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ISSUES I JULY 2011
I
nsinTr
Waste Management:
Open Dump Preventio
Featuring:
" Tribal Success Stories
Key Elements to Success
, / / Funding Resources & More
United States
Environmental Protection Agency
Publication No. EPA530-N-11-001
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1 Open Dumping on Tribal Lands
2 Preventing Open Dumping: An Overview of Transfer Stations,
Collection Programs, and Landfills
4 Open Dump Prevention on the Kickapoo Reservation through
Community Cleanup Events
6 Saginaw-Chippewa: Utilizing Casino Earnings to Eliminate
Open Dumping
8 Umatilla's Waste Management Program: Finding an Alternative to
Open Dumping
10 Yurok Tribe Cleans its Legacy Dump Sites: Challenges & Opportunities
12 Yakama Nation Streamlines the Cleanup of Large Open Dump Sites
14 Funding Sources
16 What isw/STARS?
17 Resources
18 Kids' Page
21 Alleviating Open Dumping on Tribal Lands: Key Elements of Success
To be placed on our mailing list or to
submit future topics, please e-mail:
Kim Katonica-Mule
U.S. EPA Tribal Solid Waste Program
katonica.kim@epamail.epa.gov
-------
Open Dumping on Tribal Lands
On March 1,2010, U.S.
Environmental Protection
Agency (EPA) Administrator,
Lisa Jackson, reported to the
National Congress of American
Indians that open dump sites
"... are a persistent challenge in
tribal areas across the country.
Hazardous waste sites and open
dumps expose tribal residents to
dangerous toxins and contami-
nation of land and water. That
presents a serious health and
environmental hazard. But make
no mistake; it is also a significant
economic obstacle." Working
together to prevent open dumps
on tribal lands is imperative to
protecting the environment,
economy, and social welfare of
future generations.
Open dumping continues to
be a problem on tribal lands due
to many factors including the lack
of access to convenient, affordable
disposal sites for: bulky materials,
electronic waste (e-waste), tires,
vehicles, and household haz-
ardous waste. Other challenges
include complex open dump sites
that are difficult to clean, close,
and maintain, as well as lack of
funding for solid waste manage-
ment alternatives to open dump-
ing. In this issue of the Tribal
Waste Journal, you will hear from
tribal waste managers respon-
sible for initiating, maintaining,
and fostering support for new
programs that provide ways to
prevent open dumping.
This issue aims to give a new
perspective on open dumping
by highlighting an assortment of
successful environmental pro-
grams at various stages of devel-
"This issue aims
to put a fresh
perspective on
open dumping
by highlighting
an assortment
of successful
environmental
programs at
various stages of
development or
implementation."
opment or implementation. We
hope that your tribe can relate to
one or more of these stories and
get some new ideas to imple-
ment. To help make new solid
waste connections, the tribal
waste managers who have shared
their stories have provided their
contact information at the end of
each article. Please contact that
person if you would like to learn
more about his or her program.
In this issue, you will find
information on the many differ-
ent types of waste you may find
in open dumps. These include
bulky items, old appliances, and
hazardous waste (such as old
paint or batteries) which are
not collected along with other
household waste. In many of the
featured stories, special programs
were initiated to focus on the
collection and disposal of these
along with other waste streams.
It is important to have waste
management programs in place
before, or along with, efforts to
clean up open dumps. Cleaning
and closing open dumps may
only solve part of the problem.
If tribal members do not have
another means of disposal, new
open dumps may occur. To
help you determine sustainable
alternatives to open dumping,
we have included information
on different waste management
strategies for your tribe. These
include building a new transfer
station or initiating a new collec-
tion service for tribal members.
Based on the stories enclosed
in this issue, we developed a list
of six key elements of success.
These key elements include: col-
laboration, support, education,
sustainability, perseverance, and
respect. Keep an eye out for these
elements as you read through the
issue.
JULY 2011
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Tribal Waste Journal 1
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Preventing Open Dumping:
An Overview of Transfer Stations,
Collection Programs, and Landfills
I any environmentally safe
alternatives to open dump-
ing exist. Some include transfer
stations, collection programs
and landfills. These types of
alternatives may be managed by
the tribe, a contractor, or via a
partnership (tribe-to-tribe, tribe-
to-local government, etc.). The
resources available to your tribe
will help you identify the best
ways to manage your solid and
hazardous waste.
Transfer Stations
Transfer stations, or convenience
centers, serve as a central collec-
tion site for waste from multiple
sources (via personal vehicles,
smaller trucks, etc.). The ag-
gregated waste is transferred via
large haul trucks to regulated
disposal sites such as landfills
or waste-to-energy facilities.
According to "Waste Transfer
Stations: A Manual for Decision-
Making," available at www.epa.
gov/waste/nonhaz/municipal/
pubs7r02002.pdf, "[transfer
stations serving rural or tribal
areas tend to be small. They
are optimally located within a
reasonable driving time from the
service area's largest concentra-
tion of homes and businesses."
When planning a successful
transfer station, it is important to
consider the following:
What is a Pay-As-You-Throw Program?
Traditionally, fees for curb-side garbage pickup are the same for every
household employing the service. Each household is charged via mu-
nicipal tax base, or via fixed fee, regardless of the amount of garbage
collected. For example, if you only generate one bag of trash, but your
neighbor clears out their home generating 10 bags of trash, you both
pay the same for the garbage pick-up service. The Pay-As-You-Throw
(PAYT) program differs in that it charges each household based on
the amount of garbage thrown away either per bag or by weight. The
PAYT program, also known as "unit pricing" or "variable-rate pric-
ing," acts as a financial incentive to decrease the amount of garbage
generated. Reduction is accomplished through recycling materials,
composting organic waste, and reducing the amount of garbage gener-
ated to begin with through source reduction (purchasing products with
less packaging, etc.). Many PAYT resources such as videos, tool kits,
booklets, lessons learned, success stories, and fact sheets are available
on EPA's PAYT website at www.epa.gov/payt. To help determine wheth-
er PAYT is right for your community, visit EPA's website on SMART
BET (Saving Money and Reducing Trash Benefit Evaluation Tool) at
www.epa.gov/waste/conserve/tools/payt/tools/smart-bet/index.htm.
central location to collection
routes;
access to major transportation
routes;
site size requirements;
sufficient space for onsite road-
ways, queuing, and parking;
truck and traffic compatibility;
ability for expansion;
space for recycling, compost-
ing, and public education;
buffer space;
gently sloping topography;
access to utilities;
zoning designations and
requirements.
Issue 2 of the Tribal Waste
Journal focused on transfer sta-
tions tips, tools, resources, and
success stories. It is available at
www.epa.gov/waste/wycd/tribal/
pdftxt/twj-2.pdf.
Collection Programs
Collection programs may be in
the form of a public collection,
contract collection, or private
collection. Based on the needs
of your tribe and the availability
of collection services, you may
decide to pursue one or more of
these types of programs. Some
communities use a mixture of
public and private collection
services based on the size and
distribution of residents, busi-
nesses, and industries on their
reservation. Partnering with
neighboring tribes, local govern-
ments, or commercial operations
2 Tribal Waste Journal
JULY 2011
-------
to combine resources may offer
financial savings for all involved.
Tribes may work out pay-
ment for collection programs in a
variety of ways, including adding
a fee to an existing utility bill,
having tribal members reim-
burse the tribal government for
services rendered, funding the
program through fees collected
from alternative sources such as a
casino fee, or having tribal mem-
bers work out a rate with the
private hauler. Another option
for paying for waste collection is
a Pay-As-You-Throw program,
which charges customers on a
per-volume or per-weight basis.
Landfills
Compared to open dumps -
"areas where waste is disposed
of without proper controls" -
landfills follow prescribed laws
and regulations aimed at pro-
tecting human health and the
environment, including regular
application of cover, controlled
access to the sites, and other
environmental controls. Under
the Resource Conservation and
Recovery Act (RCRA) (40 CFR
258), the federal government reg-
ulates the operation of municipal
solid waste landfills (MSWLF).
EPAs RCRA website, www.epa.
gov/waste/nonhaz/municipal/
landfill/msw_regs.htm, provides
detailed information on MSWLF
regulations. More information
on flexibility requests is available
in the draft document, "Site-
Specific Flexibility Requests for
Municipal Solid Waste Landfills
in Indian Country," located at:
www.epa.gov/waste/nonhaz/mu-
nicipal/landfill/indian/siteflex.
htm.
Costing Tools for Transfer
Stations, Collection Services,
and Landfills
To assist tribes with determin-
ing the economic feasibility of
tribally-operated waste manage-
ment services, EPA Region 9 de-
veloped the "Tribal Solid Waste
Program Costing Tool." This tool
focuses on potential planning,
construction, operation, and
maintenance costs associated
with collection services, transfer
stations, and/or landfills. When
deciding among the three op-
tions, it is very important to first
undergo a feasibility study to get
the overall picture of the amount
of waste generated from tribal
members, non-tribal residents,
tribal government operations,
businesses, schools, casinos, etc.
In addition, a feasibility study
will help assess the costs of waste
collection using different alterna-
tives. The costing tool provides
information on different types
of funding, including the fund-
ing of start-up materials as well
as determining a sustainable
funding source such as user fees.
The costing tool can be found
at www.epa.gov/region9/waste/
tribal/resources.html.
In 2000, EPA Region 5
developed the "Illegal Dumping
Economic Assessment (IDEA)
Cost Estimating Model." The
model helps to determine the
costs associated with open dump-
ing and its economic impact on
a community. The Microsoft
Excel application is free and
available for download from the
EPA Region 5 Illegal Dumping
Prevention Project website at
www.epa.gov/reg5rcra/wptdiv/il-
legal_dumping/index.html.
ng among
the three options, it is
very important to first
undergo a feasibility
study to get the overall
picture of the amount
of waste generated from
tribal members, non-
tribal residents, tribal
government operations,
businesses,
casinos, ef
JULY 2011
-------
Open Dump Prevention on the
Kickapoo Reservation through
Community Cleanup Events
Through tribal leadership and
community participation,
a shift from open dumping to
responsible waste management
took place on the Kickapoo
Reservation, Brown County,
Kansas. This shift aligns with
the tribe's mission to "enhance
the quality of life for the tribe,
its members and its commu-
nity, while preserving its cul-
ture and retaining its right to
self-governance by protecting
tribal sovereignty and its assets,"
Responsible waste management
helps preserve the tribe's mission
and creates a sustainable commu-
nity for future generations.
In 2000, 14 open dump
sites scarred the 19,200-acre
Kickapoo Reservation. These
dumps consisted of a myriad
of wastes; some of which dated
back 40 years. Dumping had
persisted on the reservation
because of the lack of a viable
disposal method for bulky and
metal items such as used mat-
tresses, broken refrigerators, and
other appliances. Vehicle tires
were also widely distributed
across the open dump sites.
To eliminate open dumping,
Kickapoo Tribe's Environmental
Program, under the Natural and
Cultural Resources Division,
holds an annual "community
cleanup" event on the reserva-
tion. The cleanup event works in
two ways. First, several days are
spent collecting trash scattered
across the reservation that has
accumulated in ditches, particu-
larly along roadways. Secondly,
Environmental Program staff
drive around the reservation
collecting bulky items and metal
goods left curb-side by tribal
Spotlight on: Electronic Waste (e-Waste)
PLUG-IN TO
eCYCLING'
WITH U.S. EPA
Recycling of e-waste includes used electronic goods such as
televisions, computers, printers, phones, fax machines, etc.
EPA encourages the re-use of electronics by first ensuring
that it is in working order and donating it to an organization,
school, or community. Recycling electronics enables manu-
facturers to strip precious metals, copper, and engineered
plastics, all of which require considerable energy to process and manufacture, from your electronics
for re-use. Additional information on e-Waste may be found at www.epa.gov/waste/conserve/materials/
ecycling/basic.htm.
4 Tribal Waste Journal
JULY 2011
-------
members. Requests to assist
tribal elders in moving heavy
items from inside their home
to the curb are encouraged and
honored. To ensure participation
in the events, the Environmental
Program staff regularly updates
the tribal websites calendar
of events, distributes flyers at
community events, posts large
informative signs at each housing
cluster, and publishes informa-
tion about the event in the tribal
newsletter.
Tribal member support
of the cleanup event over the
past ten years has enabled the
Kickapoo Tribal Government to
provide an array of solid waste
collection events through the
Environmental Program. In
2008, the annual cleanup event
became a twice-a-year event.
Continued success of the event
provides momentum for the
tribal government to support
other waste management initia-
tives on the reservation, includ-
ing a tire collection campaign, an
electronic waste (e-waste) event,
and a recycling program. From
2008 to 2011, the Environmental
Program has removed and
recycled 3,015 tires from open
dumps on the reservation. Once
the tires were removed, the
Environmental Program was
able to fully clean and close half
of the open dumps in only two
weeks. In addition, e-waste col-
lection events were held in 2009,
2010, and 2011, each yielding
six pallets worth of phones, fax
machines, computer monitors,
television sets, and copy ma-
chines that would have otherwise
been dumped. Nearly two tons
of recyclables were collected over
the course of one year from tribal
government offices and local
businesses. The Environmental
Program also started recycling
services at the school and casino
located on the reservation. The
casino recycling effort started in
August 2010 with tin and shred-
ded paper. In April 2011, a card-
board baler was purchased by the
Environmental Program for use
at the casino. Thus far, 7,747.5
pounds of tin, 8,772 pounds
of shredded paper, and 15,400
The Environmental Program
has changed the behavior of
tribal members from relying
on open dumps to relying
on the community cleanup
events. New waste collection
and management initia-
tives on the reservation have
targeted problematic waste
streams with great success.
pounds of cardboard have been
diverted from the waste stream
and recycled.
For more information on the
Kickapoo Tribe's activities, con-
tact Luke Terry, Environmental
Director, at 785-486-2601,
Extension 1 or luke.terry@ktik-
nsn.gov. The Kickapoo Tribe
website is located at http://ktik-
nsn.gov.
Spotlight on: Household Hazardous Waste
Many products that are found in homes contain potentially corrosive, toxic, ignitable, or reactive ingredients.
When discarded these products are called household hazardous wastes (HHW). Common HHW include
paints, cleaners, oils, batteries, and pesticides. If mixed and disposed together with regular household waste,
these products may contaminate air, water, or soil depending on their final disposal method (landfill or incin-
eration). Additionally, dumping toxics down drains or storm sewers creates a direct and immediate negative
impact to your environment. Proper disposal is essential to protecting human health and the environment.
EPA encourages HHW collection programs that may be facilitated by your local transfer station or tribal gov-
ernment. For more information, visit EPA's HHW website www.epa.gov/waste/conserve/materials/hhw.htm.
JULY 2011
Tribal Waste Journal 5
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Saginaw Chippewa:
Utilizing Casino Earnings to
Eliminate Open Dumping
In 2000, Tribal Council rep-
resentatives for the Saginaw
Chippewa Indian Tribe, located
in Michigan, removed the recy-
cling program from the Soaring
Eagle Casino and Resort operat-
ing budget. Recycling activities
were then seen as unnecessary
and having little economic value
to the tribe, especially given tight
financial constraints. However,
the tribes Recycling Coordinator,
Mr. Craig Graveratte, thought
that this might not have been the
case. Mr. Graveratte presented
the Tribal Council with an idea
to perform a waste audit utilizing
tribal and county resources. This
audit would determine the actual
costs of the previous recycling
program which would help
Tribal Council best decide how
to budget for waste management
at the casino. After the idea was
approved, Mr. Graveratte began
interviewing casino manage-
ment and housekeeping staff,
collecting data on the amount
and type of waste disposed over
a period of three months, and
presented his findings to the
Tribal Council. From this audit,
he determined that the Tribal
Council could save an estimated
$140,000 annually by recycling
just cardboard. Impressed with
the findings, the Tribal Council
immediately reinstated the recy-
cling program at the casino.
This audit and the subse-
quently positive financial gain
through recycling sparked
interest in providing more com-
prehensive waste management
services to tribal members from
the Bands of Ojibway, includ-
ing the Saginaw, Black River,
and Swan Creek living on the
138,240-acre reservation. A gam-
ing contract was drawn between
the Soaring Eagle Casino and
Resort and the members of the
tribe. Currently, two percent of
earnings are invested into tribal
"From this audit,
he determined that
the Tribal Council
could save an
estimated $140,000
annually by recycling
just cardboard.
Impressed with the
findings, the Tribal
Council immediately
reinstated the
recycling program
at the casino."
Spotlight on: Abandoned Vehicles
Abandoned vehicles threaten the environment and health of a tribe by: attracting
pests which may become disease vector breeding grounds, serving as a detriment
to local businesses because of their unsightliness, producing leaking fluids that
may seep into the soil, groundwater, and/or surface water, and by possibly contain-
ing lead-acid batteries and mercury switches that are especially toxic and must be
properly disposed of prior to crushing. EPA's publication, "Developing an Abandoned
Vehicle Cleanup Program for Tribal Governments," provides a step-by-step guidance
for developing a vehicle cleanup program for your tribe. This publication is available
on-line at http://epa.gov/region9/waste/tribal/pdf/Abandoned_Vehicle_Guide.pdf.
6 Tribal Waste Journal
JULY 2011
-------
government operations. This new
revenue stream funds the tribal
members' curbside trash removal
and recycling program.
With the momentum of its
recycling program success, the
Tribal Utility Authority also be-
gan programs targeted at special
waste streams. They collected
used grease from grease pits,
2,000 tires, and 2,300 pounds
of household hazardous waste
(HHW). The casino also initiated
their own program to reduce
the number of disposable cups
being used by staff during breaks.
By switching to reusable cups
in 2005, the casino prevented 1
million non-biodegradable cups
from ending up in the landfill.
For the Saginaw Chippewa
Indian Tribe, the successful
waste management operation has
improved the health, safety, and
welfare of the community. Mr.
Graveratte reported that initial-
In 2007, the
Saginaw Chippewa
Indian Tribe won
the Michigan
Recycling Coalition's
Outstanding
Recycling Program
Award.
ing the curbside pick-up and
recycling program eliminated the
issue of open dumping on the
reservation.
For more information on
the Saginaw Chippewa Indian
Tribe's environmental activities,
contact Rick Meyers at 989-772-
8810 or rmeyers@sagchip.org.
Craig Graveratte may be reached
at cgraveratte@sagchip.org. The
Saginaw Chippewa's website is
www.sagchip.org.
Spotlight on:
Compostable
Material
Organic materials including
yard waste and food scraps
comprise 25 percent of the
entire amount of municipal
solid waste (MSW) generated
in the U.S. in 2008. These
materials may easily be com-
posted and reused in gardens
or on agricultural fields. For
more information on what
can and cannot be compos-
ted and how to start your own
composting program, visit
www.epa.gov/waste/conserve/
rrr/com posti ng/i ndex. htm.
The June 2005 Tribal Waste
Journal features information
and successful tribal com-
posting success stories. This
publication is available on-
line at www.epa.gov/waste/
wycd/tribal/pdftxt/twj-4.pdf.
JULY 2011
Tribal Waste Journal 7
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Umatilla's Waste Management Program:
Finding an Alternative to Open Dumping
In the past, tribal members liv-
ing on the Confederated Tribes
of the Umatilla's Reservation in
Oregon disposed of their solid
waste in open dumps located
across the 172,000 acre reserva-
tion. The municipal solid waste
landfill criteria implemented by
EPA in the 1990s (40 Code of
Federal Regulations 257 and 258)
provided insight into the poten-
tial harm that the open dumps
may be causing to the environ-
ment and health of the tribal
members. The Confederated
Tribes quickly began to evaluate
other solid waste management
alternatives. Options included
using rail to move waste to a
regulated landfill, incineration or
installing a new transfer station.
They determined that a transfer
station would be the best option
for eliminating open dumping on
the reservation.
Construction of the transfer
station took place from 1999
to 2001 at a cost of $1.3 mil-
lion It was financed, in part, by
federal government funding.
The 13,000 square foot transfer
station was built by a tribally-
owned construction company.
Waste is either collected curb-
side or hauled by residents to
the transfer station seven days a
week. The waste is then pro-
cessed, and transported to an
EPA-approved landfill located
55 miles away. Recyclables and
household hazardous waste are
collected, sorted, and stockpiled
on site and transferred to facili-
ties off site. The minimum fee
charged is $8.00 per bag to take
out waste less than 200 pounds
or $55 per ton, which remains
competitive among other area
transfer stations. Currently,
the transfer station serves 900
residents and 93 commercial
customers throughout the
Spotlight on: Recycling
Based on the total amount of trash generated on an annual basis,
EPA estimates that a single individual living in the U.S. gener-
ates 4.34 pounds of garbage on a daily basis. Of the 4.34 pounds
of garbage, only 1.5 pounds of it is estimated to be recycled.
Recycling reduces air and water pollution associated with making
new products from raw materials. It also reduces the amount of
greenhouse gas (GHG) emissions contributing to global climate
change. For more information on how recycling reduces GHG
emissions, visit EPA's Waste Reduction Model (WARM) website at
www.epa.gov/warm. More information on municipal solid waste in
the U.S. may be found at www.epa.gov/waste/nonhaz/municipal/
msw99.htm.
al/
Reservation. The transfer station
is currently 1,500 tons short of
reaching the optimum operation
efficiency level of 6,000 tons.
Ms. Bonnie Burke,
Operations Manager for the
Tribal Environmental Recovery
Facility (TERF), launched an
education and outreach cam-
paign focused on the benefits of
using the transfer station. The
campaign educated people on
the hazards of open dumping
and the effects it has on both
human health and the environ-
ment. The campaign also helped
ease the transition to reducing
solid waste by recycling. Targeted
outreach and education to both
tribal elders and children was a
critical component of Ms. Burkes
campaign. Ms. Burke is conduct-
ing a survey of the participating
tribal elders requesting feedback
on the success of the curbside re-
cycling program. Umatilla is also
working with an intern to run an
afterschool program to educate
school children on recycling.
Over a period of ten years, the
amount of waste collected has in-
creased by 4,000 tons due to the
TERF staff's determination and
outreach and education efforts.
For more information on
the Confederated Tribes of the
Umatilla Reservation's activities,
contact Bonnie Burke at 541-
276-4040 or terfmngr@gmail.
com. The tribe's website is www.
umatilla.nsn.us.
8 Tribal Waste Journal
JULY 2011
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The Importance of Outreach and Education in Open Dump Prevention
Community members are more
likely to support and participate
in new waste management pro-
grams when they are involved in
the planning process from the
very beginning. When develop-
ing alternatives to open dump-
ing on your reservation, consider
creating an outreach plan to
ensure all tribal members are
well-informed and engaged in
all of the various aspects of the
process. Key elements in an
outreach plan include:
Target audience, including
children and tribal elders;
Outreach goals;
Targeted message tailored for
each audience; and
Appropriate outreach
method(s) (see Table 1 for
ideas which can be used indi-
vidually or combined).
Once you begin outreach,
ensure that you are responsive
to community feedback and
continually modify methods and
the message to address com-
munity concerns and changing
program goals.
Table 1. Comparing Tribal Outreach Methods
Method
Signage
Inserts/
Flyers/
Articles
Investment of Time/Labor
Low. Develop message for sign
and set up at sites.
Low. Develop message for flyer
and distribute.
Monetary Cost
Low-Medium. Dependent on the
quality of the signs (i.e., tem-
porary versus permanent).
Low. Paper, printing/photocopy-
ing, labor.
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.
Door- Medium-High. Canvassers must
to-Door dedicate afternoons/evenings
Campaigns over a set period of time to
promote message.
Low-Medium. If volunteers
agree to canvass, costs wil
down.
stay
Outreach to
Schools
Medium-High. Dependent on
size of event(s) and activities
planned.
Meetings Medium-High. Dependent on
and size of event(s) and activities
Community planned.
Events
Medium-High. Dependent on
size of event(s), activities
planned and materials needed.
Medium-High. Dependent on
size of event(s), activities
planned and materials needed.
Medium-High. Talk to residents
one-on-one to address their
concerns.
High. Potentially large audi-
ence; 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.
Workshops/
Training
Medium-High. Dependent on
size of workshop and training
activities planned.
Medium-High. Dependent on
size of workshop or training
activities planned and materials
needed.
High. Provide specific train-
ing to audience, address
their questions and concerns.
Helpful when introducing new
programs.
For more information, Chapter 6 of the "Tribal Decision Maker's Guide" provides additional
information on Public Education and Community Outreach and includes tribal examples. This
document may be found at: www.epa.gov/waste/wycd/tribal/index.htm.
EPA Region 9's Tribal Solid Waste Outreach website, www.epa.gov/region9/waste/tribal/out-
reach.html, provides outreach documents such as brochures, fact sheets, and suggested school cur-
ricula focusing on waste management.
JULY 2011
Tribal Waste Journal 9
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Yurok Tribe Cleans their Legacy Dump
Sites: Challenges & Opportunities
sites on the reservation: Roaches
Creek, Johnson's Road, and
Tully Creek. Each site presented
unique challenges such as the
Roaches Creek site's hill-side lo-
cation that required a helicopter
to assist the cleanup. Johnson's
Road was the largest and least
accessible of all three sites and
required more than half of the
grant money for the cleanup.
Hazardous waste accumulation
The Yurok Tribe is located
across 63,035 acres in
California. A nine-member tribal
council represents 5,000 enrolled
members and oversees 200 tribal
government employees.
Under an $800,000 grant
sponsored by the California
Integrated Waste Management
Board in August 2008, the Yurok
Tribe cleaned and closed the
three largest legacy open dump
Vehicle Roundup and Disposal in
the Klamath River Watershed
The Yurok Tribe collaborated with the Hoopa and Karuk tribes
to collect 400 vehicles from the Klamath River Watershed using
funding leveraged from IGAP and state grants. The project began
with a door-to-door education and outreach campaign to 200 trib-
al members. They were provided with information regarding the
human health and environmental hazards of abandoned vehicles.
The most costly aspect of the collection was towing the vehicles
to a central location and crushing them using an on-site mobile
crusher. The vehicles were then transported to a recycling center.
Due to low market demand, the tribes were unable to receive
payment for the recycled scrap metal; however, no charges were
incurred for vehicle removal. Mr. Henderson plans to monitor the
scrap metal market for opportunities to make future collection
events profitable for the tribe.
- car batteries, paint cans, fuel
cans, etc. - at both the Johnson's
Road and Tully Creek sites posed
a threat to the health of the com-
munity and the environment.
Fortunately, none of the sites
had yet experienced surface soil
contamination from the hazard-
ous waste.
Eighteen tribal mem-
bers received the 40-hour
Occupational Safety and Health
Administration Hazardous Waste
Operations and Emergency
Response Standard training to
prepare for for cleaning the haz-
ardous waste found at the open
dump sites. Funding for this
training was supported by Indian
Health Services.
After these sites were
cleaned, the Yurok Tribe took
preventive measures to discour-
age residents from dumping at
the closed sites by posting signs
with logistical information on
the City of Humboldt's house-
hold hazardous waste collection
program. Restrictive barriers
including gates, rails, and fences
10 Tribal Waste Journal
JULY 2011
-------
were also installed. Mr. Ken
Henderson, Assistant Director,
Pollution Prevention Division,
keeps the community up-to-date
with site cleanup and closure ac-
tivities during quarterly District
meetings held in the seven tribal
districts across the reservation.
Five new open dump sites
have been identified and are
targeted for the next round of
cleanup and closure. An EPA
Indian General Assistance Gap
grant will be utilized during the
upcoming fiscal year to offset the
costs of cleanup.
For more information on the
Yurok Tribe's activities, contact
Ken Henderson at 707-482-1822,
Extension 1007 or khender-
son@yuroktribe.nsn.us. The
Yurok Tribe's website is www.
yuroktribe.org.
Focus on Ordinances:
Prohibiting Illegal Dumping on
the Yurok Reservation
The Yurok Tribal Ordinance
(Ordinance No. YTC - 1-08) was
developed to establish Tribal law
prohibiting the "open disposal,
dumping, depositing, burying
or unpermitted burning of any
waste materials whatsoever on
any lands or in any waters of
the Yurok Reservation...". The
Ordinance is separated into nine
sections including:
1. Authority
2. Purpose
3. Definitions
4. Effect of Ordinance
5. Application
6. Enforcement
7. Penalties
8. Sovereign Immunity
9. Effective Date and
Amendments
The ordinance includes en-
forcement by warning, citation,
and prosecution depending
on the offense. It also in-
cludes fines up to $1,500
plus the cost of cleanup and
time dedicated to community
service. For more information
on developing an ordinance for
your tribe, visit EPA Region 9's
website on developing solid
waste codes and ordinances
at www.epa.gov/region9/waste/
tri bal/sol idwastecode. htm I.
Watching crew work down
slope. Photo courtesy Ken
Henderson.
Cleanup of the Johnson Creek open dump site. Photo courtesy Ken Henderson.
"In August 2008, the Yurok
Tribe cleaned and closed
the three largest legacy
open dump sites on the
reservation."
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Yakama Nation Streamlines the
Cleanup of Large Open Dump Sites
Located on 1.4 million acres
in the mid-Columbia River
Basin of the Pacific Northwest,
the Yakama Nation is home to
10,000 enrolled members. Three
full time and two part time staff
members comprises the Yakima
Nation Solid Waste Program for
the one million-acre reservation.
In 2006, the Solid Waste Program
began overhauling their 1977
Solid Waste Management Plan.
They focused on creating a new
mission statement and goals for
the program. The Yakama Nation
wove together the concepts of
sustainability - economics, envi-
ronment, and equity - to create a
program that is economical, en-
vironmentally safe, and one that
incorporates ancestral ecological
knowledge into its practices. They
determined that capacity build-
ing, outreach and education, and
empowering tribal members are
key components to adapting and
managing a successful solid waste
management program.
To further understand
the current state of their waste
management program, the Solid
Waste Program office decided to
conduct a waste stream analy-
sis. Through the analysis, they
determined that the Yakama
Nation produces 30,000 tons of
solid waste annually. This equates
to five pounds of waste per person
per day. They also determined that
open dumps impose a financial
burden of $720 per ton to remove
the waste. However, if the trash
were disposed of properly (i.e., at
a landfill) it would only cost $32
per ton to dispose. In addition, a
1995 study from the University of
California at Davis identified more
than 130 open dump sites located
across the entire reservation.
Beyond the financial burden,
open dumps create an unhealthy
environment with adverse health
and environmental effects for
both people and animals. Once
the Yakama Nation Solid Waste
Program understood the enormity
of the problem, they quickly began
efforts to build capacity within
their department. Ms. Loretta
Zammarchi, the Solid Waste
Program Coordinator, indicated
that training staff to identify and
assess illegal dump sites was their
first priority. Due to the complex-
ity of the illegal dumping problem,
training focused on the following
key skills:
Reading and interpreting maps;
Distinguishing between recy-
clable materials and garbage;
Performing daily logs and site
assessment reports;
Identifying cleanup costs;
Estimating site volume;
Bidding out projects;
Digital photo collection;
GIS training; and
Creating cleanup work plans
and reports.
With trained staff, the
Yakama Nation began the pro-
cess of identifying and cleaning
up the illegal dump sites on the
reservation. Digital imagery was
used to identify property own-
ers because of the "checkerboard
pattern" of county and tribal
lands. None of this would have
been possible without the train-
ing the staff received.
Using Indian Environmental
General Assistance Program
(IGAP) funds, the tribe pur-
chased heavy machinery includ-
ing a mini-excavator to assist in
the remediation process. This
investment has saved time and
money by increasing the efficien-
cy of cleanups.
The Yakama Nation under-
stood that the cleanup of the open
dumps would not be sustainable
without a mindset change within
the community, so they solicited
feedback from the reservation's
residents to help them determine
the most popular methods for
preventing future open dumping.
Of the 1,400 surveys mailed, the
Solid Waste Program received
responses from 170 residents. The
Tire Pile Cleanup
Yakama Nation received
an opportunity through the
Washington Department of
Ecology to clean up a tire pile
on the reservation. The reme-
diation process on the pile,
which consisted of 350,000
tons of tires, took 18 months
at a cost of $600,000.
For more information, visit
Washington State Department
of Ecology's Waste Tire Pile
Cleanup website at www.ecy.
wa.gov/programs/swfa/tires/
cleanup.html.
12 Tribal Waste Journal
JULY 2011
-------
majority of the responses sug-
gested that the Yakama Nation
tribal government impose a fine
for those caught dumping trash
illegally. It was determined from
the survey results that a fine may
deter individuals from driving 35
miles out of their way to dump
their garbage on the reservation
because they consider it to be
"free" when in fact it serves as
both a financial and time bur-
den on the tribal governments
resources and staff.
After seeing the results of
the survey and witnessing illegal
dumping from people off the res-
ervation, the Solid Waste Program
decided that in order to make the
program sustainable, they would
need to update their tribal codes.
After much research, sifting
through old laws and codes, and
using tribal legal resources, the
Solid Waste Program developed
new tribal codes. The codes were
adopted by the tribal council
within five months. Adopting the
codes will help the tribe reach
its ultimate goal to "protect the
rights, land, and resources of the
Case Study: White Swan Open Dump Site
The open dump site located in the small rural community of White
Swan on the Yakama Nation tribal lands was a challenge for the
tribe. The dump site was costing $45,000 per year, including dai-
ly cleanup efforts, for the tribe. To combat open dumping, signs
were posted at the site and tribal police was contacted to patrol
the site. However, the key to reducing the amount of open dump-
ing was developing a positive relationship with the tribal members
living in the White Swan community. Through cooperation and
collaboration, the Solid Waste Program and the tribal members
in the White Swan community worked hand-in-hand in an effort
to combat open dumping. Outreach efforts targeted tribal elders,
school-aged children, and their families. An annual cleanup keeps
tribal members involved in keeping White Swan clean.
Yakama Nation."
To date, the Solid Waste
Program has closed 148 open
dump sites and removed more
than 4,000 tons of illegally
dumped garbage. They con-
tinue to monitor those sites to
make sure that illegal dumps
do not return and are evaluat-
ing the impact of the post-site
cleanup preventive measures,
such as installing site barricades
and posting signs. They are also
continuing outreach and educa-
tion to the community on the
multiple options available to
the residents for trash removal.
These options include a transfer
station, personally hauling your
waste to the county landfill and
curb-side pickup.
The Yakama Nation Solid
Waste Program serves as an
example of how a small group of
dedicated individuals can create
a successful tribal solid waste
management program.
For more information on the
Yakama Tribe's activities, contact
Loretta Zammarchi at 509-865-
5121, Extension 6453 or loretta@
yakama.com.
Spotlight on: Tires
*
Tire cleanups protect human health and the environment from the threat of large, uncontrollable tire
fires that emit hazardous air pollutants including polycyclic aromatic hydrocarbons (PAHs), benzene,
styrene, phenols, butadiene, and runoff containing water pollutants such as arsenic and lead. Other
threats from tire piles include disease carrying pests inhabiting the piles and mosquitoes breeding in
stagnant water collecting inside the tires. Fortunately, used tires may be recycled into a variety of prod-
ucts. EPA estimates that at least 110 types of products can contain recyclable tire rubber. These may
include, playground cover, soil additives, flooring/matting, and landfill construction materials. Recycled
tires are most often reused in highway pavement mixtures. Choose to commit to the health and safety
of current and future generations by utilizing proper disposal methods for old tires. For more informa-
tion, visit EPA's Frequent Questions for Scrap Tires website www.epa.gov/waste/conserve/materials/
tires/faq.htm or EPA's Scrap Tire Cleanup Guidebook available at www.epa.gov/reg5rcra/wptdiv/solid-
waste/tires/guidance.
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Funding Sources
EPA provides several funding
opportunities in the form of
grants, cooperative agreements,
and interagency agreements to
assist tribes and intertribal con-
sortia with waste management
activities. These activities may
include open dump assessment,
cleanup, outreach/education,
and compliance assurance/en-
forcement. General information
on these and other solid waste
grants and funding for tribes is
available at www.epa.gov/waste/
wycd/tribal/finance.htm. More
specific information on the fund-
ing sources below may be found
through the Catalog of Federal
Domestic Assistance (CDFA)
website at www.cfda.gov.
Brownfields Assessment
and Cleanup Cooperative
Agreements
CDFA Reference Number 66.818
Brownfield sites are real properties
whose expansion, redevelopment,
or reuse may be complicated by
the presence or potential presence
of a hazardous substance, pollut-
ant, or contaminant. The objec-
tives of the brownfield assessment,
revolving loan fund, and cleanup
cooperative agreements (project
grants) are to provide funding
to: (1) inventory, characterize,
assess, and conduct planning and
community involvement related
to brownfield sites; (2) capitalize a
revolving loan fund and provide
subgrants to carry out cleanup
activities at brownfield sites; and
(3) carry out cleanup activities at
brownfield sites that are owned
by the grant recipient. Funding
for the cooperative agreements is
estimated to be $119.6 million for
fiscal year 2011.
Brownfields Training,
Research, and Technical
Assistance Grants and
Cooperative Agreements
CDFA Reference Number 66.814
CERCLA 104(k)(6) provides
EPA with authority for a pro-
gram of training, research, and
technical assistance to individu-
als and organizations to facilitate
the inventory of brownfields
properties, assessments, cleanup
of brownfields properties, com-
munity involvement, or site
preparation. Brownfield sites
are real property, the expansion,
redevelopment, or reuse of which
may be complicated by the pres-
ence or potential presence of a
hazardous substance, pollutant,
or contaminant. For more infor-
mation contact your Regional
Brownfields Coordinator.
Contact information is found
at www.epa.gov/swerosps/bf/
corcntct.htm.
Community Action for a
Renewed Environment (CARE)
Program
CDFA Reference Number 66.035
Community Action for a
Renewed Environment (CARE)
Program supports analyses,
studies, evaluations, surveys,
investigations, conferences, dem-
onstrations and special purpose
projects which empower com-
munities to reduce risks from
exposures to toxic pollutants in
the air, in the water, and on the
land through collaborative action
at the local level. EPA estimates
$2.2 million of funding will be
available for CARE project grants
for fiscal year 2011. For more
information, visit EPAs CARE
website at www.epa.gov/care.
Indian Environmental General
Assistance Program (IGAP)
CDFA Reference Number 66.926
Authorized under the Indian
Environmental General
Assistance Program Act of 1992,
the Indian General Assistance
Program (IGAP) provides capac-
ity building and management
capabilities for federally-recog-
nized tribes and intertribal con-
sortia to develop environmental
programs. Funding for IGAP has
increased from $8.4 million in
the early 1990s to an estimated
$71 million for fiscal year 2011.
IGAP funding may be applied to
identify baseline environmental
needs; establish administrative,
legal, technical, and enforcement
capability; foster compliance
through programs, ordinances,
and education and outreach;
communications capability; and
management. IGAP grants are
14 Tribal Waste Journal
JULY 2011
-------
administered by EPA's American
Indian Environmental Office and
are negotiated by EPA Regional
Indian Program Managers and
Coordinators. The list of regional
coordinators is located on-line
at www.epa.gov/tribalportal/
contactinfo/regcontacts.htm. For
more information, visit EPA's
Indian GAP website, at www.epa.
gov/Indian/gap.htm.
Tribal Solid Waste
Management Assistance
Project
CDFA Reference Number 66.808
Under the Tribal Solid Waste
Management Assistance Project,
eligible federally-recognized
tribes may apply for funding un-
der one of four categories to: (1)
characterize/assess open dumps;
(2) develop integrated waste
management (IWM) plans and
tribal codes and regulations; (3)
develop and implement alterna-
tive solid waste management
activities/facilities (including
equipment acquisition); and (4)
develop and implement cleanup,
closure, and post-closure pro-
grams for open dumps in Indian
Country. Each proposal must
address only one of the four
proposal categories. Applicants
interested in applying for more
than one category may do so as
long as each proposal is for only
one category. For more informa-
tion visit http://epa.gov/waste/
wycd/tribal/finance.htm.
Hazardous Waste
Management Grant
Program for Tribes
CDFA Reference Number: 66.812
The Hazardous Waste
Management Grant Program for
Tribes provides financial as-
sistance to federally recognized
tribes and intertribal consortia
for the development and imple-
mentation of hazardous waste
programs; building capacity to
improve and maintain regulatory
compliance; and developing solu-
tions to address hazardous waste
impacting tribal lands. For more
information visit http://epa.gov/
waste/wycd/tribal/finance.htm.
JULY 2011
Tribal Waste Journal 15
-------
What is w/STARS?
Developed by the Indian
Health Service (IHS) in re-
sponse to the Indian Lands Open
Dump Cleanup Act of 1994
(Public Law 103-399), w/STARS,
or Web Sanitation Tracking and
Reporting System, is a database
that inventories sanitation issues
on American Indian and Alaskan
Native (AI/AN) lands. The data
in w/STARS is used by IHS to
track sanitation projects across
multiple media types including
water, waste water, solid waste,
human health services, etc.
In 1998, IHS released a re-
port of the status of open dumps
on AI/AN lands to the U.S.
Congress. A copy of the report
may be viewed at www.oehe.ihs.
gov/Solid_W/l 998_ODReport/
1998OpenDumpsReport.pdf. IHS
reported a total of 1,104 open
dumps with content ranging
from municipal solid waste to
hazardous and special waste to
combinations of different waste
types. In recent years, IHS and
EPA have collaborated to refine
the Operation and Maintenance
Data System (OMDS) portion of
w/STARS to list data on all open
dumps on AI/AN lands. EPA has
assisted IHS in gathering accu-
rate information on open dumps,
including the GPS coordinates
and exact materials found at the
sites. It is expected that more
than 3,000 open dumps will be
included in the new Report.
For more information
on w/STARS OMDS, contact
your local IHS Area Office. For
more information, visit the IHS
website at www.ihs.gov/index.
cfm?odule=AreaOffices.
16 Tribal Waste Journal
JULY 2011
-------
Resources
Earth 911
http://earth911.com
The Earth 911 Recycling
Directory is the most accurate and
comprehensive directory of its
kind and contains information on
how to recycle more than 240 dif-
ferent products. The information
is free for consumers to use on the
website and the toll-free, bilingual
hotline (1-800 CLEANUP). A free
iPhone application (iRecycle) is
provided as well.
C=M"
JLEPA
Illegal Dumping
Prevention Guidebook
Illegal Dumping Prevention
Guidebook
www.epa.gov/reg5rcra/wptdiv/
illegal_dumping/downloads/il-
dmpng.pdf
Published by EPA Region 5
in March 1998, the "Illegal
Dumping Prevention
Guidebook" is a valuable re-
source in developing a targeted
illegal dump prevention plan.
The Guidebooks Toolkit provides
information on site maintenance
and controls, community out-
reach and involvement, targeted
enforcement, and program mea-
surement.
TO SOI,IP WASTl
MANAGEMENT
Tribal Decision
Maker's Guide
www.epa .gov/waste/wycd/tri ba I/
tribalguide.htm
The Tribal Decision Maker's
Guide provides an overview
of solid waste management -
covering solid waste planning,
regulations, collection, disposal,
recycling, education, and more. It
includes more than 40 case stud-
ies and examples from tribes that
are leaders in solid waste man-
agement, as well as a substantial
list of resources at the end of
each chapter.
SMM Web Academy:
Recycling and Solid Waste
Management Educational
Series
www.epa.gov/epawaste/rcc/web-
academy/index.htm
The Sustainable Materials
Management Web Academy
provides information on materi-
als management to stakehold-
ers through webinars related to
SMM. You can learn about key
issues, successful projects, and
a variety of best management
practices for creating outstand-
ing waste management pro-
grams through free webinars.
You may download informa-
tion from past webinars such
as "Electronics: Responsible
Recycling Practices," "Social
Marketing - Building a Toolkit to
Motivate Environmental Action,"
and "Food Waste/Organics
Reduction and Recycling," or
sign up for a future webinar.
Tribal Waste Journal, Respect
Our Resources: Prevent
Illegal Dumping
www.epa .gov/waste/wycd/triba I/
resource.htm#twj
The first issue of the Tribal Waste
Journal focused on illegal dump
prevention and was published in
May 2002. This issue focused on
the following: building a multi-
faceted prevention program, in-
corporating community outreach
and involvement, keeping sites
clean, and measuring the success
of your program.
JULY 2011
Tribal Waste Journal 17
-------
KIDS' PAGE
Learn about the President's
Environmental Youth Awards (PEYA)
yoL\v viei^bovoo^ ov
\wlf U el.Aevs fo sf^vf <^
pvogv^m? 1-P so, f Ue Pvesi
-------
KIDS' PAGE
Durham Fair Recycling Project
rrn g. ROY Scout Troop t'
°y1
-Mieh School's Environmental
The Coginchaug rugn removed more
Coginchaug Organization Ituu ^ ^ 20_flujd-ounce
than 19,000 bottles,-- one- ^ Fajr _by jnitl.
beverage bottles sold durm^e £CO c,ub a|so educated
ating a recycling Progr^ , During the 3-day fair,
fair participants about recycu B. £CO
Ihich attracts hundreds of thouSnaJdcS0°ected recyclable
dub volunteers walked aroun ^.^ ,
in the containers. The ECO Club
ing station on the fairgrounds^
were delivered to recycling org,
the recyclable go0^!nb°^arketed tne reoy-.-"&
products. The ECO uu newspapers about
to visitors at the fair and infornmde^ness s^pported this
the project. The commu^;ythjs first-time recycling effort
a big success.
containers
that converted
^^^
recycling effort
No More Trash Talk:
Lets Cleanup Our Act
Ecological
Homer, Alaska (EPA Region 10)
mi
">y iuur, cutting waste hv Rn
"We'll Bring It to You"
SSru?id^Electronics ^cycling
HB Woodlawn 6th Grade Science Class Groun
Arlington, Virginia (EPA Region 3) P
The inspiration for the "We'll Bring It to You" r,,,hciH c, .
The students collected more than 450 nier « ,
JULY 2011
Tribal Waste Journal 19
-------
KIDS' PAGE
ame nmei
All sorts of garbage can end up in open dumps. In UNO ,oou<
Tribal Waste Journal, we explored the different types of garba
Instructions
Find the words in the word search puzzle below!
Word Key
Tire
Car
Computer
Television
Refrigerator
Microwave
Battery
Paint
Bottles
Cans
20 Tribal Waste Journal
-------
Alleviating Open Dumping on Tribal
Lands: Key Elements of Success
In this issue, five tribal waste management programs were highlighted. The wide array of success stories high-
light how creativity and determination can help alleviate open dumping. Though each tribe has a different story
to tell, the stories all share the following six common elements that have led to success in addressing open
dumps on tribal lands.
1 Collaboration can assist a tribe
in addressing the issue of lim-
ited available resources. It can
also create economies of scale that can
enable program success. For instance,
when the Saginaw Chippewa Tribe
determined that an independent waste
collection service was too expensive, a
creative arrangement with the neigh-
boring county service was created to
fill the gap. Similarly, the Yurok Tribe
reached out to two neighboring tribes
to pool Indian General Assistance
Program funds and state grants to im-
plement a vehicle round-up program.
This program not only resulted in the
successful cleanup of 400 vehicles, but
also the establishment of a lasting re-
lationship among the three neighbor-
ing tribes. In addition, several of the
program managers now hold seats on
a specialty task force to continue their
collaborative efforts.
2 Support from the Tribal
Council or Board of Trustees
is key to each program's suc-
cess. Whether it is a mandate from
the Tribal Council to deliver a high
quality environmental program or the
recognition that illegal dumping laws
are needed to enable police enforce-
ment actions, each program has had a
commitment from the tribal govern-
ment to succeed. The champions of
each project found a way to convince
their community leaders to embrace
the needed change and endorse its
mission.
3 Education of both environ-
mental staff and the community
is a critical element of all waste
management efforts. For example, the
Kickapoo Tribe started in the schools,
by making recycling a part of the chil-
dren's curriculum. In another example,
the Umatilla Tribe focused on educat-
ing the elders on what items can be
placed in the curbside recycling bins.
These examples showcase how educa-
tion is key to developing a viable plan,
establishing participation in the effort,
and ensuring success.
4Sustainability is defined as
"meeting the needs of the pres-
ent without compromising the
ability of future generations to meet
their own needs," by the Commission
on Environment and Development.
An example of a sustainable tribal
waste management program is that of
the Yakama Nation. With the com-
bined goals of economic efficiency
and environmental safety, as well
as incorporating ancestral ecologi-
cal knowledge into its practices, the
Yakama Nation mirrors the "three E's"
of sustainability: economics, environ-
ment, and equity.
5 Perseverance is an important
step in ensuring the success of a
program. For example, fund-
ing for the Saginaw Chippewa's former
recycling program was discontinued
by the Tribal Council because it was
thought to be economically inefficient.
However, the recycling coordinator
convinced the Council to reinstate the
program after conducting a waste au-
dit and calculating that the tribe could
save more than $100,000 annually
without hiring additional staff.
5 Respect is also extremely vital
to a successful waste manage-
ment program. Respect for the
land, for tribal ancestry, and for other
community members, including waste
haulers and transfer station staff, has
led to cleaner tribal lands and more
respectful treatment of resources.
As you move forward and face
the continued challenges of
open dumping, consider these
six key elements and how they
can help you implement a
successful tribal environmental
program.
JULY 2011
Tribal Waste Journal 21
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United States
Environmental Protection
Agency
US EPA Office of Resource Conservation and Recovery
EPA530-N-11-001
www.epa.gov/tribalmsw
July 2011
Printed on 100% recycled/recyclable pa-
per with a minimum 50% post-consumer
waste using vegetable-based inks.
------- |