Out of the Box Approach and Paradigm Shift to the Trash Policy
Agency staff have always just roll-up their sleeves and addressed the issue in the field. The approach was timely, responsive and alleviated wasted time. In effect, agencies have been providing extra services with public resources for private enterprise benefit. The issue of addressing Loose Trash (LT) assumes it is the sole responsibility of the MS4. But, in any jurisdiction you notice that LT almost entirely originates on or from private property and related activities. Rather than taking on the sole responsibility I am suggesting a paradigm shift - simply put the cost and responsibility back onto the responsible party(s). In fact, all Permittees, commercial, industrial and residential site owners must address the pollutant known as litter to the MEP.
Many assumed the methodologies in the Trash Policy provide a representative basis to the LT problem. However, it is just a time shot since the occurrence of LT within a community is not static and its existence is as complicated as the ever evolving and changing social demographics of a community. With this concept in mind here is an approach to the Policy that is not only successful, but extremely cost effective.
Rather than adhering to the sampling approaches provided we assessed the entire community and determined all identifiable sources via the “Comprehensive Visual Trash Assessment” (CVTA). Regardless of the approach chosen (FCS or FCSE) we realized that since the cost would be tens of millions of dollars over time addressing the problem it would be prudent and responsible to identify the: Exact locations of LT, Likely or specific sources of LT.
The approach takes into account that many neighborhoods already have FCS and extensive layers of contractors that address LT. CVTA were conducted multiple and several times during the baseline year to develop a sound basis for the Plan. Results confirmed the primary sources of LT is the direct result of identifiable parties:
• Environmental degradation associated with homeless activities
• Sites owned and/or operated by other Permittees
• Activities associated with educational activities
• Activities and sites owned by transportation agencies
• Identified problematic sites
Primary sources contribute over 90% of the LT problem and fortunately the locations identified are owned and/or operated by other responsible parties.
Lesser identified sources of LT include:
• Activities associated with specified sites and other Permittees
• Sites prone to illegal dumping
• Vacant lots
After identifying the problematic sites and determining source(s) we evaluated based on actual data which approach would long-term meet the objectives of the Policy. Included in the data driven exercise was an in-depth analysis of all current activities addressing LT within the community. All data was entered into GIS to get a visual representation of LT and existing trash management practices being deployed. Based upon the data we elected to develop a FCSE approach. Goals included engaging all elements of the community and developing consensus either voluntarily or through enforcement with measurable results in a cost effective manner. The approach included the following strategies:
• Coordination and collaboration with identified responsible parties
o Followed by a visual assessment (VA) of the identified locations to determine improvement
• General public education and outreach with all aspects of the community
o Followed by an annual VA of the identified locations to determine improvement
• If site compliance could not be achieved voluntarily then compliance driven activities for various identified problematic sites and/or activities would occur
o Followed by VA of the identified locations to determine improvement within 60 days. Additional compliance driven activities would follow, if required
The approach has been very successful.