F ajardo is a municipality on the east coast of Puerto Rico with beautiful marinas and vibrant tourist activity, which are an important part of its economy. It has a beautiful nature reserve called Las Cabezas de San Juan, a bioluminescent bay, and key areas of the Yunque National Rainforest, mainly undeveloped areas in a state of conservation. Several areas were affected by illegal dumping activities, and Fajardo representatives, who had little success in combating the problem, contacted RCAP Solutions for assistance. RCAP Solutions (RSOL) performed a site visit to the affected areas. It validated the severity of the situation and shared opportunities to improve these areas and eventually eliminate the problem. The first aspect we focus on is who is causing the problem and why. A major reason is often a lack of education and limited environmental awareness of residents. The lack of empathy and respect for society is another element; however, in this case, we focus on the most practical points to address the problem. How do we engage those who can address the problem and allocate resources to support the necessary management? For those who will treat or remedy the area, it is important to know why. For those who have the decision-making capacity to allocate resources, it is more important to know the effect illegal dumping has on our communities, public health, and the environment. There are certain criteria and tools available that we must consider when reporting these clandestine dumping activities. How do we effectively and fully report these illegal landfills to each stakeholder? Who are those stakeholders? First, a distinction must be made between clandestine landfills, where an organization, company, or individual regularly disposes of its waste systematically, and the repeated dumping by members of the community without any consideration to the damage it will cause. In both cases, this can occur on private property either by the owner or by others without the owner’s consent. In general, this constitutes a clandestine landfill, since it is not an authorized location for the disposal or management of waste. If there are no controls in place to prevent pollution, it is considered an illegal landfill that endangers public health and the environment. When organizations dump waste as part of an operation, they are required to have adequate management of the waste they generate, and these waste generators or managers are known as a regulated community. They assume responsibility in the eyes of the government for all of their operations and must comply with the regulations that apply to them. They need to have the permits from the regulatory bodies according to the type of operation. These regulations may be more stringent in some states or territories, either by federal or state legislation, including subdivisions of local government. These regulators may be part of the “stakeholders” with which we need to address the issue and should be included in our reporting process. Those that are contributing to the illegal dumping in one of these regulated communities are considered waste handlers. Typically, the complaint may be for facilities that fall within the
definition of an illegal dump if they do not follow regulations or damage is observed in the areas surrounding or influenced by the facility. However, in this case, RSOL is referring to landfills in places that are not managed or regulated for this purpose but are open spaces, public or private. Some evidence or examples that we will mention could be helpful for the regulated areas that also have illegal or clandestine activity. How do we know what kind of illegal landfill it is? The kind of illegal landfill usually depends on the type of materials found and the amount of each material in proportion to the others. We refer to categories of materials as such: construction and demolition waste (C&D); furniture and bulky material such as mattresses and appliances (whites) and electronics (e-waste); household hazardous waste (HHW); tires, auto parts, and chemical waste such as oils, grease, and paint; biological waste such as dead animals; clinical waste; and other types. Assessing the Problem The RCAP Solutions staff assessed the affected areas and the services available for controlled disposal. Interviews were conducted with residents to understand the current behavior, including stakeholders such as landfill staff. Discarded building materials were identified in the affected locations, likely associated with small contractors or homeowners conducting DIY projects or home repairs. Other materials, such as kitchen furniture and crockery pieces, toilets, and sinks, helped to validate these assumptions. In the area of commercial activity, it was possible to identify a large number of tires dumped on the side of the road near the landfill, with the intention of hiding the number of continuous deposits made. This is indicative of a relentless and systematic practice. It is important not only to document the activity by taking photos of the sites, the discarded materials, the access areas, and observations of the disturbances created on the site, but also to thoroughly review all details. RSOL also established that the probable cause was due to a lack of solid waste services in the area. Although the municipality offers special collections and publicizes these services, some interviewees were unaware of the collection routes and what types of materials the municipality collects. Unfortunately, there is no service available for some materials, and little information is available on how to proceed if you need to dispose of those types of materials. If the residents believe that there are no other alternatives, they will dispose of their waste when and where they can without any further consideration. Once they dump it somewhere, they believe that the problem belongs to someone else, mainly the government. Among those interviewed, there was no knowledge of who owns the areas where the dumping takes place or the possible effects on their health or the environment due to this illegal dumping. Others simply want to avoid the cost of landfill disposal and show a certain level of ignorance on the topic. In the case of used tires, storage costs can be added to the equation due to a deficiency in the disposal system in place for the diversion of this type of material. Data to Assess Potential Impact Photos, interviews, and a deeper knowledge of the problem are a vital component, but the challenge is to present this information to the stakeholders and engage them in the solutions, which can
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