information).
Major Program Costs
The major costs associated with managing
solid waste include:
• Program planning
• Facility design and construction
• Equipment purchase
• Cleanup
• Operation and maintenance
• Personnel training and administration
• Landfill closure and post-closure care
Program Planning
Your tribe needs funding to perform waste
audits to identify waste types and volumes,
develop integrated solid waste management
plans to coordinate and guide your program,
and complete feasibility studies and cost
assessments for different waste management
options.
Facility Design and Construction
Solid waste management facilities can
include recycling centers, convenience cen-
ters, transfer stations, and landfills. Tribes
need funds to hire engineers and architects
to design the facility, as well as for new road
construction, improvements, and repairs;
utility installation (i.e., water, electricity,
natural gas); and other construction costs.
Equipment
Solid waste management programs and facil-
ities require various types of equipment, such
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Front-end loader moving waste at the Eastern Band of Cherokee Indians'
transfer station.
as collection vehicles, roll-off bins, waste
compactors, and front-end loaders or bull-
dozers. Some programs also pay for the indi-
vidual trash cans and recycling bins that are
distributed to residents.
staff salaries or wages; operation, maintenance,
and repair of equipment and facilities; commu-
nity education and outreach initiatives; and
enforcement of codes and ordinances.
Personnel Training and Administration
Collection vehicle drivers and facility staff
need technical training to operate and main-
tain equipment. Enforcement officials will
need training on proper implementation of
tribal codes and ordinances. Environmental
staff might require legal, environmental
health, technical, communication and edu-
cation, grant writing, or financial training.
Cleanup
Open dump cleanups require significant
amounts of funds to plan and complete.
Costs include the purchase or rental of roll-
off bins or other waste containers, hauling
fees, tipping fees at the transfer station or
landfill, and labor costs.
Operation and Maintenance
Once your program is in place or your facility
begins operations, funds are needed to pay for
HAZWOPER certified workers clean up hazardous waste in Kokhanok
Village (Alaska).
Sources of Funding
There are two primary sources of solid waste
funding—internal and external. Most tribes
have found that they require a combination
of several internal and external funding
mechanisms to fully support their solid waste
programs.
Potential internal funding sources include
monies allocated from the tribal general
fund, solid waste service user fees, revenue
generated from the sales of recyclable materi-
als, and tipping fees from accepting waste
from neighboring communities and business-
es at your transfer station or landfill.
External funds typically are grants and loans
from federal agencies or, less frequently, pri-
vate foundations or organizations. Many tribes
have found that federal grants and loans are
necessary to construct solid waste manage-
ment facilities such as transfer stations or
landfills because of the high capital cost.
-------
There are a few exceptions, however, such as
the Onondaga Nation in New York that paid
for the construction of its transfer station
completely on its own. It is important to note
that very few federal grants will fund solid
waste facility operation and maintenance
costs. Tribes and Alaskan Native villages will
need to fund facility operation and mainte-
nance internally or through other means.
Internal Sources of Funding
Tribes can access the following internal
sources for funding:
• Tribal general fund
• User fees
• Sale of recyclables
• Tipping fees from neighboring communi-
ties and businesses
Tribal General Fund
Tribes can fund a portion of their solid waste
management program with money from the
tribal general fund. On many reservations,
however, general fund monies help finance
programs that are considered a higher priori-
ty than solid waste, such as drinking and
waste water management and schools.
Some tribes use some of the revenue generat-
ed from tribal businesses, such as casinos or
manufacturing industries, to fund solid waste
management, either through the general
fund or specified set-asides. Use of the rev-
enue from these operations varies from tribe
to tribe. Another approach to generating
revenue is to levy fees on the sale of products
such as cigarettes, gas, or alcohol. The St.
Regis Mohawk Tribe in New York, for exam-
ple, has added fees to cigarette and gas sales.
These fees go into the tribal general fund
and finance the tribal government, including
part of its solid waste management program.
User Fees
User fees for solid waste services are a com-
mon source of funding for many tribes.
These fees include transfer station or landfill
tipping fees and waste collection service fees.
Many tribes use a flat user fee, while others
have instituted Pay-As-You-Throw (PAYT)
programs, which charge per bag or pound of
waste disposed. The St. Regis Mohawk Tribe,
for example, operates a PAYT program.
Under this program, residents using the
tribe's door-to-door waste collection service
purchase special blue trash bags from the
tribe. The tribe's collection truck attendants
pick up these bags only. Residents that do
not use the door-to-door collection service
can bring their waste directly to the tribe's
transfer station, where they are charged a
per-pound disposal fee.
The Confederated Tribes of the Umatilla in
northeast Oregon employ a similar program.
The tribes offer a curbside collection service
that costs $22.70 per month. Customers can
fill two 32-gallon garbage cans, which collec-
tion trucks pick up once a week. The tribes
subsidize collection costs for senior citizens
and disabled people—these customers only
pay $7 per month. As an alternative to curb-
side collection, residents can bring trash
directly to the transfer station, where they
pay for disposal services on a per-pound
basis. These fees help fund the collection
service and transfer station operation.
Additionally, 7 percent of the collected fees
is set aside for maintenance and repair of the
transfer station.
In northeast Montana, the Fort Peck
Reservation (Assiniboine and Sioux Tribes)
Operations and Maintenance Department
charges residents $14 a month for curbside
waste collection. This monthly fee is included
on residents' utility bills. The fee only partial-
ly covers collection service operating costs, so
the tribes are examining other ways to make
the service self-sustaining. The tribes also
maintain five roll-off sites as an alternative to
-------
the curbside collection service. To use these
sites, tribal members must purchase a permit.
Residential permits are $15 a month, while
businesses and contractors pay $300 a month.
To provide an incentive for residents to
reduce the amount of waste they produce, the
tribes are considering replacing the monthly
permits with a $15 per visit tipping fee.
Sale of Recyclables
Another potential source of funding for your
tribe's solid waste program is revenue from
the sale of certain recyclable materials. The
Eastern Band of Cherokee Indians in North
Carolina, for example, discovered through a
waste audit that the tribe generates large
quantities of cardboard. Fortunately, a steady
demand for recycled cardboard exists in the
area, which allows the tribe to make a small
profit from its sales. The St. Regis Mohawk
Reservation in New York also sells recy-
clables to help fund its collection program
and transfer station operations. The ability
to sell recyclables will depend on local
demand and markets, as well as your tribe's
ability to generate a large enough volume of
contaminant-free, high-value materials to
make selling profitable. Remotely located
reservations or those with small populations
might not find it profitable to sell recy-
clables. For more information on tribal recy-
cling programs, refer to Chapter 5.
Tribes and villages with composting opera-
tions have another potential opportunity for
generating revenue—the sale of finished
compost. The Eastern Band of Cherokee in
North Carolina operates a successful com-
posting operation at its transfer station. In
fact, there is such a high demand from nurs-
eries, landscapers, and individual homeown-
ers for the finished compost that the tribe
had to create a waiting list. Charging a fee
for the finished compost product from the
beginning is important, as it conveys to the
tribal members and customers that the com-
post is a valuable material.
Tipping Fees from Neighboring
Communities and Businesses
Allowing surrounding communities and busi-
nesses to use your transfer station is another
potential source of revenue available to
tribes. In order to accept off-reservation
waste, your transfer station or landfill must
have enough capacity to accommodate the
extra waste. The Eastern Band of Cherokee
Indians, for example, accepts waste at its
transfer station from neighboring Swayne
County and some private businesses in
Jackson County, North Carolina. Since the
Cherokee designed its facility to accommo-
date its waste for the next 10 years, the facil-
ity currently has the excess capacity to
accept Swayne County's waste.
To be profitable, you will need to ensure that
incoming revenue from tipping fees cover
increased operation and maintenance, waste
hauling, and disposal costs. You will need to
research tipping fees in your area to make
sure you can establish competitive rates that
are still profitable. Calvin Murphy with the
Cherokee Tribal Utilities cautions tribes
against building a transfer station for profit.
"You might not ever see a return on your
investment," he said. "When sizing our
transfer station, we concentrated on our own
waste, not Swayne County's waste."
The Confederated Tribes of Umatilla Indians
in Oregon is considering accepting waste from
neighboring counties at its transfer station.
The transfer station has a design capacity of
200 tons per day. To break even, the transfer
station must take in 60,000 tons per year (164
tons per day). Currently, the transfer station is
taking in less than 30 tons per day. To offset
operation and maintenance costs and move
the facility into the black, the tribe is looking
to expand its customer base beyond tribal resi-
dents and businesses to include customers in
neighboring Pendleton City.
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External Sources of Funding
Tribes can apply for grant funding from the
following outside sources:
• Federal grants and loans
• Private and nonprofit foundations
Most grant funds and loans are used as start-
up funds for recycling and other waste man-
agement programs, not to sustain long-term
programs.
Federal Grants and Loans
Some federal agencies, including EPA, IHS,
U.S. Department of Health and Human
Services' Administration for Native
Americans, USDA's Rural Development,
HUD, and BIA, offer financial assistance to
tribes and Native villages for solid and haz-
ardous waste management projects. Most of
the grants and loans available provide
monies for planning, outreach and educa-
tion, construction, or equipment purchase.
As noted earlier, few federal grant programs,
however, allow funds to be used for program
or facility operation and maintenance.
TASWER also can help tribes and Alaskan
Native villages secure funding by directing
them to the appropriate representative for
"The challenge is finding a
grant that fits your needs.
Creativity is the key to suc-
cess. Grant writers need to
find ways to make grants fit
tribal needs. At the same
time, tribal leaders must real-
ize that some needs can not
be met through grants."
-Deb Madison,
Environmental Program Manager,
Fort Peck Reservation Environmental
Protection Office
each source of funding. TASWER's Web site
lists some sources of funding available to
tribes and Alaskan Native villages.
Private and Nonprofit Foundations
A number of private and nonprofit founda-
tions and organizations run environmental
grant programs. The Confederated Tribes of
the Umatilla in Oregon, for example,
received a $25,000 grant from the JELD-
WEN Foundation to construct its transfer
station and recycling program. EPA's Grant
Resources for Solid Waste Activities in Indian
Country provides an extensive list of private
sources of funding for tribes and Alaskan
Native villages.
Some tribes can fund their solid waste man-
agement program by piecing together grant
Wading Through the Paperwork
Securing federal grants and loans is a great way to pay for
facility construction, but it does not come without difficulties
or challenges. Frequently, the biggest roadblock to obtaining
federal grants is the application. Most agency applications are
very long and complicated. USDA's Rural Development
grant/loan application, for example, provides a checklist of
required items to help applicants, which is six pages long and
double-sided. Some applications require specific information
or data that many tribes do not have on hand, such as HUD's
Indian Community Development Block Grant (ICDBG) appli-
cation, which requires specific census data.
Even after you submit the application, the work is not neces-
sarily complete. Laura Weber, director of solid waste manage-
ment for the St. Regis Mohawk Reservation, relates how her
tribe applied for and received HUD ICDBG, IHS, and USDA
grants to pay for the construction of its transfer station. Even
though the tribe received the ICDBG and IHS grants first,
USDA served as the lead agency and required the tribe to fol-
low the USDA grant management and paperwork guidelines
for all three grants. As part of this, the tribe had to go through
a complex series of procedures to finalize the design, perform
site assessment testing, and secure a bonded contractor. At
each step of the way, the tribe had to get the lead agency to
approve everything in writing.
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monies from a variety of sources. To manage
its waste, the Confederated Tribes of the
Umatilla built a transfer station adjacent to
the reservation. It took nearly 10 years of
careful planning and more than $1.3 million
to design and build the transfer station. The
tribes contributed $200,000 of their own
funds to this project. The remaining funds
came from several federal grants, including a
$350,000 Indian Community Development
Block Grant from HUD, a $196,000 grant
from the Administration for Native
Americans, and a $150,000 Sanitation
Deficiency System grant from IHS. The
tribes also received a $564,000 loan from
USDA and a $25,000 grant from the private
JELD-WEN Foundation.
Another possible strategy for increasing your
tribe or village's chance of receiving grants is
to break big projects into discreet portions
and seek funding for the individual parts. For
example, obtaining $75,000 from an agency
for a portion of your program, such as pur-
chasing a collection truck, might be easier
than obtaining $600,000 for the entire pro-
gram all at once.
To pay for the closure of its 12 identified
open dumps and construct a balefill landfill
and baler building, the Oglala Sioux Tribe
(OST) of the Pine Ridge Reservation in
South Dakota secured more than $3.7 mil-
lion dollars from federal agencies. The OST
Tribal Council also contributed an addition-
al $100,000 to the project. This money was
needed to comply with a 1990 U.S. District
Court decision that ordered IHS, BIA, and
the Oglala Sioux Tribe to close open dumps
on the Pine Ridge Indian Reservation. These
grants and loans covered solid waste manage-
ment planning, open dump cleanup and clo-
sure, construction of the balefill and baler
building, and the purchase of related equip-
ment. Grants included:
• $591,000 from EPAs Office of Solid
Waste and Emergency Response
• $600,000 from BIAs Office of Trust
Responsibility
• $724,000 from IHS's Sanitation
Deficiency System
• $1,200,000 from USDAs Rural
Development (of which 75 percent was
a grant and 25 percent a loan)
• $337,268 from the Interagency Solid
Waste Work Group
• $250,000 from the Oglala Sioux
Housing Authority
Finding Out About Funding
Opportunities
There are many ways to learn about what
funding opportunities are available to tribes
and Alaskan Native villages. A few of the
more common methods include:
• Announcements from federal agencies
• Internet searches
• Communication with other tribes
• Communication with regional agency
representatives
Announcements from Federal Agencies
Most federal agencies announce grant and
loan availability in the Federal Register and
provide information on their Web sites.
Some agencies send out announcements and
solicitations for their grant programs. The
Interagency Work Group, for example, mails
an annual announcement and solicitation
for its open dump cleanup grants.
Internet Searches
Many tribes learn about grant programs by
conducting simple Internet searches. USDAs
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Leveraging Non-Monetary Assets
In addition to seeking money for program development and implementation, many tribes have found that dif-
ferent forms of non-monetary assistance can be just as useful. Partnering with neighboring tribes and villages,
local governments, or businesses and sharing resources such as information, equipment, labor, materials, servic-
es, or facilities can provide mutual benefits and help strengthen your solid waste management program.
Cooperative arrangements with local governments can also help in addressing the impacts of activities outside
of the reservation on tribal lands. Here are just a few examples of how tribes and Alaskan Native villages have
leveraged non-monetary resources to make their programs a success.
The Wyandotte Nation in Oklahoma, partnered with neighboring Ottawa County to clean up and
secure an open dump site. The 4-acre open dump site was located on the Wyandotte Reservation, adja-
cent to a county road cutting through the tribe's land. The tribe cleaned the site and the county provid-
ed equipment and labor to dig a ditch alongside the road to prevent future illegal dumping at the site.
When the Assiniboine and Sioux Nations of the Fort Peck Reservation in Montana were investigating
options for expanding their waste collection system, they turned to neighboring Valley County for some
free advice. Valley County had been successfully operating a waste collection system using several roll-
off container drop-off sites that the tribes wanted to learn more about. Valley County willingly shared its
knowledge and experience, and provided the tribes with enough information to help develop its own
roll-off site system. The tribes also negotiated an agreement with the county to ship some of their waste
to the Valley County Landfill.
The Alaskan Native village of Galena, also known as Louden Village, secured an agreement with an area
barge company to back haul junk cars and other wastes from area villages for free. Carole Holley, the
environmental program director for the Louden Tribal Village Council, first contacted Captain Moore of
the Yutana Barge Lines. The Yutana Barge Lines was involved in a lawsuit in 1996. As part of the settle-
ment, the company agreed that its barges would provide free back hauling services to several villages.
Captain Moore not only agreed to back haul the cars to his home port of Nenana, but also suggested
that Ms. Holley call the Alaskan Railroad Corporation and ask about hauling the cars the remaining dis-
tance to Anchorage for final recovery and disposal. When Ms. Holley mentioned that Yutana Barge
Lines was back hauling the cars for free, the railroad company volunteered its services for free as well.
In the first year, more than 60 cars were removed from the villages. The car removal has become an
annual event in the villages, and Captain Moore has agreed to continue providing free back hauling
service.
Rural Development grants, for example, are
accessible through Web sites that include
descriptions of the grant programs, including
applications, instructions for applying, and
contact information for state and regional
representatives.
One online database tribes and Alaskan
Native villages can use to find out about
grant opportunities is the Catalogue of
Federal Domestic Assistance (CFDA), at
. It is a database of all feder-
al assistance programs—including grant and
loan programs—available to state, local, and
tribal governments. After identifying poten-
tial sources of funding through CDFA, tribes
should then go directly to the funding agen-
cies for application information. Tribes also
can search other federal agency Web sites for
solid waste grants and loan information.
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Communication with Other Tribes
Another way to learn about available grants
is by talking with other tribes, either through
informal conversations or networking at
conferences and meetings. Conversations
with neighboring tribes are a primary source
of grant information for some tribes. Sharing
information and experiences can be mutually
beneficial. Some tribes even exchange suc-
cessful grant applications to help improve
future applications.
Communication with Regional Agency
Representatives
In addition to speaking with other tribes or
villages, you can speak directly with your
regional agency representatives from EPA,
IHS, BIA, USDA, and HUD. Some tribal
solid waste managers have noted that this is
a crucial part of securing funds for your tribe
or village and recommend building relation-
ships with representatives from the various
federal agencies.
Building Strong Relationships
One of the most important parts of the
entire application process, and a major key
to success in receiving funding, is having a
good relationship with your agency represen-
tative. Agency representatives can help you
complete your grant applications and make
sure all of the required pieces are included.
When working on your grant application,
speak with your agency representative to
make sure you have everything you need. Go
Making Solid Waste a Priority and Building Relationships: A Winning
Combination
The Fort Peck Reservation in northeast Montana is home to the Assiniboine and Sioux Nations. In the early
1990s, the tribes realized that current waste disposal options were not meeting the reservation's needs. The
tribes adopted a roll-off bin system, which a neighboring county had successfully used for several years. To
build the first two roll-off sites, tribes applied for and received a HUD Indian Community Development
Block Grant.
To build the three remaining sites, the tribes applied for and received funding from IHS's Sanitation
Deficiency System (SDS). To get SDS funding, the tribes' Operation and Maintenance (O&M) staff had to
convince the tribal council to designate solid waste as the top priority on their annual sanitation deficiency
list. O&M staff explained that open dump sites are illegal and a liability for the tribe. Knowing that pictures
can be an effective persuasion tool, O&M staff showed the council contrasting pictures of open dumps and
roll-off sites.
O&M staff also spoke to the tribal council about their integrated solid waste management plan and
explained how the roll-off sites were a key component of the plan. The staff showed the council how the
roll-off sites fit into the big picture and demonstrated that the roll-off sites are part of a larger plan that
includes recycling and waste prevention. IHS also helped convince the tribal council to make solid waste a
priority. An IHS engineer explained to the tribal council that there was a good chance that the roll-off sites
would get funded if the tribes placed solid waste at the top of their priority list.
Developing a relationship with their IHS engineers was important for the tribes. The first IHS engineer that
tribal planners worked with was a friend, so the tribes felt comfortable communicating their needs to IHS
through this engineer. This individual paved the way for future relationships, and as a consequence the
tribes have had good relationships with successive IHS engineers.
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to the agency office if you are having diffi-
culty completing the application.
Laura Weber, director of solid waste manage-
ment for the St. Regis Mohawk Reservation,
also advocates relationship-building, based
on her tribe's experience. Her tribe first
learned about IHS Sanitation Deficiency
System (SDS) funding for solid waste from
an IHS engineer who worked on water proj-
ects with the tribe. In addition to informing
the tribe about SDS funding, the engineer
also pointed it toward HUD's Indian
Community Development Block Grant
(ICDBG) program.
St. Regis Mohawk's experiences further
demonstrate the importance of building and
maintaining relationships with your regional
agency representatives. A short time after
receiving one USDA grant, the tribe's
USDA representative called to say it had
grant funding available and that the St.
Regis Mohawk Tribe should apply for it. The
tribe worked closely with the regional proj-
ect officer during the application process,
and the tribe received the second grant for
construction of its transfer station.
If your regional representatives are not
responsive, invite them to your reservation
to build a relationship with them. The St.
Regis Mohawk Tribe conducts a weekend
cultural sensitivity workshop to help individ-
uals from outside the community understand
the tribal perspective. Partnering with a
regional representative can benefit both your
tribe and the federal agency.
If your grant application is unsuccessful, call
your agency representative and ask why, as
well as how you can improve your chances in
the future. The first time the St. Regis
Mohawk Tribe applied for a HUD ICDBG, it
was not selected. The tribe contacted the
HUD office to find out why and ask for ways
to improve the application. The HUD repre-
sentative sent back the application with an
evaluation form. The tribe used HUD's com-
"Educate [agency representatives] about your
tribe's history, culture, and current situation.
Explain your tribe's accomplishments, especial-
ly the ones dealing with solid waste. If they
understand your tribe, who you are, and what
you have accomplished, they are more likely
to support you in future endeavors."
~Kim Clausen-Jensen,
Oglala Sioux Environmental Protection Program
ments to revise the application. When the
tribe resubmitted the application, HUD
awarded the tribe an ICDBG.
In addition to building a relationship with
your agency representatives, many tribes
emphasized the importance of building a pos-
itive reputation for your tribe or village.
Building trust is a major part of this process.
If you can demonstrate to the agency repre-
sentative that your tribe or village has been
successful in the past and is responsible and
accountable, your representative is more like-
ly to support you in securing future technical
assistance and funding. One way to build this
trust is to make sure you submit all required
reports and meet all agency requirements
when you do receive a grant. This attention
to detail is especially crucial with pilot proj-
ects. If agencies can not document the suc-
cess of a pilot project, it is unlikely to be
continued. Submitting the required reports
helps the agency justify the project to inter-
nal federal reviewers and can help ensure
that the project receives continued funding.
Chapter Highlights
• Use as many internal and external fund-
ing sources as possible to fund your solid
waste program. Do not rely on a single
source.
• Ensure that you have sufficient resources
to continue funding program or facility
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operation and maintenance once grant
monies are gone.
• Leverage non-monetary assets to develop
and sustain your program.
• Build and maintain strong relationships
with agency representatives, neighbor-
ing governments, and other tribes and
villages.
• Develop a reputation of being reliable
and trustworthy. Live up to your end of
the bargain!
• Be persistent and ask for help from
agency representatives and other tribes
and villages.
Resources
The following resources can help you find
out where and how to apply for solid waste
management grants:
• Grant Resources for Solid Waste Activities
in Indian Country (EPA530-R-98-014),
available on the Web at or by contacting the
RCRA Call Center at 800 424-9346.
• Solid Waste Funding: A Guide to Federal
Assistance (EPA530-F-97-027), available
on the Web at or by con-
tacting the RCRA Call Center at 800
424-9346.
• Preparing Successful Grant Proposals tip
sheet (EPA530-F-97-020), available on
the Web at or by contacting the RCRA
Call Center at 800 424-9346.
• EPA's Grant Writing Tutorial, available
on the Web at .
• The Catalog of Federal Domestic
Assistance, on available the Web at
< www.cfda.gov>.
• Tribal Association of Solid Waste and
Emergency Response (TASWER).
Phone: 202 331-8084, Fax: 202 331-
8068, Email:, on
the Web at . Contact
TASWER for more information and
assistance in connecting with the appro-
priate agency representative.
Federal Sources of Grant
Funding
U.S. Environmental Protection Agency
(EPA) offers a number of grants for solid and
hazardous waste projects. Each grant program
provides funding for specific solid and haz-
ardous waste management activities. To
increase your chances of receiving a grant,
match your program needs to the appropriate
EPA program. Listed below are several grants
available to tribes and Alaskan Native vil-
lages from EPA. Visit the Web sites provided
with each description to learn more about
each grant program and to get application
information.
Office of Solid Waste Hazardous Waste
Management Grants
These grants provide financial assistance to
tribes and intertribal consortia for develop-
ing and implementing programs to manage
hazardous waste. Programs can include
developing and implementing hazardous
waste codes, regulations, and ordinances,
along with enforcement policies and proce-
dures; identifying and assessing hazardous
waste generation and management; develop-
ing and implementing integrated hazardous
waste management plans; developing and
implementing used oil collection and recy-
cling programs; developing outreach and
education materials; and creating hazardous
waste management training. For more infor-
-------
mation, contact your regional tribal haz-
ardous waste management representative or
call Denise Roy at 703 308-8458.
InterAgency Open Dump Cleanup
Project Grants
The goal of the Tribal Solid Waste
Interagency Workgroup Cleanup Project is
to help tribes close or upgrade open dump
sites. Specific goals include assisting tribes
with: 1) completing and implementing com-
prehensive, integrated waste management
plans, 2) developing realistic solid waste
management alternatives, 3) closing or
upgrading existing open dumps, and 4)
developing post-closure programs. Since
1999, federal agencies have committed $6.1
million to 31 tribes to clean up open dumps.
EPA mails the Cleanup Project information
and application package annually to every
federally recognized tribe. It also is available
from EPA's Tribal Municipal Solid Waste
Funding Web page at . For
more information, contact your regional
solid waste Indian coordinator. To find your
regional coordinator's contact information,
visit .
Alaska Solid Waste Management
Demonstration Grant's Project
This collaborative project between the
Alaska Native Health Board and EPA funds
village-based solid waste projects. Grant
awards range from $2,000 to $10,000.
Eligible projects can range from developing a
solid waste management plan to properly
closing a community dump site. For further
information, contact the Alaska Native
Health Board, Phone: 907 562-6006, Fax:
907 563-2001, or E-mail: . EPA's Tribal Municipal Solid
Waste Funding Web page pro-
vides more details.
American Indian Environmental Office
(AIEO) General Assistance Program
(GAP) Grants
The primary purpose of GAP grants is to
support the development of a core tribal
environmental protection program. Tribes
can use GAP grant funds for planning, build-
ing solid waste infrastructure, enforcement,
or outreach and education. For a description
of the GAP grant program, including eligi-
bility and application information, visit
.
Brownfields Economic Redevelopment
Initiative
This initiative helps states and communities,
including tribes and Alaskan Native villages,
clean up and redevelop brownfields.
Brownfields sites are abandoned, idled, or
under-used industrial and commercial facili-
ties where expansion or redevelopment is
complicated by real or perceived environ-
mental contamination. EPA offers several
grant and loan opportunities under this ini-
tiative for which tribes and Alaskan Native
villages are eligible. For more information on
this initiative, visit . For complete brownfields
application information, visit .
Indian Health Service (IHS) provides
health services to American Indians and
Alaskan Natives. IHS inventories sanitation
deficiencies in Indian and Alaskan Native
communities—tribes or villages report sani-
tation deficiencies as proposed improvement
projects each year. To significantly increase
their chance of receiving IHS funding, tribes
need to place their solid waste project at the
top of their annual sanitation deficiency list.
Tribes can use IHS Sanitation Deficiency
System (SDS) funds to construct water, sew-
erage, and solid waste disposal systems and
facilities. For more information on SDS
funding, contact your regional IHS represen-
tative. Regional contact information is avail-
-------
able through IHS' Area Offices and Facilities
Web site, .
U.S. Department of Health and Human
Services' Administration for Native
Americans (ANA) awards funds to Native
American tribes and Alaskan Native villages
through environmental regulatory enhance-
ment project grants. ANA publishes an
announcement of funds available in the
Federal Register. This announcement
describes the grant's primary areas of focus,
review criteria, and application method. For
more information, visit .
U.S. Department of Agriculture Rural
Development's Rural Utilities Service
(RUS) Water and Environmental Programs
provide loans, grants, and loan guarantees for
drinking water, sanitary sewer, solid waste,
and storm drainage facilities to tribes. Water
and Waste Grants and Loans set aside fund-
ing for Native American tribes that can fund
up to 75 percent of the cost of a project.
What is not funded by the grant can be
offered as a low-interest government loan.
Tribes can use these grants and loans to con-
struct, enlarge, extend, or improve rural
water, sanitary sewage, solid waste disposal,
and storm water disposal facilities. Visit the
RUS Web page at for details and applica-
tion information.
U.S. Department of Housing and Urban
Development (HUD) Community
Development Block Grants (CDBG) pro-
gram aims to develop viable communities by
ensuring decent, affordable housing, a suit-
able living environment, and economic
opportunities for low- to middle-income
communities. Several tribes have used these
grants to fund solid waste management proj-
ects or programs that improve housing devel-
opments. Within the CDBG program, HUD
specifically sets aside funds for Native
American tribes for Indian Community
Development Block Grants (ICDBG). For
eligibility and application information, visit
HUD's CDBG Web page at .
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Acronyms List
ANA — Administration for Native
Americans
ANHB — Alaska Native Health Board
BIA — Bureau of Indian Affairs
C&D — Construction and demolition
CCA — Clean Air Act
CERCLA — Comprehensive
Environmental Response,
Compensation, and Liability Act
CWA — Clean Water Act
EPA — Environmental Protection Agency
HUD — Housing and Urban Development
ICDBG — Indian Community
Development Block Grant
HHW — Household hazardous waste
IHS — Indian Health Service
ISWM — Integrated solid waste manage-
ment
MSW — Municipal solid waste
PAYT — Pay-as-you-throw
RCRA — Resource Recovery and
Conservation Act
RUS — Rural Utility Service
SDS — Sanitation Deficiency System
SDWA — Safe Drinking Water Act
SWANA — Solid Waste Association of
North America
TASWER — Tribal Association of Solid
Waste and Emergency Response
TSCA — Toxic Substances Control Act
USDA — United States Department of
Agriculture
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Appendix A: Glossary
Balefill: A landfill that only accepts waste
that has been baled.
Baler: A machine used to compress recy-
clables or waste into bundles to reduce
their volume. Balers are often used on
recyclables such as newspaper, plastics,
and corrugated cardboard.
Burn Barrel: A container (e.g., a 55-gallon
drum) used for open burning of waste.
Buy-Back Center: A facility to which indi-
viduals bring recyclables in exchange for
payment.
Clean Air Act (CCA): The Clean Air Act
is a federal law that requires EPA to set
national health-based air quality stan-
dards to protect people and the environ-
ment against common pollutants,
including ozone (smog), carbon monox-
ide, sulfur dioxide, nitrogen dioxide,
lead, and particulate soot. State govern-
ments must devise cleanup plans to meet
the heath standards by a specific date. In
addition, EPA sets national standards for
major new sources of pollution including
automobiles, trucks, and electric power
plants. EPA also is charged with devel-
oping controls for major sources of such
toxic pollutants as benzene.
Clean Water Act (CWA): The Clean Water
Act is a federal law that established the
basic structure for regulating discharges
of pollutants into the waters of the
United States. It gave EPA the authority
to implement pollution control programs
such as setting wastewater standards for
industry. The Act also continued
requirements to set water quality stan-
dards for all contaminants in surface
waters. The Act made it unlawful for
any person to discharge any pollutant
from a point source into navigable
waters, unless a permit was obtained
under its provisions. It also funded the
construction of sewage treatment plants
under the construction grants program
and recognized the need for planning to
address the critical problems posed by
nonpoint source pollution.
Closure: The termination of the active life
of a waste management unit by either:
1) installation of a final cover, or 2)
removal of all waste and contaminated
soils and containment devices.
Composting: The controlled decomposition
of organic materials, such as leaves,
grass, and food scraps, by microorgan-
isms. The result of this decomposition
-------
process is compost, a crumbly, earthy-
smelling, soil-like material.
Comprehensive Environmental Response,
Compensation, and Liability Act
(CERCLA): The Comprehensive
Environmental Response,
Compensation, and Liability Act, com-
monly known as Superfund, was enacted
by Congress in 1980. This law created a
tax on the chemical and petroleum
industries and provided broad federal
authority to respond directly to releases
or threatened releases of hazardous sub-
stances that may endanger public health
or the environment. Over 5 years, $1.6
billion was collected and the tax went to
a trust fund for cleaning up abandoned
or uncontrolled hazardous waste sites.
CERCLA established prohibitions and
requirements concerning closed and
abandoned hazardous waste sites; provid-
ed for liability of persons responsible for
releases of hazardous waste at these sites;
and established a trust fund to provide
for cleanup when no responsible party
could be identified.
Construction and Demolition (C&D)
Debris: Materials resulting from the
construction, remodeling, repair, or dem-
olition of buildings, bridges, pavement,
and other structures. Typically includes
concrete, asphalt, wood, metals, drywall
(gypsum wallboard, sheet rock, or plas-
ter), and roofing materials. Some tribes
and states also include land clearing
debris such as stumps, rocks, and dirt in
this category of waste.
Convenience Centers: Community waste
and/or recyclables drop-off sites. They
typically consist of one or more bins for
waste and/or recyclables and are located
at spots convenient for residents, such as
near major roads or at shopping centers
or community centers.
Curbside Collection: Programs in which
waste or recyclable materials are collect-
ed at the curb, often from special con-
tainers, and then taken to various
processing facilities.
Drop-off Collection: A method of collecting
waste, recyclable, or compostable materi-
als in which the materials are taken by
individuals to collection sites, where
they deposit the materials into designat-
ed containers.
End-Use Market: A company or other enti-
ty that purchases recycled materials for
use as feedstock in manufacturing new
products.
Generator: Any entity that produces solid
waste. Generators are usually divided
into the following types: residential—
single or multi-family households; com-
mercial—offices, retail and wholesale
outlets; institutional—social, education-
al or charitable activities; and industri-
al—industrial processes or
manufacturing operations.
Generation Rate: Amount of solid waste
produced over a given period of time.
For example, a community might pro-
duce 1,600 tons of waste per year. For a
population of 2,000, that amounts to 4.4
pounds per person per day.
Household Hazardous Waste: The leftover
content of consumer products used in
and around the home that contain haz-
ardous components, including certain
paints, cleaners, stains and varnishes, car
batteries, motor oil, and pesticides.
Certain types of household hazardous
waste have the potential to cause physi-
cal injury to sanitation workers, contami-
nate septic tanks or wastewater
treatment systems if poured down drains
or toilets, and present hazards to children
and pets if left around the house. While
households do not have to separate
-------
household hazardous waste from trash
under federal law, some states and locali-
ties have special disposal requirements
for this waste.
Incinerator: A furnace for the routine burn-
ing of waste materials using controlled
flame combustion.
Integrated Solid Waste Management: A
solid waste management system com-
posed of the following actions, steps,
methods, processes, and facilities: plan-
ning, financing, regulation, operation,
and management. It also includes: reduc-
tion of solid waste generation (source
reduction), collection, transfer, materials
recycling, composting, combustion
(incineration or waste-to-energy), and
disposal. EPA defines integrated solid
waste management as a process for man-
aging solid waste and materials diverted
from solid waste through a combination
of any of the following four methods of
management: source reduction, recy-
cling, combustion, and landfilling.
Medical Waste: All wastes from hospitals,
clinics, or other health care facilities
that contain or have come into contact
with diseased tissues or infectious
microorganisms. Can include human
blood and blood products, pathological
waste, discarded sharps (e.g., needles,
lancets, scalpels, broken medical instru-
ments), and contaminated animal waste.
Also referred to as "red bag" waste
because of the red biohazard bags in
which it is discarded.
Open Burning: The uncontained burning of
solid waste in a pit, pile, container, or
open dump.
Open Dump: An uncovered site used for
disposal of waste without environmental
controls. Under RCRA, any site receiv-
ing solid waste that does not comply
with Subtitle D municipal solid waste
landfill standards.
Pay-As-You-Throw (PAYT) Program: A
waste and recyclables collection program
that provides a financial incentive to
reduce, reuse, and recycle waste by
charging residents for hauling and dis-
posal costs based on the amount of
garbage they throw away.
Post-Closure Care: The monitoring of a
closed waste management unit to verify
that unacceptable releases from the unit
are not occurring.
Recycling: A series of activities that
includes collecting recyclable materials
that would otherwise be considered
waste, sorting and processing recyclables
into raw materials such as fibers, and
manufacturing raw materials into new
products.
Resource Conservation and Recovery Act
(RCRA): This act authorizes EPA to
control solid and hazardous waste from
"cradle to grave." RCRA regulates haz-
ardous waste generation, transportation,
storage, treatment, and disposal. RCRA
also sets forth a framework for the man-
agement of non-hazardous solid waste.
Amendments to RCRA in 1986 also
authorized EPA to address environmen-
tal problems arising from underground
storage tanks (USTs) storing petroleum
and other hazardous substances.
Reuse: Using a product more than once,
either for the same purpose or for a dif-
ferent purpose. Reusing items by repair-
ing them, donating them to charity and
community groups, or selling them also
reduces waste.
Roll-off Container: A large waste or recy-
clables container that fits onto a tractor
trailer that can be dropped off and
picked up hydraulically.
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Safe Drinking Water Act (SDWA): The
Safe Drinking Water Act is the main
federal law that ensures the quality of
Americans' drinking water. Under the
Act, EPA sets standards for drinking
water quality and oversees the states,
localities, and water suppliers that
implement those standards.
Solid Waste: Wastes from residential, com-
mercial, and institutional sources, such
as durable and nondurable goods, con-
tainers and packaging, food scraps, yard
trimmings, inorganic wastes, and con-
struction and demolition debris.
Source Reduction (or Waste Prevention):
Refers to any change in the design, man-
ufacture, purchase, or use of materials or
products (including packaging) to
reduce the amount or toxicity before
these materials become municipal solid
waste. Source reduction also refers to the
reuse of products or materials.
Special Wastes: A non-regulatory term used
by tribes to describe problem wastes typi-
cally generated by households that are
not disposed in household garbage con-
tainers primarily due to their size or
because of disposal restrictions. The
most common special wastes include
tires, furniture, bicycles, appliances and
other white goods, and car batteries.
Tires and lead-acid car batteries are
examples of special wastes that might
have disposal restrictions.
Toxic Substances Control Act (TSCA):
This act, passed by Congress in 1976,
requires the that all chemicals produced
or imported into the United States be
tested, regulated, and screened for toxic
effects. TSCA requires that any chemi-
cal that reaches the consumer market be
tested for possible toxic effects prior to
commercial manufacture. Existing chem-
icals that pose health and environmental
hazards are tracked and reported under
TSCA. The management and disposal of
asbestos and polychlorinated biphenyls
(PCBs) are regulated under TSCA.
Transfer Station: A site or facility where
waste materials are taken from smaller
collection vehicles (or private vehicles)
and placed in larger vehicles, including
truck trailers, railroad cars, or barges for
transport. Recycling and some waste
processing also might take place at trans-
fer stations.
Waste Reduction: Using source reduction,
recycling, or composting to prevent or
reduce waste generation.
Waste Stream: The total flow of solid waste
from generators within the jurisdiction
that must be recycled, reused, or dis-
posed of.
Waste Wise: WasteWise is a free, voluntary
EPA partnership program through which
tribes, communities, and organizations
can work to eliminate waste, benefitting
their bottom line and the environment.
The WasteWise program can help part-
ners design their own solid waste reduc-
tion programs tailored to their needs.
Yard Trimmings: Leaves, grass, clippings,
prunings, and other natural organic mat-
ter discarded from yards or gardens. Yard
trimmings also may include tree stumps
and brush, but these materials are not
normally handled at composting facilities.
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Appendix B: Tribal Information
Sources and Contacts
EPA Region 1 (CT, MA, ME,
NH, Rl, VT)
U.S. EPA Regional Tribal Coordinator
Municipal solid waste and hazardous waste:
Chuck Franks, 617 918-1554
JFK Federal Building, Boston, MA 02203-
2211
Mohegan Tribe of Indians of
Connecticut
Phone: 860 204-6112; Fax: 860 204-6129
Mailing Address: The Mohegan Tribe, P.O.
Box 488, Uncasville, CT 06382
EPA Region 2 (NJ, NY, PR, VI)
EPA Regional Tribal Coordinator
Municipal solid waste and hazardous waste:
Lorraine Graves, 212 637-4099
290 Broadway, 26th Floor, New York, NY
10007-1866
St. Regis Mohawk Tribe of New York
Phone:518358-5937
Mailing Address: Environment Division, 412
State Route 37, Akwesasne, NY 13655
Onondaga Nation in New York
Phone: 315 492-4210
Mailing Address: Onondaga Nation, Box
319 B, Hemlock Road, via Nedrow, NY
13120
EPA Region 3 (DC, DE, MD,
PA, VA, WV)
(No federally recognized tribes.)
EPA Region 4 (AL, FL, GA, KY,
MS, NC, SC, TN).
EPA Regional Tribal Coordinators
Municipal solid waste:
Davy Simonson, 404 562-8457
Hazardous waste:
Patricia Herbert, 404 562-8449
Atlanta Federal Center, 61 Forsyth Street,
SW., Atlanta, GA 30303-3104
Eastern Band of Cherokee Indians in
North Carolina
Phone: 828 497-6977, or 828 497-3908
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EPA Region 5 (IL, IN, Ml, MM,
OH, Wl)
EPA Regional Tribal Coordinators
Municipal solid waste:
Dolly Tong, 3128864019
Hazardous waste:
Margaret Millard, 312 3534440
77 West Jackson Boulevard, Chicago, IL
60604
Bois Forte Band of Chippewa in
Minnesota
Phone: 218 757-3261
Mailing Address: Department of Natural
Resources, Box 16, Nett Lake, MN 55772
Fond du Lac Band of Lake Superior
Chippewa in Minnesota
Phone: 218 878-8006
Mailing Address: 1720 Big Lake Road,
Cloquet, MN 55720
Grand Traverse Band of Ottawa &
Chippewa Indians in Michigan
Phone: 231 271-3538
Mailing Address: 2605 NW Bayshore Drive,
Buttons Bay, MI 49682
Hannahville Indian Community in
Michigan
Phone: 906 466-2934
Mailing Address: N14911 Hannahville Bl
Road, Wilson, MI 49896
Keweenaw Bay Indian Community in
Michigan
Keweenaw Bay Tribal Center
Phone: 906 353-6623
Lac Courte Oreilles Chippewa Tribe in
Wisconsin
Phone: 715 865-2329
Mailing Address: 13394 West Trepania
Road, Building 1, Hayward, WI 54843
Lac du Flambeau Band of Lake Superior
Chippewa Indians in Wisconsin
Phone: 715 588-3303, extension 255
Oneida Tribe of Indians of Wisconsin
Phone: 920 869-4374
Mailing Address: P.O. Box 365, Oneida, WI
54155
Red Cliff Band of Lake Superior
Chippewa Indians in Wisconsin
Phone: 715 779-3700
E-mail: judyps@ncis.net
Red Lake Band of Chippewa in
Minnesota
Phone: 218 679-3959; Fax: 218 679-2830
Mailing Address: P.O. Box 279, Red Lake,
MN 56671
White Earth Band of Chippewa in
Minnesota
Phone: 218 935-2488; Fax: 218 935-2524
E-mail: welakes@tvutel.com
Mailing Address: 2209 271st Avenue Unit 2,
Mahnomen, MN 55720
EPA Region 6 (AR, LA, NM,
OK, TX)
EPA Regional Tribal Coordinators
Municipal solid waste:
Anan Tanbouz, 214 665-8195
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Hazardous waste:
Ann Zimmerman, 214 665-8532
First Interstate Bank Tower, 1445 Ross
Avenue, Suite 1200, Dallas, TX 75202-2733
Alabama-Coushatta Tribe of Texas
Phone: 936 563-4391
Mailing Address: Route 3, Box 640,
Livingston, TX 77351
EPA Region 8 (CO, MT, ND,
SD, UT, WY)
EPA Regional Tribal Coordinators
Municipal solid waste and hazardous waste:
Ron Lillich, 303 312-6149 and Susanna
Trujillo, 303-312-7008
999 18th Street, Suite 500, Denver, CO
80202-2466
Delaware Nation in Oklahoma
Phone: 405 247-2448; Fax: 405 247-9393
E-mail: aapanahkih@westerndelaware.nsn.us
Mailing Address: P.O. Box 825, Anadarko,
OK 73005
Jicarilla Apache Tribe in New Mexico
Phone: 505 759-3242
Pawnee Nation in Oklahoma
Phone: 918 762-3655; Fax: 918 762-6446
E-mail: cri@cimtel.net
Mailing Address: P.O. Box 470, Pawnee, OK
74058
Seminole Nation in Oklahoma
Phone: 405 382-5112; Fax: 405 382-3211
E-mail: mdouglas@mbo.net
Mailing Address: P.O. Box 1603, Seminole,
OK 74818-1603
Region 8 Montana Office
Municipal solid waste and hazardous waste:
Stephanie Wallace, 406 457-5018
Hazardous waste:
Susan Zazzali, 406 457-5019
301 S. Park, Drawer 10096, Helena, MT
59626-0096
Assiniboine and Sioux Nations of Fort
Peck Reservation in Montana
Phone: 406 768-5155
Mailing Address: Fort Peck Reservation, P.O.
Box 1027, Poplar, MT 59255
Cheyenne River Sioux Tribe in South
Dakota
Phone: 605 964-4155; Fax: 605 964-4151
E-mail: crstchrm@rapidnet.com
Mailing Address: Box 590 Main Street,
Eagle Butte, SD 57625
Zuni Pueblo in New Mexico
Phone: 505 782-4481
Mailing Address: P.O. Box 339, Zuni, NM
87327
Oglala Sioux Tribe of the Pine Ridge
Reservation in South Dakota
Phone: 605 867-5236
Mailing Address: P.O. Box H, Pine Ridge,
SD 57770
Rosebud Sioux Tribe in South Dakota
Phone: 605 856-5644; Fax: 605 856-5647
E-mail: resource@gwtc.net
Mailing Address: Resource Development
Office, PO Box 517, Rosebud, SD 57570
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Spirit Lake Tribe in North Dakota
Phone: 701 766-4221
Mailing Address: Tribal EPA Office, P.O.
Box 99, Fort Totten, ND 58335
EPA Region 9 (AS, AZ, CA, GU,
HI, NV)
EPA Regional Tribal Coordinators
Municipal solid waste:
Kelly Doordan, 415 972-3383
Hazardous waste:
Rebecca Jamison, 415 972-3382
75 Hawthorne Street, San Francisco, CA
94105
Blue Lake Rancheria in California
Phone: 707 668-5101
Mailing Address: P.O. Box 428, Blue Lake,
CA 95525
Campo Band of Mission Indians in
California
Phone: 619 478-9046
Mailing Address: 36190 Church Road, Suite
1, Campo, CA 91906
Fallon Paiute-Shoshone Tribes in
Nevada
Phone: 775 423-6075
Mailing Address: 8955 Mission Road, Fallon,
NV 89406
Fort McDowell Yavapai Nation in
Arizona
Phone: 480 837-5121
Mailing Address: P.O. Box 17779, Fountain
Hills, AZ 85269
Gila River Indian Community in
Arizona
Phone: 520 562-2234; Fax: 520 562-2245
E-mail: mariella@gilanet.net
Mailing Address: P.O. Box 97, Sacaton, AZ
85247
Hop! Tribe of Arizona
Phone: 928 734-2441
Mailing Address: P.O. Box 123, Kykotsmovi,
AZ 86039
Manzanita Band of Mission Indians in
California
Phone: 619 766-4930
Mailing Address: P.O. Box 1302, Boulevard,
CA 91905
Quechan Indian Tribe in Arizona
Phone: 619 572-0213; Fax: 619 572-2102
Mailing Address: Quechan Indian Tribe,
P.O. Box 1899, Yuma, AZ 85366-1899
San Carlos Apache Tribe in Arizona
Phone: 520 475-2218; Fax: 520 475-2268
E-mail: scatepa@mail.theriver.com
Mailing Address: P.O. Box 0, San Carlos, AZ
85550
Smith River Rancheria in California
Phone: 707 487-9255
Mailing Address: 250 North Indian Road,
Smith River, CA 95567
Walker River Paiute Tribe in Nevada
Phone: 775 773-2306
Mailing Address: P.O. Box 220, Schurz, NV
89427
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White Mountain Apache Tribe of
Arizona
Phone: 520 338-4346
Mailing Address: P.O. Box 700, Whiteriver,
AZ 85941
EPA Region 10 (AK, ID, OR,
WA)
EPA Regional Tribal Coordinators
Municipal solid waste:
Fran Stefan, 206 553-6639
Hazardous waste:
Nina Kocourek, 206 553-6502
1200 Sixth Avenue, Seattle, WA 98101
Confederated Tribes of the Warm
Springs Reservation of Oregon
Phone: 541 553-4943
Confederated Tribes of the Umatilla
Indian Reservation in Oregon
Phone: 541 276-4040
Mailing Address: Confederated Tribes of the
Umatilla Indian Reservation, PO Box 638,
72292 South Market Road, Pendleton, OR
97801
Makah Tribe of Indians in Washington
State
Phone: 360 645-2201
Mailing Address: P.O. Box 115, Neah Bay,
WA 98357
Nez Perce Tribe of Idaho
Phone: 208 843-2820
Spokane Tribe of Indians in Washington
State
Phone: 509 258-4581
Mailing Address: P.O. Box 100, Wellpinit,
WA 99040
EPA Region 10-Alaska Field
Office
EPA Regional Tribal Coordinators
Municipal solid waste:
Jean Gamache, 907271-6558
West 7th Avenue, #19, Anchorage, AK
99513
Galena Village, Alaska
Phone:907656-1711
Metlakatla Indian Community in Alaska
Phone: 250 628-3234
Native Village of Barrow-lnupiat
Traditional Government in Alaska
Phone: 907 852-4411 or 800 478-4412; Fax:
907 852-8844
National and Regional Sources
of Information and Training
Alaska Inter-Tribal Council
Phone: 907 563-9334; Fax: 907 563-9337
Web Site: www.aitc.org
Mailing Address: 431 W 7th Avenue suite
201, Anchorage AK, 99501
Alaska Native Health Board (ANHB)
Phone: 907 562-6006; Fax: 907 563-2001
Web Site: www.anhb.org
Mailing Address: 3700 Woodland Drive,
Suite 500, Anchorage, AK, 99517
Association of State and Territorial
Solid Waste Management Officials
(ASTSWMO)
Phone: 202 624-5828; Fax: 202 624-7875
Web Site: www.astswmo.org
Mailing Address: 444 North Capitol Street,
NW Suite 315, Washington, DC. 20001
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Institute for Tribal Environmental
Professionals (ITEP) and Northern
Arizona University Solid Waste Training
for Alaskan Native Villages
Phone: 928 523-9555; Fax: 928 5234266
Web Site: www4.nau.edu/itep/s_waste.html
E-mail: ITEP@nau.edu
Mailing Address: The Institute for Tribal
Environmental Professionals, Northern
Arizona University, P.O. Box 15004,
Flagstaff, AZ 86011
Inter Tribal Council of Arizona (ITCA)
Phone: 602 258-4822; Fax: 602 258-4825
Web Site: www.itcaonline.com
Mailing Address: 2214 North Central
Avenue, Suite 100, Phoenix, AZ 85004
Inter-Tribal Environmental Council
(ITEC)
Phone: 918 458-5498; Fax: 918 458-5499
Web Site: www.itecmembers.org
Mailing Address: P.O. Box 948, Tahlequah,
OK 74465-0948
National Tribal Environmental Council
Jerry Pardilla, Executive Director
Phone: 505 242-2175; Fax: 505 242-2654
Web Site: www.ntec.org
E-mail: jpardilla@ntec.org
Mailing Address: 2501 Rio Grande Blvd.,
Suite A, Albuquerque, NM 87104
National Tribal Environmental Research
Institute (NTERI)
Web Site: www.nteri.net
Solid Waste Association of North
America (SWANA)
Phone: 800 GO-SWANA (800 467-9262);
Fax: 301 589-7068
Web Site: www.swana.org
E-mail: info@swana.org.
Mailing Address: P.O. Box 7219, Silver
Spring, MD 20907-7219
Street Address: 1100 Wayne Avenue, Silver
Spring, MD 20910
Tribal Association for Solid Waste &
Emergency Response (TASWER)
Phone: 202 331-8084; Fax: 202 331-8068
Web Site: www.taswer.org
E-mail: contact@taswer.org
Mailing Address: 1001 Connecticut Avenue,
NW, Suite 400, Washington, DC 20036
U.S. Environmental Protection Agency
(EPA)
Waste Management in Indian Country pro-
vides information to help tribes address
MSW management needs. Readers can
download funding guides, technical docu-
ments, the Tribal Waste Journal, educational
materials, and more. The Web site describes
MSW regulations, new developments,
upcoming conferences, valuable links, and
tribes' successful programs.
Phone: 202 566-1886; Fax: 202 566-1908
Web Site: www.epa.gov/tribalmsw
Mailing Address: US EPA, Office of Solid
Waste (5305W), 1200 Pennsylvania Avenue,
NW, Washington, DC 20460
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American Indian Environmental Office
(AIEO) coordinates an Agency-wide effort
to strengthen environmental protection in
Indian Country. AIEO oversees development
and implementation of the Agency's Indian
Policy and ensures that the agencywide
implementation of its Indian Program is con-
sistent with the Administration's policy to
work with tribes on a government-to-gov-
ernment basis to protect tribal health and
environments.
Phone: 202 564-0303; Fax: 202 564-0298
Web Site: www.epa.gov/indian
Mailing Address: USEPA, AIEO, Mail Code:
4104M, 1200 Pennsylvania Avenue, NW,
Washington, DC 20460
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Appendix C: Sample Public
Education Tools Used by Tribes
The Metlakatla Indian Community
Environmental Office sponsored a series
of posters to encourage people to reduce,
reuse, and recycle,
The St. Regis Mohawk Tribe
Environmental Division sponsored a
series of comic strips called Kwis & Tiio:
Solid Waste Management on the 'Rez to
increase the community's awareness of
proper solid waste management practices
and to illustrate how people's disposal
practices directly impact our environ-
ment.
St. Regis Mohawk Tribe PAYT Program
Brochure
Fond du Lac Band of Lake Superior
Chippewa Tribe's environmental brochure
to educate residents about illegal dump-
ing.
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United States Environmental Protection Agency
Solid Waste and Emergency Response (5306W)
EPA530-R-03-013
November 2003
www.epa.gov/tribalmsw
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