In reading the Recycling_Goal_Preliminary_Recommendations_2009-07-21-web_post.pdf file the report states that C&D, paper and yard trash comprise 61% of waste (page 13). The report recommends at the bottom of page 13,
"An option to significantly impact the C&D recycling rate would be to require that all C&D be processed at a materials recovery facility (MRF) prior to disposal. A MRF basically separates recyclable from non-recyclable materials."

This report suggestion should be further advanced by encouraging the creation of economic markets to reuse/recycle waste materials. Without economically viable markets that encourage use of these materials, additional source separated material will be of no sale value.

I recommend that the FDEP departments (solid waste, air, and water (industrial, consumptive water use/NPDES)) convene and evaluate specific waste materials (such as scrap glass, tires, roof shingles) as raw materials for industrial re-use and/or combustion source material that have been permitted. The FDEP departments should collectively determine regulatory avenues to coordinate and streamline the permitting requirements for these uses. For example, scrap tires provide excellent heat and raw material input for cement production. Through repeated permitting by FDEP, waste tire use at cement plants is becoming a more streamlined permitting process. However, the time and expense of permitting has and continues to be a significant barrier.

Furthermore, FDEP should collectively determine if certain waste materials can be directly transported to certain processes versus requiring the intermediary step of transport to/from MRF for source separation which adds time and costs to re-use. A MRF is not required in all processes (for example, waste tires can be directly delivered to cement plants) which reduces cost and transportation, improving the economics.

In order to reach a 75% recycling goal, FDEP should consider to reduce waste material through internal coordinated efforts. The FDEP divisions should coordinate to evaluate opportunities to reduce permitting delays and costs to reduce solid waste while maintaining protection of the environment.

A recommended starting point of waste material sources and alternative uses: http://www.recycledmaterials.org/too...ines/index.asp

Sincerely,
Max Lee, Ph.D., P.E.
Senior Project Engineer
Koogler & Associates, Inc