Div of Waste Management and Radiation Control DEC 2 2 2017 PROMONTORY POINT RESOURCES an Alios Environmental company December 20, 2017 Scott T. Anderson, Director Division of Waste Management and Radiation Control Utah Department of Environmental Quality PO Box 144880 Salt Lake City, Utah 84114-4880 Re: Promontory Point Resources Class V Permit Application Needs Assessment Report Addendum Director Anderson: This letter transmits a Needs Assessment Report Addendum. The purpose of this report is to supplement our permit application and expand on the Needs Assessment Report infonnation submitted with the Promontory Point Landfill’s Class V Permit Application (March 2017, Appendix L-l) and to address comments provided by your office on July 12, 2102. These comments were provided in a report titled Evaluation of the Promontory/ Point Resources LLC, Needs Assessment Report (SC&A, Inc., 2017). With this supplemental infonnation we believe the Pennit Application contains all of the requirements of §19-6-108, (10) and (11) and applicable Solid Waste Rules. We respectfully request that DWMRC complete its review of our Class V Pennit Application. Please make us aware of any additional deficiencies as soon as practical. Thanks to you and your staffs time spent meeting and reviewing our application. If you have any questions on any of the Application materials please contact me or Ann Gamer at (317) 4574845 or ann.gamer@allosenv.com. Sincerely Promontory Point Resources, LLC Brett Snelgrove -------- ■> Director- Utah Operations 298 24th Street, Suite 170 Ogden, UT 84401 ▲ Allosenv.com A 435-414-9880 Div of Waste Management and Radiation Control DEC 2 2 201? imu-26(7-0!IOU ALLOS ENVIRONMENTAL Needs Assessment Report Addendum Promontory Point Landfill Addendum to Class V Needs Assessment Report, Permit Application, March 2017 Appendix L-1 Box Elder County, Utah December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS Contents Executive Summary..................................................................................................................................... iv Purpose of This Report....................................................................................................................... iv Local Support...................................................................................................................................... iv Need for Promontory Point Landfill......................................................................................................v Promontory Serves Industry................................................................................................................vi Conclusions.........................................................................................................................................vi 1 2 3 4 Introduction...........................................................................................................................................1 1.1 Purpose of This Report Addendum............................................................................................1 1.2 Contents of This Report Addendum........................................................................................... 2 Promontory Point Landfill.................................................................................................................... 3 2.1 Location......................................................................................................................................3 2.2 Permits and Approvals.............................................................................................................. 4 2.3 Facility 2.3.1 2.3.2 2.3.3 2.4 Development History................................................................................................................. 5 2.4.1 Box Elder County Support............................................................................................ 5 2.4.2 Economic Benefits........................................................................................................ 7 Description.................................................................................................................... 4 Site Suitability............................................................................................................... 4 Standards for Performance, Design, and Operations.................................................. 4 Capacity........................................................................................................................5 Demographics and Waste Generation Forecasts............................................................................... 8 3.1 Population Forecasts................................................................................................................. 8 3.1.1 Northern Utah Communities......................................................................................... 8 3.1.2 Waste Growth............................................................................................................... 9 3.2 Waste 3.2.1 3.2.2 3.2.3 3.2.4 Market...........................................................................................................................11 Utah Municipal and Commercial Waste......................................................................11 Industrial Waste...........................................................................................................13 Special Waste (Nonhazardous Waste).......................................................................15 Regional Waste Market...............................................................................................16 Needs Assessment............................................................................................................................19 4.1 Proven 4.1.1 4.1.2 4.1.3 Market for Nonhazardous Waste................................................................................. 19 Waste Source............................................................................................................. 21 Market Analysis.......................................................................................................... 23 Review of Other Waste Facilities............................................................................... 28 4.2 Public 4.2.1 4.2.2 4.2.3 4.2.4 Benefits......................................................................................................................... 35 Need for Additional Capacity...................................................................................... 36 Recoverable Energy and Resources......................................................................... 38 Waste Reduction and Better Waste Management Methods...................................... 39 Hazardous Waste Management................................................................................. 40 4.3 Compliance History of Owners and Operators........................................................................ 41 December 20, 2017 i Needs Assessment Report Addendum Promontory Point Landfill 5 6 Additional Determinations................................................................................................................. 43 5.1 Environmental Considerations............................................................................................... 43 5.1.1 Location Standards.................................................................................................... 44 5 1.2 Design Standards........................................................................................................ 45 5.1.3 Plan of Operations....................................................................................................... 45 5.2 Need to Serve Industry within the State.................................................................................. 46 5.2.1 Industry within Box Elder County................................................................................ 46 5 2 2 Industry within the State.............................................................................................. 47 Conclusion......................................................................................................................................... 48 Tables Table 1. Table 2. Table 3. Table 4. Table 5. Table 6. Table 7. Table 8. Table Table Table Table Population Forecasts...................................................................................................................... 9 Estimated Annual Municipal Solid Waste Generation at 4.44 Pounds per Person per Day........12 Estimated Annual Municipal Solid Waste Generation at 6.0 Pounds per Person per Day........... 13 Projected Employment by County..................................................................................................14 Employment by Industry and Growth.............................................................................................15 Remediated Soil in Northern and Southern California (2014-2015)............................................ 18 Annual Municipal Solid Waste Generation in Northern Utah........................................................ 22 Travel Time and Cost Differences from Midpoint to Promontory Point Landfill and Bayview Landfill............................................................................................................................. 27 9. Cost Comparison.......................................................................................................................... 28 10. Municipal District Summary.........................................................................................................33 11. Economic Benefits Summary...................................................................................................... 36 12. Landfill Capacity Summary......................................................................................................... 37 Figures Figure 1. Figure 2. Figure 3. Figure 4. Figure 5. Figure 6. Location Map..................................................................................................................................3 Annual City Growth Projections to 2050.......................................................................................10 Union Pacific Railroad Lines.........................................................................................................17 Northbound and Southbound Haul Routes (100-mile Distance)................................................. 24 Round-Trip Travel Times from Midpoint to Promontory Point Landfill......................................... 26 Existing Landfill Locations........................................................................................................... 29 Appendices Appendix A. Appendix B. Appendix C. Appendix D. Appendix E. Gardner Policy Institute, Economic and Fiscal Impact of Promontory Point Landfill Gardner Policy Institute, Utah’s Long-Term Demographic and Economic Projections Referenced Calculations NUERA Information Sheet - Bayview Landfill Project Evaluation Report Findings and Response Matrix on Needs Assessment Report ii December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS Acronyms and Abbreviations Alios C&D DWMRC 1-15 Alios Environmental (parent company of Promontory Point Resources, LLC) construction and demolition waste Division of Waste Management and Radiation Control IRL Interstate 15 Intermountain Regional Landfill MSW municipal solid waste NUERA Northern Utah Environmental Resource Agency RGBs polychlorinated biphenyls Promontory Promontory Point Resources, LLC RCRA Resource Conservation and Recovery Act SLVSWMF Salt Lake Valley Solid Waste Management Facility SUVSWD UP South Utah Valley Solid Waste District Union Pacific Railroad USEPA United States Environmental Protection Agency December 20, 2017 iii Needs Assessment Report Addendum Promontory Point Landfill Executive Summary Purpose of This Report This Needs Assessment Report Addendum describes Promontory Point Landfill, presents the developmental history of the landfill, summarizes the economic benefits of the landfill to Box Elder County, provides an overview of the waste market that could use the landfill, presents the need for additional landfill capacity in the state, and presents the public and industry benefits that the landfill provides as a commercial facility (Class V non-hazardous waste facility) as required pursuant to Utah Code Title 19, Chapter 6, Part 1, Section 108, § 10 and § 11 of the Utah Solid and Hazardous Waste Act. This report also includes information requested during an August 10, 2017, meeting between Promontory Point Resources, LLC (Promontory, the landfill owner), and the Utah Division of Waste Management and Radiation Control (DWMRC) Director, staff, and DWMRC consultant (SC&A). Promontory Point Landfill is a permitted Class I landfill located on the southern tip of the Promontory Point Peninsula in Box Elder County. The landfill has been permitted as a Class I facility since 2001, and construction of the initial landfill cell was completed in December 2017. When the landfill’s road improvements are completed in the spring of 2018, the facility will begin accepting waste via truck, which is estimated to start in July 2018. The Class V designation and the finalization of the on-site rail service from the adjacent Union Pacific Railroad main track will expand the landfill’s wasteshed. Most heavyindustrial manufacturing facilities are rail-served, and Promontory Point Landfill will provide a cost-effective alternative for transporting many waste streams. Local Support According to a report published in 2017 by the University of Utah’s Kern C. Gardner Policy Institute, Utah’s population is projected to increase significantly, by 93%, over the next 50 years. Northern Utah’s seven counties (Utah County and counties north) are projected to have 79% of the state’s total population (5.8 million) by 2065. Annual waste volumes are expected to grow by 63% by 2050 and 88% by 2065 in the seven northern Utah counties. The increase in population and subsequent increase in waste will necessitate expanded waste-disposal options. Additionally, heavy industries in the region that are located far from disposal sites and are adjacent to a rail line, or waste consolidation point, will have a cost-effective disposal option of using the rail line to transport their waste to Promontory Point Landfill. Box Elder County and the State of Utah recognize the need for and support the development of long-term waste-disposal infrastructure at Promontory Point Landfill. Box Elder County passed County Ordinance 422 amending its zoning to allow a Class V landfill. Box Elder County issued a Private Activity Bond for the construction of the landfill, and the landfill’s Class V status was approved by House Joint Resolution 20. iv December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS Need for Promontory Point Landfill Utah’s communities demand low-price waste disposal. Market viability comes down to economics and the overall waste-disposal system costs for communities and businesses. System-wide costs include collection, transportation, and disposal costs. Promontory can guarantee airspace, will offer disposal fees that are competitive, and will provide communities with long-term cost certainty for disposing of their waste. Considering traffic congestion in Davis, Salt Lake, and Utah Counties, Promontory Point Landfill is a more cost-effective option for northern Utah communities than other Utah disposal sites. Many municipal waste districts along the Wasatch Front with landfills are facing end-oflandfill-life issues; many large municipal waste-disposal operations are consolidating, and these landfills could have as little as 21 to 29 years of life remaining. After municipal landfills close, the two commercial Utah landfills will have some capacity; however, Promontory Point Landfill will help ensure that these companies do not form a duopoly, which could drive disposal prices higher. The Box Elder County Economic Development Director, Mitch Zundel, commissioned a study from the Gardner Policy Institute regarding the economic and fiscal impacts associated with Promontory’s new solid waste facility. Their model estimated the new workers and total population attracted by the total (direct, indirect, and induced) economic activity produced by Promontory Point Landfill to be a 15-year average of 185 new jobs in Box Elder County and 375 total new jobs in the state. Promontory Point Landfill, therefore, is aligned with Governor Gary Herbert’s rural jobs initiative, which aims to strengthen local rural economies, create jobs, and support local business. For Box Elder County, the net revenues (income, sales, and property tax, less expenditures) were modeled to be up to $2.3 million annually, with a net present value of $31.0 million. New state net revenues were modeled to average $0.92 million each year with a net present value of $12.5 million. The total new direct tax revenue from Promontory Point Landfill to Box Elder County is projected to increase from $0.91 million initially and grow to $2.2 million annually in 15 years. Modern landfilling is an environmentally sound waste management practice. Promontory’s leadership and operations support staff have well over 100 years of solid waste management experience. In their previous work experience, they have not received notice of any major violations. For minor infractions, all regulatory issues were addressed to the satisfaction of the appropriate agency. Promontory believes in appropriate resource utilization, recycling, and reuse to preserve our natural resources. Promontory is willing to partner with municipalities and facilitate discussions about the feasibility of diverting and recovering organics, recyclables, and other inert and reusable materials at the landfill. Promontory is committed to protecting and enhancing the environment. Promontory Point Landfill meets all siting restrictions and engineering design standards found in Utah Solid Waste Rules. The environmental impacts will not be materially different than they are under the active Class I landfill permit. The minor land-use impacts are offset by powering the site with renewable energy, by installing a landfill gas collection system and using the gas as a transportation fuel offsetting the use of dirtier diesel fuel, by implementing a dust-control plan, and by facilitating transportation efficiency, which can December 20, 2017 v Needs Assessment Report Addendum Promontory Point Landfill decrease air pollutant emissions. Implementing Promontory Point Landfill’s Class V permit now will help eliminate the need for new landfills and their potential land-use conflicts. Additional considerations could include natural resource enhancements in the landfill’s buffer or non-operational areas. Promontory Serves Industry Waste management is an integral part of industry in Utah. Box Elder County sees an opportunity to attract industrial and manufacturing businesses by developing low-cost and long-term disposal infrastructure for waste generated by these businesses. For Box Elder County, Promontory Point Landfill is an economic driver and will support future economic development in accordance with Governor Gary Herbert’s rural jobs initiative. The Gardner Policy Institute projects that a 188.7% increase in the administrative and waste services sector is needed to manage future waste generated by Utah’s fast­ growing population. Promontory Point Landfill would be developed ahead of the anticipated population growth and the critical need for additional disposal capacity. Promontory Point Landfill expands the waste-disposal choices for Utah’s communities and businesses. Conclusions In conclusion, annual waste volumes will grow substantially as Utah’s population continues to expand. The need for a Class V designation for Promontory Point Landfill is based on the market and economic assessment, which shows strong needs and benefits for a regional facility. Box Elder County wants to offer industry lower disposal costs that are provided by the economies of scale offered by larger landfill operations, similar to other municipalities in other parts of the state. Promontory Point Landfill’s Class V designation is supported by Box Elder County, which sees substantial economic and fiscal benefits. Because of the lack of environmental effects and limited land-use conflicts, Box Elder County has changed its zoning to allow the use of the land for a Class V landfill and has issued private activity bonds for construction. Promontory Point Landfill is a critical and integral component of industry in Utah, which needs to increase employment in its waste services sector by 188.7% by 2065 to keep up with the disposal demand. All local and legislative approvals are in place, and the information presented in this report demonstrates compliance with and provides evidence for the fulfilment of the requirements of Utah Code Title 19, Chapter 6, Part 1, Section 108, § 10 and § 11 of the Utah Solid and Hazardous Waste Act for Promontory Point Landfill. With DWMRC’s approval of Promontory Point Landfill’s operating plan and Class V Landfill Permit Application, and Governor Gary Herbert’s approval, Box Elder County and the existing and future industries in the state can start to recognize the benefits of Promontory Point Landfill. vi December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS 1 Introduction Promontory Point Landfill is a permitted Class I landfill. Promontory Point Landfill is seeking a Class V landfill permit, which would allow it to operate as a commercial nonhazardous solid waste disposal facility, as defined by Utah Administrative Code Rule R315-301-2(11) and Utah Statute Title 19, Chapter 6, Section 102(3)(a). This document contains all of the information required by Utah Code Title 19, Chapter 6, Part 1, Section 108, § 10 and § 11 of the Utah Solid and Hazardous Waste Act for evaluating a Class V landfill. Like Class I landfills, Class V landfills are permitted to receive for disposal: • municipal solid waste; • any other nonhazardous solid waste, not otherwise limited by rule or solid waste permit, including construction and demolition waste (concrete, bricks, rocks, and wood), yard waste, and other inert wastes; • in conjunction with municipal solid waste or other nonhazardous solid waste, waste from a conditionally exempt small quantity generator of hazardous waste; • industrial waste is any solid waste generated at a manufacturing or other industrial facility that is not a hazardous waste or that is waste from a conditionally exempt small quantity generator of hazardous waste; and • special waste, which is nonhazardous solid waste but that requires special handling or is asbestos, ash, bulky waste (automobile bodies, furniture, appliances, waste tires), dead animals, waste containing polychlorinated biphenyls (PCBs), petroleum contaminated soils, waste asphalt, and sludge. As part of the requirements of the Class V Permit Application, Promontory submitted a Needs Assessment Report in compliance with Utah Code, Title 19, Chapter 6, Part 1, Section 108, § 10 and § 11. The Needs Assessment Report' was originally included as Appendix L-1 of the Promontory Point Landfill Class V Permit Application and is discussed in more detail in Section 1.1 (Purpose of This Report Addendum). This report addendum presents an overview of waste generation in Utah, the economic and fiscal benefits of Promontory Point Landfill having a Class V designation, and the necessity of additional long-term waste-disposal capacity to serve the growing population and industry in Utah. 1.1 Purpose of This Report Addendum As part of the Class V Landfill Permit Application process, Promontory Point Resources, LLC (Promontory), is submitting information to the Director of the Utah Division of Waste Management and Radiation Control (DWMRC) regarding the economic market analysis and need justification for a new commercial landfill in Utah. This information is required pursuant to Utah Code Title 19, Chapter 6, Part 1, Section 108, § 10 and § 11 of the Utah Solid and Hazardous Waste Act. The information in this report supplements1 1 Class V Needs Assessment Report, WIH Resources, March 2017 December 20, 2017 1 Needs Assessment Report Addendum Promontory Point Landfill Promontory’s Class V Permit Application (March 2017) Appendix L-1 titled Class V Needs Assessment Report. Promontory’s Needs Assessment Report in the Permit Application was reviewed by DWMRC and its consultant, SC&A. SC&A reviewed the report and supplied the DWMRC with its review findings in an Evaluation Report in July 2017.2 Promontory’s responses to each of findings in the Evaluation Report are provided in Appendix E of this report addendum. Promontory met with DWMRC’s Director, staff, and SC&A on August 10, 2017, to review the Evaluation Report findings, discuss the main benefits of Promontory Point Landfill, and get clarification regarding the factors most important for DWMRC’s review. Promontory has prepared new information based on the aforementioned meeting. Some of the information provided in the Needs Assessment Report is superseded by information in this Needs Assessment Report Addendum. This report addendum discusses in greater detail the need for the Class V designation for Promontory Point Landfill, which would allow the landfill to receive public or privately contracted nonhazardous solid waste from other sources in addition to, but of the same type as, the waste it can already receive under the currently active Class I landfill permit. 1.2 Contents of This Report Addendum The remainder of this Needs Assessment Report Addendum describes Promontory Point Landfill, presents the developmental history of the landfill, summarizes the economic benefits of the landfill to Box Elder County, provides an overview of the waste market that could use the landfill, presents the need for additional landfill capacity, and presents the public benefits that the landfill provides as a commercial facility. The main report addendum sections are as follows: • Section 2 describes the partnership that Promontory has developed with Box Elder County and the economic and fiscal benefits that the landfill provides to the county and the state. • Section 3 presents an overview of Utah’s demographics and expected future population as well as the resulting waste generation. Section 3 also presents information regarding Utah’s industrial waste and, because Promontory Point Landfill will be rail-served, the regional nonhazardous wastes that could be disposed at the facility. • Section 4 provides the core needs assessment information pursuant to Utah Code § 19-6-108 (9) and (10). Section 4 includes all information for the market analysis and need for additional capacity. It is organized by Utah Code section and contains the information needed for the Director to approve the operating plan. • Section 5 provides the additional determinations required by Utah Code § 19-6-108 (11), which is the potential beneficial and adverse environmental effects of the landfill and the need to serve industry within the state. 2 Evaluation of the Promontory Point Resources, LLC, Needs Assessment Report, SC&A, July 10,2017 2 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS Promontory Point Landfill Location Promontory Point Landfill is located on the west side of the southern tip of the Promontory Point Peninsula at 18900 West along East Promontory Road in Promontory, Utah (Figure 1). A ridgeline along the Promontory Peninsula serves as a visual shield from the Wasatch Front. The site is in Township 6 North, Range 5 West, Section 19, Salt Lake Meridian, Box Elder County. Of the 1,981-acre site, about half (981 acres) is permitted for disposal. The other 1,000 acres serve as buffer area around the planned disposal footprint. An additional 137 acres south of Promontory Road will be used for rail operations and access. Figure 1. Location Map LEGEND Promontory Landfill Location “l-----1------175 25 50 Miles December 20, 2017 3 Needs Assessment Report Addendum Promontory Point Landfill 2.2 Permits and Approvals Promontory Point Landfill meets all siting and engineering requirements and has had a Class I permit since September 2011. Permit Modification #1 was a minor modification due to the change in ownership and was issued in 2015. Permit Modification #2 was a major modification due to changes in the landfill design and financial assurance requirements. The active permit was issued by DWMRC on March 15, 2017. Citing favorable economic impacts and pursuant to Utah Code Title 19, Chapter 6, Section 108, § 3, the Utah legislature approved Promontory Point Landfill with House Joint Resolution 20 in the 2016 legislative session. Refer to Section 2.4.2 (Economic Benefits) for detailed information regarding the economic and fiscal benefits of Promontory Point Landfill. The Box Elder County Commission approved Ordinance 422 on July 6, 2016, amending the county’s zoning map to allow the Class V landfill. Also refer to Section 2.4.1 (Box Elder County Support) for information about additional local permits and approvals. 2.3 Facility Description The following sections briefly describe the site, confirming details provided in the Permit Applications and demonstratingcompliance with applicable regulations. 2.3.1 Site Suitability Promontory Point Landfill meets all the location standards in R315-302 for Class I and Class V landfills. A detailed description is provided in Section l.c of the Class V Landfill Permit Application (March 2017). Also refer to Section 5.1 (Environmental Considerations) for a concise summary of the landfill’s siting criteria and the technical and engineering performance standards designed to protect human health and the environment. 2.3.2 Standards for Performance,Design, and Operations Promontory Point Landfill has been designed to meet or exceeds all of the standards for maintenance and operation in R315-303 for Class I and Class V landfills. These standards include performing gas monitoring and taking appropriate action if explosive gases are detected. A fugitive dust plan was included in the Class V Permit, and this plan is part of the operations to address ambient air quality standards at the property boundary. A groundwater monitoring system is being designed, and sampling and analysis plan has been developed, to meet the requirements of R315-308. Corrective action plans are also in place if the surface water run-on/run-off system fails or if groundwater contamination is detected. Regular inspections of the leachate collection and recovery system groundwater monitoring network and of the landfill gas collection system will be a part of the ongoing operations in order to assess the structural integrity and effectiveness of all installed equipment. 4 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS 2.3.3 Capacity The 1,981-acre site has about 981 acres permitted for disposal. The landfill airspace capacity has been estimated based on the proposed base grading plan, the proposed final grading plan, and the proposed liner system and final cover system designs, as presented in the Class V Landfill Permit Application, Appendix Y (Phase 1 Plans). This layout resulted in an estimated capacity of about 775 million cubic yards or equivalent to an estimated capacity of 656 million tons of waste. Promontory provided projected municipal solid waste, industrial waste, and special waste tonnage in the Class V Landfill Permit Application. Assuming that the site initially receives 200,000 tons per year, or 750 tons per day, and that disposal rates increase by an average of 2% per year, the landfill has a projected lifespan of approximately 125 years.3 2.4 Development History 2.4.1 Box Elder County Support Promontory’s partnership with Box Elder County has developed over several years. Box Elder County was presented information regarding the potential benefits of permitting a regional facility. The following is a summary of Box Elder County’s actions approving the development of Promontory Point Landfill. • A public hearing was held by the Box Elder Planning Commission on June 16, 2016, to solicit comments on Ordinance 422, which amended the county’s zoning map to allow the Class V landfill. The Box Elder County Commission approved Ordinance 422 on July 6, 2016. • On September 7, 2016, the County Commission unanimously adopted Resolution 16-08 approving Box Elder County’s assistance with Promontory’s application to the Utah Private Activity Bond Review Board (which is under the Governor’s Office of Economic Development) for a private activity revenue bond. • On October 5, 2016, the Box Elder County Commission heard more details about the bond issue. The meeting also included a request for public comments and questions. Regarding the security of the revenue, Promontory explained the rigorous feasibility evaluations done by its equity investors and the bond purchasers. • At the October 5, 2016, Commission meeting, the Commission was also presented with the results of an analysis of the County’s municipal services. The analysis showed that there is a $1.6 million funding gap for these services.4 This is germane to the operation of Promontory Point Landfill because, in addition to state payroll and corporate taxes, the landfill will generate local taxes of almost $1 million initially, which will grow to over $2 million in 2031.5 For more information, refer to Section 2.4.2 (Economic Benefits). 3 Application for a Permit to Operate a Class V Landfill, Appendix U, Terta Tech BAS, March 2017 4 Municipal Service Tax Feasibility Study, presentation by Lewis, Young, Robertson, & Burningham, Inc.; October 2016 5 Economic and fiscal impacts associated with Promontory Point Resources’ new solid waste facility, 2017-2031, Kem C. Gardner Policy Institute, University of Utah, November 18, 2016 December 20, 2017 5 Needs Assessment Report Addendum Promontory Point Landfill • On December 7, 2016, the Utah Private Activity Bond Review Board gave its approval for Box Elder County to issue the private activity bond. • On March 15, 2017, the Box Elder County Commission reviewed and approved, as a condition of its conditional-use permit, Promontory’s mitigation agreement. This mitigation agreement provided the County with details regarding its contingency plans for fire, groundwater contamination, surface water runoff, landfill gas controls, fugitive dust, litter control, procedures for rejecting hazardous waste, and other related components of the landfill operating plan. Through this coordination, Box Elder County recognized the need to develop a long-term waste-disposal infrastructure in order to help attract new business, including heavy industrial and manufacturing businesses, to the area by providing environmentally responsible disposal options for its discarded material. Because Little Mountain Landfill has no composite liner, no leachate collection system, and no groundwater-monitoring system, it is not applicable for most industrial wastes where liability indemnification is important to those businesses. In Promontory leadership’s experience, for owners of large industrial plants, liability and indemnification are major concerns when making waste management and disposal decisions about their waste. Municipal or publicly owned facilities often provide little protection from a liability and indemnification standpoint, since a lot of heavy-industrial companies are often significantly larger, financially, than the communities where they reside. In theory, a municipality could offer liability protection and indemnification. In practice, if there were ever environmental issues at a publicly owned landfill and a major industrial company was known to have industrial waste in that facility, responsibility for any mitigation or cleanup could fall on the industrial company. As evidence that Box Elder County’s landfill is not suitable, only 170 tons of industrial waste was shipped to Little Mountain Landfill in 2015. As a result of landfill conditions and the lack of indemnification, some of the largest industries have constructed their own on-site landfills. There are 3 Class lllb landfills in Box Elder County, Nucor and ATK are examples, and 25 in the state. Given the conditions at Little Mountain Landfill, any future industrial companies might be hesitant to contract with Box Elder County and, therefore, would have to build their own landfill. A $15 million or more capital investment is needed to develop a large landfill that meets modern engineering design standards. It is often not financially feasible or politically possible for smaller public entities to invest this amount of capital. If it does, the investment could result in high operating costs ($/ton) if waste from only within the municipality’s boundary (Class I) is delivered. Promontory Point Landfill would give such businesses in all northern Utah counties an economical and environmentally responsible alternative. To make this new landfill in Box Elder County as financially attractive as possible for attracting new business, the County wants a regional facility and wants to accept waste from outside the county. A Class V landfill will provide citizens and businesses, now and in the future, with the benefit of low disposal rates due to the economy of scale offered by a larger operation. 6 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS 2.4.2 Economic Benefits Background The Box Elder County Economic Development Director, Mitch Zundel, commissioned a study from the University of Utah’s Kern C. Gardner Policy Institute regarding the economic and fiscal impacts associated with Promontory’s new solid waste facility.6 The Gardner Policy Institute used Promontory’s estimated waste volumes received in the first 3 years of operation under the Class V permit, and then increased these volumes by 2% per year to the end of the 15-year analysis period. Promontory provided estimates of required employment levels, capital expenditures for the construction of the initial landfill facilities and periodic liner expansion, and operating expenditures. The Gardner Policy Institute analyzed the effects of the construction and operation of a new solid waste facility for Box Elder County. The results are based on annual employment; compensation; capital, operations, and maintenance expenditures; state income taxes; property taxes; and other local tax data. The Gardner Policy Institute used its REMI PI+ economic model to forecast the economic effects of Promontory’s new solid-waste facility in Box Elder County. In its analysis, the jobs and compensation provided to Promontory employees, plus the capital, operations, and maintenance expenditures, are direct effects. The economic activities associated with required purchases from local suppliers, who in turn make purchases from other local suppliers, are indirect employment and income effects. In addition, the Gardner Policy Institute modeled the spending of direct and indirect employees with their new wages in the local economy creating “induced employment” economic benefits. Results The Gardner Policy Institute’s model also estimated the new workers and total population attracted by the total (direct, indirect, and induced) economic activity produced by Promontory's new landfill. The model showed that a 15-year average of 185 new jobs in Box Elder County and 375 total new jobs in the state would result (based on the total waste volumes and the timing of the deliveries). In terms of total population (including school- and college-age people), Promontory Point Landfill is predicted to support up to 657 people by 2031. Promontory Point Landfill, therefore, is aligned with Governor Gary Herbert’s rural jobs initiative,7 which aims to strengthen local rural economies, create jobs, and support local business. Refer to Appendix A for the Gardner Policy Institute’s complete analysis. With respect to the fiscal impacts (government revenues), Promontory Point Landfill is important to Box Elder County. The increased economic activity produces new income, sales tax revenues, and property tax revenues, while the growing population creates the need for additional government expenditures. The Gardner Policy Institute estimated fiscal impacts based on multi-year historical relationships between personal income and industry output and tax revenues, and accounts for additional expenditures per capita for the relevant populations (school age, college age, and total population). For Box Elder County, the net revenues were modeled to be as much as $2.3 million annually, Refer to footnote 5 on page 5. 7 http://25kiobs.com December 20, 2017 7 Needs Assessment Report Addendum Promontory Point Landfill with a net present value of about $31.0 million. New state net revenues were modeled to average $0.92 million each year, with a net present value of $12.5 million. As mentioned in Section 2.4.1 (Box Elder County Support), the County is facing a $1.6-million-dollar funding gap in its Municipal Services Fund. The total budget in 2016 was $8.1 million with total expenditures of $9.7 million. The total new direct tax revenue from Promontory Point Landfill to Box Elder County is projected to increase from $0.91 million initially and grow to as much as $2.2 million in 15 years. This represents 11.2% of the Municipal Service Fund budget (9.4% of expenditures) initially based on the actual amount of waste received, growing to 27.2% (22.7% of expenditure) in 2031 (assuming that the budget is not increased and waste assumptions are met). Consequently, Promontory Point Landfill offers Box Elder County the potential opportunity to avoid tax increases that would be needed to close the funding gap. 3 Demographics and Waste Generation Forecasts 3.1 Population Forecasts Utah’s population is projected to increase from about 3 million people in 2015 to about 5.8 million people in 2065; this is an increase of 2.8 million people, or about 93%. This total growth equates to an annual growth rate of about 1.3%. All counties in Utah are expected to grow in population over the next 50 years. Population growth will be most pronounced along the Wasatch Front (Weber, Davis, Salt Lake, and Utah Counties). Salt Lake County is projected to remain the most populous county. However, Utah County’s population is expected to increase by 177% from 2015 to 2065 and be close to the population of Salt Lake County. Washington County, in the extreme southwestern part of Utah, is projected to grow rapidly and become the fourth-most-populous county with 509,000 people, surpassing Weber County (389,334) by 2065.8 Refer to Section 3.1.1 below for detailed projections. 3.1.1 Northern Utah Communities Although all counties in Utah are projected to experience population growth over the next 50 years, the most growth (in total number of people) will take place in Salt Lake and Utah Counties. Table 1 shows population projections in the northern Utah counties in 2015, 2050, 2060, and 2065. 8 Utah’s Long-Term Demographic and Economic Projections, Kem C. Gardner Policy Institute, University of Utah, July 1,2017 8 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS Table 1. Population Forecasts County Salt Lake 2015 2050 2060 2065 Average Growth Rate (2015-2065) 1,094,650 1,531,282 1,648,280 1,693,513 0.88% Utah 585,694 1,297,515 1,504,433 1,620,246 2.10% Davis 336,091 493,263 527,545 544,958 0.78% Weber 242,737 356,812 379,350 389,334 0.95% Cache 121,855 204,114 223,154 234,744 1.29% Box Elder 52,971 77,472 83,248 86,218 0.98% Morgan 11,080 21,978 23,583 24,065 1.62% 2,445,078 3,982,436 4,389,593 4,593,078 Total — Source: Utah’s Long-Term Demographic and Economic Projections, Kem C. Gardner Policy Institute, University of Utah, July 1,2017 These northern Utah counties are projected to have 79% of the state’s total population (5.8 million) by 2065. The “ring counties” (Morgan, Summit, Rich, and Uinta) around the Wasatch Front are also expected to grow rapidly from an overall percentage standpoint. However, total waste volumes in future years will be dominated by the larger counties listed in Table 1 above. The wastes from these ring counties could use Promontory Point Landfill once these counties’ landfills reach capacity. However, the waste from larger counties forms the basis for landfill capacity estimates for the locally generated waste and the need information in this report addendum. 3.1.2 Waste Growth Another factor in estimating landfill capacity is the assumed rate of waste growth within a specific landfills wasteshed (areas that brings their waste). As is normal, some areas develop faster, on a percentage basis, than others due to a variety of factors including availability of developable land and proximity to employment. The Utah Governor’s Office of Management and Budget subdivides county population forecasts and growth rates by municipality.9 Figure 2 shows the forecasted average annual growth rate between 2012 and 2050 for various cities along the Wasatch Front. 2012 baseline projections, Governor’s Office of Management and Budget, https://qomb.utah.qov/budqet-policv/ demoqraphic-economic-analvsis/ December 20, 2017 9 Needs Assessment Report Addendum Promontory Point Landfill Figure 2. Annual City Growth Projections to 2050 10 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS As shown above in Figure 2, cities in the following areas are projected to grow at a faster rate (1.5% to 2%) than the rest of the Wasatch Front (1 % to 1.5%): • • • • • Southern part of Salt Lake County (South Jordan, Herriman, and Bluffdale) Northern part of Utah County (Lehi, Saratoga Springs, and Eagle Mountain) Southern part of Utah County (Springville, Spanish Fork, Mapleton, and Payson) Northern Davis County (Syracuse and West Point) Western and Northern Weber County (Hooper and West Haven) Shorter-range forecasts made by the Mountainland Association of Governments estimated growth rates of 3.1% for southern Utah County to 2030 and 2.3% for all Utah County cities to 2040.10 This city-level resolution is an important factor when calculating waste growth and the remaining capacity of various landfills and in projecting the need for future landfill airspace. To be conservative, Section 4 (Needs Assessment) and the calculations in Appendix C provide capacity information for various existing landfills based on an assumed 2% rate of waste growth. 3.2 Waste Market 3.2.1 Utah Municipal and Commercial Waste Municipal solid waste (MSW) is defined as “household waste, nonhazardous commercial solid waste, and non-hazardous sludge.” Commercial solid waste is defined as “all types of solid waste generated by stores, offices, restaurants, warehouses, and other nonmanufacturing activities, excluding household waste and industrial wastes” (R315-301). Together, these wastes are categorized as municipal waste, since commercial waste is not reported or tracked separately by DWMRC. Construction and demolition waste, or C&D waste, is “solid waste from building materials, packaging, and rubble resulting from construction, remodeling, repair, abatement, rehabilitation, renovation, and demolition operations on pavements, houses, commercial buildings, and other structures.” Examples of C&D waste provided in Utah solid waste rules and include concrete, bricks, other masonry materials, soil, rock, waste asphalt, rebar contained in concrete, untreated wood, and tree stumps. Table 2 and Table 3 provide estimates of future waste generation. The annual municipal waste generation in Table 2 was estimated based on a per-capita generation rate of 4.44 pounds per person per day from the U.S. Environmental Protection Agency (USEPA).11 This generation rate was applied to the population forecasts from Table 1 above to estimate the future amount of waste generated in each county. Annual waste growth therefore follows estimates of the rate of population growth. 10 Mountainland Association of Governments, 2005, from Solid Waste Planning Technical Report, URS, June 2007 11 Municipal Solid Waste Generation, Recycling and Disposal in the US, U.S. Environmental Protection Agency, 2012 December 20, 2017 11 Needs Assessment Report Addendum Promontory Point Landfill Table 2. Estimated Annual Municipal Solid Waste Generation at 4.44 Pounds per Person per Day In tons per year County 2015 Salt Lake 2050 2060 2065 886,995 1,240,798 1,335,601 1,372,254 Utah 474,588 1,051,376 1,219,042 1,312,885 Davis 272,335 399,691 427,470 441,579 Weber 196,690 289,125 307,387 315,477 Cache 98,739 165,394 180,822 190,213 Box Elder 42,922 62,776 67,456 69,862 8,978 17,809 19,109 19,500 1,981,247 3,226,968 3,556,887 3,721,771 Morgan Total As shown in Table 2 above, annual waste volumes would be 88% higher by 2065, or nearly double the 2015 volumes. Promontory Point Landfill provides 105 years of capacity for these seven counties assuming 2050 waste volumes (3,226,968 tons annually) or a total capacity of 340,000,000 tons. The values in Table 2 above reflect a waste-generation assumption of 4.44 pounds per person per day. However, Utah’s per-capita waste generation is much higher if all waste types are included. For example, using reported disposal volumes by Salt Lake County waste management entities in 2015 (including MSW and C&D waste), Promontory calculated a per-capita generation rate of 6.82 pounds per person per day.12 Similarly, taking Utah County’s total land-disposal tonnages and its population in 2015, this equates to a generation rate of 6.98 pounds per person per day.13 This per-capita rate is similar to that recently published in California, which has a much higher diversion recycling rate, and which calculated a land disposal rate of 6.0 pounds per person per day in 2016.14 Table 3 below provides the total waste quantities based on population forecasts and a waste generation assumption of 6.0 pounds per person per day. Using this rate, Promontory calculates a total seven-county waste generation of over 5 million tons annually by 2065. 12 2015 population of 1,094,650 and 1,363,135 tons municipal and C&D waste in Salt Lake County. Refer to Appendix C. 13 2015 population of 585,694 and 746,092 tons of municipal and C&D waste in Utah County. Refer to Appendix C. 14 State of Disposal and Recycling in California 2017 Update, CalRecycle, August 2017 12 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS Table 3. Estimated Annual Municipal Solid Waste Generation at 6.0 Pounds per Person per Day In tons per year County 2015 2050 2060 2065 1,198,642 1,676,754 1,804,867 1,854,397 Utah 641,335 1,420,779 1,647,354 1,774,169 Davis 368,020 540,123 577,662 596,729 Weber 265,797 390,709 415,388 426,321 Cache 133,431 223,505 244,354 257,045 Box Elder 58,003 84,832 91,157 94,409 Morgan 12,133 24,066 25,823 26,351 2,677,360 4,360,767 4,806,604 5,029,420 Salt Lake Total Some of this waste is C&D waste, which is about 30% of Utah and Salt Lake Counties’ total waste. While not specifically analyzed in this report addendum, future C&D waste will also need land disposal. The capacity of existing C&D landfills and future landfill capacity needed was not quantified by Promontory. However, these volumes are not insignificant, and Promontory expects them to be substantial based on the expected growth shown in Table 5 below. C&D waste disposal will require new land areas, and such development would displace other land uses. Promontory Point Landfill’s size would provide C&D waste disposal with less land-use conflicts. 3.2.2 Industrial Waste Industrial solid waste is “any solid waste generated at a manufacturing or other industrial facility that is not a hazardous waste or that is a hazardous waste from a conditionally exempt small quantity generator of hazardous waste.” Industrial solid waste includes waste from electric power generation; fertilizer or agricultural chemical industries; food and related products or byproducts industries; inorganic chemical industries; iron and steel manufacturing; leather and leather product industries; nonferrous metals manufacturing or foundry industries; organic chemical industries; plastics and resins manufacturing; the pulp and paper industry; rubber and miscellaneous plastic product industries; stone, glass, clay, and concrete product industries; textile manufacturing; transportation equipment manufacturing; and water treatment industries. Industrial solid waste does not include mining waste, oil and gas waste, or other waste excluded by Subsection 19-6-102(18)(b) of Solid and Hazardous Waste Act. In 2015, DWMRC reported the disposal of more than 1.2 million tons15 of industrial waste in Utah’s landfills and incinerators. Most of this waste was landfilled in large Class V landfills or Class III landfills, meaning that the waste was managed on the same site as the industrial facility (examples are Western Metals, Nucor, ATK Launch Systems, Intermountain Power, and PacifiCorp). Excluding the Intermountain Power Agency’s 15 2015 waste volumes from a DWMRC tracking spreadsheet provided by Alan Moore in 2016 December 20, 2017 13 Needs Assessment Report Addendum Promontory Point Landfill large Class lllb ash landfill (522,000 tons in 2015), about 704,000 tons of industrial waste were disposed in Utah in 2015. Because the Class V landfills do not report the source of this waste, it is unclear exactly how much of this industrial waste is generated in Utah and how much is imported from other states. To estimate future trends in industrial waste generation, Promontory evaluated future employment forecasts. In Utah as a whole, employment is expected to increase from 1,863,692 jobs in 2015 to 3,658,710 jobs by 2065, nearly double the 2015 level. Table 4 summarizes the projected employment values for northern Utah counties, which are about 84% of all jobs in Utah. Table 4. Projected Employment by County 2015 2055 2065 County Percent Change 2015 to 2065 Salt Lake 844,316 1,385,240 1,454,567 72% Utah 311,650 753,266 887,896 185% Davis 172,614 302,616 328,512 90% Weber 131,651 197,804 201,696 53% Cache 73,119 124,227 134,247 84% Box Elder 26,715 42,470 45,989 72% 4,456 8,141 9,079 104% 1,564,521 2,813,764 3,061,986 96% Morgan Total Not all industries will generate significant amounts of waste. In fact, the majority of waste from commercial businesses is included in the values presented in Section 3.2.1 (Utah Municipal and Commercial Waste). However, a number of the new or expanding businesses will generate industrial waste. Refer to Section 2.4.1 (Box Elder County Support) for the unique liability and indemnification considerations for this waste type. In addition to population forecasts, the Kern C. Gardner Policy Institute projected employment by industry types to 2065.16 Table 5 presents the expected growth for various industries and their rank with respect to the total percentage change between 2015 and 2065. In order to provide a view to the future and for ease of reference, Table 5 does not include all industries. Table 5 does include some of the larger industries, the top-ranked industries in terms of growth, those that will contribute significant amounts of waste (bold text), and the industry (administrative and waste services) that is needed to manage this future waste. Refer to footnote 8 on page 8. 14 I December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS Table 5. Employment by Industry and Growth 2015 2065 Percent Change 2015-2065 139,236 394,184 365.5% 1 Professional and technical services 88,018 204,007 231.8% 2 Administrative and waste services 85,999 248,263 188.7% 3 Health 140,163 289,890 106.8% 6 State and local government 198,676 358,892 80.6% 9 Retail 157,969 220,018 39.3% 14 Accommodation and food 112,549 154,388 37.2% 15 Manufacturing 123,742 156,397 26.4% 16 Industry Construction Rank As you can see from Table 5, construction (+365.5%) and administrative and waste services (+188.7%) are projected to be two of the top three growing industries. And although Utah’s economy is shifting to be more service-focused, the amount of waste from manufacturing and other industrial industries is expected to grow substantially in the future. Box Elder County is attractive to industrial and manufacturing businesses because of its inexpensive land values, the demographics of its work force, and its proximity to existing transportation infrastructure. Promontory Point Landfill provides the long-term industrial waste-disposal infrastructure that is an integral part of industry in Utah. Promontory Point Landfill will also help attract heavy industries to Box Elder County and other northern Utah communities, which is desired by local economic development officials. The investment in rail infrastructure, which would occur before the significant waste growth and new disposal demand, expands hauling options for communities facing endof-landfill-life issues and that are transitioning to hauling waste out of their district. Also see Section 4.1.1 (Waste Source) for a summary of the market or “wasteshed” that could use Promontory Point Landfill. 3.2.3 Special Waste (Nonhazardous Waste) Special waste is nonhazardous solid waste that requires special handling or is asbestos, ash, bulky waste (automobile bodies, furniture, appliances, waste tires), dead animals, waste containing PCBs, petroleum-contaminated soils, waste asphalt, or sludge. Box Elder County has changed its zoning to allow a regional Class V landfill land use. As described throughout this report addendum, Box Elder County needs additional sources of revenue, and it seeks the development of industrial and manufacturing businesses and the associated jobs they bring to sustain their communities in the long term. Box Elder County also wants to benefit from the economy of scale provided by a regional waste system. By taking nonhazardous special waste from outside Box Elder County, Promontory Point Landfill will be better able to keep disposal costs ($/ton) low due to December 20, 2017 15 Needs Assessment Report Addendum Promontory Point Landfill improved economies of scale, and disposal costs can be driven even lower as waste volumes to the landfill increase. 3.2.4 Regional Waste Market Promontory intends for Promontory Point Landfill to serve the expanding regional need for waste-disposal services. With a Class V designation, Promontory Point Landfill would become rail-served, and rail service would significantly expand the landfill’s potential wasteshed. Promontory Point Landfill is adjacent to Union Pacific Railroad’s (UP) main track. Most heavy-industrial manufacturing facilities are rail-served, so Promontory Point Landfill would provide a cost-effective alternative for transporting waste long distances. Figure 3 shows the reach of potential industrial and special-waste customers. Promontory has preliminary approval from UP to build a rail spur. Promontory Point Landfill offers a more economically favorable disposal option for materials that are nonhazardous but more heavily regulated in other western states. For example, California has imparted more-stringent disposal regulations on a number of non-RCRA (Resource Conservation and Recovery Act) wastes. Given that there are many industrial facilities in California, Promontory Point Landfill is strategically located to provide disposal solutions to these industries because of the proximity of UP’s main line. Both RCRA and non-RCRA wastes in California are subject to additional fees at the time of disposal. The fees vary according to material type. The approved disposal sites in California charge the fees according to material type and are responsible for passing the fees to the State Board of Equalization, which collects fees for the California Department of Toxic Substances Control. Wastes disposed out of state have no additional fees. The additional regulations, fees, and limited disposal capacity in California result in tipping fees that are $60 to $80 per ton. Add the system costs associated with over-theroad transportation, and rail service and out-of-state disposal becomes more economical in comparison for a large percentage of manufacturing facilities in California and elsewhere. 16 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS Figure 3. Union Pacific Railroad Lines #i dmefiton m (H, y *■ December 20, 2017 17 Needs Assessment Report Addendum Promontory Point Landfill Regional Industrial Waste According to the most recent USEPA Biennial Report,'7 large-quantity generators in the western United States generated more than 647,000 tons of RCRA hazardous waste. In the experience of Promontory’s leaders, these types of facilities produce 1 to 2 times the special and industrial waste volumes of their hazardous waste generation. This generation rate places the special and industrial waste volumes at about 1,200,000 tons per year from large process industries within the potential rail-served wasteshed. Regional Special Waste Low-level contaminated soil is another potential special waste source for Promontory Point Landfill. It is difficult to specify the exact volume (potential annual total tonnage) of contaminated soil that could be delivered to Promontory Point Landfill. The same market forces of transportation and disposal costs will determine the most economical disposal location for this waste. Promontory has confirmed interest from remediation contractors, which are confidential. However, the interest gave Promontory’s investors confidence in the landfill’s market opportunity and has allowed funding to be obtained for the next phase of development. As an illustration of the potential for receiving low-level contaminated soil, USEPA estimates that, on an acreage basis, 74% of Brownfield sites, 62% of Superfund sites, and 76% of RCRA Corrective Action sites are not ready for their anticipated use. This equates to 16.4 million acres or 72% of USEPA land clean-up programs that still need to be addressed.18 Promontory’s Needs Assessment Report reported the approximate tonnage of remediated soil from northern and southern California in 2014 and 2015. This quantification was not an exhaustive compilation of all volumes generated. Table 6 illustrates a portion of the market opportunity for Promontory Point Landfill as a railserved Class V facility. Table 6. Remediated Soil in Northern and Southern California (2014-2015) In tons 2014 2015 Annual Average Northern California 200,450 387,769 294,110 Southern California 623,014 175,950 399,482 Source of Waste Biennial Report, U.S. Environmental Protection Agency, 2016 18 https://www.epa.qov/cleanups/measurinq-proaress-epas-land-cleanup-proqrams 18 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill allos 4 Needs Assessment Section 3 (Demographics and Waste Generation Forecasts) presents the backdrop for the needs assessment information in this section and in Section 5 (Additional Determinations). Promontory’s original Class I Permit Application19 approved by the Utah Department of Environmental Quality for Promontory Point Landfill included the following description for “Purpose and Need”: The need for the landfill results from the expanding waste disposal requirements of the rapidly growing population in northern Utah. Many of the existing landfills along the Wasatch Front are nearing closure or are under scrutiny due to encroachment of expanding urban areas. The proposed landfill would provide an alternative disposal option for the municipalities and counties of Utah, while offering the advantages of low operational cost, long-term capacity, and relatively low transportation costs. As mentioned in Section 1.1 (Purpose of This Report Addendum), the information in this report addendum is required pursuant to Utah Code Title 19, Chapter 6, Part 1, Section 108, § 10 and § 11 of the Utah Solid and Hazardous Waste Act. Section 4 (Needs Assessment) of this report addendum is organized according to, and provides information to address, each of the three main code subsections quoted below. Utah Revised Statutes § 19-6-108 (10): The director may not approve a commercial nonhazardous solid or hazardous waste operation plan unless it contains the information required by the board, including: (a) evidence that the proposed commercial facility has a proven market of nonhazardous solid or hazardous waste (b) a description of the public benefits of the proposed facility (c) compliance history of an owner or operator of a proposed commercial nonhazardous solid or hazardous waste treatment, storage, or disposal facility, which may be applied by the director in a nonhazardous solid or hazardous waste operation plan decision, including any plan conditions. 4.1 Proven Market for Nonhazardous Waste This section provides information to the Director to evaluate Utah Code § 19-6-108 (10) (a), which requires evidence that the proposed commercial facility has a proven market of nonhazardous solid or hazardous waste. As described in Section 3.2 (Waste Market) and shown above in Table 2 and Table 3, there is no shortage of waste in northern Utah now (between 1,981,247 and 2,677,360 tons), and there will be even more in the future as waste grows exponentially to a projected annual tonnage of between 3,227,000 and 4,361,000 tons in 2050 and between 3,721,000 and 5,029,000 tons by 2065. Annual waste volumes are expected to grow by 63% by 2050 and 88% by 2065 in the seven northern Utah counties. 19 Refer to footnote 3 on page 5. December 20, 2017 19 Needs Assessment Report Addendum Promontory Point Landfill Utah’s communities demand low-price disposal. Therefore, market viability comes down to economics and the overall waste-disposal system costs for communities and businesses. System-wide costs include collection, transportation, and disposal costs (also known as “tipping fees”) as described below. Collections Waste-collection costs vary, and, because collections are provided to residents by municipalities directly or from private waste-collection companies, it is difficult to accurately quantify these costs without a thorough review of all city finances. Collection costs are a function of the number of collection vehicles needed to serve a community and the distance to a drop-off location, either a landfill or a transfer station. As some municipally owned landfills close, municipalities will incorporate transfer stations and begin hauling waste to more-remote regional landfills. This report addendum does not analyze future collection cost effects from regionalization, since the collection costs for these communities will not be significantly different as they change the collection drop-off point from landfills to transfer stations or as existing transfer station operators change their destination landfills. Transportation As the trend of waste disposal consolidation continues, the transportation cost to haul waste to more-remote regional facilities becomes an important factor for wastemanagement districts. Transportation costs with a truck trailer are a function of distance, travel times, transfer truck payload, and the amount of time spent at the transfer station and landfill, which all defjne cycle times and the number of transfer trucks and trailers required to move the waste. Section 4.1.2 (Market Analysis) discusses factors affecting transportation costs and why Promontory Point Landfill is a cost-effective option for northern Utah communities. Tipping Fees Disposal fees, or tipping fees, vary in Utah and in the region. Tipping fees are a function of operations, capital and operating costs, and, for commercial companies, a return on investment. The tipping fee, expressed as cost per ton ($/ton) of waste, is affected by the tonnage received at a particular landfill. Because fixed costs do not change and operating costs do not correlate with tonnage on a one-to-one basis, tipping fees can decrease as tonnage increases and landfills become more efficient. Because siting and building a new landfill is very expensive and might not be politically possible,20 this economy of scale is vitally important as smaller municipal landfills close and as their operations require the use of transfer hauling to larger regional landfills. Promontory Point Landfill can guarantee airspace and will offer tipping fees that are competitive and give communities long-term cost certainty for disposing of their waste. 20 Information Sheet - Bayview Landfill Project, FAQ #4, Northern Utah Environmental Resource Agency (NUERA), no date. Refer to Appendix D. 20 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill /A ALLOS 4.1.1 Waste Source As described in Section 2.4.1 (Box Elder County UT Rev. Stat. § 19-6-108 (10) (a) (i) Support), Box Elder County desires to have a Information on the source, quantity, regional facility to increase its waste volumes and and price charged for treating, storing, benefit from economies of scale to lower disposal and disposing of potential prices and also to attract businesses to the area. nonhazardous solid or hazardous As described in Section 2.4.2 (Economic waste in the state and regionally ... Benefits), Box Elder County and the State will both benefit economically and fiscally due to the direct and indirect economic activity generated by Promontory Point Landfill’s operation. In order to maximize these benefits, Box Elder County supports a Class V designation for Promontory Point Landfill. As described in Section 3.2 (Waste Market), the source of waste for Promontory Point Landfill will consist of municipally and commercially generated waste from northern Utah, C&D and industrial nonhazardous waste generated within Utah, and other regional nonhazardous waste: Northern Utah Salt Lake County is served primarily by two Class I landfills, Trans-Jordan Landfill and the Salt Lake Valley Solid Waste Management Facility (SLVSWMF), and by two Class V landfills (Intermountain Regional Landfill and Wasatch Regional Landfill, located in Utah County and Tooele County, respectively). Waste from southern Utah County is committed to the Bayview Landfill, and waste in northern Utah County is shipped to Bayview, Wasatch Regional, and Intermountain Regional. The percentage of total waste that is generated in Salt Lake and Utah Counties and that is going to various Class I and Class V landfills is not known because the landfills do not report the waste source in their annual reports. SLVSWMF recently processed a permit modification for a vertical expansion that will provide disposal capacity for over 66 years. Trans-Jordan is closer to other Class I (Bayview) and Class V (Intermountain Regional and Wasatch Regional) landfills, so Promontory did not include Salt Lake County waste as a source in its economic feasibility analysis. Similarly, Cache County is in the process of switching to Logan City North Landfill, which has 81 years of capacity, as reported by SC&A. Therefore, Promontory also does not assume that Cache County would use Promontory Point Landfill. Note, however, that Promontory Point Landfill is a completely feasible option for all of the communities in Salt Lake, Utah, and Cache Counties. Promontory Point Landfill’s primary, locally generated wasteshed is waste from Davis County cities and communities to the north. Some of this waste is managed by Wasatch Integrated Waste Management District and by Weber County, which have operating interest in Bayview Landfill. Promontory estimates that Bayview Landfill will fill faster than SC&A reported, and the communities served by Bayview Landfill will eventually need another long-term disposal option. Refer to Section 4.1.3 (Review of Other Waste Facilities) for estimates of Bayview Landfill’s capacity given its anticipated future waste volumes. December 20, 2017 21 Needs Assessment Report Addendum Promontory Point Landfill As shown in Section 4.1.2 (Market Analysis), based on transportation costs, Promontory Point Landfill is a cost-effective solution for waste from Davis, Weber, Morgan, and Box Elder Counties. Table 7 presents the estimated waste volumes (annual tons) from these counties now and in future years. As shown in Table 7, annual waste generation from these counties is forecasted to increase by almost 50% by 2050 and by almost 63% by 2065. Table 7. Annual Municipal Solid Waste Generation in Northern Utah3 In tons per year0 County 2015 2050 2060 2065 Davis 368,020 540,123 577,662 596,729 Weber 265,797 390,709 415,388 426,321 Box Elder 58,003 84,832 91,157 94,409 Morgan 12,133 24,066 25,823 26,351 703,953 1,039,730 1,110,030 1,143,810 47.7% 57.7% 62.5% Total Percent increase _ a Values are repeated from Table 3 and exclude Cache County waste. b Estimated based on population forecasts and a waste-generation rate of 6.0 pounds per person per day to account for future C&D waste. When Promontory Point Landfill secures a portion of this municipal waste and/or regional industrial waste, there will be more-than-adequate tonnage to operate the landfill efficiently and to offer competitive tipping fees. All of these counties will benefit from lower disposal costs provided by Promontory Point Landfill. The investment in the rail infrastructure expands hauling options for communities that are transitioning to hauling waste to more-remote regional landfills. Being immediately adjacent to a UP main line means that Promontory Point Landfill potentially would have more-direct and -frequent rail service. Therefore, depending on the rail rates, total tonnage, and locations of consolidation points, it might be feasible to haul waste from northern Utah communities by rail to Promontory Point Landfill. As discussed in Section 3.2.2 (Industrial Waste), DWMRC reports a total industrial waste disposal of over 1,200,000 tons. Because landfills do not report the source of this waste, it is unclear exactly how much of this waste is generated in Utah and how much is imported from other states. Nevertheless, as population grows, industrial waste is expected to grow since employment will need to keep up and provide jobs for the growing population. Promontory Point Landfill will provide a long-term disposal option for existing and future industrial waste from the state. Regional Waste Promontory Point Landfill offers an economically favorable disposal option for materials that are nonhazardous but more heavily regulated in other states. Where heavy industries are located far from disposal sites but are adjacent to a rail line, rail hauling to Promontory Point Landfill offers a cost-competitive solution considering the overall system costs, as described in Section 4.1.2 (Market Analysis). 22 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill A, Promontory expects to capture a percentage of regional industrial and special waste. Assuming that only 15% to 20% of regional nonhazardous industrial waste (1,200,000 tons) and remediated soil from northern California (294,110 tons) and southern California (399,482 tons) is disposed at Promontory Point Landfill, Promontory reasonably expects to secure about 284,000 to 379,000 tons annually. This would be in addition to any municipal waste volumes listed in Table 7 above. Price Charged The prices charged vary and depend on many factors including waste type, the total tonnage from a specific customer, and the delivery method. Tipping fees from other state and regional, private, commercial/industrial landfills are unavailable because that pricing information is proprietary. CalRecycle, in its 2015 report Landfill Tipping Fees in California, acknowledges the proprietary nature of tipping fees. In its research, SC&A estimated that disposal fees in California are about $60/ton (refer to Appendix E). In Promontory’s experience, California’s tipping fees are commonly $65/ton or higher. The Northern Utah Environmental Resource Agency (NUERA)21 reports that “nationally, landfill tipping fees average around $45/ton and are commonly around $80/ton” and that “tipping fees in the Denver area appear to be about 25% higher than tipping fees along the Wasatch Front.” The fees charged to Promontory’s customers are also proprietary. Promontory Point Landfill’s operating costs would be similar to those of other Utah area landfills (with tipping fees less than $30/ton) because amortized capital and mobile equipment costs, equipment operating costs, and labor costs would be similar for a similar level of operation. 4.1.2 Market Analysis Utah’s communities demand low system-wide costs. System-wide costs are the ”all-in” costs of UT Rev-stat- § 19-6-108 (10) (a) (ii) collection, transportation, and landfill disposal Market analysis of the need fora commercial facility given existing and costs (disposal costs are also called “tipping potential generation of nonhazardous fees”) as described in Section 4.1 (Proven Market solid or hazardous waste in the state for Nonhazardous Waste). For the purpose of the and regionally ... Class V Permit Application, need is defined by . . ...... , market viability and an analysis that shows how Promontory Point Landfill is a cost-effective, long-term option for northern Utah communities. Market viability comes down to economics and the overall waste-disposal system costs for communities and businesses. The following sections describe one important aspect of the system-wide costs: transportation costs. Trucking Costs Trucking costs are a function of distance (miles) or travel time (hours), which define cycle times (loading, outbound travel, unload, and return travel), the number of transfer trucks required, and transfer truck payload (tons). Promontory used Utah’s maximum gross vehicle weight, 80,000 pounds (40 tons), as the maximum payload. To evaluate the Refer to footnote 20 on page 20. December 20, 2017 23 Needs Assessment Report Addendum Promontory Point Landfill range of hauling costs, Promontory determined the approximate midpoint between the southernmost landfill option, Bayview Landfill, and Promontory Point Landfill. These landfills are separated by about 200 miles along the main haul route, Interstate 15 (1-15). The 100-mile midpoint is near where U.S. Highway 89 and 1-15 converge in the LaytonKaysville area (Figure 4). Figure 4. Northbound and Southbound Haul Routes (100-mile Distance) 24 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS Promontory used a cost as a function of distance ($3.00 per mile22) and a cost as a function of time ($150 per hour23) equations to define a hauling cost range. The hauling cost calculation using the per-mile cost is the rate ($3.00 per mile) multiplied by the distance (200 miles round trip) divided by the payload (40 tons). The resulting transportation cost is about $15 per ton (refer to the equation below). Haul distances farther than this result in a slightly higher cost, and it would follow that shorter hauling distances are slightly less expensive. ^25x200 miles Halllin8C0St= m'e40tons------- =$15/t°" Trucking cost using the time relationship ($150 per hour) is more complicated because travel times are based on speeds, which can vary by the class of road and its speed limit, and actual travel speeds can vary considerably based on traffic conditions. The $15/ton hauling cost is equivalent to about a 4-hour cycle time for that 200-mile round trip assuming free-flowing traffic and an average trip speed of about 50 miles per hour (mph). Using the mileage rate function does not account for differences in expected travel and cycle times, which are important considerations because these factors affect the required number of haul vehicles needed to transfer waste. For example, with a 4-hour cycle time, a transfer truck could make two round trips in a standard 8-hour work day. If the cycle time increases to 6 hours, hauling the same amount of waste would require additional vehicles and drivers or, if two cycles are made, it would extend the workday to 12 hours and increase labor costs. Traffic congestion on 1-15 is expected to worsen over time as the Wasatch Front’s population grows. This congestion will lead to longer travel times and increased vehicle emissions. In order to determine future transportation costs, Promontory obtained estimated future travel times on 1-15 and then added calculated travel times based on speed limits for the less-congested segments of the two haul routes. Travel times for 1-15 in the southbound direction were obtained from the Central Corridor Study technical memoranda.24 Travel times on 1-15 in the northbound direction were obtained from the West Davis Corridor Travel Demand Model Report25 These two references have different timeframes. The West Davis Corridor report analyzed baseline conditions in 2011 and projected conditions in 2040. The Central Corridor Study technical memoranda used a baseline of 2014 and projected conditions in 2050. The travel times in the AM peak (6:00 to 9:00 AM) and PM peak (3:00 to 6:00 PM) periods were provided for each direction. The calculated travel times for the periods were averaged because travel times are a function of travel direction and time of day. For example, morning traffic on 1-15 in the southbound direction through Salt Lake County (a 32-minute modeled travel time) is much lighter than in the southbound direction in the Solid Waste Master Plan Update, Wasatch Integrated Waste Management District, 2017 23 “Rail Intermodal Rates Reflect Truck Trends,’’ DAT Solutions, https://www.dat.com/bloa/post/Rail-lntermodalRates-Reflect-Truck-Trends. December 22, 2015 24 Wasatch Front Central Corridor Study 2050, Wasatch Front Regional Council, http://wfccstudv.orq. May 2017 25 West Davis Corridor Project, Technical Report 7, 2040 Travel Demand Model Report, Utah Department of Transportation, 2016 December 20, 2017 25 Needs Assessment Report Addendum Promontory Point Landfill evening (a 61-minute modeled travel time). The resulting round-trip travel times are plotted in Figure 5. Figure 5. Round-Trip Travel Times from Midpoint to Promontory Point Landfill The round-trip travel time from the midpoint shown above in Figure 4 hauling south is calculated to be about 5.76 hours (including 30 minutes of loading and unloading time) in 2014. The round-trip travel time from the midpoint hauling north is calculated to be about 5.20 hours in 2014. Because 1-15 is expected to exceed its capacity in Salt Lake County by 2030 and because the travel time on 1-15 is longer going south, the travel time difference is anticipated to increase dramatically in future years, as shown above in Figure 5. The round-trip travel time in 2050 is calculated to be about 5.40 hours going north, a 12-minute increase over 2014. The round-trip travel time going south in 2050 through congestion on 1-15 in Salt Lake County (6.30 hours) is calculated to be about 32 minutes longer than in 2014 in congested but flowing traffic conditions. Hauling Costs in 2017. Assuming that the waste from Weber County (186,000 tons) and Wasatch Integrated Waste Management District (125,000 tons will be transferred) in 2017 would originate at the assumed midpoint, and using a $150-per-hour rate for a 40ton payload, the hauling cost would be about $19.92 per ton to Promontory Point Landfill and $21.47 per ton to Bayview Landfill. Note that these two districts’ transfer stations are both located north of the midpoint, so costs could be slightly less than estimated, and future hauling cost could vary depending on actual fuel, labor, and equipment costs. Hauling Costs in 2050. The difference between cycle times hauling south (6.3 hours) compared to hauling north (5.4 hours) in 2050 is calculated to be 54 minutes in congested-but-moving conditions on 1-15. Inflating the waste volumes by 2% per year to 2050 (597,000 tons) and using the calculated round-trip haul time in 2050 results in a hauling cost of $20.25 per ton to Promontory Point Landfill versus $23.47 per ton to Bayview Landfill, a 16% increase. Promontory Point Landfill could save these districts almost $2 million annually in hauling costs. 26 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS Table 8 summarizes hauling cost differences based on travel times. Refer to Appendix C for more information. Table 8. Travel Time and Cost Differences from Midpoint to Promontory Point Landfill and Bayview Landfill Travel Time Cost 2017 2050 2017 2050 Midpoint to Promontory Point Landfill on northbound 1-15 (round trip) 5.20 hours 5.40 hours $ 19.92/ton $20.25/ton Midpoint to Bayview Landfill on southbound 1-15 (round trip) 5.76 hours 6.30 hours $21.47/ton $23.47/ton Difference (southbound compared to northbound) 34 minutes (+11%) 54 minutes (+17%) $1.55/ton (+8%) $3.22/ton (+16%) Direction and Destination Total annual savings3 $1,927,950 3 Assumes a combined 597,000 tons of waste from Weber and Davis Counties in 2050. As mentioned in Section 4.1 (Proven Market for Nonhazardous Waste), waste tends to flow to most cost-effective option. Trucking costs are an important factor, and, considering the projected congested conditions along 1-15, Promontory Point Landfill offers a competitive choice for northern Utah communities. The decreased travel times have air quality benefits. Vehicle emission rates vary based on travel speeds. At low speeds (less than about 30 mph), emissions from heavy truck are about 50% higher than at cruising speeds (40 to 60 mph).26 Trucks traveling in highly congested traffic conditions are expected to emit more pollutants given both their higher emission rates at lower speeds and their longer engine run times. Rail Hauling As with in-state customers, the value for an out-of-state customer to use Promontory Point Landfill also depends on transportation costs. The rail-haul cost will vary by location and market conditions. However, unlike truck hauling, which has a linear cost relationship (a cost-per-time or cost-per-distance relationship as described in the previous section), the rail-haul cost is not a function of the distance hauled but is priced on a “value-of-service” basis. This means that, because truck transportation is available everywhere, if the rail transportation costs are marginally less than the trucking costs, rail hauling is a viable option. In addition, because railroads are sharing their track capacity assets among many shippers, they create a tiered pricing structure that ranks shippers in priority from the “richest” shippers (product or commodity) down to the “poorest” shippers. Once the capacity is exhausted, or “constrained,” some shippers simply get priced out. Large quantities of nonhazardous industrial waste, environmental remediation refuse, and contaminated soils can generally pay the railroads well enough to overcome any capacity Heavy-Duty Diesel Vehicle Emissions Modeling in California’s EMFAC Model, California Air Resources Board, November 2016 December 20, 2017 27 Needs Assessment Report Addendum Promontory Point Landfill constraints and overcome pricing pressures out of California and many other western and central U.S. locations. Because Promontory Point Landfill can offer tipping fees that will make the overall disposal costs (including hauling and tipping) economical, customers could ship waste to Promontory Point Landfill via rail. For example, when rail-haul costs are less than about $60 per ton, which they often are, Promontory Point Landfill becomes a financially viable disposal option for waste from California (Table 9) because its tipping fees are in the mid $20 to mid $30 per ton range, similar to other large landfills in Utah. Table 9. Cost Comparison Disposal Location Tipping Fees (per ton) Transportation Costs (per ton) All-In Disposal Costs (per ton) Promontory Point $25-$35 $60 for rail to Promontory $85-$95 California landfills $60-$90 $30 for local truck haul3 $90-$120 a A $30/ton haul would be about 200 miles at $3.00 per mile. The rate per mile might be higher in California where truck payload limits are smaller. 4.1.3 Review of Other Waste Facilities DWMRC identifies 17 Class V landfills in the state.27 Some Class V landfills are in rural counties or are designated for special waste (C&D and asbestos) and therefore would not compete with Promontory Point Landfill. Two Class V designated facilities are Energy Solutions’ Clive facility and Clean Harbors Grass Mountain, which are designated for radioactive and hazardous waste, respectively. These two facilities would also not compete for the nonhazardous waste disposal offered by Promontory UT Rev. Stat. § 19-6-108 (10) (a) (iii) Review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste ... Point Landfill. The four Class V landfills in northern Utah that could compete for nonhazardous waste were identified in the SC&A Evaluation Report as ECDC Environmental, Payson City Corporation, Intermountain Regional, and Wasatch Regional. The Bayview Class I landfill is another competitor. If it obtains contracts with local governmental entities so that it can maintain its Class I landfill designation, it can receive waste from outside its historic wasteshed (the South Utah Valley Solid Waste District [SUVSWD]). These Class V and Class I landfills are shown in Figure 6 and discussed in more detail below. https://deq.utah.qov/ProqramsServices/proqrams/waste/solidwaste/disposalfacilities.htm 28 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS Figure 6. Existing Landfill Locations December 20, 2017 29 Needs Assessment Report Addendum Promontory Point Landfill ECDC Environmental Landfill, Class V ECDC is located in East Carbon City, Carbon County, Utah. It is a Class V landfill owned and operated by Republic Waste Services, Inc., the second-largest waste-services company in the nation. The landfill sits on about 2,400 acres28 and has reported a remaining waste capacity of over 1,000 years.29 ECDC reported 16,171 tons and 15,349 tons of MSW and 284,002 tons and 324,255 tons of industrial waste in 2014 and 2015, respectively. Republic did not report the in-state industrial tonnage; Promontory believes that the majority of the industrial waste to ECDC originates outside of Utah. Historically, two Wasatch Front communities rail-hauled their waste to ECDC. However, rail hauling became unreliable because of rail service logistics to this site. Promontory believes that the short line from UP to ECDC, which was operated by ECDC with its owned or contracted engines, was costly to operate and had a slow turn-around time for returning rail cars to customers. Because of the hauling distance (324 miles round trip from a Wasatch Front midpoint in Kaysville along Interstate 16 and U.S. Highway 6), even in the best free-flowing traffic and good weather conditions, it is uneconomical ($24 to $30 per ton30) to transfer waste over the road to ECDC from northern Utah communities unless a extremely low tipping fee can compensate for the collection, transfer, and hauling costs associated with using ECDC. ECDC’s tipping fees are not known. It appears that, rather than reduce its tipping fee at ECDC, Republic opened the Wasatch Regional Landfill in Tooele County to compete for some northern Utah municipal waste. Payson City Corporation Landfill, Class V Payson City Corporation Landfill is a small, 30-acre, Class V landfill in Utah County about 2.5 miles west of Payson. As reported in 2004, the capacity of Payson Landfill was 770,560 tons (or 75 years).31 Using these values, the estimated annual tonnage is 10,274 tons. Payson Landfill reported a tonnage of 18,350 tons in 2013, representing a 6.7% annual growth rate from 2004 to 2013. Assuming a 2% annual waste growth rate starting in 2013 and assuming the same capacity (770,560 tons), Payson Landfill has about 22 years of landfill capacity. Based on its small landfill volume, Payson City Corporation is likely not actively seeking additional waste streams for the landfill because receiving a significant increase in waste would quickly deplete the landfill’s capacity. For example, increasing the current waste tonnage at Payson Landfill in 2018 by 2.5 times would be about an additional 50,000 tons, which is equivalent to about one-third of Bayview Landfill, one-sixth of Trans-Jordan Landfill, or about one-fourth of Weber County’s waste. Such an increase in the current waste tonnage at Payson Landfill would consume the landfill space by 2025, or 7 years. Therefore, Payson Landfill appears to not be a viable long-term disposal option. https://dea.utah.qov/businesses/E/ECDCEnvironmental/docs/2008/11 Nov/ECDC Permit Application.pdf 29 Refer to footnote 2 on page 2. 30 Calculated assuming a 40-ton truck at $3 per mile or an 8-hour, 320-mile round-trip at $150 per hour. 31 https://dea.utah.qov/businesses/P/PavsonCitv/PavsonClassVLandfill.htm 30 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS Intermountain Regional Landfill, Class V Intermountain Regional Landfill (IRL), another Class V landfill, is located south of Fairfield in Utah County. It is owned and operated by ROC Fund Landfill Holdings, LLC. IRL was opened in 2012. It sits on half a section (320 acres) and has a capacity of about 17,340,000 tons.32 At this capacity and current waste tonnage, IRL has capacity for over 50 years. The tipping fee at IRL is not known. It is served mainly by private haulers that use a transfer station/recycling center in Salt Lake County. The reported tonnage received at IRL in 2015 was 139,140 tons. IRL’s Class V Permit Application33 identifies the area of northern Utah County and southern Salt Lake County as its potential wasteshed. In 2018, the North Pointe Solid Waste Special Service District’s contract with Republic Waste Services, Inc., expires.34 If IRL is successful in securing all of northern Utah County’s waste, it could add up to 247,000 tons in 2018.35 Similarly, if Trans-Jordan Landfill closes in 5 to 7 years because of development pressures, IRL could also dispose of waste from southern Salt Lake County. Assuming an additional year-2020 waste volume from southern Salt Lake County communities of 343,369 tons,36 the total tonnage to IRL could be as high as 755,690 tons in 2020. At this tonnage, IRL would reach capacity in 2036, only 18 years from 2017 (refer to Appendix C). If the North Pointe Solid Waste Special Service District and Trans-Jordan Cities were to first use Bayview Landfill (refer to the section below titled NUERA Bayview Landfill, Class I) and then switch to use IRL’s airspace, the total landfill capacity in Utah County would be consumed by 2053, or 36 years from 2017 (refer to Appendix C). Wasatch Regional Landfill, Class V Wasatch Regional Landfill is located about 6 miles north of Interstate 80 in Tooele County. The landfill is about 1,969 acres. In 2015, Wasatch Regional reported that 517,110 tons of MSWand 57,013 tons of C&D waste were disposed of at the landfill. The total capacity is reportedly 305 years.37 Currently, waste for Wasatch Regional comes from transfer stations in Lindon, Tooele County, Weber County, and Salt Lake City. The future annual waste volumes and resulting capacity (or landfill “life”) are not known. The North Pointe Solid Waste Special Service District’s contract with Wasatch Regional Landfill expires in 2018, and IRL and Bayview Landfill offer cost-effective solutions based on the anticipated hauling costs (IRL is 30 miles from the Lindon transfer station versus 99 miles from Lindon to Wasatch Regional Landfill) from North Pointe. Intermountain Regional Class V Landfill Permit Modification, DWMRC, March 2017 33 Application fora Permit to Operate a Class V Landfill, HDR, February 2011 34 NUERA Bayview Landfill Project Plan, Draft, https://www. Utah .aov/Dmn/files/240641. pdf, accessed September 26, 2017 35 Based on North Pointe's 2015 MSW and C&D waste inflated by 2% per year to 2018 36 Based on Trans-Jordan’s reported 2015 MSW and C&D waste inflated by 2% per year to 2020 37 Refer to footnote 2 on page 2. December 20, 2017 31 Needs Assessment Report Addendum Promontory Point Landfill Northern Utah Environmental Resource Agency (NUERA) Bayview Landfill, Class I NUERA’s Bayview Landfill is not a commercial Class V landfill. It is another disposal option for some municipally generated waste. If NUERA secures contracts solely with local governments for the waste generated within the governmental boundaries, Bayview Landfill can maintain its Class I (noncommercial) designation.38 However, this facility is mentioned because the capacity estimates provided to SC&A (85 years) might not have considered Bayview Landfill’s future waste volumes. NUERA is an interlocal cooperative entity established to “provide environmentally sound, cost-effective, solid waste management services for the communities of northern Utah while encouraging source reduction and recycling.”39 NUERA’s members are: . • • • • • South Utah Valley Solid Waste District (SUVSWD) North Pointe Solid Waste Special Service District (NPSWSSD) Trans-Jordan Cities Wasatch Integrated Waste Management District (WIWMD) Weber County Logan City NUERA recently purchased Bayview Landfill from SUVSWD because the landfill is currently underutilized (meaning it could process more waste given its current equipment and personnel). Like Box Elder County, NUERA realized the economies of scale that could be recognized by increasing the waste stream and helping to maintain lower landfill operating costs as a cost per ton. For example, Bayview Landfill’s operating cost, on a per-ton basis, was forecasted to decrease by about 13% by adding 34,800 tons, which is a throughput increase of 26%.40 This waste is coming from the North Pointe Solid Waste Special Service District in 2017 and is 20% of North Pointe’s total tonnage. This operating cost decrease can lower tipping fees and can affect the feasibility of adding transfer stations to a waste district’s system in that overall cost increases of system changes are minimized. Promontory Point Landfill offers the same economy-of-scale benefit to northern Utah communities. Bayview Landfill was quoted as having a capacity of 25,000,000 tons,41 or 85 years.42 However, the annual waste tonnage assumption used in the capacity calculation is not known. In order to estimate the remaining capacity, Promontory reviewed waste volumes from various NUERA members in 2015 and then projected when, without Promontory Point Landfill, these districts might need to use Bayview Landfill. As you can see in Table 10, Trans-Jordan Cities and Wasatch Integrated Waste Management District are nearing capacity in their landfills and are currently dealing with end-of-landfill-life issues. For example, as noted in Table 10, Wasatch Integrated Waste Management District is building a transfer station capable of processing 125,000 tons per op State of Utah Attorney General’s opinion on commercial landfills, August 8, 2002 oq Refer to footnote 20 on page 20. 40 Refer footnote 33 on page 31. 41 Remaining Landfill Cell 2 and Cell 3 capacity from Bayview’s 2011 permit application. 42 Evaluation of the Promontory Point Resources, LLC, Needs Assessment Report, Table 1: Capacity of Select Utah Landfills, SC&A, July 2017 32 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill A ALLOS year and will start transferring this tonnage43 despite the remaining capacity at Davis Landfill. Similarly, Trans-Jordan Landfill is situated in a prime development area for Salt Lake County, and for some time Trans-Jordan Cities has been dealing with pressure to close the landfill early because of encroaching developments. Whether Trans-Jordan Landfill can utilize its remaining capacity remains to be seen. Table 10. Municipal District Summary 2015 Waste (tons, approx.) District-Owned Landfill Capacity SUVSWD Springville Transfer Station 134,000 Not applicable3 Bayview North Pointe Lindon T ransfer Station 247,700 Not applicable0 Wasatch Regional and Bayview Trans-Jordan Cities 312,000 15 years T rans-Jordan 300,000 (125,000)° 23 years Davis County and Bayview Weber County 186,600 Not applicable0 Wasatch Regional Box Elder County 38,000 38 years Little Mountain Not applicable0 81 years Logan-Cache and LoganNorth Valley District/Facility Wasatch Integrated Waste Management District/Davis Landfill Logan City North Valley Landfill(s) Used a SUVSWD sold Bayview Landfill to NUERA. b North Pointe does not operate a landfill; it uses Wasatch Regional Landfill and is starting to use Bayview Landfill. c Wasatch Integrated is building a transfer station to process 125,000 tons and transfer it to Bayview Landfill in late 2018 or early 2019. d Weber County uses a transfer station to haul waste out of the county to Wasatch Regional Landfill. e Logan City recently sited a new landfill in northern Cache County to provide long-term waste disposal and is therefore not included in the capacity estimates presented in this section. The following two sections provide landfill life estimates for Bayview Landfill under two scenarios. These scenarios are based on recent developments in the waste market for NUERA members. Scenario 1 - Initial Bayview Scenario Scenario 1 represents an initial waste tonnage scenario in which SUVSWD, North Pointe Solid Waste Special Service District, and Trans Jordan Cities use Bayview Landfill. North Pointe can transfer 20% (34,800 tons) of its waste until 2018 and has started to do so. North Pointe’s contract with Wasatch Regional Landfill expires in 2018. Because of the more economical transfer haul, North Pointe could decide to move all of its projected 252,654 tons to Bayview Landfill in 2018. In this analysis, Promontory assumes that Trans-Jordan Cities would begin transferring waste to Bayview Landfill in 10 years. Assuming a 2% growth rate, this waste from Trans-Jordan Cities would be 403,605 tons in 2028. Adding SUVSWD’s waste and assuming a 2% growth rate, the capacity of Bayview Landfill is about 29 years. Refer to Appendix C for calculations. 43 RFP 2017-09 and Update to the 2013 Integrated Solid Waste Management Plan, GBB, June 2017 December 20, 2017 33 Needs Assessment Report Addendum Promontory Point Landfill Scenario 2 - Aggressive Waste Assumptions Scenario 2 is a more aggressive scenario in which all NUERA members (except Logan) move their waste to Bayview Landfill within 5 years. In addition to SUVSWD, North Pointe, and Trans-Jordan Cities (assumed to switch within 5 years), this scenario assumes that Wasatch Integrated Waste Management District provides 125,00 tons in 2018 (note that the calculation does not include the remaining 185,000 tons that will presumably remain at Davis Landfill), and Weber County transfers 186,000 tons in 2020. The total tonnage going to Bayview Landfill in 2022 is estimated to be 1,098,043 tons. Assuming 2% growth for this waste, Bayview Landfill would reach capacity in 21 years. Refer to Appendix C for calculations. Summary of Other Commercial Landfills Many municipal waste districts along the Wasatch Front with landfills are facing end-oflandfill-life issues. Given the anticipated population growth, waste volumes will increase dramatically in the future. NUERA attributes Utah’s low tipping fees to the existence of municipally owned landfills with publicly posted rates.44 The regionalization of the municipal waste will keep disposal fees low by taking advantage of economies of scale. However, under the assumptions listed above for the two NUERA Bayview Landfill scenarios, municipal owned landfills owned by NUERA members could have as little as 21 to 29 years of life. Other commercial landfills in northern Utah (Intermountain Regional and Wasatch Regional) are viable options for some of this municipal waste. Promontory Point Landfill offers another cost-competitive commercial landfill option for the northernmost Wasatch Front communities. Refer to Section 4.1.2 (Market Analysis) for trucking cost estimates that show the benefit of Promontory Point Landfill. NUERA states that, in the past, “when municipally owned landfills have been closed and replaced by only one or two privately owned landfills, tipping fees have soared.”22 Using Promontory Point Landfill would help ensure that IRL and Republic (Wasatch Regional) do not form a duopoly, which could drive disposal prices higher. Using Promontory Point Landfill would extend the life of municipal landfills and help maintain the municipal cost controls quoted by NUERA for a longer period. If IRL is used by North Pointe Solid Waste Special Service District and Trans-Jordan Cities after Bayview Landfill reaches capacity, in 2046 under Scenario 1, future waste volumes would be so large that IRL would provide only 7 additional years of disposal. Once IRL is full, the total permitted disposal capacity of landfills in Salt Lake County (except the Salt Lake Valley), Davis County, and Utah County would be used in a maximum of 36 years. For more information, refer to Section 4.2.1 (Need for Additional Capacity). If IRL fills up and Promontory Point Landfill is not available, there would be only one option: Wasatch Regional Landfill. Wasatch Regional Landfill then becomes a monopoly, which is not good for Utah, even if the landfill has adequate disposal capacity. If Promontory Point Landfill is also used for a portion of municipal waste in northern Utah, this could extend the life of municipal landfills and also provide another commercial option. Giving municipalities a broader choice by introducing additional competition in the commercial sector will help keep disposal rates lower for a longer period. Refer to footnote 20 on page 20. 34 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS In addition, from the perspective of a public waste-management entity, extending the life of some existing landfill operations provides citizens with several long-term benefits. These benefits include a convenient location for self-hauling waste, a location for processing organics, a convenient (closer to demand) compost sales location, more capacity for C&D waste disposal, and a location for disposing of recycling residuals that is closer to the recycling centers. In addition, final landfill closure later allows districts to delay the expense and accrue more funds for other waste infrastructure improvements (transfer stations) or for other waste-reduction and -diversion programs. Public Benefits The public benefits of Promontory Point Landfill are many. To address Utah Code Title 19, Chapters, Part 1, Section 108, § 10 (b), Promontory points out the following key benefits: • Promontory Point Landfill allows the continued regionalization and associated economies of scale for northern Utah communities. With a Class V permit, waste volumes at the landfill will increase, thereby decreasing operational costs ($/ton), and the communities will benefit from lower waste-disposal costs and long-term guaranteed airspace. • Promontory Point Landfill offers hauling cost-effectiveness now and in future years because 1-15 through Davis, Salt Lake, and Utah Counties will exceed capacity and traffic congestion will intensify. Because waste tends to flow to the most costeffective options, transportation costs are an important factor. Considering the projected congested conditions on 1-15, Promontory Point Landfill offers a competitive choice for northern Utah communities. Davis and Weber County could save about $2 million annually by 2050. • Decreased travel time has air quality benefits. Vehicle emission rates vary based on travel speeds. Trucks traveling in highly congested traffic conditions are expected to emit more pollutants given both their higher emission rates at lower speeds and their longer engine run times. • Promontory Point Landfill addresses the need for a long-term waste-disposal option for future municipal and industrial waste in Utah. Forecasts show annual waste volumes nearly doubling by 2065. As population grows and undeveloped land is developed, it will become more and more difficult to locate and permit new landfills. • The economic benefits to Box Elder County are also significant and align with Governor Gary Herbert’s rural jobs initiative, which aims to strengthen local rural economies, create jobs, and support local business. Table 11 shows how this increased economic activity produces new income, sales tax revenues, and property tax revenues, while the growing population creates the need for additional government expenditures. • The site will be powered by 100% renewable power. Back-up propane generators will be at the site for emergencies, but Promontory plans to power the site with a solar microgrid. December 20, 2017 35 Needs Assessment Report Addendum Promontory Point Landfill Table 11. Economic Benefits Summary Economic Benefits Category Initially In 15 Years Employment Box Elder County direct employment 19 jobs 208 jobs Box Elder County indirect and induced employment 109 jobs 115 jobs Total state indirect and induced employment 203 jobs 406 jobs Box Elder County population supported 25 people 38 people State total population supported 56 people 657 people $1,017,300 $2,527,600 $31,005,600 — $421,600 $1,048,100 $12,488,100 — Direct Box Elder County tax revenue $906,000 $2,200,000 Total state revenue $649,300 $3,660,400 Demographics* Net Revenues0 Box Elder County net revenues Box Elder 15-year net present value State net revenues0 State 15-year net present value Taxes a Includes working populations and their school- and college-age dependents. b Values are net of expenditures. The 15-year averages are reported in Section 2.4 (Development History) of this report addendum. 4.2.1 Need for Additional Capacity Municipal landfills might not last as long as UT Rev. Stat. § 19-6-108 (10) (b) (i) reported in the SC&A Evaluation Report or as estimated by NUERA and others. Landfill capacity The need in the state for the additional or landfill “life” is a function of annual waste capacity for the management of nonhazardous solid or hazardous tonnage and waste growth assumptions. The waste ... solid waste disposal picture is changing in northern Utah with Wasatch Integrated and North Pointe moving a portion of their waste stream to Bayview Landfill. Since system-wide costs are significant considerations in wastedisposal decisions, it might make sense for southern Salt Lake County and northern Utah County communities to use Bayview Landfill. However, as demonstrated in Section 4.1.2 (Market Analysis), Weber and Davis Counties would have a shorter haul time to Promontory Point Landfill and therefore it would be more economical to haul waste north to Promontory Point Landfill. If NUERA members move their waste to Bayview Landfill, the capacity of the landfill would be only 21 to 29 years under the two scenarios presented in Section 4.1.3 (Review of Other Waste Facilities). NUERA attributes low disposal rates to the existence of 36 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill A ALLpS municipal landfills. NUERA also claims that costs soar when there are only one or two private landfill options. Therefore, adding Promontory Point Landfill to the waste-disposal mix gives municipalities’ additional choices regarding whether to use up their landfill’s remaining capacity or prolong their landfill’s life by using the private sector for a portion of their waste. For those without landfill capacity, Promontory Point Landfill would provide additional private-sector competition (Table 12). Table 12. Landfill Capacity Summary Facility Class Maximum Capacity Municipal Facilities Bayview Landfill I 21 to 29 years3 Box Elder County Little Mountain Landfill I 38 years0 Trans-Jordan Landfill I 15 years0 Wasatch Integrated Davis County Landfill I 23 years0 Intermountain Regional Landfill (IRL) V 18 to 50 years0 Promontory Point Landfill V 100 to 125 years0 Wasatch Regional Landfill V 305 years0 Bountiful City Corporation Landfill I 33 years Uinta County Landfill I 10 years Summit County Landfill I 7 years Logan North Valley Landfill I 81 years Payson City Landfill V 75 years Commercial Facilities Others'3’0 3 Bayview Landfill scenarios are (1) North Pointe delivers waste in 2018 and Trans-Jordan Cities in 2028 and (2) scenario 1 but with Trans-Jordan Cities’ waste in 2022 and adding waste from Wasatch Integrated in 2019 and from Weber County in 2020. 0 From SC&A Evaluation Report. Annual waste and volume assumptions were not provided. c IRL scenarios are: (1) North Pointe and Trans-Jordan Cities deliver waste in 2018 and 2020, respectively and (2) IRL’s current waste stream inflated 2% per year. d Capacity of Promontory Point Landfill estimated by (1) assuming 200,000 tons initially and (2) increasing 2% per year and by assuming year 2050 annual waste. e Other facilities include small landfills or those that (like Logan’s and Payson’s) have committed waste streams and long-term disposal capacities and were, therefore, not included in the Promontory Point Landfill evaluation and its potential local wasteshed. Promontory Point Landfill is a viable option for all of these facilities. December 20, 2017 37 Needs Assessment Report Addendum Promontory Point Landfill The following items summarize the need for additional capacity for nonhazardous solid waste. 4.2.2 • Using Promontory Point Landfill would help ensure that Intermountain Regional and Republic (Wasatch Regional) do not form a duopoly, which could drive disposal prices higher. NUERA states that, in the past, “when municipally owned landfills have been closed and replaced by only one or two privately owned landfills, tipping fees have soared.” • Providing additional alternatives in the commercial/private sector will keep disposal prices low overall through competitive bidding. • Box Elder County wants to benefit from the economy of scale offered by a regional facility as do other communities in the state. • The economy of scale is vitally important as smaller municipal landfills close and as their operations change to use transfer hauling to larger regional landfills. Attempting to site and build a new landfill for a municipality will be expensive individually and might not be politically possible. • Waste management is an integral part of industry in Utah. The Gardner Policy Institute projects that a 188.7% increase in the administrative and waste services sector is needed to manage future waste generated by Utah’s fast-growing population. Promontory Point Landfill would be developed before the anticipated population growth and the need for additional disposal capacity. Promontory Point Landfill expands the waste-disposal choices for Utah communities and businesses. • Having a long-term and cost-effective waste-disposal infrastructure that can offer liability indemnification to help attract industry to Box Elder County. • Using Promontory Point Landfill would extend the life of municipal landfills and help maintain the municipal cost controls quoted by NUERA for a longer period. Using Promontory could also keep municipal landfills open for as long as possible and could provide a convenient option for self-haul customers and the continuation of other services (such as recycling, composting, and waste management education). Recoverable Energy and Resources Promontory is installing a solar microgrid and will use the renewable power to avoid the need to purchase electricity for day-to-day operations.45 UT Rev-stat § 19-6-108 (1°) (b) O') The energy and resources recover­ able by the proposed facility ... Promontory will install a landfill gas collection system when landfill gas emission rates exceed regulatory limits. The landfill gas can be used directly to generate electricity, or it can be cleaned, compressed, and used as fuel for mobile equipment. When adequate gas is generated, Promontory can clean and compress landfill gas and displace the use of diesel fuel and its dirtier emissions. 45 Back-up propane generators will be installed for emergency operations. 38 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS 4.2.3 Waste Reduction and Better Waste Management Methods Waste reduction is based on state or local waste management policies, not by disposal location. Promontory Point Landfill, however, does not exclude any options, and there will always be post-processing residuals that will require land disposal. UT Rev. Stat. § 19-6-108 (10) (b) (iii) The reduction of nonhazardous solid or hazardous waste management methods, which are less suitable for the environment, that would be made possible by the proposed facility ... For the communities that will use Promontory Point Landfill, incorporating a transfer station(s) creates a consolidation point and provides opportunities to segregate materials and to divert organics, recyclables, or other inert materials before the waste goes to the landfill. While no new or emerging waste technologies that make claims of reducing environmental impacts have yet proven to be commercially viable, Promontory’s management is well-versed in various recovery methods and conversion technologies. For now, landfilling is a cost-effective and environmentally sound option, but Promontory is committed to pursuing the highest and best use of materials. Promontory believes in appropriate resource utilization, recycling, and reuse to preserve our natural resources. Promontory is willing to partner with municipalities and facilitate discussions about the feasibility of diverting and recovering organics, recyclables, and other inert and reusable materials at the landfill. Given the size of the property, its remote location, and its proximity to rail, the Promontory site might be suitable for diverting materials and making them available for reuse. For example, if trains arrive from California or other western U.S. ports, returning trains could back-haul recyclables for distribution to the global market. Section 5.1 (Environmental Considerations) and Section 2.3.2 (Standards for Performance, Design, and Operations) of this report provide additional details on the environmental suitability of Promontory Point Landfill. In summary, the site meets all siting and all the location standards. Promontory will construct a solar microgrid to power the electrical equipment and lighting to make the landfill as self sufficient as possible. Promontory Point Landfill has been built with a composite liner and leachate collection and removal system, as well as a groundwater monitoring system to measure liner and leachate management performance. Although it is not a requirement, a fugitive dust control plan was included in the Class V Permit, and this plan is part of the operations to address ambient air quality standards at the property boundary. For many northern Utah communities, because of expected traffic conditions in south Davis, Salt Lake, and Utah Counties, customers could experience a decreased travel time to haul waste north to Promontory Point Landfill compared to other landfills. The decreased travel times have air quality benefits. Trucks traveling in highly congested traffic conditions are expected to emit more pollutants given both their higher emission rates at lower speeds and their longer engine run times. With Promontory’s infrastructure investment, some communities and some pending special remediation project managers (prison relocation and airport expansion) could decide to rail-haul waste to Promontory Point Landfill. Certain existing facilities in the greater Salt Lake area might be able to be equipped to load waste into rail cars. Rail hauling in-state waste would reduce truck traffic, reduce fuel consumption, and reduce December 20, 2017 39 Needs Assessment Report Addendum Promontory Point Landfill air pollutant emissions. On average, rail transportation is 4 times more efficient than trucking.46 With the majority of waste generated along the Wasatch Front communities, all of which are PM2 547 nonattainment areas, alternative transportation should be considered. From Promontory’s customers’ perspective, transporting waste by rail has potential benefits from the standpoints of sustainability and carbon impacts (greenhouse gases or GHG) reduction, which most large industrial businesses track for purposes of managing their carbon output and reporting to their stakeholders. As of November 2017, over 1,300 businesses have voluntarily adopted GFIG reduction targets in the 2015 Paris Agreement.48 In addition to electronic waste tracking, Promontory’s state-of-the-art industrial waste tracking technology platform will facilitate real-time reporting for these customers who are committed to track, report, and reduce their company-wide GFIG emissions. As mentioned in the Needs Assessment Report, most heavy process manufacturing and industrial service facilities are rail-served, so rail-hauling waste provides a cost-effective alternative for transporting waste long distances. Given that large concentrations of industrial facilities are located throughout the western United States, Promontory Point Landfill is strategically located to provide disposal solutions to these industries due to its proximity to UP’s main line. 4.2.4 Hazardous Waste Management Not applicable. Promontory Point Landfill will take only nonhazardous waste. UT Rev- stat- § 19-6-108 (1°) (b) (iv) Whether any other available site or method for the management of hazardous waste would be less detrimental to the public health or safety or to the quality of the environment... 46 Freight Railroads Help Reduce Greenhouse Gas Emissions, Association of American Railroads, April 2017, https://www.aar.orq/BackqroundPapers/Railroads%20and%20Greenhouse%20Gas%20Emissions.pdf 47 PM2 5 is particulate matter less than 2.5 microns in diameter. 40 “America’s Pledge Phase 1 Report: States Cities, and Businesses in the United States are Stepping Up on Climate Action,’’ https://www.americaspledqeonclimate.com. November 2017 40 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS 4.3 Compliance History of Owners and Operators Promontory’s leadership and operations support staff have well over 100 years of solid waste management experience. In their previous work experience, they have not received notice of any major violations. For minor infractions, all regulatory issues were addressed to the satisfaction of the appropriate agency. The following sections provide brief bios for Promontory’s leadership and operations management team. Resumes can be provided on request. UT Rev. Stat. § 19-6-108 (10) (c) The compliance history of an owner or operator of a proposed commercial nonhazardous solid or hazardous waste treatment, storage, or disposal facility, which may be applied by the director in a nonhazardous solid or hazardous waste operation plan decision, including any plan conditions ... Jon Angin, CEO Mr. Angin has more than 30 years of management and project experience in the solid waste and recycling industry. Mr. Angin has overseen the operations, maintenance, finance, and environmental compliance of solid waste management systems and facilities. This has included solid waste processing, transfer, and disposal assets such as hauling operations, transfer stations, intermodal facilities, recycling centers, buyback centers, material recovery facilities, landfills, vehicle and container maintenance operations, call centers and payment processing operations. Mr. Angin is the former Northwest Region Vice President for a large waste management company where he was responsible for all of the company’s operations and compliance in Oregon, Washington, Idaho, and Alaska, as well as two specialized landfills in California. He also held senior management positions with an engineering consulting firm and a waste conversion technology company. During his career in the waste industry, he has led numerous strategy development initiatives, integrated energy technology, and large capital infrastructure projects. Kevin Her, VP of Operations Kevin has more than 30 years of operational experience in the solid waste, hazardous waste, and environmental remediation industries across North America and Europe. In his various roles, Kevin has managed numerous high-volume waste-disposal facilities in Chicago, the San Francisco Bay Area, and Birmingham, England. He directed the operating transition of 16 landfill and 10 quarry businesses from a British company to an American company throughout England over a 3-year period. This experience and expertise has allowed Kevin the opportunity to work with many environmental regulators and community leaders, adjacent to major waste-disposal facilities, to develop positive outcomes for all stakeholders. Kevin has held positions of increasing responsibility for managing multimillion-dollar waste-disposal assets for publicly and privately owned entities creating excellent results. Most recently, he was responsible for managing one of the largest landfill gas-to-energy production facilities in California, which facility generated up to 12 megawatts of continuous electrical power. Throughout his career, Kevin has combined environmental stewardship with sound business acumen to produce strong financial performance. December 20, 2017 41 Needs Assessment Report Addendum Promontory Point Landfill Will Spears, VP of Finance Will Spears has 30 years of waste management and recycling industry experience, including 23 years in financial leadership roles and 7 years in operational leadership roles for an industry-leading company. He also has over 25 years of experience working with, and the assessing financial viability of, both existing and proposed waste-by-rail operations. He most recently completed 8 years as a financial leader for seven landfills and related transfer stations in the Pacific Northwest and Alaska. Prior to that, he spent 5 years managing a regional rail-served landfill in Oregon. Ranked in the top 10 largest landfill operations in the United States, this facility includes both solid and hazardous waste services, managing over 2.5 million tons of material each year. Rick Martin, VP of Sales and Marketing Rick is responsible for the development and leadership of all sales, marketing, customer service, and IT platform (website and operating systems) activities at Promontory Point Landfill. Rick has over 30 years of experience in the environmental and energy sectors. Beginning at Waste Management International, Hong Kong, Rick was personally responsible for the development of the waste identification (profile), tracking (manifesting), and customer communication process for the project. At EnviroChem, Rick was responsible for all site activities including operation of the fully permitted (hazardous waste) 10-day transfer and consolidation facility. Rick was challenged with turning around a poorly operated and unprofitable facility in Apex, North Carolina. Rick was responsible for all operations, maintenance, and sales activities for five operating branches located in Michigan and northwest Ohio. He was responsible for operational efficiency, regulatory compliance, safety compliance, billing operations, and sales leadership for a staff of more than 200 employees. During his tenure at each facility, all regulatory issues were addressed and remedied to the satisfaction of the appropriate agency. Ann Garner, Director of Technical Services Ann has over 26 years of experience in the environmental and waste industry, focusing on advising clients and employers regarding environmental permitting, compliance, and waste management needs. Her expertise comes from experience working for an industry leader in environmental services and several environmental engineering companies. Most recently Ann was responsible for the creation, development, and leadership of a National Technical Service Center, which provides client-focused technical and customer support for national industrial clients. Her expertise also encompasses managing large industrial site investigations and remediation projects, compliance and permitting for various industries, and development of waste analysis plans. She also has experience in business development and consulting for the geology section of a state department of environmental management. Ann has led both local and remote teams of geologists, scientists, and professionals who conducted investigations and advised clients based on the regulations and the client’s specific business needs. 42 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS Michael B Giancola, Business Advisor Michael has more than 32 years of high-level operational, administrative, and executive experience in the public sector including over 25 years in the solid waste industry. In his experience as an executive officer, he directed the administration and operation of an entire county organization. The organization had a $6.3-billion annual budget, consisted of over 18,000 employees, and had 24 departments. Michael reported to a five-member elected board who, with Michael’s input, set public policy and identified short- and long­ term strategic operational and financial goals. As a former director of public solid waste department, Michael was responsible for the oversight of three active landfills, which together managed 14,000 tons of daily trash. These landfills are partnered in the development of two landfill gas-to-energy projects. Additional Determinations Utah Revised Statute § 19-6-108 (11) points the director to evaluate the environmental effects of the project and how Promontory Point Landfill will serve industry of the state. The applicable citation is provided below. (11) The director may not approve a commercial nonhazardous solid or hazardous waste facility operation plan unless director determines that: (a) the probable beneficial environmental effect of the facility to the state outweighs the probable adverse environmental effect; and (b) there is a need for the facility to serve industry within the state. Environmental Considerations Modern landfilling is an environmentally sound UT Rev. Stat. § 19-6-108 (11) (a) waste management practice. Promontory is The probable beneficial environmental committed to protecting and enhancing the effect of the facility to the state environment. The due diligence for landfill siting outweighs the probable adverse and purchase and the environmental surveys environmental effects ... performed for the Class I Permit Application indicate that Promontory Point Landfill is in a location suitable for landfill development. The site meets all siting and all the location standards in R315-302-1 for Class I and Class V landfills. Promontory does not envision any materially different environmental effects with the Class V permit. In addition, Promontory has an approved Plan of Operations which defines the ongoing monitoring and the procedures used to observe the performance of the landfill’s environmental protection measures. In addition to R315 standards, and as part of the conditional-use permit with Box Elder County, Promontory has committed to improve the roadway over time and control dust on the access road and inside the site. December 20, 2017 43 Needs Assessment Report Addendum Promontory Point Landfill The following sections briefly summarize the location, engineering, and operating standards designed to protect human health and the environment. Also refer to Part II (Application Checklist) of Promontory’s March 2017 Class V Permit Application for direction regarding where to find details about environmental protection measures. 5.1.1 Location Standards A detailed description of compliance with location standards is provided in Section l.c of the Class V Landfill Permit Application (March 2017). The following list summarizes the major conclusions: • No cultural or historic resources will be impacted (refer to Appendix E of the Permit Application). • No residences, parks, monuments, recreation areas, or wilderness areas are within 1,000 feet of the site boundary (refer to Section 1 .c.3 of the Permit Application). • No ecologically or scientifically significant areas or threatened or endangered species habitats are present in the site area (refer to Appendix F of the Permit Application). • No sole-source aquifers or other public drinking water sources are near the site. • No floodplains, wetlands, or other waters of the United States are located at the site. • No prime or unique farmlands are found on the site. In addition to near-surface conditions, the landfill’s geologic and hydrogeological setting is appropriate for developing a landfill because there are no major geologic hazards (active faults or subsidence areas) and the principal aquifer is not used for domestic purposes. The landfill is located over 3,000 feet from the Great Salt Lake and is about 200 feet higher in elevation. The lowest part of the landfill liner will be 50 feet above groundwater levels. Promontory Point Landfill has and will continue to disturb the natural condition of the site. However, the Utah legislature has delegated responsibility for land-use planning and regulation to the state’s Counties49 and Cities. As mentioned in Section 2.4.1 (Box Elder County Support), the Box Elder County Commission approved Ordinance 422 modifying the zoning to allow Promontory Point Landfill as a Class V facility. Therefore, the County has determined that there are no zoning restrictions and believes that the land disturbances at the site are acceptable. The minor land-use impacts would be offset with the following integrated features, planned actions, and other potentially feasible and environmentally beneficial activities: • By using solar panels, Promontory Point Landfill will be powered by a 100% renewable source of energy. • Promontory will install a gas-collection system and, when landfill gas volumes are adequate, will collect, clean, and use the landfill gas as a transportation fuel. • The operating plan for Box Elder County’s conditional use permit includes a fugitivedust-control plan for minimizing dust on access roads and to help prevent dust from leaving the site. 49 Utah Code Title 17 (Counties), Chapter 27a (County Land Use, Development, and Management Act) 44 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ALLOS • Engineering controls include a composite liner, a leachate collection system, and groundwater monitoring wells to check the environmental performance of these features. • Promontory has cleaned up illegal dumps at the site and will removal topsoil that might contain lead contamination from lead bullets and shot. • Promontory Point Landfill’s large size will reduce the need for other future landfills and the potential land-use conflicts they might introduce. • Promontory is willing to partner with municipalities and facilitate discussions about the feasibility of diverting and recovering organics, recyclables, and other inert and reusable materials at the landfill. • Given the size of the property, its remote location, and its proximity to rail, the Promontory site might be suitable for diverting inert materials and making them available for reuse. • Compared to other existing landfills, the route for transporting waste from some communities to Promontory Point Landfill would be on less-congested freeways. The resulting decreased travel time will have benefits in terms of reduced emissions and improved air quality. If Utah communities determine that rail hauling is feasible, there would be additional emission reduction and air quality benefits from rail transportation. Promontory Point Landfill does not have any significant adverse environmental impacts and will not have any materially different impacts with a Class V permit. Promontory can potentially add natural resource enhancements (plant native vegetation or wetland enhancements for example) on its non-operational areas. During the public comment period for the Class V Permit Application, Promontory will work with interested resource agencies and DWMRC to offset any currently unforeseen direct environmental impacts in accordance with environmental laws and regulations. 5.1.2 Design Standards The March 2017 Class V Permit Application includes all of the engineering features that Promontory will construction to comply with the performance standards of R315-303-2 and other related solid waste rules. The environmental protection features include composite liners, leachate collection systems, groundwater monitoring, explosive gas monitoring, litter controls, and stormwater run-on or run-off controls, to name a few. 5.1.3 Plan of Operations The Plan of Operations for the Class V Permit Application includes, but is not limited to, waste handling procedures, plans for litter control, environmental monitoring, and corrective actions. The Plan of Operations for the Class V Permit Application is essentially the same as the Plan of Operations approved by DWMRC and integrated in the Class I Permit. In March 2017, Promontory Point Landfill’s mitigation agreement was reviewed and approved by Box Elder County. The mitigation agreement provided the County with details from the Plan of Operations regarding its contingency plans for fire, groundwater contamination, surface water runoff, landfill gas controls, fugitive dust, litter December 20, 2017 45 Needs Assessment Report Addendum Promontory Point Landfill control, procedures for rejecting hazardous waste, and other related landfill operating procedures. 5.2 Need to Serve Industry within the State Waste management is an integral part of industry in Utah. There is no shortage of waste in northern Utah now (between 1,981,247 and 2,677,360 tons), and there will be even more in the future as waste grows exponentially to a projected annual tonnage of between 3,227,000 and 4,361,000 tons per year in 2050 and between 3,721,000 and 5,029,000 tons per year by 2065. In the seven northern Utah counties, annual waste volumes are expected to grow by 63% by 2050 and 88% by 2065.50 A portion of this waste is generated by industry in Utah. The University of Utah’s Kern C. Gardner Policy Institute projected that the administrative and ut Rev. Stat. § 19-6-108 (11) (b) waste services sector will need to grow 188.7% in There /s a need for the facility t0 serve order to manage future waste generated by industry within the state. Utah’s fast-growing population. This represents the third-fastest-growing sector behind construction and professional and technical services. 5.2.1 Industry within Box Elder County For Box Elder County, Promontory Point Landfill is an economic driver and will support future economic development in accordance with Governor Gary Herbert’s rural jobs initiative. The Gardner Policy institute calculated that Promontory Point Landfill would support a 15-year average of 185 new jobs in Box Elder County. By 2031, a total of 323 direct, indirect, and induced jobs would be supported by Promontory Point Landfill’s operation. The economic and fiscal monetary benefits are substantial due to the direct, indirect, and induced effects of Promontory Point Landfill. For Box Elder County, the net revenues attributable to Promontory Point Landfill were modeled to be about $2.3 million annually, with a 15-year net present value of $31.0 million. Because of these substantial benefits, the Box Elder County Commission and the Utah Private Activity Bond Review Board approved the issue of private activity bonds to jump-start the development of Promontory Point Landfill and its supporting local industries. Box Elder County is attractive to new industrial and manufacturing businesses because of its inexpensive land values, the demographics of its work force, and its proximity to existing transportation infrastructure. Box Elder County also recognized the need to develop a long-term waste-disposal infrastructure in order to help attract new industry, including heavy industrial and manufacturing businesses, to the area. However, the capital investment for Box Elder County to build a modern landfill that could offer indemnification protection to new industries is prohibitive and politically challenging. Therefore, they are looking to Promontory to be their partner. 50 Annual waste generation range is defined by using 4.4 and 6.0 pounds per person per day. 46 December 20, 2017 Needs Assessment Report Addendum Promontory Point Landfill ▲ ALLOS 5.2.2 Industry within the State For other areas of northern Utah, large, municipally-owned landfills could have as little as 21 to 29 years of life. Using Promontory Point Landfill would help ensure that Intermountain Regional and Republic (Wasatch Regional) do not form a duopoly, which could drive disposal prices higher. As mentioned previously, NUERA states that “in the past, when municipally owned landfills have been closed and replaced by only one or two privately owned landfills, tipping fees have soared.” The ability to keep municipal landfill options available for a longer time and to have Promontory as an additional private landfill competition within the private sector will increase and keep future wastedisposal rates low, which is good for Utah industry. For Promontory Point Landfill’s most likely wasteshed (Weber and Davis Counties), waste trucking costs are projected to be 16% higher when hauling waste south on congested 1-15 compared to going northbound. This equates to an additional cost of about $2 million annually by 2050 (assuming 2050 waste volumes from Weber and Davis Counties). Other private industries in these northern Utah counties can expect a similar level of cost inefficiencies because of the greater levels of congestion on interstates through Salt Lake, south Davis, and Utah Counties. Construction is projected to be the fastest-growing industry in Utah, increasing 365.5% by 2065. C&D waste is currently about 30% of total landfilled waste. While not specifically analyzed in this Needs Assessment Report Addendum, future C&D waste will also need land disposal. The capacity of existing C&D landfills and the future landfill capacity needed was not specifically quantified by Promontory. However, these volumes are not insignificant now, and they are expected to grow substantially. C&D waste disposal will require new land disposal areas, which would displace other land uses. Promontory Point Landfill also provides C&D waste disposal but with less land-use conflicts. In addition, as forecasted by the Gardner Policy Institute, administrative and waste services need to grow by 188.7% by 2065 to keep up with the disposal demand. Therefore, Promontory Point Landfill is a critical and integral component of industry in Utah. The economic activity produced by Promontory’s new landfill will support a 15-year average of up to 375 total new jobs in the state. By 2031, up to 614 new jobs will be supported. This number is the sum of direct, indirect, and induced employment effects. In other words, Promontory will purchase goods from local industry, who will in turn purchase inputs from other local industries. The State will also benefit fiscally; new state net revenues will average $0.92 million each year, with a 15-year net present value of $12.5 million. To date, Promontory has hired a contractor who has delivered over $8,000,000 in work with its local employees. December 20, 2017 47 Needs Assessment Report Addendum Promontory Point Landfill 6 Conclusion Annual waste volumes will grow substantially as Utah’s population continues to expand. The need for a Class V designation for Promontory Point Landfill is based on the market and economic assessment, which shows strong benefits from a regional facility. Box Elder County wants to offer businesses lower disposal costs provided by the economies of scale offered by larger landfill operations, similar to other municipalities in other parts of the state. Box Elder County also sees an opportunity to attract industrial and manufacturing businesses by developing low-cost and long-term -disposal infrastructure for waste generated by these businesses. Promontory Point Landfill’s Class V designation is supported by Box Elder County, which sees substantial economic and fiscal benefits. Because of the lack of environmental effects and limited land-use conflicts, Box Elder County has changed its zoning to allow the use of the land for a Class V landfill. Promontory Point Landfill is a critical and integral component of industry in Utah, which needs to increase its administrative and waste services employment by 188.7% to keep up with waste-disposal demand. All local and legislative approvals are in place. With DWMRC’s approval of Promontory Point Landfill’s operating plan and Class V Landfill Permit Application, and Governor Gary Herbert’s approval, Box Elder County and the existing and future industries in the state can start to recognize the benefits of Promontory Point Landfill. 48 December 20, 2017 Appendix A Gardner Policy Institute, Economic and Fiscal Impacts of Promontory Point Landfill Kem C. Gardner Technical Memo h POLICY INSTITUTE THE UNIVERSITY OF UTAH I To: From: Date: Subject: Mitch Zundel, Director Box Elder County Economic Development John C. Downen, Senior Research Analyst Juliette Tennert, Director of Economic and Public Policy Research November 18,2016 Economic and fiscal impacts associated with Promontory Point Resources' new solid waste facility, 2017-2031 We are pleased to respond to your request for an analysis of the Promontory Point Resources new solid waste facility in Box Elder County. Table 1 summarizes the results. Our analysis is based on input data provided by Promontory Point Resources (PPR); the validity of the results is dependent upon the accuracy of these inputs. This analysis does not con­ sider the effects of any state or local incentives. Table 1: Promontory Point Resources Summary Local Impacts (Millions of constant 2016 dollars) Annual Average Impact Total Employment Direct1 185 158/101 Indirect & Induced Total Personal Income 84 $11.5 Net New Local Revenues $31.0 Net New State Revenues $12.5 NPV2 I.The higher number is the annual average of the jobs projected by PPR for 2017 through 2031. The lower number is the "exogenous" portion of these jobs, attributable to out-of-state revenues. 2 Net present value calculated at a 1.1% discount rate. Note: Results do not include the effects of state or local incentives. Source: Kem C. Gardner Policy Institute analysis of PPR data using the REMI PI+ model and Gardner Policy Institute fiscal model The remainder of this memo provides an overview of the methodology, the economic context relative to PPR, and fur­ ther detailed results. All dollar amounts are in inflation-adjusted 2016 dollars. Methodology and Model Economic impacts are generated when "new" or outside money is spent in a region. Because PPR expects to earn reve­ nues from both in-state and out-of-state sources, the Gardner Policy Institute adjusted the firm's employment, compen­ sation and expenditures by the out-of-state share of revenues. The Gardner Policy Institute then used the REMI PI+ model to estimate the economic and demographic impacts of PPR's new solid waste facility in Box Elder County. REMI is a dynamic model that incorporates input-output, economic geography, econometric and general equilibrium com­ ponents. In this analysis the jobs and compensation at PPR, plus capital, operations and maintenance expenditures, are INFORMED DECISIONS™ 1 gardner.utah.edu the direct effects. This increased economic activity spurs purchases from local suppliers, who may in turn purchase in­ puts from other local suppliers. These rounds of activity produce the indirect employment and income effects. Finally, the direct and indirect employees spend some of their new wages in the local economy, creating induced employment and income. This overall increase in economic activity attracts new workers to the state, some of whom will bring their school- and college-aged children with them. On the fiscal side, the increased economic activity produces new income, sales and property tax revenues, while the growing population creates additional government expenditures. The Gardner Policy Institute estimates fiscal impacts based on multi-year historical relationships between personal income, industry output and tax revenues on the one hand, and expenditures per capita for the relevant populations (school age, college age and total population) on the other. Context Promontory Point Resources is classified in NAICS industry 562, Waste Management and Remediation Services. As of the first quarter of 2016 the Utah Department of Workforce Services categorizes 268 establishments in this sector statewide. Of these, 243 are private companies, 24 are local government entities, and one is federal. The largest estab­ lishments are Ace Disposal, Allied Waste Services of Northern Utah, BFI, Clean Harbors Aragonite, EnergySolutions, EnviroCare, and Waste Management of Utah, each with 100 to 249 employees. There are three establishments in Box Elder County—one private, Hillside Recycling with 14 employees, and two county entities, the Box Elder County Landfill and Brigham Refuse Collection. Total employment in the sector averaged 3,141 statewide and 27 in Box Elder. The average establishment size for NAICS 562 in Utah was 11.7 employees. Covered employment in Utah's Waste Management and Remediation Services sector rose 49 percent from 2,771 jobs in 2001 to a peak of 4,137 in 2011 (see Figure 1).' Over this period there was only a modest decline from 2007 to 2008, at the onset of the recession. However, since 2011 sector employment has fallen by 24 percent to 3,141 in Q1 2016. NAICS 562 represents only 0.22 percent of Utah's total covered employment; this is about three-quarters of the industry's share of national employment (location quotient of 0.77). The number of waste management and remediation establishments in Utah rose from 182 in 2001 to 275 in 2014, then dipped to about 267 in 2015 and the first quarter of 2016. Figure 1: NAICS 562 Employment and Establishments in Utah, 2001-Q1 2016 4,300 •Employees Establishments 290 4,100 270 3.900 250 3.700 230 £ 3,500 210 -§l 3,300 190 I E ^ 3,100 170 2.900 150 2.700 130 2,500 110 e % LU fN(N(NCN(NrN(NrNCN(NrNC\lCslCsJ(NrM a Source: Bureau of Labor Statistics, Quarterly Census of Employment and Wages and Utah Department of Workforce Services INFORMED DECISIONS™ 2 gardner.utah.edu Analysis The Gardner Policy Institute analyzed the impacts of the construction and operation of a new solid waste facility in Box Elder County. The results are based on annual employment; compensation; capital, operations, and maintenance ex­ penditures; state income taxes; property taxes; and other local tax data provided by Promontory Point Resources. As such, the validity of the results depends on the accuracy of the inputs. The Gardner Policy Institute did not consider the potential intangible impacts to reputation or community perceptions of a large solid waste facility in the county. Direct Effects Table 2 presents the annual direct employment, compensation2 and expenditures provided by PPR for the 2017-2031 period. Employment is projected to grow slowly from 2017 through 2020, increasing from 36 to 50, but from 2021 through 2031 PPR expects to add 25 jobs annually. Total compensation, measured in constant 2016 dollars, grows from almost $2.3 million in 2017 to $29.9 million in 2031. In-state non-payroll expenditures average about $18.5 million an­ nually between 2017 and 2031, with initial expenditures of $25.0 million in 2017. Expenditures consist of construction of landfill cells (initial and ongoing), construction and maintenance of a rail spur and truck facilities, operations and maintenance for rail car and truck loading and unloading, and general operating expenditures. PPR projects state cor­ porate income tax payments to grow from $41,900 in 2017 to $808,800 in 2031. Total local taxes paid increase from $906,000 to $2.2 million over the same period. 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QJ S ^ ~ o (V Q- Q U H g i! < in H CD a) 1 ^ s g s ^3 s s S I11 ^ „ i5 H i B £ 0 S =j, ^ B f 5 q vj cd §s ■& g ^ « z reO uu Is 1 S 2 1C ~0J E § 2 s ^ t 3 — 01 - -a s ^ o: c > o- £ -S' 1? id 2 5 8 o CO 7 c s % 3 p c: a u cj o Q- I- U U I- 1! £- S 3 > 3 3 2 i Policy Ins titute analysis o f PPR data using the REMI PI+ model and Gardner Policy Institute fiscal model S vO C. Gardner *- vo co in vo -in in •vn -in -vn Source: Kem ^ m gardner.utah.edu Figure 3: New County Revenues and Expenditures Due to RPR Project, 2017-2031 $3.0 I New Revenues £ ^ «§ vO o P' / •?' .. Utah Historical •s> & ——US Historical ---US Projection ---Utah Projection Source: Census Bureau 2014-2060 National Projections; Kem C. Gardner Policy Institute 2015-2065 State and County Projections; Utah Department of Health. INFORMED DECISIONS™ 24 gardner.utah.edu Figure 11 Utah Historical and Projected Life Expectancy 1968-2065 90 —..— Female Historical ---Female Projection Male Historical ---Male Projection Sources: Kem C. Gardner Policy Institute 2015-2065 State and County Projections; Utah Department of Health. INFORMED DECISIONS™ 25 gardner.utah.edu Figure 12 Utah Historical and Projected Components of Change 1990-2065 80,000 70.000 60.000 50.000 40.000 30.000 20.000 10,000 0 10,000 - ^ Nc^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ^ ■■INet Migration ^—Natural Increase ^—Growth Sources: Kem C. Gardner Policy Institute 2015-2065 State and County Projections; Utah Population Estimates Commit­ tee Estimates (1990-2009); DemographyUTAH Population Committee 2010-2016 Population Estimates. INFORMED DECISIONS™ 26 gardner.utah.edu Figure 13 Select Age Groups as a Percent of the Total Utah Population 2015-2065 100% 1.26% 8.92% 90% 1.49% 2.26% 3.18% 3.31% 4.01% 12.00% 12.79% 13.69% 15.73% 16.25% 48.52% 47.33% 47.05% 2045 2055 2065 80% 70% 48.97% 60% 48.32% 49.35% 50% 40% 30% 20% 10% 0% 2015 2025 2035 ■ 0-4 ■ 5-17 ■ 18-24 25-64 65-84 85+ Source: Kem C. Gardner Policy Institute analysis of U.S. Census Bureau Decennial Census and Population Division data; Kem C. Gardner Policy Institute 2015-2065 State and County Projections. INFORMED DECISIONS™ 27 gardner.utah.edu Figure 14 U.S. Dependency Ratios 1970-2060 100 90 80 79.0 73.1 71.9 70 61.6 61.6 60 50 20.3 H 20.1 41.3 ■ 41.5 76.4 72.9 64.0 58.9 35.5 ■ 37.5 ■ 38.2 36.5 H 35.6 ■ 34.7 40 30 20 36.3 H ■ 34.8 10 0 1970 1980 1990 2000 2010 ■ Youth 2020 2030 2040 2050 2060 ■ Retirement Age Source: Kem C. Gardner Policy Institute analysis of U.S. Census Bureau Decennial Census and Population Division data. Note: Dependency Ratios are computed as the number of nonworking age persons per 100 working age (18-64 year old) persons in the population. Youth are less than 18 years old and retirement age is 65 years and older. INFORMED DECISIONS™ 28 gardner.utah.edu Figure 15 Utah Dependency Ratios 1970-2060 100 89.9 90 80 13.9 80.0 78.3 76.1 13.5 70 82.3 15.8 60 68.6 68.2 69.9 70.3 71.9 14.4 ■ 15.2 20.0 24.7 27.0 54.3 ■ 50 40 76.0 66.5 30 66.4 530 ■ ■ 45.6 ■ 44.9 ■ 44.4 ■ 43.3 20 10 0 1970 1980 1990 2000 2010 ■ Youth 2020 2030 2040 2050 2060 ■ Retirement Age Source: Kem C. Gardner Policy Institute analysis of U.S. Census Bureau Decennial Census and Population Division data; Kem C. Gardner Policy Institute 2015-2065 State and County Projections. INFORMED DECISIONS™ 29 gardner.utah.edu Figure 16 Historical and Projected Total Employment Growth Utah and U.S., 2010-2065 4.0% T3 .v- 1> Utah ------ U.S. Sources: Kem C. Gardner Policy Institute 2015-2065 State and County Projections; U.S. Bureau of Economic Analysis & U.S. Bureau of Labor Statistics historical employment data. INFORMED DECISIONS™ 30 gardner.utah.edu Kem C. Gardner POLICY INSTITUTE THE UNIVERSITY OF UTAH ADVISORY BOARD Conveners Kem C. Gardner Michael 0. Leavitt Christian Gardner Roger Tew Vicki Varela Mitt Romney Matthew S. Holland Ruth V. Watkins Clark Ivory Ted Wilson Ron Jibson Natalie Gochnour, Director Board Scott Anderson, Co-Chair Mike S. Leavitt Gail Miller, Co-Chair Ex Officio Vivian S. Lee Doug Anderson Senator Orrin Hatch Kimberly Gardner Martin Deborah Bayle Governor Gary Herbert Ann Millner Lane Beattie Speaker Greg Hughes Cristina Ortega Cynthia A. Berg Senate President Wayne Niederhauser Jason Perry Taylor Randall Roger Boyer Wilford Clyde Representative Brian King Senator Gene Davis Jill Remington Love Sophia M. DiCaro Mayor Ben McAdams Brad Rencher Lisa Eccles Mayor Jackie Biskupski Josh Romney Spencer P. Eccles Charles W. Sorenson Matt Eyring James Lee Sorenson KEM C. GARDNER POLICY UTE STAFF AND ADVISORS Leadership Team Staff Natalie Gochnour, Associate Dean and Director Samantha Ball, Research Associate Jennifer Robinson, Associate Director Mallory Bateman, Research Analyst James A. Wood, Ivory-Boyer Senior Fellow DJ Benway, Research Analyst Dianne Meppen, Director of Survey Research Cathy Chambless, Senior Research Associate Pamela S. Perlich, Director of Demographic Research Marin Christensen, Research Associate Juliette Tennert, Director of Economic and Public Policy John C. Downen, Senior Research Analyst Research Emily Harris, Demographic Analyst Michael T. Hogue, Senior Research Statistician Faculty Advisors Mike Hollingshaus, Demographer Adam Meirowitz, Faculty Advisor Colleen Larson, Administrative Manager Matt Burbank, Faculty Advisor David LeBaron, Research Associate Shelley Kruger, Accounting and Finance Manager Senior Advisors Jennifer Leaver, Research Analyst Jonathan Ball, Office of the Legislative Fiscal Analyst Sara McCormick, Senior Research Associate Gary Cornia, Marriott School of Business Levi Pace, Research Analyst Joshua Spolsdoff, Research Associate Dan Griffiths, Tanner LLC Roger Hendrix, Hendrix Consulting Nicholas Thiriot, Communications Specialist Joel Kotkin, Chapman University Natalie Young, Research Analyst Darin Mellott, CBRE Derek Miller, World Trade Center Utah Chris Redgrave, Zions Bank Bud Scurggs, Cynosure Group Wesley Smith, 24NINE INFORMED DECISIONS Kem C. Gardner Policy Institute AN 411 East South Temple Street, Salt Lake City, Utah 84111 INITIATIVE OF THE DAVID ECCLES flMin SCHOOL OF 801-585-5618 BUSINESS gardner.utah.edu Appendix Referenced Calculations Computed by: Terry Warner Date: 12/18/2017 Project: PPR Class V Support Task: 002 Checked by: Erich Jezowicz Date:12/18/2017 Job #: 10066970 Workbook: PPR Class V Calcs, per capita Page: lof 10 Per Capita Solid Waste Generation UT County MSW, tons C&D, tons 108,656 North Pointe CD Landfill 2,616 Santaquin CD Landfill Intermountain Payson City CD Landfill 139,141 South Utah Valley Solid Waste DistrictSpringville Transfer Station 134,067 North Pointe Solid Waste DistrictLindon Transfer Station 190,254 43,137 37,996 56,106 517,887 228,205 16,430 DCD-Orem Transfer Station Total storage Percent storage distribution Grand total 69.4% tons 30.6% 746,092 lb Served population 17,690 1,492,184,500 people 585,694 lbs waste per person per day 7.0 SL County MSW, tons Trans-Jordan MSW Landfill Salt Lake Valley SWMF MSW Landfill Salt Lake Valley SWMF-Transfer Station Allied Salt Lake Transfer Station 287,622.65 179,805.00 135,591.00 98,202.31 Management CD Landfill Total storage Percent storage distribution Served population lbs waste per person per day c:\pwworking\west01\d0455375\PPR Class V Calcs 24,298.13 344,863.00 View CD Landfill ranH LULdl UrdilU C&D, tons 292,752.72 947,882 69.5% 415,253 30.5% 1,363,135 tons lb people 2,726,269,620 1,094,650 6.8 Computed by: Terry Warner Date:12/18/2017 Checked by: Erich Jezowicz Date: 12/18/2017 Workbook: PPR Class V Calcs. Landfill Life Calcs Page: 2 of 10 Landfill Life Estimation IRL Volume/Capacity landfill capacity 28,900,000 CY capacity of waste 23,120,000 -20% for cover 17,340,000 tonnage (® 1500 ibs/CY growth 2.00% ref: https://documents.dea.ut3h.gov/waste-management-and-radiation-control/facilities/roc/DSHW-2017-002193.pdf 2015 Year IRL North Pointe Solid Waste District TJC Total 2015 2018 msw 139,140 C&D - 139,140 190,254 43,137 233,391 287,623 24,298 311,921 617,017 67,435 Total 2020 2020 Total 247,677 344,386 684,452 344,386 755,690 Scenario 1 - North Pointe in 2018 and Transjordan in 2020 Year Calendar year Current W to IRL TJC NP total Cumulative remaining space 2016 141,923 141,923 281,063 0 2017 144,761 425,824 16,914,176 1 2 2018 147,656 144,761 395,333 821,157 2019 150,610 16,518,843 16,115,603 3 2020 153,622 4 5 2021 156,694 2022 6 2023 7 17,058,937 247,677 252,630 403,240 1,224,397 344,386 257,683 755,690 1,980,087 15,359,913 262,836 770,804 2,750,892 159,828 351,273 358,299 268,093 786,220 3,537,112 14,589,108 13,802,888 163,025 365,465 273,455 801,945 4,339,056 13,000,944 2024 166,285 278,924 817,984 2025 284,503 834,343 9 10 2026 2027 169,611 173,003 5,157,040 5,991,383 12,182,960 8 372,774 380,230 387,834 290,193 6,842,413 10,497,587 176,463 395,591 295,997 851,030 868,051 7,710,464 9,629,536 11 12 2028 179,992 403,503 301,916 885,412 8,595,876 8,744,124 2029 183,592 411,573 903,120 9,498,996 13 2030 187,264 921,182 10,420,178 7,841,004 6,919,822 14 15 16 17 18 19 20 21 22 2031 191,009 419,804 428,200 307,955 314,114 320,396 939,606 2032 2033 2034 2035 2036 2037 2038 2039 2040 194,830 198,726 202,701 206,755 210,890 215,108 219,410 223,798 228,274 326,804 333,340 340,007 346,807 353,743 360,818 368,035 375,395 382,903 958,398 977,566 997,117 1,017,060 1,037,401 1,058,149 1,079,312 599,193 611,177 11,359,784 12,318,182 13,295,748 14,292,865 15,309,925 16,347,326 17,405,475 18,484,787 19,083,980 19,695,157 5,021,818 4,044,252 3,047,135 2,030,075 992,674 (65,475) (1,144,787) (1,743,980) (2,355,157) 436,764 445,500 454,410 463,498 472,768 482,223 491,868 c:\pwworking\west01\d0455375\PPR Class V Calcs 11,348,617 5,980,216 KH Computed by: Terry Warner Date:12/18/2017 Project: PPR Class V Support Checked by: Erich Jezowicz Date: 12/18/2017 Task: 002 Workbook: PPR Class V Calcs. Landfill Life Calcs Job #: 10066970 Page: 3 of 10 Scenario 2 Year 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Calendar year 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 2048 2049 2050 2051 2052 2053 2054 Current W to IRL 141,923 144,761 147,656 150,610 153,622 156,694 159,828 163,025 166,285 169,611 173,003 176,463 179,992 183,592 187,264 191,009 194,830 198,726 202,701 206,755 210,890 215,108 219,410 223,798 228,274 232,839 237,496 242,246 247,091 252,033 257,074 262,215 267,459 272,808 278,265 283,830 289,507 295,297 301,203 TJC NP total 439,877 448,674 457,648 466,801 476,137 485,659 495,373 505,280 515,386 141,923 281,063 144,761 425,824 147,656 573,481 150,610 724,090 153,622 L 877,712 156,694 1,034,406 159,828 1,194,234 163,025 1,357,259 166,285 1,523,544 169,611 1,693,155 173,003 1,866,158 176,463 r 2,042,621 179,992 2,222,614 183,592 2,406,206 187,264 2,593,470 191,009 2,784,480 194,830 2,979,309 198,726 3,178,035 202,701 3,380,736 206,755 3,587,491 210,890 3,798,381 4,013,488 215,108 219,410 4,232,898 223,798 4,456,696 228,274 4,684,970 232,839 4,917,809 237,496 5,155,305 242,246 5,397,552 247,091 5,644,643 252,033 5,896,675 1,273,398 7,170,073 1,298,866 8,468,939 1,324,843 9,793,782 1,351,340 11,145,123 1,378,367 12,523,489 1,405,934 13,929,424 1,434,053 15,363,477 1,462,734 16,826,211 1,491,989 18,318,199 - ' - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 576,448 587,977 599,736 611,731 623,966 636,445 649,174 662,157 675,400 c:\pwworking\west01\d0455375\PPR Class V Calcs - - Cumulative remaining space 17.058,937 16,914,176 16,766,519 16,615,910 16,462,288 16,305,594 16,145,766 15,982,741 15,816,456 15,646,845 15,473,842 15,297,379 15,117,386 14,933,794 14,746,530 14,555,520 14,360,691 14,161,965 13,959,264 13,752,509 13,541,619 13,326,512 13,107,102 12,883,304 12,655,030 12,422,191 12,184,695 11,942,448 11,695,357 11,443,325 10,169,927 8,871,061 7,546,218 6,194,877 4,816,511 3,410,576 1,976,523 513,789 (978,199) Computed by: Terry Warner Date:12/18/2017 Project: PPR Class V Support Task: 002 Checked by: Erich Jezowicz Date: 12/18/2017 Workbook: PPR Class V Calcs. Landfill Life Calcs Job #: 10066970 Page: 4 of 10 Bayview Volume/Capacity Cell 2 3 total remarks Cell 2 stages 3 and 4 2009 Permit Appliction and URS 2007 report capacity 5,000,000 tons 20,000,000 tons 25,000,000 tons 2015 IVISW TonnageNUERA References: SUVSWD North Pointe Weber Wasatch TJC Total Annual increase httDs://www.utah.gov/omn/files/240641.Ddf 134,000 247,700 186,000 125,000 312,000 34,800 initial 20% of NP in 2017 httos://www. utah.gov/Dmn/files/242513.odf 2017 master plan and TS RFP 1,004,700 tons per year 2.00% annual Scenario 1 -Southern NUERA members (SUVSWD, TJC, NP) Year Calendar Year 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 SUVSWD 139,414 142,202 145,046 147,947 150,906 153,924 157,002 160,142 163,345 166,612 169,944 173,343 176,810 180,346 183,953 187,632 191,385 195,213 199,117 203,099 207,161 211,305 215,531 219,841 224,238 228,723 233,297 237,963 242,722 247,577 252,528 North Pointe 34,800 252,654 257,707 262,861 268,118 273,481 278,950 284,529 290,220 296,024 301,945 307,984 314,143 320,426 326,835 333,372 340,039^ WIWMD - - - - - - - - - - - - - - - - - “ - - - - - - - - - - - - - - 346,840 353,777 360,852 368,069 375,431 382,939 390,598 398,410 406,378 414,506 422,796 431,252 439,877 448,674 c:\pwworking\west01\d0455375\PPR Class V Calcs Weber Co TJC - 403,605 411,677 419,911 428,309 436,875 445,613 454,525 463,616 472,888 482,346 491,993 501,832 511,869 522,106 532,549 543,200 554,064 565,145 576,448 587,977 Annual - - 174,214 394,856 402,753 410,808 419,024 427,405 435,953 444,672 453,565 462,637 471,889 884,932 902,631 920,684 939,097 957,879 977,037 996,578 1,016,509 1,036,839 1,057,576 1,078,728 1,100,302 1,122,308 1,144,754 1,167,649 1,191,002 1,214,823 1,239,119 1,263,901 1,289,179 Cumulative Tonnage 174,214 569,069 971,822 1,382,631 1,801,655 2,229,059 2,665,012 3,109,684 3,563,249 4,025,886 4,497,775 5,382,708 6,285,339 7,206,022 8,145,120 9,102,999 10,080,036 11,076,613 12,093,122 13,129,962 14,187,538 15,266,265 16,366,568 17,488,876 18,633,630 19,801,280 20,992,282 22,207,105 23,446,224 24,710,125 25,999,304 Capacity Remaining 24,825,786 24,430,931 24,028,178 23,617,369 23,198,345 22,770,941 22,334,988 21,890,316 21,436,751 20,974,114 20,502,225 19,617,292 18,714,661 17,793,978 16,854,880 15,897,001 14,919,964 13,923,387 12,906,878 11,870,038 10,812,462 9,733,735 8,633,432 7,511,124 6,366,370 5,198,720 4,007,718 2,792,895 1,553,776 289,875 - Computed by: Terry Warner Date:12/18/2017 Checked by: Erich Jezowicz Date: 12/18/2017 Workbook: PPR Class V Calcs. Landfill Life Calcs Page: 5 of 10 Scenario 2 -Conservative, all NUERA members except Logan/Cache Co Year Calendar Year 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045 2046 2047 SUVSWD 139,414 142,202 145,046 147,947 150,906 153,924 157,002 160,142 163,345 166,612 169,944 173,343 176,810 180,346 183,953 187,632 191,385 195,213 199,117 203,099 207,161 211,305 215,531 219,841 224,238 228,723 233,297 237,963 242,722 247,577 252,528 North Pointe 34,800 252,654 257,707 262,861 268,118 273,481 278,950 284,529 290,220 296,024 301,945 307,984 314,143 320,426 326,835 333,372 340,039 346,840 353,777 360,852 368,069 375,431 382,939 390,598 398,410 406,378 414,506 422,796 431,252 439,877 448,674 c:\pwworking\west01\d0455375\PPR Class V Calcs WIWMD - 125,000 127,500 130,050 132,651 135,304 138,010 140,770 143,586 146,457 149,387 152,374 155,422 158,530 161,701 164,935 168,234 171,598 175,030 178,531 182,101 185,743 189,458 193,247 197,112 201,055 205,076 209,177 213,361 217,628 TJC Weber Co - - - - - 358,390 365,558 372,869 380,326 387,933 395,691 403,605 411,677 419,911 428,309 436,875 445,613 454,525 463,616 472,888 482,346 491,993 501,832 511,869 522,106 532,549 543,200 554,064 565,145 576,448 587,977 186,000 189,720 193,514 197,385 201,332 205,359 209,466 213,656 217,929 222,287 226,733 231,268 235,893 240,611 245,423 250,332 255,338 260,445 265,654 270,967 276,386 281,914 287,552 293,303 299,169 305,153 311,256 317,481 Annual 174,214 394,856 527,753 724,308 738,794 1,111,960 1,134,199 1,156,883 1,180,021 1,203,621 1,227,694 1,252,248 1,277,293 1,302,838 1,328,895 1,355,473 1,382,583 1,410,234 1,438,439 1,467,208 1,496,552 1,526,483 1,557,012 1,588,153 1,619,916 1,652,314 1,685,360 1,719,068 1,753,449 1,788,518 1,824,288 Cumulative Tonnage 174,214 569,069 1,096,822 1,821,131 2,559,925 3,671,885 4,806,084 5,962,967 7,142,988 8,346,609 9,574,303 10,826,551 12,103,843 13,406,682 14,735,577 16,091,050 17,473,632 18,883,866 20,322,305 21,789,513 23,286,065 24,812,548 26,369,560 27,957,713 29,577,629 31,229,943 32,915,303 34,634,371 36,387,820 38,176,338 40,000,626 Capacity Remaining 24,825,786 24,430,931 23,903,178 23,178,869 22,440,075 21,328,115 20,193,916 19,037,033 17,857,012 16,653,391 15,425,697 14,173,449 12,896,157 11,593,318 10,264,423 8,908,950 7,526,368 6,116,134 4,677,695 3,210,487 1,713,935 187,452 - - Computed by: Terry Warner Date:12/18/2017 Checked by: Erich Jezowicz Date: 12/18/2017 Workbook: PPR Class V Calcs. Landfill Life Calcs Page: 6 of 10 Payson Volume/Capacity Waste capacity770,560 tonshttos://dea.utah.Eoy/businesses/P/PavsonCitv/PavsonClassVLandfill.htm Estimated life __ Year Calendar Year 0 1 2 3 4 5 6 7 8 9 10 11 12 13 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 75 years^ ReportedjnSC&A Evaluation Report 10,274 annual tons 2004 50,000 Assumed additonal waste Payson Other Waste 10,274 10,480 10,689 10,903 11,121 11,343 11,570 11,802 : 12,038 18,350 18,717 19,091 19,473 19,863 20,260 20,665 21,078 21,500 21,930 22,369 22,816 23,272 23,738 24,212 24,697 25,191 25,694 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 50,000 Annual 10,274 10,480 10,689 10,903 11,121 11,343 11,570 11,802 12,038 18,350 18,717 19,091 19,473 19,863 70,260 70,665 71,078 71,500 71,930 72,369 72,816 73,272 73,738 74,212 74,697 75,191 75,694 ---------------------- ------------------------- — c:\pwworking\west01\d0455375\PPR Class V Calcs Cumulative Tonnage 10,274 20,754 31,443 42,346 53,467 64,810 76,381 88,183 ' 100,220 118,570 137,287 156,379 175,852 195,714 265,974 336,639 407,718 479,218 551,148 623,516 696,332 769,604 843,342 917,555 992,251 1,067,442 1,143,136 Capacity Remaining 770,560 749,806 739,117 728,214 717,093 705,750 694,179 682,377 670,340 651,990 633,273 614,181 594,708 574,846 504,586 433,921 362,842 291,342 219,412 147,044 74,228 956 (72,782) (146,995) (221,691) (296,882) (372,576) Project: PPR Class V Support Computed by: Terry Warner Date: 12/18/2017 Task: 002 Checked by: Erich Jezowicz Date:12/18/2017 Job #: 1066970 Workbook: PPR Class V Calcs. Hauling Costs Page: 7 of 10 Travel Times Central Corridor Study: Data and Modeling Technical Memorandum FINAL 041817 Study contained travel time estimates for the 1-15 segments, which are the inputs in the shaded cells. Travel times for other segments were calculated based on approximate speeds 2014 2050 minutes minutes 18 43.0 53.0 Lehi 27 32.0 36.0 Lehi Santaquin 36 60 36 36 Santaquin Bayview 19 55 21 21 Locality AM travel Kaysville Salt Lake Salt Lake Travel, total miles miles 100 mph miles 132 min 146 min 30 min 30 Travel + Loading 2.7 hr 2.9 min hr Round trip 5.4 hr 5.9 hr Loading (load and unload time) PM travel miles mph 2014 2050 minutes minutes Kaysville Salt Lake 18 34 38 Salt Lake Lehi 27 61 75 Lehi Santaquin 36 60 36 36 Santaquin Bayview 19 55 21 21 Travel, total miles 100 miles 152 min 170 min Loading (load and unload time) 30 min 30 min Travel + Loading 3.0 hr 3.3 hr Round trip 6.1 hr 6.7 hr c:\pwworking\west01\d0455375\PPR Class V Calcs Project: PPR Class V Support Computed by: Terry Warner Date:12/18/2017 Task: 002 Checked by: Erich Jezowicz Date:12/18/2017 Job #: 1066970 Workbook: PPR Class V Calcs. Hauling Costs Page: 8 of 10 Travel Times West Davis Corridor Model: WDC Base Travel Demand Model Study contained modeled average speeds for 1-15 segments which are inputs in the shaded cells. Travel times for other segments were calculated based on approximate speeds Locality AM travel 2011 miles mph 59.7 minutes 20 60 35 42 65 Ogden Lampo Junction 20 42 Lampo Junction Promontory 38 Kaysville Ogden 100 Total travel Loading (load and unload time) Travel + Loading Round trip Locality Kaysville Ogden Lampo Junction Total travel PM travel Ogden Lampo Junction Promontory 100 Loading (load and unload time) Travel + Loading Round trip c:\pwworking\west01\d0455375\PPR Class V Calcs 2040 miles mph 56.0 60 35 miles mph 49.3 60 35 42 65 127 min 129 30 2.6 min hr 30 2.6 min min hr 5.2 hr 5.3 hr 2011 miles 20 42 38 minutes 21 2040 mph 46.4 60 35 minutes 24 42 65 minutes 26 42 65 131 min 133 min 30 2.7 min hr 30 2.7 min hr 5.4 hr 5.4 hr Project: PPR Class V Support Computed by: Terry Warner Date:12/18/2017 Task: 002 Checked by: Erich Jezowicz Date:12/18/2017 Job #: 1066970 Workbook: PPR Class V Calcs. Hauling Costs Page: 9 of 10 Travel Times Estimates Travel Times (see above Figure Year Bayview 2011 2014 5.15 5.76 2040 2050 PPR 5.30 6.30 Average Travel Times AM/PM travel To Bayview, yr To PPR, yr 2014 2050 2011 2040 AM travel, hrs 5.4 5.9 5.2 5.3 PM, travel, hrs 6.1 6.7 5.4 5.4 Average travel, hrs 5.7 6.3 5.3 5.4 c:\pwworking\west01\d0455375\PPR Class V Calcs K* Computed by: Terry Warner Date:12/18/2017 Project: PPR Class V Support Checked by: Erich Jezowicz Date:12/18/2017 Task: 002 Job #: 1066970 Workbook: PPR Class V Calcs. Hauling Costs Page: 10 of 10 Annual Travel Cost Projection Year Locality Roundtrip, hours Cost per trip (S$l50/hour $/ton at 40 tons per load tons/year (Weber C + WIWMD) Annual cost Annual cost difference Percent difference (lower) c:\pwworking\west01\d0455375\PPR Class V Calcs 2050 2017 to Bayview to Bayview to Promontory to Promontory 5.7 5.3 6.3 5.4 $ 939.00 $ 859.00 $ 797.00 $ 810.00 $ 23.48 $ 21.48 $ 19.93 $ 20.25 $ 311,000 311,000 597,814 6,678,725 6,196,675 $ 14,033,683 $ 482,050 597,814 $ $ 12,105,733 1,927,950 16% Appendix NUERA Information Sheet- Bayview Landfill Project I NORTHERN UTAH ENVIRONMENTAL RESOURCE AGENCY Logan City Environmental Department 153 North 1400 West Building A Logan, Utah 84321 (435) 716-9755 loganutah.org North Pointe Solid Waste Special Service District 2000 West 200 South Lindon, Utah 84042 (801)225-8538 utahcountygarbage.org Information Sheet - Bayview Landfill Project What is NUERA? The Northern Utah Environmental Resource Agency (NUERA) was created as an interlocal cooperation entity under Utah Code Ann. § 11-13-101 et seq., by an agreement dated October 28, 2014. The members of NUERA are the City of Logan, Weber County, Wasatch Integrated Waste Management District, TransJordan Cities, North Pointe Solid Waste Special Service District, and South Utah Valley Solid Waste District. NUERA is governed by a 12-member board consisting of two board members appointed by each of the six member entites. The Operations and Management (O&M) Committee of NUERA has six members consisting of the solid waste managers of each of the member entities. NUERA currently has no paid employees. / South Utah Valley Solid Waste District P.O. Box 507 Springville, Utah 84663 (801)489-3027 suvswd.org Trans-Jordan Cities P.O. Box 95610 South Jordan, Utah 84095 (801)569-8994 transjordan.org Wasatch Integrated Waste Management District P.O. Box 900 Layton, Utah 84041 (801)614-5600 wasatchintegrated.org Weber County Solid Waste 867 West Wilson Lane Ogden, Utah 84401 (801) 399-8358 co.weber.ut.us The Mission Statement of NUERA: To provide environmentally sound, cost effective solid waste disposal services for the communities of northern Utah while encouraging source reduction and recycling. Who is on the Board of NUERA? Bob Stevenson - NUERA Chair, Representing Wasatch Integrated Waste Management District Dave Newton - NUERA Vice-Chair, Representing Trans-Jordan Cities Kane Loader - NUERA Secretary-Treasurer, Representing Trans-Jordan Cities Craig Peterson, Representing Logan City Darrell Gibbons, Representing Logan City Dale Goodman, Representing North Pointe Solid Waste Special Service District Tim Irwin, Representing North Pointe Solid Waste Special Service District Brandon Gordon, Representing South Utah Valley Solid Waste District Wayne Parker, Representing South Utah Valley Solid Waste District John Petroff, Representing Wasatch Integrated Waste Management District Kerry Gibson, Representing Weber County Matthew Bell, Representing Weber County Who are the Operations and Management Committee Members? Terry Ficklin - Chair, South Utah Valley Solid Waste District, tficklin@suvswd.org Rodger Harper - Vice Chair, North Pointe Solid Waste Special Service District, rodger ,np@gmail. com Nathan Rich - Secretary, Wasatch Integrated Waste Management District, nathanr@wi wmd. org Issa Hamud, Logan City, issa.hamud@loganutah.org Mark Hooyer, Trans-Jordan Cities, markhooyer@transjordan.org Kevin McLeod, Weber County, kmcleod@co.weber.ut.us PO Box 900 Layton, Utah 84041 Bayview Landfill Project Overview When the municipally-owned landfills in Davis and Salt Lake Counties reach the end their useful lives, the municipal solid waste will likely need to be transferred (put in large trailers and hauled by trucks) to a regional landfill. Both Weber County and North Pointe Solid Waste District no longer operate their own landfills, and currently transfer solid waste to a privately owned landfill in Tooele County. South Utah Valley Solid Waste Management District (SUVSWD) owns the Bayview Landfill, a large, fully-permitted landfill that is currently underutilized. NUERA has formed a Project that will allow NUERA members to purchase the Bayview Landfill from the SUVSWD. The negotiated purchase price of the Bayview Landfill by NUERA is $5,750,000. Bringing additional waste into the Bayview Landfill from participating NUERA members will substantially reduce operating costs at that facility saving businesses and citizens of the SUVSWD service area millions of dollars over time by lowering the landfill operating costs. Allowing NUERA Members to jointly share ownership of the facility provides long term assurance (80+ years) to the other participating member communities that they will have a place to take their waste at reasonable rates that will be controlled directly by participating members. This project is a win-win partnership and a great example of local governments working together to provide a shared solution to a common challenge. The project will benefit our member cities, their citizens, and local business for years to come. Background Information on the Solid Waste Industry along the Wasatch Front Landfills are a high fixed-cost business because of the large capital expenditure required to open and maintain a landfill and the high cost of equipment used at landfills. Unit operating costs at a landfill can be substantially lowered by taking advantage of economies of scale. Landfills become very efficient at about 300,000 tons per year, and unit costs continue to decline up to about 500,000 tons per year. Individually, none of the participating entities in this project handles enough waste to reach these economies of scale. However, together, participating entities can deliver enough waste to a jointly owned landfill to drive unit costs very low, which benefits the ratepayers of all participating entities. Utah currently has some of the lowest landfill dumping (“tipping”) fees in the nation. Tipping fees along the Wasatch front currently range from $29/ton to $35/ton at the municipally operated landfills and transfer stations. Nationally, landfill tipping fees average around $45/ton and are commonly as high as $80/ton. Why are tipping fees in Utah so low? Because of the existence of municipally owned landfills with publicly posted disposal rates. Solid waste disposal has historically been the responsibility of local government in Utah and across the Nation. Over the past 20 years, as many smaller County and City owned landfills have closed, the industry has shifted toward fewer and larger regional landfills, many owned by private companies. This shift has some benefits as larger landfills are more efficient to operate (lower cost) and also tend to employ the latest in environmental protections. However, in some markets when municipally owned landfills have been closed and replaced by only one or two privately owned landfills, tipping fees have soared. The Wasatch Front faces this potential problem as municipally owned landfills which began operation in the 1950’s and 1960’s are one by one running out of space. Are privately owned and operated landfills bad? Of course not. They often provide valuable services at competitive pricing and should always be considered as an option. But we need to Page 2 remember that landfills owned by for-profit corporations are built and operated to generate profit for their shareholders or owners, as they should be. There is nothing wrong with a profit motive, we just need to be aware how it impacts the local market. Tipping fees at privately owned landfills are almost always negotiable, vary for each hauling customer and are typically not publically posted. A privately owned landfill can be used to create a vertically integrated hauling and disposal business, which may not accept waste from competing hauling companies. The existence of at least one municipally owned landfill in a market with a publically posted, nonnegotiable tipping fee, set by a board of elected or appointed officials who are directly accountable to the public, guarantees a competitive private sector hauling market. When no municipally owned landfill or transfer station is available in a market, the competitive independent haulers who do not own their own disposal capacity will cease to exist. NUERA’s proposed Bayview Landfill Project will ensure a long term competitive market in the waste hauling sector. The cost of collection and hauling typically represents 60% of the total cost of solid waste disposal. Are landfills operated by municipalities, counties, or special service districts bad? Of course not. Landfills are operated by public entities to provide services desired by their constituents under direct control of elected officials, and are highly regulated by the State and Federal Governments with transparency for the rate payer. Municipally-owned and operated landfills also typically provide a suite of services not provided by private landfills including; allowing residents and self-haul customers to deliver waste, providing recycling opportunities, providing green waste recycling and composting programs, accepting and properly disposing of Household Hazardous Waste, providing extended operating hours, providing education and outreach to schools and communities about waste and recycling issues, and operating renewable energy projects. These types of activities bring value to a solid waste management system, but may not provide the profits that a privately owned landfill requires. Frequently Asked Questions (FAQ’s) 1. How did the Bayview Project Evolve? SUVSWD’s Bayview Landfill currently handles 131,000 tons of waste per year, and operates at a cost per ton of $ 18.23. SUVSWD has been looking for ways to reduce the overall cost of their system, and released a request for proposals (RFP) in 2015 inviting proposals for privatization of the SUVSWD transfer station and/or the Bayview Landfill. Based upon a previously prepared Landfill Valuation Report completed by Cornerstone Environmental (January 2015), SUVSWD knew that one way to reduce unit costs was to increase tonnage received by the landfill. SUVSWD received proposals from five private companies with interest in operating the Bayview Landfill. SUVSWD determined that none of the were in the best interests of the district, and postponed action on the private sector proposals received. NUERA and SUVSWD then began a conversation to determine if a mutually beneficial project could be developed. The project was developed using the financial evaluation provided by SUVSWD (the Cornerstone Report). 2. Has an independent financial analysis of the project been performed? Yes, the NUERA Board approved funding for an independent analysis of anticipated project operating costs. This analysis was conducted by an independent solid waste engineering firm (IGES). IGES reviewed Cornerstone’s assessments and projections and found them to be correct, Page 3 and perhaps overly-conservative. IGES also conducted their own independent financial analysis, the results of which were similar to those reached by the Cornerstone report. These results indicate that if the municipalities work together and bring sufficient waste to the Bayview Landfill, the participating entities can collectively enjoy substantially lower landfill tipping fees while also obtaining an ownership interest which provides for long-term security and control over future pricing. That evaluation has been extended to include evaluation of likely hauling costs for each of the participating entities. 3. Why wasn’t private industry asked to provide a solution? It was. South Utah Valley Solid Waste District received proposals for privatization of the SUVSWD transfer station and the Bayview Landfill. Five proposals were received and evaluated by SUVSWD and none were considered to be in the best interest of the District. 4. S5,750,000 is a lot of money. Do we really need to purchase the landfill? The current purchase price of the landfill is $5,750,000, and the project will also require an additional $500,000 for initial operational requirements. Currently five members are considering participating in the landfill purchase, which makes the cost to each participating member $1,250,000. Purchasing a landfill with more than 80 years of disposal capacity at a unit cost of less than $0.20 per ton is an incredible opportunity. By comparison, there is a landfill currently under construction in Northern Utah that will provide approximately 80 years of capacity for a community of about 120,000 in population at a cost of approximately $ 10:$ 12 million. The risk of purchasing an existing, currently permitted and operating landfill like Bayview is very low, whereas attempting to site and build a new landfill would be farm more expensive and perhaps not politically possible. 5. Compared to what a new landfill costs, why is SUVSWD willing to sell the Bayview Landfill so cheaply? SUVSWD realizes that they will save their citizen rate payers more money over time by sharing their landfill so that the operating costs can be substantially reduced for all participants, while yet preserving more-than-ample space for their own citizens for the next 80 years. 6. Has the public been left out of the process? NUERA and each of the member entities are subject to the Utah Open and Public Meetings Act. All meetings of these entities have been properly noticed, recorded, and open to the public as required by law. This particular project has been openly discussed in NUERA meetings for well over a year. Several closed meeting sessions have been held within the past month, as is appropriately allowed by Utah law, in order to finalize negotiations of the real estate contract. The participation of each entity will require approval of their respective governing boards in a properly noticed open meeting. 7. Does this project violate anti-trust laws? Anti-trust laws are designed to protect consumers from predatory business practices by ensuring that fair competition exists in the open-market. The same laws have long recognized that critical public infrastructure needs to be regulated to prevent private entities from developing monopolies which allow them to extract excess profits from public infrastructure without the benefit of a truly competitive market. This project does not prevent the private sector from building, owning, or Page 14 operating landfills in any way. The project does ensure protection to rate payers from the very-real threat of a privately-owned landfill monopoly. 8. If the private sector can, and in some cases already is providing these services, why do taxpayers need to pay for the government to compete with private industry? Government has a duty to ensure that rate payers are getting the best value for the services that they request. Local government has always had the responsibility to provide environmentally sound and cost effective waste disposal, especially as solid waste is considered as critical local infrastructure. This project will lower waste disposal costs, including hauling costs, for the participating entities in the short term, and will provide direct control over rising costs in long term. By combining the waste streams of the member entities NUERA will be able to operate a very efficient landfill. 9. The Utah Taxpayers Association Says... “In the greater Denver area, trash and landfills are nearly all privately owned and operated without government intervention or competition. Rates in Denver are much cheaper for landfill use than they are currently along the Wasatch Front. Clearly, the free market is doing its job in Denver, keeping prices at the correct level instead ofgovernment over inflating the market and raising prices on taxpayers. ” It is true that the greater Denver area is served by a number of privately owned landfills. The following pricing was obtained from the following facilities through a few quick phone calls: a) Buffalo Ridge Landfill: $37.50 per ton. (Owned and operated by Waste Management). , b) Denver Regional and Front Range Landfills: $46 per ton. (Owned and operated by Republic Waste Services). c) North Weld Landfill: Minimum charge of $ 100 for 2 tons, then $3 8 per ton for additional tonnage. (Owned and operated by Republic Waste Services). Based on this information, the statement given by the Utah Taxpayers appears to be false, and is misleading. Tipping fees in the greater Denver area appear to be about 25% higher than tipping fees along the Wasatch Front, not including transportation costs. Utah currently has only two competitive privately operated landfills. Local governments along the Wasatch Front have done a good job controlling waste disposal rates and protecting the interests of our citizen rate payers. Elected officials and citizen rate payers along the Wasatch Front should be pleased that local government is acting now to preserve a system that is already in-place locally, and that ensures that Utahns continue to pay some of the lowest waste disposal rates in the country far into the future. 10. Why is the Utah Taxpayers Association Concerned? Why would the Utah Taxpayers Association choose to represent the interests of Republic Waste Services in this issue? Republic Waste Services is the second largest waste services company in the nation, which generated over $6 Billion in revenues in 2014 and returned $779 Million to shareholders during the same period. The Utah Taxpayers Association should be supporting the efforts of transparent government under local control to provide the best possible combination of service and cost. Page 5 Appendix Evaluation Report Findings and Response Matrix on Needs Assessment Report Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Ite m Old Page/ Section 1. Cover Letter, pg. 1 (Note: Information on cover letter identified potential data gaps which are also addressed under specific comments captured in report Appendix A. Therefore, see response to comments under Appendix A Section, below) Appendix A, “Completeness of Statutory Requirements,” provides more detailed information. See responses #8 to #37 2. Cover Letter, pg. 2 The report lacks analysis of trends in waste generation; recent reports show a decline in nonhazardous waste generation per capita in the United States. Source information in Appendix B, “Data Validation” See response to comments #38 to #52 “Application for a Permit to Operate a Class V Landfill,” A. The Class V Permit Application, Parts I, II, and appendices, prove compliance with location standards, contain the design features that are incorporated into the Promontory Point Landfill, and the operational approach to protect the environment. Comment Cover Letter, Pg- 2 4. A. The report lacks sitespecific information about location, geology, and potential adverse environmental impact B. Other landfills, such as Intermountain Regional, include robust analysis of GHG emissions associated with transport to and from the facility in their permit application. Cover Letter, rep0rt iacks mention of PS' ^ the implications of a court case that is pending {Young Resources Limited Partnership v. Promontory Landfill & Promontory Point Land Resources, LLC) that 5. Cover Letter, PS- ^ could affect the size of the facility. rep0rt acks resumes and disclosure of any noncompliance issues for facility founders and all senior management. Updated 18-Dec-17 5:54 PM Relevant Information from Report 2011, https://deq.utah.gov/ businesses/I/ IntermountainRegional/ docs/201 l/02Feb/ Intermountain Regional Landfill Class V Permit Application.pdf How Addressed B. There are no significant environmental impacts at the site, the Class V designation would not change that, and any impact would be similar to any other modem landfills. See the information in the Needs Assessment Report Addendum for more information. The court case (160100006) was dismissed on July 26,2016. The case would not have had an impact on the project because the operation boundary would have been adjusted and it would not have materially affected capacity. Promontory Point Resources (Promontory, now Alios Environmental) provide biographies in the Needs Assessment Report Addendum. Promontory’s management team does not have any major noncompliance issues. Resumes can be provided upon request. 1 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization Ite m Old Page/ Section 6 Cover Letter, P8‘1 Comment HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report The report lacks information on storage or treatment processes prior to landfilling, if the facility plans to offer these services. How Addressed Not applicable. Waste processing would primarily be handled by others. Promontory Point Landfill would dispose of residuals from recycling, organics and other material diversion programs. Promontory is willing to partner with municipalities and facilitate discussions about the feasibility of recovering organics, diverting recyclables, and other inert and reusable materials at the site. Given the size of the property, its remote location, and its proximity to rail, the Promontory site is suitable for long­ term stockpiling of diverted materials and making them available for reuse. 7. Cover Letter, pg. 2 Of the 25 items identified for data validation, 7 had sources provided and were confirmed. However, most claims did not have sources provided and required additional research. Several claims remained unconfirmed due to lack of needed information. Appendix B, “Data Validation,” provides more detailed information. See responses under Appendix B comments #38 to #52. Some of the data provided are based on market knowledge given Promontory’s and their consultant team’s collective professional experience. Response to Comments contained in SC&A Report Appendix A 8. Subsection 10A: Information on the source, quantity, and price charged for treating, storing, and disposing of potential nonhazardous solid or hazardous waste in the state and regionally Updated 18-Dec-17 5:54 PM Promontory Point Resources, LLC (PPR) has identified numerous sources of municipal, industrial, and out-ofstate waste; however, it has not provided detailed information on waste quantity. In addition, it does not provide projected pricing for each waste type. It does not present sufficient information on storage and treatment at the facility, if applicable. The report's claim that “there are seven permitted Class I landfills within Salt Lake region that accept MSW within a fiftymile radius of Ogden and two Class V landfills” is unsupported. Table 2 in the Needs Assessment Report is a summary of existing landfills serving various geographies in relatively close proximity to Promontory. The wastes from these geographies are potential future sources for Promontory. As encroaching development and other pressures increase, the full capacities of these landfills might or might not be realized. Note that Table 1 in the SC&A report (Capacity of Select Utah Landfills) is misleading in that the assumptions (volume or airspace, annual waste, and annual waste growth) used in the capacity estimate are not provided. 2 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization Ite m Old Page/ Section 9. Subsection 10A: Comment Information on the source, quantity, and price charged for treating, storing, and disposing of potential nonhazardous solid or hazardous waste in the state and regionally 10. Subsection 10A: Information on the source, quantity, and price charged for treating, storing, and disposing of potential nonhazardous solid or hazardous waste in the state and regionally HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report Promontory Point Resources, LLC (PPR) has identified numerous sources of municipal, industrial, and out-ofstate waste; however, it has not provided detailed information on waste quantity. In addition, it does not provide projected pricing for each waste type. It does not present sufficient information on storage and treatment at the facility, if applicable. A. In terms of quantity, the report references two Class I landfills in the areas that are near capacity (unsupported). Promontory Point Resources, LLC (PPR) has identified numerous sources of municipal, industrial, and out-ofstate waste; however, it has not provided detailed information on waste quantity. In addition, it does not provide projected pricing for each waste type. It does not present sufficient information on storage and treatment at the facility, if applicable. B. Claims of need for additional capacity are supported by population projections and per-person waste generation estimates {supported). How Addressed SC&A’s outreach confirmed the Needs Assessment Report assertion that Trans-Jordan and Wasatch Integrated landfills are approaching capacity. Uinta and Summit Counties, which are also close to capacity as reported by SC&A, offer relatively small volumes but could also use the Promontory Point Landfill. Comment noted. Local land use planners, transportation, state resource management, and regional water agencies are all planning for the substantial growth expected over the next few decades. Promontory Point Landfill offers a long-term solution for waste management in this rapidly growing area. Utah’s population is projected to increase from about 3 million people in 2015 to about 5.8 million people in 2065; this is an increase of 2.8 million people. Northern Utah counties are projected to have 79% of the state’s total population (5.8 million people) by 2065. Annual waste volumes in northern Utah will be 88% higher by 2065 (between 3.7 million and 5.0 million tons annually), nearly double 2015 volumes (2.0 million to 2.7 million tons). Additional landfill capacity is needed. Traffic on 1-15 is expected to exceed its capacity in Salt Lake County by 2030. Even with planned improve­ ments, travel times on 1-15 going south through Salt Lake City is anticipated to increase dramatically in future years. So, for northern Utah communities, there are cost and emissions reduction benefits to using Promontory Point Landfill. Updated 18-Dec-17 5:54 PM 3 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12,2017 Commenting Organization Ite m Old Page/ Section 11. Subsection 10A: Comment Information on the source, quantity, and price charged for treating, storing, and disposing of potential nonhazardous solid or hazardous waste in the state and regionally 12. Subsection 10A: Information on the source, quantity, and price charged for treating, storing, and disposing of potential nonhazardous solid or hazardous waste in the state and regionally HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report Promontory Point Resources, LLC (PPR) has identified numerous sources of municipal, industrial, and out-ofstate waste; however, it has not provided detailed information on waste quantity. In addition, it does not provide projected pricing for each waste type. It does not present sufficient information on storage and treatment at the facility, if applicable. C. The report claims that “the facility has the capacity to provide all municipal solid waste disposal needs for Box Elder, Cache, Weber, Davis, and Morgan Counties for the next six hundred years” at the current levels of waste generation Promontory Point Resources, LLC (PPR) has identified numerous sources of municipal, industrial, and out-ofstate waste; however, it has not provided detailed information on waste quantity. In addition, it does not provide projected pricing for each waste type. It does not present sufficient information on storage and treatment at the facility, if applicable. D. Regarding price, the report indicates that the tip fee will be comparable to that of other Utah regional landfills, but the claim and figures provided are unsupported. How Addressed Comment noted. As described, the size and location of the Promontory Point Landfill is a good long-term solution. {supported). The fees charged to Promontory’s customers are proprietary. The price can vary and will depend on many factors including waste type, total tonnage from a specific customer, and the delivery method. Tip fees from other regional, private commercial/ industrial landfills are unavailable because that pricing information is also proprietary. CalRecycle, in a 2015 report Landfill Tippingfees in California, also acknowledges the proprietary nature of the tipping fees. In its research, SC&A estimated disposal fees in CA are around $60/ton (Appendix B, Data Validation). This value is within the range of costs provided in the Needs Assessment Report. Promontory’s operating costs would be similar to those of other Utah area landfills (with tipping fees from about $20.50/ton to about $30.50/ton) because amortized capital and mobile equipment costs, equipment operating costs, and labor costs would be similar for a similar level of operation. (See also response to comment #52, which compares an assumed volume for Promontory to existing northern Utah landfills.) With a proposed tipping fee lower than in CA, the value for a customer Updated 18-Dec-17 5:54 PM 4 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer HDR Cover Letter from DWMRC July 12, 2017 Commenting Organization Utah Department of Environmental Quality, DWMRC Ite m Old Page/ Section Comment Relevant Information from Report Date: 10/24/17 How Addressed to use Promontory is highly dependent on transportation costs. Rail haul cost will vary by location and market conditions. However, unlike truck haul which has a linear cost-per-time or a cost-per-distance relationship ($/mile), rail haul cost is not a function of the distance hauled but is priced on a “value of service” basis. This means that because truck transportation is available everywhere, if the rail transportation costs are marginally less than trucking, rail haul is a viable option. In this example, if rail haul costs are around $30 per ton, Promontory becomes an economically better disposal option. In addition, because railroads are sharing their track capacity assets among many shippers, they create a tiered pricing structure that prioritizes the richest shippers down to the poorest shippers. Once the capacity is exhausted, or “constrained”, some shippers simply get priced out In HDR’s experience, environmental remediation refuse and contaminated soil can generally pay the railroads well enough to overcome any capacity constraints and pricing pressures out of California, and many other western and central U.S. locations. Promontory can, therefore, offer tip fees that will make the overall disposal costs (including transportation costs) economical and allow customers to ship waste on rails to Promontory. 13. Subsection 10A: Information on the source, quantity, and price charged for treating, storing, and disposing of potential nonhazardous Updated 18-Dec-17 5:54 PM Promontory Point Resources, LLC (PPR) has identified numerous sources of municipal, industrial, and out-ofstate waste; however, it has not provided detailed information on waste quantity. In addition, it does not provide E. Other information on price includes generalizations of lower costs associated with the regionalization of waste disposal, the cost effectiveness of transfer stations, and a claim that Regarding regionalization, landfill operating costs per ton are, in fact, driven down when more tonnage is received at one location because the amount of staffing and equipment needed to manage waste does not increase proportionally to increased waste volumes. For example, Bayview Landfill’s operating cost, on a per ton basis, was forecast to 5 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12,2017 Commenting Organization Ite m 14. Old Page/ Section Comment Relevant Information from Report projected pricing for each waste type. It does not present sufficient information on storage and treatment at the facility, if applicable. Subsection 10A: The report has not provided a market analysis since it does not present the quantities from each waste source and PPR's pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste generation and more indepth review of other landfills is required. A. The need for a commercial facility is based on claims of reduced supply, increased demand, and general benefits. In terms of supply, the report claims that “small, local landfills across the Western United States are closing and being replaced by transfer stations” (unsupported). The report has not provided a market analysis since it does not present the quantities from each waste source and PPR’s pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste B. The report claims that there is increased demand for the facility based in part on estimates of waste generation per person per day and of population increase in the Northeastern Salt Lake Region (supported). Subsection 10A: A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally Updated 18-Dec-17 5:54 PM Date: 10/24/17 Utah Department of Environmental Quality, DWMRC solid or hazardous waste in the state and regionally A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally 15. HDR PPR can provide a long-term solution with “pricing that is materially lower” to the “many” landfill owners and municipalities within the Salt Lake Region that are planning for end-of-life issues (unsupported). How Addressed decreased by about 13% by adding 34,800 tons, which is +26% to Bayview Landfill. This waste is coming from northern Utah County and is 20% of its total volume. (Draft NUERA Bayview Project Plan, 2016). This operating cost decrease can lower tipping fees and can affect the feasibility of adding transfer stations to a waste district’s system in that overall cost increases of system changes are minimized. Promontory offers the same economy of scale benefit to northern Utah and other regional communities. Regionalization is a well understood waste management trend as development pressures limit the ability to site new landfills close to population centers. See response to #13. Transfer stations and longtransfer hauls are a direct result. Commercialization or privatization is a preferred approach of many communities because of the power for market forces, and economies of scale, to keep disposal prices low and to minimize legacy environmental liability issues. Comment noted. Local land use planners, transportation agencies, state agencies and local water districts are all planning for the substantial growth expended over the next few decades. Promontory offers a long-term solution for waste management. Moreover, transferring some waste to Promontory Point Landfill can extend the life of municipal landfills. This extension provides citizens several long-term benefits including a convenient location for self-haul customers, a location for processing 6 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization ite m Old Page/ Section Comment HDR Utah Department of Environmental Quality, DWMRC Relevant Information from Report generation and more indepth review of other landfills is required. 16. Subsection 10A: A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally The report has not provided a market analysis since it does not present the quantities from each waste source and PPR's pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste generation and more indepth review of other landfills is required. Date: 10/24/17 How Addressed organics, a convenient (closer to demand) compost sales location, more capacity for CD waste disposal, and a location for disposing of recycling residuals that is closer to the recycling centers. In addition, closing landfills later allows districts to delay the expense and accrue more funds for other waste infrastructure improvements (transfer stations) and other waste-reduction and -diversion programs. C. Increased demand also comes from the potential to accept waste from outside Utah: “CalHaz.” The report claims that there are currently only two landfills in California that accept “Cal-Haz” waste, and neither of them are served by rail (unsupported). California non-hazardous waste is another potential source for Promontory Point Landfill. The landfill assumed a small percentage of the values reported for this special waste in its financially feasibility evaluation. Promontory has confirmed interest from industrial customers and remediation contractors. This provided Promontory’s investor confidence in the market opportunity and allowed funding to materialize for the next phase of development. Alios is a partner in a northern California rail consolidation facility with a separate group of investors. This group of investors also sees Promontory Point Landfill as a financially viable disposal option. From Promontory’s customers’ perspective, transporting waste by rail has potential benefits from the standpoints of sustainability and carbon impacts (greenhouse gases or GHG) reduction, which most large industrial businesses track for purposes of managing their carbon output and reporting to their stakeholders. As of November 2017, over 1,300 businesses have voluntarily adopted GHG reduction targets in the 2015 Paris Agreement (America's Pledge Phase 1 Report: States Cities, and Businesses in the United States are Stepping Up on Climate Action, November 2017). Updated 18-Dec-17 5:54 PM 7 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Cover Letter from DWMRC July 12,2017 Ite m Old Page/ Section Preparer HDR Commenting Organization Utah Department of Environmental Quality, DWMRC Comment Relevant Information from Report Date: 10/24/17 How Addressed On average, rail is 4 times more efficient than trucking {Freight Railroads Help Reduce Greenhouse Gas Emissions, Association of American Railroads, April 2017). As mentioned in the Needs Assessment Report, most heavy process manufacturing facilities are rail-served, so rail-hauling waste provides a cost-effective alternative for transporting waste long distances. Given that large concentrations of industrial facilities are located throughout the western United States, Promontory Point Landfill is strategically located to provide disposal solutions to these industries due to its proximity to Union Pacific Railroad’s main line. Promontory’s state-of-the-art accounting system will facilitate real­ time reporting for these customers who are committed to track, report, and reduce their company-wide GHG emissions. 17. Subsection 10A: A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally The report has not provided a market analysis since it does not present the quantities from each waste source and PPR's pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste generation and more indepth review of other landfills is required. D. The report also states that “most” contaminated soil is designated as “Cal-Haz,” but it does not provide exact figures (unsupported). Low-level contaminated soil is another potential source for Promontory. It is impossible to speculate on the exact figure (potential total volume) of contaminated soil that could be delivered to Promontory. The same market forces of transportation and disposal costs will determine the most economical disposal location for this waste. EPA estimates that, on an acreage basis, 74% of Brownfields, 62% of Superfund, and 76% of RCRA Corrective Action sites are NOT ready for their anticipated use. This is equates to 16.4 million acres or 72% of EPA land clean-up programs still to be addressed. https://www.epa.gov/cleanups/measur ing-progress-epas-land-cleanupprograms Updated 18-Dec-17 5:54 PM 8 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer HDR Cover Letter from DWMRC July 12,2017 Commenting Organization Utah Department of Environmental Quality, DWMRC Ite m Old Page/ Section 18. Subsection 10A: Comment A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally 19. Subsection 10A: A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally 20. Subsection 10A: A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally Updated 18-Dec-17 5:54 PM Relevant Information from Report The report has not provided a market analysis since it does not present the quantities from each waste source and PPR's pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste generation and more indepth review of other landfills is required. E. The report has not provided a market analysis since it does not present the quantities from each waste source and PPR's pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste generation and more indepth review of other landfills is required. F. The report has not provided a market analysis since it does not present the quantities from each waste source and PPR's pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other G. The report also cites general benefits of the regionalization of waste disposal (reduced costs, greater efficiency, improved services, etc.) (unsupported). Date: 10/24/17 How Addressed The report states that “large quantity generators in the Western United States generated more than 647,000 tons of RCRA hazardous waste” (supported). Confirmation of a source for Promontory Point Landfill. Table 3 illustrates market opportunity for a rail-served Class V facility in Utah (unsupported). The values in Table 3 were a result of Promontory’s research and coordination with its potential customers. The values in the table are representative of one market opportunity for the Promontory Point Landfill. As described in response to comment #12, the rail served nature of the landfill expands the potential wasteshed but is not the sole driver. Promontory has already secured Service Agreements from several industrial customers, contingent upon receipt of the Class V designation and construction of rail infrastructure at the site. See response to comment 13. 9 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12,2017 Commenting Organization Ite m Old Page/ Section Comment HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed information analyzing trends in waste generation and more indepth review of other landfills is required. 21. Subsection 10A: A market analysis of the need for a commercial facility given existing and potential generation of nonhazardous solid or hazardous waste in the state and regionally 22. Subsection 10A: A market analysis of the need for a commercial facility given existing and potential Updated 18-Dec-17 5:54 PM The report has not provided a market analysis since it does not present the quantities from each waste source and PPR's pricing information is lacking. It does present claims of need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste generation and more indepth review of other landfills is required. H. The report argues that the proposed facility is good for hazardous waste, including ash, and Table 4 summarizes the estimated coal ash along rail system (unsupported). The report has not provided a market analysis since it does not present the quantities from each waste source and PPR’s pricing information is lacking. It does present claims of I. Promontory Point Landfill does not, and will not, accept hazardous waste. Ash is not categorized as a hazardous waste. Coal ash is managed under RCRA subtitle D (EPA 2016). Union Pacific is a major coal hauler and there are several coal fired power plants along its rail lines. Online map: http://arcg.is/0bGGvr. However, ash management decisions are dynamic and depend on, among a multitude of other considerations including coal combustion residual rules and effluent limitation guidelines, the anticipated decommission plans of the local utility. Many utility owners are currently weighing decision on capital investments. Some plant owners might decide to handle ash on site. However, others might decide that because they are close to retirement, the capital expense needed to meet current CCR regulations might not be justified for the short operating duration and so they will ship ash off site. As Union Pacific is a major rail hauler, there might be opportunities to back haul ash from these sites using the same equipment that currently returns to the coal source empty. Again, Promontory’s needs assessment assumes a variety of non­ hazardous industrial waste streams, not coal ash specifically. The report claims that coal-fired power plants will soon need off-site disposal, and Table 5 summarizes the locations and See response to comment #21 10 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Cover Letter from DWMRC July 12,2017 Ite m 23. Old Page/ Section HDR Commenting Organization Utah Department of Environmental Quality, DWMRC Comment Relevant Information from Report generation of nonhazardous solid or hazardous waste in the state and regionally need based on reduced supply and increased demand, as well as general benefits of the facility. Other information analyzing trends in waste generation and more indepth review of other landfills is required. Subsection 10A: The report identifies all facilities within a 50-mile radius except a new facility (“Logan City North Valley”) set to open in Pall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility's competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. A. The report states that there are “seven permitted Class I landfills within Salt Lake region that accept MSW within a fifty-mile radius of Ogden and two Class V landfills” (unsupported). The report identifies all facilities within a 50-mile radius except a new facility (“Logan City North Valley”) set to open in Fall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility's competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. B. The report states that “within the Greater Salt Lake Region, there are two Class V landfills that could compete for waste volumes from outside the State of Utah; Salt Lake SWM Landfill and the Wasatch Regional Landfill.” However, it states that the PPR facility would have an advantage A review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; 24. Preparer Subsection 10A: A review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; Updated 18-Dec-17 5:54 PM Date: 10/24/17 How Addressed estimated tons of coal ash (unsupported). A landfill with a Class I designation would not take the industrial or regional waste described in the Needs Assessment Report. Information on capacity, tipping fees, and environmental compliance record of other commercial facilities is not available because of the proprietary nature of that information. The report incorrectly identified the Salt Lake Valley Landfill as a Class V facility. The Wasatch Regional Landfill and Intermountain Regional are the two Class V landfills in northern Utah which are not rail served and, therefore, receive mainly MSW from the Wasatch Front. 11 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12,2017 Commenting Organization Ite m Old Page/ Section Comment HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed because one of these landfills does not actively seek these types of waste and the other is not along rail lines (unsupported). 25. Subsection 10A: A review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; The report identifies all facilities within a 50-mile radius except a new facility (“Logan City North Valley”) set to open in Fall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility's competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. C. The report states that two of the Class I landfills are near capacity and that “many landfill owners and municipalities within the Salt Lake Region are currently planning for end of life issues such as closure and long-term monitoring costs, waste disposal alternatives, increasing transport costs, future disposal capacity, and regulatory oversight” (unsupported). Master planning is an ongoing exercise for waste districts. In May 2017, Wasatch Integrated Waste Management District’s Administrative Control Board approved an Update to its Integrated Solid Waste Master Plan which identified the need to implement a transfer station following closure of Wasatch’s Davis Energy Recovery Facility, which happened early 2017 (GBB 2017). Trans Jordan has prepared siting and system-wide cost studies to evaluate the addition of transfer stations for the past 15 years (HDR 1998,2001, 2006 and 2010). For context, Logan City started planning for its solid waste management future in 1999. The Waste Disposal Alternatives Study (HDR 2000) evaluated options following closure of the Logan Landfill. It has taken 18 years of citizen outreach, local approvals, and state authorizations to break ground on the Logan North Valley Landfill. The rapid local growth has made solid waste master planning very important, and some entities are behind in their planning efforts. Elected officials and solid waste management leaders like to have options available to address waste management needs long term. Promontory would be a viable costeffective, long-term option as a Class V because the regional waste would subsidize the disposal cost for local MSW currently going to Class I landfills. Updated 18-Dec-17 5:54 PM 12 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization Ite m Old Page/ Section 26. Subsection 10A: Comment A review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; 27. Subsection 10A: A review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; Updated 18-Dec-17 5:54 PM HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report The report identifies all facilities within a 50-mile radius except a new facility (“Logan City North Valley”) set to open in Fall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility's competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. D. The report does not mention any specific facilities beyond the immediate region or proposed sites. Its main argument for competitive advantage is the proximity to rail. The report identifies all facilities within a 50-mile radius except a new facility (“Logan City North Valley”) set to open in Fall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility’s competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. E. The report states that the facility will be “the only major Class I, Subtitle D landfill located directly adjacent to the main trunk of the Union Pacific Railroad line,” allowing it to service areas beyond Utah in addition to the commercial sector (unsupported). How Addressed With Cache County’s move to the North Valley Landfill, all facilities are assumed to meet current siting and landfill design standards. Similarly other regional commercial landfills are assumed to be in compliance with their respective State environmental regulations. Therefore, the main competitive advantage for special waste to Promontory is the cost effectiveness of the rail served facility. See also response to comment #23 regarding the proprietary nature of other facilities. See response to comment #12 regarding rail. See also the Needs Assessment Report Addendum for more information. In the context of the application for a Class V permit which would allow Promontory Point Landfill to serve areas beyond Utah, the Needs Assessment Report incorrectly identified the Promontory facility as a Class I facility. The Needs Assessment Report Addendum clarifies the service area with the landfill designated as Class V. However, Promontory Point Landfill is a Class I facility, and, as a Class I, it can serve areas in Utah when it secures contracts with local governments or special service districts. With the rail infrastructure investment at Promontory, some communities and some pending special remediation project managers (prison relocation and airport expansion) could decide to rail-haul waste to Promontory. Some districts might realize that rail hauling is feasible. Rail hauling in-state waste would reduce truck traffic, reduce fuel consumption, and reduce air pollutant emissions. 13 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization Ite m Old Page/ Section 28. Subsection 10 A: Comment A review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; 29. Subsection 10A: A review of other existing and proposed commercial nonhazardous solid or hazardous waste facilities regionally and nationally that would compete for the treatment, storage, or disposal of the nonhazardous solid or hazardous waste; 30. Subsection 10B: The need in the state for the additional capacity for the management of nonhazardous solid or hazardous waste Updated 18-Dec-17 5:54 PM HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report In addition to accepting “CalHaz” and ash as previously mentioned, the report claims that the facility will provide “turn-key disposal solutions for contaminated soil” (unsupported). How Addressed See responses to comments #17, #19, and #21. The report identifies all facilities within a 50-mile radius except a new facility (“Logan City North Valley”) set to open in Fall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility's competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. F. The report identifies all facilities within a 50-mile radius except a new facility (“Logan City North Valley”) set to open in Fall 2017. However, the report lacks a robust review of these local sites and presents little information on facilities outside the region. The main argument for the facility's competitive advantage is its proximity to rail; however, much of the evidence and rationale for that claim is unsupported in the report. G. The report presents the average disposal price for soils or solids in different regions of the United States (supported). Comment noted The report lacks information to demonstrate the need for additional capacity. The report establishes need based on the growing local population and the facility's ability to take commercial and out-ofstate waste (unsupported). See the response to comment #10. Annual waste volumes in northern Utah will be 88% higher by 2065 (between 3.7 million and 5.0 million tons annually), nearly double 2015 volumes (2.0 million to 2.7 million tons). The Promontory Point Landfill has local support and has received conditional use permit approval. The Class V designation (commercial 14 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Cover Letter from DWMRC July 12, 2017 Ite m Old Page/ Section Comment Preparer HDR Commenting Organization Utah Department of Environmental Quality, DWMRC Relevant Information from Report Date: 10/24/17 How Addressed landfill) significantly benefits Box Elder County. The County Commission approved an amendment to Chapter 3-8 Land Use Management & Development Code to specify a Solid waste Zone (Ordinance 442). Chapter 3-8 also specifies Host Fees for the County. These host fees will total $2.00 per ton starting in 2019 for Promontory. Box Elder is a large rural county in northwest Utah. It has a small population of 42,910 of which 9,585 people (18%) live in unincorporated portions of the County and it has very small tax base. According to their 2016 budget, the County had total revenue of about $8,103,000 from all sources. With expenditures of $9,706,620 Box Elder County was faced with a funding gap of $1,603,629. Promontory Point Landfill offers Box Elder County the ability to close this gap with host fees and taxes. Box Elder County commission a study by the University of Utah’s Gardner Policy institute to look at the economic and fiscal benefits of the Promontory Point Landfill. In addition to host fees, the economic impact generated by the Promontory Point Landfill equates to a 15-year (2017 to 2031) net present value of $31,000,000 in new net local revenues and $12,500,000 in new State revenues. In the context of Box Elder’s funding gap, landfill related transactions will pay $906,000 in local taxes initially and growing to 2,200,000 in year 2031. The Utah Legislature recognized the “favorable economic impact on Box Elder County in the form of new permanent jobs and host fees” and approved House Resolution 20 in 2016 that authorized the commercial facility in accordance with Utah Code 19-6-108 part (3)(c)(B) Updated 18-Dec-17 5:54 PM 15 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization Ite m Old Page/ Section 31. Subsection 10B: Comment The energy and resources recoverable by the proposed facility; 32. Subsection 10B: The energy and resources recoverable by the proposed facility; 33. Subsection 10B: The reduction of nonhazardous solid or hazardous waste management methods, which are less suitable for the environment, that would be made possible by the proposed facility; Updated 18-Dec-17 5:54 PM Although the report presents some information on methane recovery and the facility's ability to “store” certain wastes for re-use, it should provide additional information on storage, treatment, and potential methane generation. HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed The report states that the facility will be primarily “powered by renewable energy, designed to efficiently capture and clean methane to produce transportation fuels and built to ‘store’ certain municipal solid waste and nonhazardous industrial wastes for current and future beneficial re-use applications” (unsupported). To clarify, Promontory will install a solar microgrid to power the Promontory Point Landfill site. Also, Promontory will install a gascollection system to capture the methane generated by the landfill. In the future, when enough gas is generated, the methane will be cleaned and used as a transportation fuel. Although the report presents some information on methane recovery and the facility's ability to “store” certain wastes for re-use, it should provide additional information on storage, treatment, and potential methane generation. In addition, the report states that captured gas will be used to generate electricity “as well as cleaned and compressed to manufacture transportations fuels and power natural gas fueled vehicles” (unsupported). See response to comment #31 Although the report briefly mentions recovery techniques, it lacks a discussion of waste reduction management methods. The report states that the facility “will be a state-of-the-art disposal and materials management center, operated by highly experienced personnel, who will ensure proper disposal, recovery and tracking of industrial waste entering the site” (unsupported). Given its Class I permit, Promontory meets all solid waste facility siting and design standards in R315. See Permit Application (March 2017) materials. Because of the size of the Promontory site, there is opportunity to segregate waste, stockpile inert materials for reuse, and implement other waste­ processing technologies to recover embodied energy. Promontory leadership has vast experience operating landfills. They have in excess of 100 years of industry experience. Leadership biographies are presented in the Needs Assessment Report Addendum. Waste reduction management methods are driven by state and local policies. Promontory does not change these policies. Landfilling is an environmentally safe and responsible waste disposal method. The Promontory Point Landfill does not preclude any waste reduction methods. 16 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12,2017 Commenting Organization Ite m Old Page/ Section 34. Subsection 10B: Comment Whether any other available site or method for the management of hazardous waste would be less detrimental to the public health or safety or to the quality of the environment. 35. Subsection 10C: Compliance history of an owner or operator of a proposed commercial nonhazardous solid or hazardous waste treatment, storage, or disposal facility, which may be applied by the director in a nonhazardous solid or hazardous waste operation plan decision, including any plan conditions. 36. Subsection 11A: The probable beneficial environmental effect of the facility to the state outweighs the probable adverse environmental effect; This requirement is not applicable. Although the proposed facility does intend to take “Cal-Haz” waste, it will not accept federally regulated hazardous waste. HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report The report states that hazardous waste, as identified and regulated under the Code of How Addressed Comment noted Federal Regulations, Title 40, Part 261, “will not be accepted for disposal at Promontory Point Landfill.” Additional information is needed to confirm that facility owners/upper management have no history of noncompliance (i.e., resumes or work history of founders and senior leadership). The report mentions that “the founding partners and senior leadership of Promontory Point Resources, who will manage the site, do not have any record, notice of action of noncompliance violation with the State of Utah (or any other State), Local or Federal Local Enforcement Agency ('LEA') or agency regarding compliance with nonhazardous and/or hazardous waste treatment, storage or disposal facility” (unsupported). The Needs Report Addendum contains leadership bios and Promontory can provide resumes upon request. Although the report describes several facility attributes demonstrating beneficial environmental impact, much of this information lacks needed detail. The report also fails to include potential adverse environmental impacts. The report lists several positive attributes (synthetic liner to protect groundwater, storage of certain materials for re-use, rail line usage to reduce truck vehicle miles traveled and emissions, etc.) (unsupported). See complete permit application for details of Promontory Point Landfill’s design features and environmental monitoring procedures. In addition to the Class I and Class V solid waste permit (requiring environmental protections and monitoring). Promontory will secure air quality and stormwater permits for construction and operation of the landfill, all of which are in place to protect the environment. DWMRC staff have visited the site and observed construction. A construction certification is pending Updated 18-Dec-17 5:54 PM 17 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization Ite m Old Page/ Section Comment HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed to prove that the construction was performed according to the plans and specifications in the Class I landfill permit. Regarding the potential to reduce truck vehicle miles traveled, gondola railcars have nearly 5 times the capacity of tandem axle tractortrailers. Assuming 100 tons per railcar capacity, a unit train can carry almost 100 railcars or 10,000 tons. Assuming 25-ton payload for a tractor-trailer, one unit train would replace 400 tractor-trailers. 37. Subsection 1 IB: There is a need for the facility to serve industry within the state Although the report states that there is a need for the facility, it does not provide sufficient information to support that claim. The report reiterates the need for the facility to serve industry and points to the facility’s proximity to rail as a competitive advantage. See previous responses Response to Comments contained in SC&A Report Appendix B 38. Pg. 3, Paragraph 4 “Seven permitted Class I landfills within Salt Lake region that accept MSW within a fiftymile radius of Ogden and two Class V landfills” Confirmed for current landfills, but SC&A identified an additional landfill (“Logan City North Valley”) which is set to open in Fall 2017. Also, noticed a discrepancy as Salt Lake Landfill is classified as Class V in the report but is a Class I landfill. Source: Logan City North Valley - North Valley Landfill (2016), http://www.loganutah. org/govemment/ departments/ environmental/landfill/ north valley landfill.php Salt Lake - 2016 Annual Report Logan City North Valley is a Class I facility taking waste from Cache County communities exclusively, (source: 2013 permit application) 39. Pg. 3, Paragraph 5 “Two of the current Class I landfills will soon reach capacity. Reported tonnage disposed in 2015 at both facilities was 250,070 tons.” Logan City Landfill does have a remaining capacity of 5 years but it is building a new facility. The next lowest landfill in terms of capacity is 2015 Data Updated 18-Dec-17 5:54 PM Logan City - 77,770 MSW and 35,341 C&D Trans Jordan - 287,622 MSW and 24,298 C&D 18 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Cover Letter from DWMRC July 12, 2017 Ite m Old Page/ Section Preparer Commenting Organization Comment HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed Trans Jordan Cities (15 years). Unable to confirm tonnage as the report does not name the facilities. Source: Logan City - Carl Francis, Landfill Manager for Logan City Landfill, Trans Jordan Cities - 2016 Annual Report 40. Pg. 4 “Waste generation per person per day was 4.44 pounds.” Content is correct from source and source is valid. However, this claim does not account for waste generation trends that show a leveling off and overall decrease in waste generation per capita since the 1980s. Source: Source provided - U.S. EPA, Advancing Sustainable Materials Management: 2014 Fact Sheet, November 2016, page 2. No material decrease in per capita waste generation trends. Source data is 2012 and overall economy has picked up sense that time. Recent reports from CalRecyle and calculations from Salt Lake and Utah County indicate total land disposal is closer to 6 pounds per capita per day. See the Needs Assessment Report Addendum. Trends source - U.S. EPA, Municipal Solid Waste Generation, Recycling and Disposal in the Unites States: Facts and Figures for 2012, https://www.epa.gov/ sites/production/files/ 2015-09/documents/ 2012 msw fs.pdf 41. Pg. 4 Updated 18-Dec-17 5:54 PM “Population of the Northeastern Region will increase by more than 60% by 2060.” Content is correct from source and source is valid. However, largest percent change in population growth expected to be south of this region; Washington County and counties along the Wasatch Front (Utah, Wasatch, Tooele, and Summit) projected to experience the largest Wasatch Front communities will generate the most waste (from a total tonnage standpoint) for the foreseeable future. 19 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12,2017 Commenting Organization Ite m Old Page/ Section Comment HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed percentage change between 2010 and 2050. Source: Source provided - Governor's Office of Management and Budget, Economic Analysis & Demographics, http://gomb.utah.gov/ budgetpolicy/ demographic-economicanalvsis/ Population Growth Source - Utah Foundation 42. Pg. 5, Paragraph 5 “Promontoiy Point Landfill is believed to be the only major United States Class I, Subtitle D landfill located directly adjacent to the main trunk of the Union Pacific Railroad line.” More information on site location is needed to confirm rail access. In addition, report implies direct truck access but information is also lacking. Conversations with Union Pacific have been occurring for many years. Union Pacific has define the track design standards and is currently reviewing preliminary track plans. In the future, rail access to Promontory Point Landfill could encourage other government entities in Utah to rail haul to the landfill even under its current Class I landfill designation. The Promontory Point Landfill is accessible by a Box-Elder County designated Class B road. See Appendix L-2 of the permit application, which is approval from the Utah Department of Transportation, and Appendix L-3, which is a traffic impact study submitted to Box Elder County and which was approved with Promontory’s conditional-use permit from the county. 43. 44. Pg. 6, Paragraph 2/3 Pg. 6, Paragraph 2/4 Senior leadership team has “over one hundredfifty years of combined waste industry experience.” PPR will have “largest capacity of any Class I or V facility in Utah.” Unable to confirm as website only provides bios for four team members. and resumes can be provided. Source: PPR website: http://www.promontory pt.com/meet-us/ Current website: ECDC Environmental EEC has greater capacity in terms of tons. Comment noted. Source: ECDC Updated 18-Dec-17 5:54 PM Additional bios are provided in the Needs Assessment Report Addendum https://allosenv.com/our-team The capacity of ECDC, as reported by SC&A, was not verified. Promontory Point Landfill offers a more 20 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Preparer Cover Letter from DWMRC July 12, 2017 Commenting Organization Ite m 45. 46. Old Page/ Section Comment Pg. 7, Paragraph 2 Pg. 8, Paragraph 2 47. Pg. 9, Paragraph 1+ HDR Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed Environmental 2016 Annual Report (provided by Darin Olson of Republic Services) convenient disposal option for Utah’s northernmost communities. “Despite the availability of capacity at existing Class 1 landfills in the Greater Salt Lake Area, the cost of transportation and disposal is relatively high compared to what Promontory Point Landfill can offer local communities for disposal of their residential waste.” Able to confirm average cost of disposal for municipal solid waste for Class I landfills in the region, but lacking PPR prices for comparison. Promontory prices are proprietary as are other regional commercial facilities. “Moving soil to one of the two Subtitle C landfills in California is cost prohibitive. The estimated cost to transport waste over the three-hundred-mile roundtrip route from Los Angeles to the closest landfill is approximately forty dollars ($40) per ton. Including the approximate disposal fee of eight dollars ($80) per ton, the expected all in pricing per ton is estimated to be approximately one hundred- twenty dollars ($120) per ton” External source estimates disposal fee to be closer to $60 per ton, including taxes, for remediation waste. Source: Rob Heller, Director of Landfill Sales in Southern California for Waste Management Table 3: Waste Generation in Northern and Southern California 2014-15 Estimates of overall soil and ash generated in California do not match estimates in the report. More information on the report's method of calculation is needed to confirm. Source: Promontory would not be investing in the project if it and its investors did not believe they could offer competitive pricing that could attract waste to Promontory Point Landfill. SC&A example provides support for Promontory’s cost effectiveness. Assuming $3.00 per mile waste haul (GBB 2017) in 25-ton tractor- trailers, a 300-mile roundtrip equates to about a $36 per ton hauling cost and a $96/ton total cost (assuming $60/ton disposal fee). These values are very close to the values reported in Promontory’s Needs Assessment Report. Hazardous Waste Tracking System (HWTS) Updated 18-Dec-17 5:54 PM Date: 10/24/17 The totals provided in the Needs Assessment Report are from Promontory’s research. The report acknowledges that it is not a comprehensive list compared to the references provided by SC&A. Note that the SC&A referenced CalRecycle Report references 2008 data so it would not match 2014-2015 estimates in Promontory’s Needs Assessment Report. 21 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Cover Letter from DWMRC July 12,2017 Ite m Old Page/ Section Preparer HDR Commenting Organization Utah Department of Environmental Quality, DWMRC Comment Relevant Information from Report Date: 10/24/17 How Addressed http://hwts.dtsc.ca.gov/ report list.cfm CalRecycle - https://www2.calrecvcle. ca.gov/WasteCharacteriz ation/PubExtracts/2014/ SigTableFig.pdf 48. Pg. 9, Paragraph 3+ Table 4: Annual Coal Ash Generation along the Western Union Pacific Railroad System Unable to confirm with the information provided. Source: Obtained average coal ash generated per power plant (https://www.epa.gov/ coalash/frequentquestions-about-coalash-disposal-rule#2) but unclear how exactly the report calculated these numbers See response to comment #21. 49. Pg. 10, Paragraph Table 5: Estimated On­ site Coal Ash by State Unable to confirm with the information provided. See response to comment #21. 1+ Source: Obtained average coal ash generated per power plant (https://www.epa.gov/ coalash/freauentguestion s- about-coal-ashdisposal-rule#2) and estimates of total ash that gets disposed on site (https://www.epa.gov/co alash/frequentquestionsabout-coal-ash-disposalrule#3). but unclear how exactly the report calculated these number 50. Pg. 10, Paragraph 2 Updated 18-Dec-17 5:54 PM “A gondola railcar has a maximum weight capacity of one hundred-ten tons, almost five times the capacity of an over the road tractor-trailer combination.” Weight capacity can vary, sources confirm that, in general, railcar maximum capacity is larger than that for a tandem axle. Comment noted. See also response to comment #36. Source: Railcarhttps://www.up.com/ 22 of 23 Promontory Point Class V Landfill Needs Assessment Report, Evaluation Review Comment and Response Matrix Evaluation of the Promontory Point Resources Needs Assessment Report (SC&A, July 10,2017) Cover Letter from DWMRC July 12, 2017 Ite m Old Page/ Section Preparer Commenting Organization Comment HDR Date: 10/24/17 Utah Department of Environmental Quality, DWMRC Relevant Information from Report How Addressed customers/all/equipment/ descriptions/gondolas/ index.htm Tandem axle - https://ops.fhwa.dot.gov/ freight/sw/overview/ 51. Pg. 11, Paragraph 3 “While regional tipping fees for commercial customers average approximately $30 per ton, transfer and transport can increase the total amount of disposal past $40 per ton.” The average regional tipping fees are consistent with facility websites ($30). Unable to confirm transport information with information provided. Regarding tipping fees, comment noted. A $10 per ton hauling is approximately equivalent to an 83mile round trip (at $3 per mile and 25-ton capacity tractor-trailer). Assuming a 40-ton capacity, a 133mile round trip would cost about $ 10/ton (at $3/mile). The Needs Assessment Report Addendum contains additional information on transportation costs. 52. Pg. 11, Paragraph 5+ Updated 18-Dec-17 5:54 PM Table 7: Waste Steams Available for Disposal at Promontory Point Class V Landfill Need to confirm Table 7 as it summarizes waste volume generation from key sources, based on values presented previously in this table. Table 7 of the Needs Assessment Report presents a summary of waste volumes potentially available to Promontory. The sum of annual tonnage (not including coal ash) equals 2,786,700 tons. Promontory can be operational and financially viable with only a fraction (5 to 10%) of this annual tonnage. Assuming 15% to 20% (200,000 to 300,000 tons per year) makes Promontory’s operation equivalent to the larger landfills in northern Utah (Wasatch Integrated, Bayview, Trans Jordan, Salt Lake Valley). 23 of 23