United States
      Environmental Protection
      Agency
Region 5
Illinois, Indiana, Michigan,
Minnesota, Ohio,
Wisconsin
EPA905-B-97-001
March 1998
EPA    Illegal Dumping
         Prevention  Guidebook

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Illegal  Dumping Prevention Guidebook
                    EPA 905-B-97-001
                       March 1998
                      U.S. EPA Region 5
               Waste, Pesticides and Toxics Division
               77 West Jackson Boulevard (DW-8J)
                   Chicago, Illinois 60604-3590
               For additional copies of this document,
            write the above address or call (800) 621-8431
              Recycled/Recyclable - Printed with soy-based inks
              on 100% recycled paper (30% postconsumer)

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                                    CONTENTS

INTRODUCTION  	  1

NATURE OF THE PROBLEM	  1
   What is illegal dumping?	  1
   Who illegally dumps waste? 	  2
   Why is illegal dumping a problem? 	  3
   What factors contribute to the problem?	  4
       Demographics	  4
       Physical Characteristics 	  4
       Lack of Alternative Waste Disposal and Recycling Programs 	  5
       Lack of Solid Waste Codes and Ordinances  	  5

DEVELOPING A PREVENTION PROGRAM	  6
   Leadership and Support by Local Officials  	  6
   Cooperation Among Authorities, Communities, and Industry	  6
   An Integrated Approach	  7
   Publicizing Success	  7

AVAILABLE RESOURCES  	  7

EXAMPLES OF RESOURCE ACQUISITION  FOR ILLEGAL DUMPING PROGRAMS	  9

USING THE TOOLKIT	  10

ILLEGAL DUMPING PREVENTION TOOLKIT	  13

   SITE MAINTENANCE AND CONTROLS
       Cleanup Efforts	  15
       Keeping Sites Clean 	  17
   COMMUNITY OUTREACH AND INVOLVEMENT
       Community Programs	  19
       Effective Outreach and Education	  21
   TARGETED ENFORCEMENT
       Ordinances 	  23
       Dedicated Enforcement and Prosecution	  25
       Field Operations  	  27
   PROGRAM MEASUREMENT
       Tracking and Evaluation 	  29

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INTRODUCTION
Illegal dumping, also known as "fly dumping," "midnight dumping," or "wildcat dumping," is a major
problem in many communities throughout the United States. It raises significant concerns regarding
public health and safety, property values, and quality of life. An effective illegal dumping prevention
program must be customized to address the factors contributing to the problem in a given  community.
This guidebook contains general information about illegal dumping and guidance for developing a
prevention program. A "toolkit" of practices that have proven effective in combating illegal dumping is
included along  with case studies detailing successful implementation of these practices.

This guidebook is intended for use by

    •   State, tribal, county, and local government authorities
       Community groups and civic organizations
    •   Industry
       Utilities (such as railroads and power companies)

The information presented in this guidebook is based on a study conducted to characterize illegal dumping
in urban and rural areas throughout the upper Midwest.  The study included tours of neighborhoods and
interviews with  local government officials, community groups, and industry representatives. In addition, a
literature and Internet search was conducted to gather information on successful illegal dumping
prevention programs. Over 50 individuals from communities, non-profit organizations, corporations, and
government agencies peer-reviewed this guidebook and provided invaluable suggestions for its content.
This guidebook can be found on the World Wide Web athttp://www.epa.gov/region5and will be updated
as new information on innovative prevention programs is discovered.

NATURE OF  THE PROBLEM
What is illegal dumping?
Illegal dumping is disposal of waste in an unpermitted area.  It is also referred to as "open  dumping," "fly
dumping," and  "midnight dumping" because materials are often dumped in open areas, from vehicles
along roadsides, and late at night. Illegally dumped wastes are primarily nonhazardous materials that are
dumped to avoid either disposal fees or the time and effort required for proper disposal.  These materials
typically include

    •   Construction and demolition waste such as drywall, roofing  shingles, lumber,  bricks,  concrete,  and
       siding
       Abandoned automobiles, auto parts, and scrap tires

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       Appliances or "white goods"
    •   Furniture
       Yard waste
       Household trash
    •   Medical waste

Wastes such as scrap tires, bulky items, and yard waste
may be illegally dumped because they are banned from
landfills and their proper management can be costly.
Residential and commercial wastes may be illegally
                                                    Tires and demolition debris illegally dumped at a
dumped in areas that lack or have costly pickup service,  vacant industrial site
Sites used for illegal dumping vary but may include abandoned industrial, residential, or commercial
buildings; vacant lots on public or private property; and infrequently used alleys or roadways.  Because of
their accessibility and poor lighting, areas along rural roads and railways are particularly vulnerable.  Illegal
dumping can occur at any time of day but is more common at night or in the early morning hours during
warmer months.

If not addressed, illegal dumps often attract more waste, potentially including hazardous wastes such as
asbestos, household chemicals and paints, automotive fluids, and commercial or industrial wastes.
Who illegally dumps waste?
It is difficult to profile a "typical" illegal dumper.
However, offenders can include

       Construction, demolition, remodeling, roofing,
       or landscaping contractors
    •   Waste management companies or general
       hauling contractors
       Operators of transfer stations or junkyards
    •   Automobile repair or tire shops
       Scrap collectors
    •   Local residents and "do-it-yourselfers"
                                                     Drums of industrial waste at an illegal dump site

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An individual may claim to be operating a transfer
station or recycling business and accept waste at an
unpermitted facility, only to abandon the facility when it
reaches capacity. A resident may dump wastes that did
not get picked up by local waste haulers, such as bulky
items, carpeting, or household hazardous wastes. In
many cases, illegal dumpers are breaking other laws
relating to vehicle licensing, insurance, drug
possession, or theft.
                           ,  ,                      Abandoned, unpermitted recycling facility
Why is illegal dumping a problem?
The health risks associated with illegal dumping are significant. Areas used for illegal dumping may be
easily accessible to people, especially children, who are vulnerable to the physical (protruding nails or
sharp edges) and chemical (harmful fluids or dust) hazards posed by wastes. Rodents, insects, and
other vermin attracted to dump sites may also  pose  health risks. Dump sites with scrap tires provide an
ideal breeding ground for mosquitoes, which can multiply 100 times faster than normal in the warm,
stagnant water standing in scrap tire casings.  Severe illnesses, including encephalitis and dengue fever,
have been attributed to disease-carrying mosquitoes originating from scrap tire piles. In addition,
countless neighborhoods have been evacuated and property damage has been significant because of
dump sites that caught fire, either by spontaneous  combustion or, more commonly, by arson. Illegal
dumping can impact proper drainage of runoff, making areas more susceptible to flooding when wastes
block ravines, creeks, culverts, and drainage basins. In rural areas, open burning at dump sites can
cause forest fires and severe erosion as fires burn away trees and undergrowth. Dumping activities in
such areas can also have a negative impact on plants and wildlife. Additionally, runoff from dump sites
containing chemicals may contaminate wells and surface water used as sources of drinking water.
                                            Dump sites serve as magnets for additional dumping
                                            and other criminal activities.  As a result of illegal
                                            dumping, property values decrease and the
                                            community becomes unattractive to commercial and
                                            residential developers. Without the tax revenues that
                                            accompany development, the funding available to
                                            establish and maintain effective illegal dumping
                                            prevention programs is limited.  Ultimately, it is the
                                            development of areas susceptible to illegal dumping that
                                            eradicates the problem.
Illegally dumped tires along a creek

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Finally, the costs to local government and industry associated with continuous clearing of illegally dumped
waste materials are significant. Some urban areas have reported  spending several million dollars per year
on cleanup, hauling, and disposal activities associated with illegal dump sites.  These costs may be
passed along to residents in the form of higher service fees or property taxes.

What factors contribute to the problem?
Demographics
Communities subject to illegal dumping are typically areas with limited access to convenient, affordable
waste disposal facilities or services and recycling programs.  In lower-income areas, residents may have
difficulty affording trash pickup and disposal fees. These areas may also have gang- or drug-related
activities and  high crime rates, which often result in illegal dumping being given a low priority by law
enforcement officials  and prosecutors.  The problem tends to be worse in areas with a high population of
renters who have less stake in the community or absentee property owners who do not respond to
problems. Residents in rural areas, where illegal dumping is a  common, long-time practice, may not be
aware of applicable laws or understand its harmful impacts.
Physical Characteristics
Unsecured properties, including undeveloped lots,
abandoned structures, unused industrial facilities, and
remote spaces, are inviting to illegal dumpers. Areas with
vacant properties tend to have a higher incidence of illegal
dumping because of the reduced potential for dumpers to
be sighted. Other areas, including poorly lit access roads,
property along railways, highways and alleys, charity drop
box locations, and construction sites or public areas with
waste containers are  prime  targets for illegal dumping.
Forest preserves, wooded sites, and farms (especially
those near heavily populated areas) are often targets for
illegal dumping because they are sparsely populated and dark. The borders of cities and counties tend to
have a higher incidence of illegal dumping because of a lack of police presence.
Roofing shingles dumped on a rural road
Illegal dumping occurs near junkyards, active or closed landfills, solid waste transfer stations, and
temporary dump areas at construction sites when dumpers want to avoid disposal fees or find that a site is
closed or refuses to accept waste.  Also, the presence of illegally dumped materials attracts additional
dumping.

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Natural disasters, particularly flooding, result in damaged appliances, wrecked furniture, and demolition
debris that may lead to widespread illegal dumping. EPA's  "Planning for Disaster Debris" document
(EPA530-K-95-010) is available to help plan for and address these situations.

Lack of Alternative Waste Disposal and Recycling Programs
Areas without routine or affordable pickup service for trash and recyclables tend to experience a higher
incidence of household and yard waste dumping. Also, landfills and transfer stations that have high
disposal fees, are not conveniently located, have
minimum tipping fees, or do not accept small loads
encourage dumping. Materials prohibited from
landfilling, such as yard waste, scrap tires, freon-
containing appliances, and car batteries, may be
illegally dumped unless alternate management
programs are available, affordable, and well known to
the public. EPA's "Decision-Maker's Guide to Solid
Waste Management" (EPA530-R-95-023) is available
to assist local governments in establishing
comprehensive waste management programs.         illegally dumped tires in and around an abandoned
                                                 warehouse
Communities lacking a contract with a waste hauler
and standardized billing (by which waste removal is integrated into a water or sewer charge) may have
problems with residents who refuse to pay a waste hauler for service on their own. EPA's document titled
"Solid Waste Contract Negotiation Handbook" (EPA220-B-92-004) provides suggestions for establishing
contracts with waste management companies,  and a "Pay-as-You-Throw Toolkit" (EPA530-R-96-013) is
available for communities considering volume-based disposal programs.

Preliminary research shows that communities with "pay-as-you-throw" or unit-based disposal programs do
not experience continuing dumping problems. Although such a community may initially experience
increased illegal dumping when new  programs  are launched, once the public understands the system, the
problem diminishes. Maintaining educational programs is important to avoid an ongoing problem.
Lack of Solid Waste Codes and Ordinances
Illegal dumping is a problem in many areas because of a lack of effective legal codes or ordinances
prohibiting open dumping or burning of wastes.  Both activities are prohibited by federal and most state
laws, but enforcement by local authorities is typically done under local codes, which may be less stringent.

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In some cases, the fines for a dumping offense are less than the costs for proper waste disposal, and
offenders consider the fines to be simply a cost of doing business.  Furthermore, failure to appropriately
regulate waste haulers and disposal operations invites illegal dumping.

DEVELOPING A PREVENTION PROGRAM
Any illegal dumping prevention program must address the contributing factors in the area where it is
implemented. However, successful programs are founded on

    •   Leadership and  support by local officials
       Cooperation among authorities, communities, and industry
    •   An integrated approach
    •   Publicizing success

Leadership and Support by Local Officials
Local politicians and  high-level officials must make prevention programs a priority and support them with
adequate funding, access to equipment, and labor resources. In addition, department staff must work
with available resources to carry out the program and report accomplishments back to high-level
authorities.

Local ordinances and state laws may already exist or can be developed to discourage illegal dumping.
However, ordinances and  laws are ineffective without a commitment from high-level authorities for
enforcement.  For example, police officers must have the support of their command, and the police
department must have the support of the court system. In addition, if illegal dumping is  not viewed as a
priority and little action is taken, residents become frustrated and stop contacting police  or local officials to
report problems. Residents must be encouraged to persist in contacting different local,  county, and state
agencies until they find an individual who is responsive to their concerns.

Cooperation Among Authorities, Communities, and Industry
Local authorities such as police, health, environment, public works, and sanitation departments must work
together and with local communities. Such coordination allows sharing of resources and helps avoid
duplication of effort.  For example, a typical coordination effort involves establishment of an "illegal
dumping task force"  made up of representatives from each local department with the authority or
resources to address the problem.  Including discussion of dumping issues in community-oriented police
"beat meetings" is an example of coordination with communities. Community organizations must work
together by sharing information and presenting a unified voice to authorities.

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An Integrated Approach
An effective illegal dumping prevention approach requires integration of several strategies that
complement one another, including

       Site maintenance and controls
    •   Community outreach and involvement
       Targeted enforcement
       Program measurement

Integration of these strategies and cooperation of partners from government, communities, and industry
are needed to plan, implement, and sustain a successful prevention program.  Each of these strategies is
described in detail in the "toolkit" at the end of this guidebook along with case studies demonstrating their
successful implementation.

Publicizing Success
Publicizing program results is necessary to obtain continued support from high-level authorities and to
maintain cooperation between authorities and community groups. Prevention programs must be
recognized as cooperative efforts, and successes need to be shared with all parties involved to validate
their participation,  gain additional support, and allow others to benefit from lessons learned.

Tracking  program  impacts such as arrests, fines, vehicle impoundments, cleaned-up sites, and avoided
costs is integral  to the continuation of illegal dumping  prevention efforts.  Evaluating program efforts
provides data for cost-benefit analyses, publicity efforts, budget hearings, and grant program
accountability.

AVAILABLE RESOURCES
Specific resources needed for illegal dumping prevention programs include

       Funding from  grants, private donations, operating budgets, special appropriations, and fees
       assessed  on waste management operations
       Services such as landfilling, shredding, hauling, and training
    •   Equipment such as cameras, radios, vehicles, and heavy machinery
    •   Supplies  such as dumpsters, bags, and tools as well as educational and training materials
    •   Human Resources, including personnel to conduct cleanup, enforcement, surveillance,
       inspection, and outreach activities

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All these resources are locally available in some form. Obtaining necessary resources for a new or
expanded  program requires research, creativity, and persistence. Cooperation and communication
among the various parties involved are important not only to avoid duplication of effort but also to
effectively identify, access, and contribute resources. Certain partners may be eligible or better suited to
provide resources than others. For example,

    •   A community group may be able to apply for a grant for which a local government is ineligible
    •   A civic organization may be better suited to approach a potential industry partner for assistance
       and cooperation than an enforcement agency
    •   A local government official may have a  special contact within a local or state agency who can
       provide a quicker response than a resident could obtain through a general inquiry

Many different types of resources have been applied in innovative ways to implement illegal dumping
prevention programs.  Grant funding resources  are presented below.  Both the table on page 9 and the
"toolkit" at the end of this guidebook present examples of how illegal dumping prevention programs have
been able  to access needed funding and other resources.  The EPA documents cited throughout this
guidebook as well as other EPA publications can be ordered by telephone at (800) 490-9198 or on-line at
http://www. epa. gov/ncepihom/.
                                      GRANT FUNDING
Grant funding is available from county, state and federal environmental agencies as well as private
foundations, typically in the form of environmental education, special project, or demonstration funding.
Information on grant resources is available on the Internet, which may be accessed at most public libraries
and schools.  Helpful web sites include the following:

»> The Nonprofit Gateway - http://www.nonprofit.gov

»> Grant Resources for Solid Waste Activity in Indian Country - http://www.epa.gov/tribalmsw/finance.htm

»> Summary of EPA Grant Programs - http://www.epa.gov/epahome/finance.htm

»> Environmental Grantmaking Foundations -http://www.environmentalgrants.com

»> Grant Getters Guide to the Internet - http://web.calstatela.edu/academic/orsp/grantguide.html

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          EXAMPLES OF RESOURCE ACQUISITION FOR ILLEGAL DUMPING PROGRAMS
PROGRAM DESCRIPTION
Trash Cop Program. The Central Oklahoma Trash Cop Program, which consists of environmental officers hired to
catch and prosecute lltterers and Illegal dumpers In four counties, was begun with $160,000 obtained through
fundralslng efforts by a local community group, Oklahoma City Beautiful. The program will be sustained by fines
collected from offenders.
Community Involvement. Phlllaprlde, a community group In Philadelphia, Pennsylvania, promotes neighborhood
participation In cleanup and enforcement activities. The program Is funded primarily by corporations that have had
dumping problems on their properties, such as the Conrall Corporation, which contributes up to $25,000 each year.
Industry-Funded Efforts. The Amoco Foundation supports local efforts to Improve the community In northwest
Indiana. The foundation also provides supplies and volunteers for community cleanup events and nature projects.
Educational Activities and Materials. Lake County, Indiana, received a grant from the state to prepare videos
and outreach materials on Illegal dumping for residents and elected officials.
Scrap Tire Cleanup. A community group In Detroit, Michigan, uses a county grant to pay residents to bring Illegally
dumped tires to drop-off locations. A local waste hauler donates services to transport the tires to a tire shredder,
which shreds them at no charge. A local bank donates money to cover disposal costs.
Flooded Property Restoration. The Federal Emergency Management Agency purchased sections of property In
and around St. Louis, Missouri, that flooded In 1993 and attracted Illegal dumping. Some of the property reverted to
county control after abandoned homes were demolished, waste was removed, and areas were regraded.
Scrap Tire Disposal. The City of Hammond, Indiana, has an agreement with a local junkyard under which the
junkyard donates tire shredding and disposal services In exchange for the city's scrap metal.
Cooperative Cleanup Effort. Cook County led a cooperative cleanup In Chicago Heights, Illinois, that Involved the
sheriffs work assistance program as well as trucks and heavy equipment from the highway department and forest
preserve.
Dumpsters for Cleanups. A community organization In East St. Louis, Illinois, used 550 dumpsters provided by a
local waste management company under a supplemental environmental project related to an enforcement action.
City-Sponsored Neighborhood Cleanups. The Cities of Chicago, Illinois, and Detroit, Michigan, sponsor
neighborhood cleanup days on which storage yards are opened to community groups that use tools, garbage bags,
and other materials to clean up vacant lots. Both cities also provide waste transportation and disposal support.
RESOURCES
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USING THE TOOLKIT
An effective illegal dumping prevention program involves local government, industry, and community
stakeholders working together to address the problem in a defined area.  The following steps have proven
successful for establishing and implementing a customized prevention program:

       1.   Identify and assemble stakeholders to establish interest in working together
       2.   Define the boundaries of a specific target area
       3.   Conduct a thorough assessment of the problem (see page 11)
       4.   Clearly define goals
       5.   Select program components from the "toolkit" to develop an integrated program
       6.   Develop a written description of the overall program design, existing resources, and needs
       7.   Use the written description to seek resources
       8.   Assign specific responsibilities and delegate roles
       9.   Monitor program implementation and evaluate program impacts
       10.  Publicize qualitative and quantitative impacts of the program

An integrated approach can  be effective if the appropriate tools are used.  The second part of this
guidebook contains a "toolkit" that outlines and describes practices that have proven to be effective in
combating illegal dumping. Case studies are provided that describe successful applications of the
practices and identify contacts for further information. In addition, the "toolkit" identifies specific resources
that can be used to support local implementation of an illegal dumping prevention program.
                                              10

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                           ASSESSING THE PROBLEM

The following topics should be examined when an illegal dumping problem is assessed for a given
target area:

• The Nature of the Problem
»> Locations of persistent illegal dumping problems
»> Commonalities of illegal dumping areas, including demographics and types of waste
»> Commonalities of illegal dumping incidents, such as the source of the waste, dumping incident
   characteristics, and the profile of illegal dumpers
»;* Possible driving forces behind illegal dumping, such as user fees, restrictions on curbside trash
   pickup, or lack of effective recycling programs

• The Players Involved
   Departments or agencies responsible for enforcing  laws, ordinances, or regulations
   Other organizations involved, such as community groups or local industry
   Level of coordination and communication among involved organizations
   Amount of information-sharing with other geographic areas

   Past and Ongoing Efforts
   Local laws, ordinances, or regulations that address  illegal dumping
   Existing programs or previous efforts to prevent illegal dumping
   Methods used to monitor or measure illegal dumping and any trends observed
   Previous or ongoing cleanup efforts,  such as community volunteer cleanup days
   Communication of illegal dumping prevention efforts to the community
   Efforts that have been successful or  unsuccessful and why

   Resources
   Sources of funding for previous or existing efforts to address illegal dumping
   Additional resources needed to adequately address illegal dumping  problems
                                          11

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Preceeding Page Blank
      ILLEGAL DUMPING PREVENTION TOOLKIT
                      SITE MAINTENANCE AND CONTROLS
                          Cleanup Efforts
                          Keeping Sites Clean
                      COMMUNITY OUTREACH AND INVOLVEMENT
                         Community Programs
                         Effective Outreach and Education
                      TARGETED ENFORCEMENT
                         Ordinances
                         Dedicated Enforcement and Prosecution
                         Field Operations
                       PROGRAM MEASUREMENT
                          Tracking and Evaluation
                               13

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        NO
      DUMPING
      ALLOWED
      SITE MAINTENANCE AND CONTROLS
                                         CLEANUP EFFORTS
Cleanup projects require a coordinated planning, resource
acquisition,  and  implementation  effort.    Necessary
resources include  labor, equipment, and  funding.  Labor
resources can be sought from community  and youth
groups,  local government organizations, corporations, or
state or county corrections programs. Equipment such as
containers, rakes, bags, gloves, shovels, heavy equipment,
and trucks can be provided by  public works  or highway
agencies and  private  companies.   Funding for waste
disposal  may be  provided by government agencies or
through  corporate  donations. In some cases, removed
materials such as brick and concrete can be used in a local
fill project, thus reducing disposal costs.

Local industry and  community groups  can assist in
landscaping  and improving  the physical  appearance of
areas.  Such  beautification efforts can ward off potential
dumpers.
  In  addition,  New  Spirit  uses  volunteers  from
  neighborhood organizations for trash pickups and tire
  sweeps. Contact New Spirit, (618) 874-0312.

  Barberton,  Ohio.   The city  health  department
  presented certified cleanup orders to owners of an
  illegal dump site.  The vacant 2-acre site, which was
  located in a heavily wooded area near a residence,
  contained 15-foot-high piles of household waste and
  scrap tires. Several drums of hazardous waste were
  discovered during the cleanup.  The city forced the
  owners to hire a contractor to clean up the site and
  authorized funding to cover about half the cost, in order
  to accelerate the cleanup.  The entire cost of the
  cleanup, estimated at $80,000, was recovered from the
  owners.  Contact Mike  Meusel,  Health Department,
  (330) 745-6067.
Sites must be cleaned up before a threat to public health
and safety develops.  State and federal cleanup programs,
such as Superfund, may support urgent projects where a
defined health or environmental threat exists.

A plan must be developed to remove any dumped materials
and keep sites clean. Such a plan should be developed
before a cleanup to ensure that the effort is not wasted.

Case Studies

•   East St. Louis,  Illinois. New Spirit, an organization
    representing over 30  neighborhoods,  coordinates
    Community Cleanup Days.  The events have resulted
    in removal of over 166,000 tons of waste from inner city
    areas. New Spirit obtained 550 dumpsters from a local
    waste management company as part of a supplemental
    environmental project mandated by EPA.
Drums discovered and secured during cleanup activities
                                                    15

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     NO
  DUMPING
  ALLOWED
      SITE MAINTENANCE AND CONTROLS
                                     CLEANUP EFFORTS
Pennsylvania.  Pennsylvania CleanWays is a nonprofit
organization that helps communities clean up illegal
dump sites in rural areas. As a condition to providing
assistance, before a cleanup Pennsylvania CleanWays
works with everyone involved  to develop a plan to
remove any materials dumped after the cleanup. The
"subsequent dump" team is made up of residents, law
enforcement officials, businesses, trash haulers, and
landfill operators. Residents are taught what evidence
to look for, who the responsible enforcement officials
are, how to contact them, and how to remove trash if
necessary.  Residents bag and pile trash to make it
easy for those  who have agreed to haul it away. To
date, the program has cleaned up over 40 rural sites
and 500 truckloads of waste.  Contact Sue Wiseman,
Pennsylvania  CleanWays, (412) 836-4121.

Cook  Couny,  Illinois.     The  Department  of
Environmental Control, Sheriffs Department,  Highway
Department, and Forest Preserve District partner with
communities to clean up and  maintain problem dump
sites.    Labor  is  provided  by the Sheriffs  work
assistance program, and  heavy equipment is  provided
by the Forest Preserve District. Waste is transported
for proper disposal and sites are secured with concrete
barriers by the Highway Department. Contact Charles
Lagges,   Department  of Environmental   Control,
(708) 865-6165.
  Detroit, Michigan. The city, the Michigan Department
  of  Environmental  Quality,  and EPA targeted  an
  abandoned factory being used for illegal dumping for
  cleanup and demolition.  The 11-acre site had 21
  buildings and was the site of several tire fires.  Over
  100,000 tires, 180 drums, and 30 truckloads of trash
  were removed  from the site  before demolition of the
  buildings. The area was fenced off and remains free of
  trash.  The Redevelopment of Urban Sites team was
  established to address such sites.  Contact Sarah Lile,
  Environmental Affairs Department, (313) 237-3090.
A former dump site that has been cleaned up and remains
clean
                                                16

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        NO

      DUMPING
      ALLOWED
       SITE MAINTENANCE AND CONTROLS
                                       KEEPING SITES CLEAN
Many illegal  dumping  areas continue to experience
problems after being cleaned up.   Signs, lighting,  and
barriers  can reduce or eliminate continued dumping  in a
given area.  In addition, a plan needs to be in place to
maintain the area and to promptly remove any materials
that are  dumped.

Cleaned-up sites can be converted to clean areas that no
longer attract illegal dumping. Residents benefit from the
availability of attractive space  and improved  property
values.

Signs
Some residents may  be unaware that dumping is illegal
and  punishable by fines or  prosecution.  Use of  "No
Dumping" signs can be effective in preventing dumping and
creating  awareness of ordinances. Signs placed in a high-
incidence area can specify fines and penalties or indicate
that the area is under surveillance. The area around such
signs must be kept clear of debris.
Lighting
Lighting can be an effective preventive measure in poorly
lit or remote areas that experience "midnight dumping."
Lighting increases the  visibility  of the  crime  and the
chances of the offender's being caught. Installing lighting
requires an investment in electrical service  and equipment.

Barriers
Barriers that  limit access are critical for reducing  and
eliminating dumping in areas with a single point of entry.
Fences, posts,  berms,  and concrete highway dividers
prevent vehicle access.  However, such barriers  must not
limit legal or emergency access to residences or buildings.
In some cases, offenders may continue to dump at or over
barriers instead of inside the restricted area.
Sign prohibiting illegal dumping under a city ordinance
Concrete barriers preventing access along railroad right-of-way


Landscaping and Beautification
Landscaping and beautification efforts range from simply
cutting grass and pulling weeds to establishing parks with
benches,  walkways, trees,  picnic  tables,  grills,  or
                                                    17

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        NO

      DUMPING
      ALLOWED
      SITE MAINTENANCE AND CONTROLS
                                       KEEPING SITES CLEAN
playgrounds.   Other  efforts  include painting  murals,
establishing gardens and flowerbeds, or converting sites
into  natural  areas.    Local  schools  and  university
cooperative  extension  services  can assist  at urban
gardening sites or in projects involving establishment of
plants requiring little or no maintenance.  Communities
where residents have limited access to public areas are
ideal for such projects.

Case Studies

•   Chicago, Illinois.   The city conducts a program in
    which vacant lots are secured to prevent additional
    dumping.  Vertical, steel I-beams protruding a few feet
    above the ground have proven to be the most effective
    barrier at over 500 locations.  The  city places "No
    Dumping" signs that also clearly identify the penalties
    for dumping. The signs have been effective in creating
    an  awareness that illegal dumping is not tolerated.
    Contact Alexandra Holt,  Department of Environment,
    (312) 744-3172.

•   Boston,  Massachusetts.  Boston's  beautification
    initiatives  focus   on   arranging    partnerships,
    maintenance agreements, and adoption  of space
    resulting in cleanups, paintings, and plantings. The
    Youth Clean-Up Corps Red Shirts program sent over
    2,300 youths into neighborhoods for 38 days, resulting
    in cleanup of 3,722  sites and removal of 136,709 bags
    of trash weighing over 850 tons. The Broom to Bloom
    initiative involves distribution of planters and hanging
    flower baskets along selected roadways. Contact the
    Environmental Services Cabinet, (617) 635-3425.

•   Los  Angeles, California.   The  Nuisance  Alley
    Conversion  Project is  a  joint venture between
    neighborhoods, the City Council, and the Department
    of Public Works.   The  project involves fencing  off
   "nuisance alleys and signing them over to residents for
   use as parks. Over 13 alley conversions have taken
   place at an average cost of $12,000 each.  Contact the
   Environmental Hotline, (626) 458-3561.

   Whiting, Indiana. The Amoco Corporation cleaned up
   a 10-acre property located between residences and a
   tank farm.   Beyond  reintroducing  native grasses,
   building bird boxes, eliminating invasive plant species,
   and  clearing  pathways   for   trails,  the  Wildlife
   Enhancement Council provided guidance on using
   community outreach and involvement  to sustain the
   effort.  The "Lost Marsh" is now home to 23 bird and
   59 plant species. Roadways bordering the tank farm
   were beautified by planting flowerbeds,  lawns, and
   trees.  The project generated  a renewed sense of
   environmental stewardship and  community pride, and
   it reawakened  various stakeholders to the value of
   small parcels of underdeveloped land. Contact Kevin
   Sprague, Amoco Corporation, (219) 473-3148.
Signs posted in Amoco Corporation's Lost Marsh area
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                                                       COMMUNITY OUTREACH AND INVOLVEMENT
                                   COMMUNITY PROGRAMS
Community programs established to organize special waste
cleanup events and support community-oriented policing
have  proven  effective  in  addressing  illegal  dumping
problems.

The focus of any community involvement effort should be to
teach residents what can be done to prevent illegal dumping,
how and why they should get involved, and who to contact for
assistance or to report an incident. In some areas, organized
community groups serve as the main catalyst for information
exchange and involvement among residents.

Community Events
Organized events to collect and  properly dispose of illegally
dumped materials, such as tire collections,  "Clean Sweeps,"
and cleanup days, often  involve resources provided by
government or  industry and the efforts of local residents.

Case Studies

•  Phoenix, Arizona.   The city established  an  illegal
   dumping  prevention program in 1990 that involves public
   education,   citizen   involvement,   dedicated   local
   prosecution, convenient  waste drop-off sites, and free
   disposal for small residential waste loads.  Project HALT
   (Help  Attack  Littering  and Trashing)  uses  citizen
   volunteers to monitor high-frequency dumping areas and
   aid in reporting and prosecuting illegal dumpers. In 1996
   and 1997, the program cleaned up over 15,000 tons of
   waste, and officers issued over 165 citations. Contact
   Juan Martin, Public Works Department, (602)  256-5600.

•  Tupelo, Mississippi. Upon request, the city will drop off
   a truck for use over a weekend by residents to dispose
   of wastes  generated  during home improvements or
   community cleanup projects.   Although  this program
   does not allow for disposal of tires or  industrial and
   household hazardous wastes, the city sponsors separate
   events for those materials.  The city covers the cost of
   waste transportation  and  disposal.   Contact  Boyd
    Yarbrough,  Department of Public Works, (601) 841-6435.
•   Clifton, New Jersey. The city's Clean Communities
    Program consists of events and programs intended to
    clean up and  maintain areas subject to  dumping or
    littering.  The program  is funded  by a state  grant
    program that receives money from a tax on businesses
    that sell 15 types of products that often end up as litter.
    Over 150 businesses; all the city's schools; and civic,
    youth, and neighborhood  organizations contribute to the
    program. Clifton's program has had a significant, visible
    impact on the cleanliness of city streets, parks, and
    neighborhoods. In 1991  and 1992, the amount of litter
    collected decreased from 422 to 358 tons, and over
    3,000 miles of  streets and  175 acres of parkland were
    cleaned  up.  Contact Alfred DuBois, Department of
    Public Works, (973) 470-2239.

•   Detroit, Michigan. The  "Tire Roundup" sponsored by
    the Southwest Detroit Environmental Visions (SDEV)
    community organization encourages local residents to
    get involved in cleaning  up scrap tire piles.  Using a
    grant from Wayne County, SDEV pays local residents to
    bring illegally  dumped  tires to designated drop-off
    locations. In 1995, SDEV offered 25 cents  per tire, and
    over  8,000  tires were  collected.  A waste hauler
    transported  tires from  drop-off  locations  to  a tire
    shredder that processed  the tires at no charge. A local
    bank donates $3,000 to cover the cost  of disposal.
    Contact Kathy Milberg, SDEV, (313) 842-1961.

Community-Oriented Policing
Community-oriented  policing  involves  joint efforts of
residents and  police to identify, analyze, and develop
solutions to crime-related  problems,  including  illegal
dumping. Although the implementation strategy depends on
conditions within local law enforcement agencies and the
community, the following core components are common:

•   Open communication and cooperation
•   Receptiveness to change
•   Commitment
•   Trust
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                                                       COMMUNITY OUTREACH AND INVOLVEMENT
                                    COMMUNITY PROGRAMS
Effective community-oriented policing requires officers to
(1)  communicate  how  residents  can  assist in  crime
prevention and  (2) develop cooperative relationships with
residents. Police can create such interaction by holding "beat
meetings," speaking to neighborhood groups, participating in
business and  civic events,  and conducting educational
programs for school children. Residents in turn voice their
concerns about neighborhood crime.  They also assist police
by reporting crimes  and identifying offenders  whenever
possible, participating in police-sponsored programs, and
soliciting police  involvement at community functions. Over
10,000  cities  in  the  United  States have established
community policing programs.

For information  on grants to establish community policing
programs, contact

          United States Department of Justice
         Office of Community Policing Services
             1100 Vermont Avenue, N.W.
               Washington, D.C. 20530
                    (202) 514-2058
               http://www. usdoj. gov/cops

Case Studies

•  Chicago, Illinois. The police department's community
   policing program employs a community-based approach.
   Police officers and residents meet monthly at "beat
   meetings" to identify neighborhood crime issues and
   develop  strategies.  The information provided to the
   police helps  officers to identify patterns of illegal dumping
   and prioritize surveillance operations.  Department of
   Environment staff participate  by providing  information
   specific to illegal dumping at the meetings. Wallet cards
   and refrigerator magnets are  distributed  that display a
   hotline number to call in order to  report illegal dumping
   crimes.    Contact  Alexandra  Holt,  Department  of
   Environment, (312) 744-3172.

•  Chattanooga, Tennessee. The Citizens Task Force on
   Neighborhoods reviewed city policies on illegal dumping
   and made  recommendations to  improve  community
policing, strengthen penalties, wage a public relations
campaign to market properties subject to dumping, and
establish drop-off sites for bulk waste items.   As a
result, the city provides "Sparkle Wagons" to residents
free  of charge  to haul loads of waste to  a landfill.
Several other recommendations were implemented by
the City Council, including forming a special team of
nine officers to attend neighborhood meetings and visit
schools  to speak with  students.   Contact the
Department of Public Works, (423) 757-5300.

Crimestoppers. Several communities with persistent
illegal dumping problems choose to highlight a particular
dumping  incident as the "Crime of the Week" in local
Crimestoppers programs.  The case is highlighted on
television, radio, and the Internet, providing pertinent
details about the crime and asking the public for help in
identifying suspects or vehicles  that may have been
involved.  A toll-free number is provided, and callers can
remain anonymous. If a tip leads to an arrest, the caller
providing the information is eligible for a cash reward.
Hundreds of Crimestoppers programs exist throughout
the United  States, and regional directories of local
programs  are  available.   Contact  Crimestoppers
International, Inc.,  P.O. Box 30413, Albuquerque, New
Mexico, 87190-0413 or http://www. c-s-i. org.
                                                          Promotional materials for community policing program
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                                                     COMMUNITY OUTREACH AND INVOLVEMENT
                            EFFECTIVE OUTREACH AND  EDUCATION
Many argue that the most important component of a
successful illegal dumping prevention program is public
education.  However, outreach and education programs
are only effective when the behavior of a target audience
changes or is sustained.  In this regard, designing and
implementing effective outreach and education programs
for illegal dumping  prevention are similar  to marketing
campaigns for consumer products or services.

Target Audience
Identification of a target audience that needs to change or
sustain its behavior is the first step. It is important to begin
by designing an  approach tailored to  the  specific
characteristics of the target audience.   An  audience
assessment can determine which information media are
appropriate and the best ways to explain concepts as well
as the need for multilingual information. Involving members
of the target audience greatly assists in development of
outreach materials.

A Simple  Message
A clear, simple message to which the target audience can
relate must be developed.  The message can be as simple
as "No Dumping," "Nail A Dumper," or "Keep It  Clean."
The  message can then be supported with information
convincing the audience to comply, including

•  Listing fines and penalties

   Indicating that areas are under surveillance

•  Showing photographs of dump sites

   Quantifying the  costs of cleaning up sites and the
   resulting impacts on local taxes

•  Listing proper disposal sites and practices.
Communication
Use of various methods to disseminate information will
ensure that  the  message is  received by  the  target
audience.  Media that can  be used include newspapers,
magazines, flyers, billboards, posters, television, radio, the
Internet, wallet cards,  and refrigerator magnets.  An
integrated  approach  involving  different  media  can
maximize the impact of the message.

Confirmation
Soliciting feedback on  outreach  and  education efforts
assists  in  continuation   of  current  programs   and
development of future efforts. For example, callers to a 24-
hour hotline can  be  asked how  they heard about the
system. The responses can be documented and evaluated
to determine  which advertising methods are reaching
residents.

Available Resources
If communication service providers are made aware of the
purpose of a community outreach project,  they may be
willing to donate printing services, graphics services, air
time, supplies, or equipment.  In addition, employees of
local industries may offer their time and talents to support
awareness and prevention programs.

Keep America Beautiful, Inc., helps communities to prevent
littering, encourage community beautification, and generate
ongoing support for integrated waste management.

            Keep America Beautiful, Inc.
            1010 Washington Boulevard
                Stamford, CT 06901
                 (203) 323-8987
                http://www. kab. org
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                                                      COMMUNITY OUTREACH AND INVOLVEMENT
                             EFFECTIVE  OUTREACH AND  EDUCATION
In  addition, inexpensive labor to develop and conduct
community  outreach  efforts  can  be  found  at local
universities. The Environmental Careers Organization and
the Americorps program provide low-cost student interns
involved in environmental studies for projects.

       The Environmental Careers Organization
                 179 South Street
                Boston, MA  02111
                  (617)426-4375
                http://www. eco. org

            Americorps/VISTA Program
           Corporation for National Service
            1201 New York Avenue, N.W.
              Washington, DC 20525
                  (800) 942-2677
                http://www. ens. gov

Case Studies

•  Philadelphia, Pennsylvania.  Phillapride  uses  a
   multimedia approach to  publicize  illegal  dumping
   prevention and enforcement activities. A booklet titled
   "Organizing Your Community Against Illegal Dumping"
   that outlines  methods for building teams to combat
   illegal  dumping  was  developed  and  distributed.
   Television and radio spots are used to announce ways
   for local residents to prevent and report dumping, such
   as calling a 24-hour hotline. In addition,  information
   specifically targeting children is published, including an
   educational comic book series for schools called "The
   Untrashables."  Contact Mark  Vigiano,  Phillapride,
   (215) 575-2210.

•  North-Central Texas. The Council of Governments
   established a comprehensive awareness campaign
   under a grant  from the  Texas Natural Resource
   Conservation Commission. Atoll-free, 24-hour hotline
is used to forward citizen complaints to local law
enforcement officials for response. Complaints can
also be submitted electronically via the Internet. The
program's slogan is "If You See It, Report It," and the
program has several educational aspects, including
law enforcement training and a "Top Ten Most Least
Wanted" list of illegal dump sites. Contact Heather
Lauden, Council of Governments, (817) 695-9239.

Akron, Ohio.   Keep  Akron Beautiful solicits the
involvement and support of local industry for illegal
dumping   prevention   and  awareness  programs.
Members of the "Clean Team" visit businesses to
distribute anti-littering  information and educational
materials.   In addition, "Seals of  Approval"  are
presented to businesses that demonstrate exemplary
environmental stewardship. The program encourages
individual resident involvement in littering prevention.
Contact Paula Davis,  Keep  Akron  Beautiful,  Inc.,
(330)375-2116.

Franklin County, Ohio. The Solid Waste Authority of
Central Ohio's "Nail a Dumper" program has a 24-hour
hotline,  a  dedicated  investigation team,  a strong
prosecution record, and effective outreach efforts.
Over 5,000 complaints have been received, with nearly
8 percent resulting in criminal charges being filed, and
over 1,000 cases  have  been prosecuted.   The
program's extensive education efforts  and cleanup
projects are effective  in  involving  schoolchildren,
residents,   and  companies.   An  Environmental
Investigations Workshop for other law enforcement
agencies in Ohio was developed based on actual
experiences of the county prosecutor and sheriff. The
"Nail a Dumper" program involves cooperation among
the Franklin County Prosecuting Attorney's Office,
Sheriff's Department,  Board of Health, and City of
Columbus Refuse Department.  Contact Mitzi Kline,
Franklin County Board of Health, (614) 462-3160.
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                                                                            TARGETED ENFORCEMENT
                                             ORDINANCES
The  "backbone"  of  effective  enforcement  consists of
ordinances that regulate waste management and prohibit
illegal dumping.

Ordinances can require permitting or licensing of waste
management activities, prohibit open burning and dumping
on private and public property, or require owners of rental
properties to contract for waste pickup services for renters.
Effective ordinances include clear definitions of key terms
to avoid "gray" areas.

In addition, ordinances can impose penalties, including

•   Fines
•   Incarceration
•   Vehicle impoundment
•   Cost  recovery for site cleanup or security
•   Liens on property
•   Revocation  of licenses or permits
•   Community service


Creative  use of penalties  can contribute to a prevention
program.   For example,  fines can generate program
funding (if collection  systems are adequate) or can be
transferred to an account from which citizen rewards can
be paid. Community service requirements can be directed
toward cleanup  and beautification projects.

Permitting of transfer stations and recycling facilities allows
regulators to monitor waste loads via receipts, load tickets,
or manifests.   In addition,  enforcement  officials  and
residents can  more easily recognize unlicensed waste
haulers if licensing placards or stickers  are required.
Similar controls can be used to  monitor disposal of waste
generated by demolition projects.

Ordinances, permits, and licenses are effective only to the
extent that they  are enforced  and   offenders  are
prosecuted.   Ordinances  require the  following  to  be
effective:

    Sufficient resources
    Trained enforcement officials
•    Clear lines of authority
    Timely prosecution
•    Support of the judicial system


Effective ordinances must be tailored to meet specific
needs.    However,  the  following  components  are
recommended to support  a  comprehensive  prevention
program:
         Effective Ordinance Components

        •  Definition of key terms
        •  Authority for inspections and
          enforcement
        •  Authority for vehicle impoundment
        •  Permitting and application requirements
        •  Permit renewal, transfer, and revocation
          provisions
        •  Collection and hauling requirements
        •  Storage and processing requirements
        •  Fee collection
        •  Prohibited activities and violations
        •  Litter prevention
        •  Owner responsibilities
        •  Penalty clauses
        •  Liability clauses
        •  Severability clauses
        •  Prosecution procedures
        •  Authority for emergency abatement
          activities
        •  Cost recovery
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                                                                            TARGETED ENFORCEMENT
                                             ORDINANCES
Case Studies

•   New York,  New York.   The city  defines  illegal
    dumping as  the action of "any person, their agent,
    employee, or any person under their control to suffer or
    permit  any dirt,  sand,  gravel, clay,  stone,  rocks,
    rubbish, building rubbish, sawdust, shavings or trade
    or household waste, refuse, ashes, manure, garbage,
    rubbish or debris of any sort, or any other organic or
    nonorganic material, or other offensive matter being
    transported in a  dump truck or other vehicle to be
    dumped, deposited or otherwise disposed of in or upon
    any street, lot, park, public place or other area whether
    publicly or privately owned."  Vehicle owners or drivers
    are  liable, and  fines range from $600 to $1,500.
    Section 16-119,  Administrative Code, City of New
    York.

•   Chicago, Illinois. City penalties for dumping without a
    permit can include fines up to $2,000; 6 months in jail;
    and  up to 200 hours of community service. Violators
    are liable for up to three times the cost of cleaning up
    a site, and city contracts can be terminated. Vehicles
    are  subject to seizure and impoundment,  with the
    owner of record liable for a $500 fine in addition to
    towing and storage fees. Finally, owners or occupants
    of any unimproved parcel of real estate must remove
    any  abandoned or derelict motor vehicle, garbage,
    debris,  refuse,  litter,  or  miscellaneous  waste.
    Violations can result in fines of $200 to $1,000 per day.
    Ordinances 7-28-440 and 7-28-450, Municipal Code,
    City of Chicago.
Hammond, Indiana. Permits and fees are required
for inspection of waste-hauling vehicles.  A $250 per
vehicle fee is required for vehicles, including  pickup
trucks, that haul waste. Permits are not required for
any federally, state, county, or municipally owned and
operated waste-hauling  vehicles.  At the time  of
payment for the permit, a numbered sticker is issued
that must be attached to the regulated waste-hauling
vehicle  in a  conspicuous location.   Article  94.41,
Administrative Code, City of Hammond.

State of Michigan.   The Natural Resources and
Environmental Protection Act regulates transportation,
storage, and disposal of scrap tires. Tire retailers must
maintain records indicating the number of scrap tires
removed and their final destination.  Haulers must
maintain  records  of each   load  of  scrap  tires
transported on an approved manifest form.  A copy of
the form must be provided to the person contracting for
removal of scrap tires and the  registered collection site
or licensed  landfill  where the tires are  delivered.
Haulers and  collection  site owners must  display
registration numbers and  renew their registrations
annually.    The  state   partners  with   local law
enforcement  to enforce the provisions of the act.
Public Act 451, Part 169.
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                                                                           TARGETED ENFORCEMENT
                     DEDICATED ENFORCEMENT AND PROSECUTION
Dedicated enforcement and prosecution personnel are
valuable contributors to an illegal dumping prevention
program.

Enforcement
Dedicating  officers to illegal dumping prevention  and
enforcement is an example of how high-level authorities
can support prevention efforts. Law enforcement officers
assigned to illegal dumping  must have  knowledge of
applicable laws and ordinances. In addition, they must have
the authority to issue citations, make arrests, impound
vehicles,  and conduct surveillance.  Officers from local
police or sheriffs departments are ideal candidates for
assignment. Off-duty officers can supplement on-duty staff
during  warm-weather  months,  when dumping  activity
peaks.   In many cases, investigating dumping cases
provides officers with the opportunity to further investigate
suspects or premises for other crimes.
 Trash task force arresting an environmental offender
Other government agencies (such as health,  sewer, or
environmental departments) can also dedicate  personnel
to illegal dumping  cases,  but they must  have either
appropriate authority or easy access to law enforcement
officers.   The  latter  requires an  efficient means of
communication and, more importantly, a commitment by
officers with authority to provide timely backup.
A dedicated task force can be formed that consists of
enforcement  officials  from  different departments  or
agencies with  the authority or responsibility for illegal
dumping prevention. Such collaborative efforts encourage
cooperation  and  reduce  the  burden   on  individual
organizations.  Task forces with  representatives  from
different levels  of government (city,  county,  state,  or
federal) can be effective in working together to apply the
strongest ordinance or law to an offender.

Case Studies

•   Detroit, Michigan.    The  Detroit  Environmental
    Enforcement Project (DEEP) Task Force consists of
    officials from the law, fire, police, public works, water,
    environmental affairs, communications, and planning
    departments. In the pilot phase, seven  police officers,
    two firefighters, and four state conservation  officers
    conducted   surveillance  and   investigated   illegal
    dumping in  two target precincts.  Driving unmarked
    cars (donated by  a local auto manufacturer) and
    wearing plain clothes, this team attempted to catch
    dumpers in the act.  A toll-free complaint hotline was
    established, and  reported cases  are  electronically
    tracked. The program  has resulted  in nearly 100
    arrests. Task force activities were expanded to involve
    all 12   police precincts.   Contact Gregory  Moore,
    Environmental Affairs Department, (313) 237-3095.

•   St. Louis, Missouri. The Trash Task Force consists
    of off-duty police officers who use personal vehicles to
    conduct surveillance and enforce illegal dumping
    ordinances.  Task force members are carefully chosen
    and must  be  former detectives  with experience
    investigating environmental crimes. The officers sign
    independent contracts to cover the 20 hours per week
    they spend on task force activities. They make arrests
    and contact on-duty officers using cellular phones to
    obtain  backup or transport offenders.  The task force
    also responds to citizen complaints received through
    the  Citizens Service  Bureau,  which  acts  as  a
                                                    25

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                                                                          TARGETED ENFORCEMENT
                     DEDICATED ENFORCEMENT AND PROSECUTION
    clearinghouse for illegal  dumping  questions  and
    complaints. In 1996 and 1997,  the task force made
    over 100 arrests;  towed 21 vehicles;  and made over
    1,600 investigations. Contact Jeff Towers, Trash Task
    Force, (314) 622-4628.
 Trash task force members holding sign describing reward
 program

•   Los Angeles,  California.  The Bureau  of Street
    Maintenance was spending over $4 million annually to
    clean up illegally dumped material. In partnership with
    the police department and City Council, a task  force
    consisting of two police officers and 16 reserve officers
    (police-trained volunteers) was created. The reserve
    officers survey  locations frequented  by  dumpers to
    catch violators in the act. Over 100 arrests were made
    and 60 vehicles were impounded between  1995 and
    1997.  The program realized police salary savings of
    $112,000 by using reserve officers; local businesses
    were retained,  and citizens became more active in
    reporting crimes. Contact Officer Jeff Churchill, Police
    Department, (213) 846-6521.

Prosecution
The enforcement process can be  further enhanced  by
dedicating a local prosecuting attorney to dumping cases.
Such  an approach can help ensure  that cases are
processed in a timely and consistent manner. A dedicated
prosecutor can  be a  valuable  resource  for  officers
investigating,  gathering evidence  for,  and developing
cases.  With  knowledge of the court system  and case
precedents, a dedicated prosecutor can  help ensure that
cases are prepared properly and have the best chance of
a favorable ruling.

Another option is to limit the focus of a  court session to
environmental cases.  This approach,  especially when
cases are  heard by a dedicated judge or hearing officer,
provides for consistency in case disposition and  penalties.

Case Studies

•   Charlotte, North Carolina.  The  city  and county
    established an  environmental court for violations of
    local and  county environmental laws. The court is
    limited  to  prosecuting  misdemeanors  involving
    dumping of less than 500 pounds of waste.  A related
    work group includes federal; county; state;  and local
    fire, sewer, and  police department officials involved in
    enforcement. Anyone convicted is required to run a
    full-page advertisement in a newspaper apologizing for
    the violation.  The City does no further business with
    contractors  convicted   of  environmental  crimes.
    Contact C.  Nicks Williams,  U.S. Attorney's Office,
    (704) 344-6222.

•   St. Clair County, Illinois. The Illinois Environmental
    Protection Agency works closely with the  local State's
    Attorney's Office to  prosecute environmental cases.
    About  20 percent of the state's attorney's time is
    dedicated  to  illegal dumping, greatly enhancing
    prosecution of environmental cases and  allowing for
    collection  of penalties  and  site cleanups.   The
    program's reputation serves as a deterrent to illegal
    dumping and has led to the cleanup of many sites. In
    addition, the state's attorney serves  as an advisor to
    local enforcement officials on solving  environmental
    problems.    Contact  Penni  Livingston,    State's
    Attorney's Office, (618) 277-3892.
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                                                                            TARGETED ENFORCEMENT
                                       FIELD  OPERATIONS
Field  operations  targeting   illegal  dumping   require
appropriate  officer training,  authority, equipment, and
surveillance strategies.

Training
Law enforcement officers assigned to illegal dumping
prevention must have knowledge of applicable laws and
ordinances to be effective in the field.  Training materials
can include  "pocket" or "short charge" cards outlining
relevant ordinances, sample  tickets, or training bulletins
and manuals. Short videotapes can be played at roll call,
or environmental issues can  be integrated into academy
training programs.

Several    organizations    provide   training   program
development assistance:

     EPA- National Enforcement Training Institute
    (800) 372-6384 or http://www.epa.gov/oeca/neti

    Midwest Environmental Enforcement Association
    Training Programs Coordinator, (847) 742-1249

     Southern Environmental Enforcement Network
         Training Coordinator, (334) 242-7369

     Northeast Environmental Enforcement Project
      Training Program Manager, (609) 292-0987

               Western States Project
     Training Services Coordinator,  (602) 542-8514
Case Study

•   Northern Illinois. The Illinois Environmental Crimes
    Investigators Network was established by the state
    Attorney General's Office. The network offers basic
    awareness seminars that simplify key  provisions in
    environmental crime statutes, teach basic investigative
    techniques, and  demonstrate  how available state
    resources can be assessed.  Instructors from several
    different organizations participate, including the EPA,
    state Attorney  General's Office, Illinois EPA, state
    police, and Cook County State's Attorney's Office. In
    1996 and 1997, the seminars were attended by over
    500 police and fire officers. Contact the Environmental
    Crimes Bureau, (312) 814-3918.

Authority
Officials must  have the  proper  authority  to  conduct
surveillance, inspections, and investigations.   In many
instances, local, state, and  federal officials all have some
level of authority and involvement in illegal dumping. This
can lead to incorrect assumptions that another party will
address problems.  In areas where authorities overlap,
clear definition of jurisdictions prevents duplication of effort
and increases the effectiveness of limited resources.

In other cases, officials  with insufficient resources and
authority may have primary responsibility, resulting in  an
inadequate response. Although a municipal agency may
be better situated to respond to an incident than the state,
the agency may  lack  the resources  to  adequately
prosecute cases under the  appropriate laws.

If authority is delegated  to a local entity by the state or
county, a written delegation  agreement can be established
to transfer authority and clearly define responsibilities.
Once jurisdictions are defined, continuous communication
and coordination between stakeholders are essential.

Case Study

•   Southwestern  Illinois.   The  Illinois  Delegation
    Agreement between Illinois EPA and St.  Clair and
    Madison   Counties,   delegates   illegal  dumping
    surveillance  and enforcement authorities under the
    Illinois Environmental Protection Act. Coordination has
    increased between the state and local agencies, such
    as local sheriff's departments,  as a result of the
    agreement.  In St. Clair County, health and sheriff's
    department  officials often conduct surveillance and
    enforcement activities  together.  In addition, training
    programs addressing environmental crime have been
    held for  local police  departments.   Contact Ken
    Mensing, Illinois EPA, (618) 346-5120.
                                                     27

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                                                                            TARGETED ENFORCEMENT
                                       FIELD OPERATIONS
Equipment
Proper equipment is needed to support field operations,
including

•   Radios, cellular telephones, or pagers
•   Spotlights or night-vision gear
•   Polaroid, 35-mm, or digital cameras
•   Notebooks or tape recorders
•   Citation books
•   Checklists summarizing laws and ordinances

This  equipment  is  available  from  the  tactical  or
investigation  units of local, county,  and  state police
agencies.   As agencies  obtain  new equipment,  old
equipment may be acquired at a reduced price or may be
available on loan for illegal dumping prevention.

Surveillance
Various surveillance  methods  and techniques exist to
identify  illegal  dumpers  and support their prosecution,
including

•   Stake-outs
•   Video monitoring
•   Patrols
•   Community assistance

At known dump sites, stake-outs using unmarked vehicles
or structures and night-vision equipment must take place
during peak dumping hours,  typically during the  late
evening or early morning.  Video cameras can be more
cost-effective than stake-outs because limited manpower
is   required.    If  cameras  are  purchased,  capital,
maintenance,  and  operator  training  costs must  be
considered.  Contracting with a surveillance company to
provide, install, and maintain cameras can minimize costs,
particularly for short-term or sporadic activity.  Enforcement
officials should confirm the admissibility of video evidence
in court before initiating a video surveillance program.

Patrolling areas where dumping is likely to occur may lead
to catching illegal dumpers in the act, thus increasing the
likelihood of their successful  prosecution.   A licensing
system requiring placards or other identification for waste
haulers can assist in identifying potential dumpers. Also,
rising smoke is a potential indicator of illegal dumping
because open burning may also be taking place.

Residents may be willing  to assist in surveillance  by
communicating their observations to enforcement officials.
In addition, local properties can be used for stake-outs or
installation of video cameras. Citizens must be aware of
what constitutes illegal activity and must understand what
information is needed about an illegal dumper (such as a
vehicle description and license  number).  A hotline for
notifying authorities combined with a reward system for
information leading to a conviction encourages community
involvement.

Case Studies

•   St. Clair County, Illinois. A deputy from the county
    Sheriffs   Department   is  assigned   solely   to
    environmental crime enforcement  activities in  rural
    areas. Using a standard squad car, the deputy patrols
    the areas seeking to catch illegal dumpers in the act
    and watches for rising smoke from open burning from
    a high vantage point. Citations  are commonly issued
    for open dumping and open burning of refuse and tires.
    Contact  Lt.  Steve  Saunders,  County   Sheriffs
    Department, (618) 277-3505, extension 757.

•   New  York, New  York. Under the  "Illegal Dumping
    Award Program," a citizen observing dumping and
    completing  an affidavit  leading  to a conviction is
    eligible for a reward of 50 percent of the collected fine.
    The citizen must appear at a hearing if the respondent
    challenges the charges.  Under the "Illegal Dumping
    Tip Program," a citizen providing information leading to
    a dumper  being  caught  in the act is eligible for a
    reward of 50 percent of  the collected fine.  The citizen
    is not required to  appear at a hearing, and his or her
    identity remains confidential. Contact Richard DiPietro,
    Sanitation Action Center,  (212)  219-8090.
                                                     28

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                                                                            PROGRAM MEASUREMENT
                                   TRACKING AND  EVALUATION
Tracking and  evaluation  methods  should  be used  to
measure the impact of illegal dumping prevention efforts
and determine whether goals are being met.  Baseline
figures must be established for indicators such as annual
cleanup costs, facility compliance, arrests, convictions, fine
collection, complaints, and numbers of problem sites.

Tracking
Electronic mapping systems use computerized maps and
overlays. A map of a particular area is used as a base,
and overlays are created for each type of information being
tracked.  Such information can include common dumping
locations,  facilities, inspection  or violation histories,
surveillance reports, or police districts. Individual program
elements can be  independently observed or viewed
together so that relationships and trends can be identified.
For example, by viewing the locations of problem areas
together with  the  locations  of permitted  facilities,  a
connection  may be identified.  In addition, a particular
dump site can be immediately referenced to determine the
date of the  last inspection and whether a  citation was
written.

Several mapping techniques can be used to electronically
map illegal dumping information. Geographic information
systems (GIS) such as ArcView*and Landview*, and public
domain mapping programs such as Citimap and TIGER8
are commonly  used.   The Census Bureau  provides
mapping services online at http://www.census.gov.  In
addition, much of the  same information that is tracked
electronically can be simply hand-drawn on maps.

The status of ongoing and pending enforcement activities
(such  as violations, fines collected, and the status of court
cases), cleanup activities, and inspection and surveillance
reports  can  be entered  into a  computer  database.
Printouts can display up-to-date data concerning the status
of individual cases or an overall prevention program. Use
of a digital camera to document site activities can support
enforcement cases.
Evaluation
Evaluation  of  information  being  tracked  allows  for
identification of needed adjustments and allocation  of
resources to improve the effort. Information gathered for
a defined period can be compared to baseline figures in
order to assess program performance. Arrest records or
violations  can  be  evaluated to  adjust  surveillance
schedules or target audiences for outreach and education
efforts.  Court records can be evaluated to determine the
typical disposition  of cases, which may lead to a different
approach  in  dealing with  offenders.  Finally, periodic
meetings of field personnel  to discuss observations and
trends can lead to continuous program improvement.

Case Studies

•   Chicago, Illinois.  The  city established a GIS using
    the city's "911" emergency map as a base. Individual
    overlays are  maintained  for  vehicle impoundment
    records, enforcement cases,  locations of permitted
    facilities such as  transfer stations and recyclers,
    complaints, inspection  and surveillance locations,
    police districts, community groups, and demographics.
    The  system  successfully tracks  the  status  of
    enforcement activities throughout the city. Contact
    Alexandra   Holt,     Department  of Environment,
    (312) 744-3172.

•   St. Louis, Missouri.  The Trash Task Force tracks
    and monitors illegal dumping enforcement cases using
    a comprehensive table that lists arrest dates, suspect
    names,  rewards,  arraignment  dates,  trial  dates,
    continuation dates, dispositions, docket numbers, and
    arresting officers. Thus, the task force always has up-
    to-date data available to monitor the status of individual
    cases as well as the enforcement program's  overall
    progress.  Contact  Jeff Towers, Trash Task Force,
    (314) 622-4628.
                                                     29

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                                                                      PROGRAM MEASUREMENT
                              TRACKING AND EVALUATION
East St. Louis, Illinois. New Spirit,  a community
organization, uses hand-drawn  maps  of individual
neighborhoods  to compile information on scrap tire
piles, abandoned housing or vehicles, and buildings
requiring demolition. Such areas tend to attract illegal
dumping. Community members use the maps to obtain
funding  for  demolition,  coordinate  cleanup  and
prevention  efforts,  and  raise  awareness among
residents and government officials.   Contact  New
Spirit, (618) 874-0312.
                      fZJnjg H iu
                      .' I ' I 4 . , I -. >  •:,'
   Legend for community map identifying illegal
   dumping areas
                                                    Community map identifying illegal dumping areas and
                                                    structures that are vacant or should be demolished
Detroit, Michigan.  Illegal dumping data from police
files and court records was evaluated. Arrest records
revealed that 72 percent of the  dumping arrests
occurred between 5:00 p.m. and 12:00 midnight, 57
percent of the dumping arrests  took  place on
Tuesdays and Wednesdays, 66 percent of the vehicles
used were pickup  trucks, and 90 percent  of the
offenders resided within the city. The data was used
to make adjustments in surveillance schedules and
tactics.  Court  records revealed that 62 percent of
offenders did not pay fines imposed and were issued
lien warrants. Contact Gregory Moore, Environmental
Affairs Department,  (313) 237-3095.
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