# Integrated Solid Waste (2024)

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/tribal%3Aconfederated_clusi%3Ac94cb25af12beba4

## Record

- **Collection:** Tribal code
- **Document type:** Tribal code

## Text

Integrated Solid Waste
Management Plan 2024

NovePEHU4

CONFEDERATED TRIBES OF COOS, LOWER UMPQUA, AND SIUSLAW
INDIANS

INTEGRATED SOLID WASTE MANAGEMENT PLAN
Coos Bay, Oregon

Prepared for

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians

Prepared by

RIDOLFI Inc.

November 2024

EXECUTIVE SUMMARY
This Integrated Solid Waste Management Plan (ISWMP) was prepared to guide and support the
Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians (CTCLUSI or Tribes) in
maintaining and improving environmental quality and reducing costs through proper

management of solid waste. It is designed to provide a strategic approach that will allow the

Tribes to answer three basic questions about solid waste management: (1) Where are we now?
(2) Where do we want to go? (3) How do we get there?

This ISWMP contains information needed to answer the first question. The Strategic

Implementation Plan provided in Appendix F is a critical part of the ISWMP providing the

structure, framework, and guidance for the Tribes to answer the second and third questions.
This ISWMP builds on the previous ISWMP that the Tribes developed in 2013, and considers

changes in the Tribes’ population, land base, facilities, and enterprises. It considers changes in

Oregon state laws and policies and changes in available waste management options and costs
associated with solid waste collection, handling, and disposal.

The Strategic Implementation Plan (Appendix F) provides a relatively simple and useful roadmap
that will guide the Tribes during the next five years (2024 – 2028) as they endeavor to

implement initiatives to support the accomplishments of the Tribes’ solid waste management

goals.

The objective of this ISWMP is to maintain and improve Tribal environmental quality and reduce
costs through proper management of solid waste. To support the Tribes’ efforts to achieve this

objective, this ISWMP does the following:

1. Describes current waste management practices.

2. Identifies needs, challenges, and opportunities for improvement.

3. Recommends approaches to address needs and challenges to reduce waste
management costs and environmental impacts.

This ISWMP addresses three major categories of solid waste generators:
1. Tribal residents (in Tribally managed housing and private housing)

2. Tribal facilities (administrative offices, services, and infrastructure)

3. Tribal enterprises (casinos, golf course, and planned future developments)
CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page i

The ISWMP includes quantitative estimates of the types and quantity of waste being generated.
The estimates are based on waste stream composition studies conducted by Oregon

Department of Environmental Quality. Food waste, paper, and plastic are the largest categories
of waste generated by households and commercial businesses. The waste streams from Tribal

administrative offices and services are different in some respects but are probably similar in
composition.

Currently, the Tribes are paying multiple waste disposal companies to manage waste from

facilities and Tribal housing. The cost of waste management at the casinos, golf course, RV park,

and for individual Tribal members living outside Tribal housing areas are separate from the costs
being paid by the Tribes. Waste management costs for garbage disposal represent the largest

percentage of total waste management costs; therefore, diverting a portion of this waste stream

away from landfill to recycling or composting facilities could substantially reduce costs.

This ISWMP also provides projections of future solid waste quantities and costs, which are

anticipated to increase if active measures are not taken to reduce waste generation and divert
solid waste away from disposal and into recycling and composting. If per capita waste

generation rates remain close to current rates, CTCLUSI should expect its total residential waste
generation and associated disposal costs to increase by 25 percent in 10 years.

Conclusions and recommendations are provided in Section 9 and identify alternatives for waste
management aimed at reducing waste management costs and adverse environmental impacts.

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Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page ii

TABLE OF CONTENTS
EXECUTIVE SUMMARY ................................................................................................................................................... i
1.0

INTRODUCTION................................................................................................................................................... 1
1.1
1.2
1.3

2.0

CTCLUSI TRUST LANDS AND FEE LANDS .................................................................................................. 4
2.1
2.2
2.3
2.4
2.5
2.6

3.0

History ......................................................................................................................................................... 4
Land Use ..................................................................................................................................................... 4
Demographics .......................................................................................................................................... 5
Residential.................................................................................................................................................. 5
Tribal Services ........................................................................................................................................... 6
Tribal Enterprises ..................................................................................................................................... 6

CURRENT SOLID WASTE GENERATION RATES AND COMPOSITION ............................................. 7
3.1
3.2
3.3

4.0

Goals and Objectives ............................................................................................................................. 1
Climate Change........................................................................................................................................ 1
Waste Generators.................................................................................................................................... 2

Residential.................................................................................................................................................. 8
Tribal Facilities .......................................................................................................................................... 9
Tribal Enterprises ...................................................................................................................................10

CURRENT SOLID WASTE MANAGEMENT SYSTEMS ............................................................................12
4.1

Oregon ......................................................................................................................................................12
4.1.1
4.1.2

4.2

Counties ....................................................................................................................................................13
4.2.1
4.2.2
4.2.3
4.2.4
4.2.5

4.3
4.4
4.5

5.0

Coos County..........................................................................................................................13
Curry County .........................................................................................................................13
Douglas County ...................................................................................................................13
Lane County ..........................................................................................................................14
Lincoln County .....................................................................................................................14

Tribal Departments Involved in Waste Management .............................................................14
Residential................................................................................................................................................16
Tribal Facilities ........................................................................................................................................18
4.5.1
4.5.2
4.5.3

4.6

Current Conditions .............................................................................................................12
Anticipated Changes ..........................................................................................................13

Coos Bay and Florence Tribal Administrative Offices ............................................18
Laboratory ..............................................................................................................................18
Dental Clinic ..........................................................................................................................19

Tribal Enterprises ...................................................................................................................................19

PROJECTED FUTURE WASTE GENERATION ............................................................................................20

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Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page iii

5.1
5.2
5.3

Residential................................................................................................................................................20
Tribal Facilities ........................................................................................................................................20
Tribal Enterprises ...................................................................................................................................21
5.3.1
5.3.2
5.3.3

6.0

WASTE MANAGEMENT OPTIONS AND OPPORTUNITIES FOR IMPROVEMENT.......................22
6.1
6.2
6.3
6.4
6.5
6.6
6.7
6.8

7.0

Source Reduction ..................................................................................................................................22
Reuse .........................................................................................................................................................23
Recycling ..................................................................................................................................................23
Composting .............................................................................................................................................24
Landfill Disposal .....................................................................................................................................24
Incineration..............................................................................................................................................25
Backyard Burning ..................................................................................................................................25
Hazardous Waste Management ......................................................................................................26

PUBLIC OUTREACH AND EDUCATION......................................................................................................27
7.1
7.2
7.3

8.0

Florence Casino RV Parking Expansion .......................................................................21
Coos Head Development .................................................................................................21
Hanisiich Village...................................................................................................................21

Goals and Objectives ...........................................................................................................................27
Outreach Methods ................................................................................................................................27
Measuring Effectiveness .....................................................................................................................28

IMPLEMENTATION ...........................................................................................................................................29
8.1
8.2
8.3
8.4

Roles and Responsibilities of Tribal Personnel ..........................................................................29
Strategic Implementation Plan ........................................................................................................29
Resources and Funding Sources .....................................................................................................29
Recommendations for Waste Reduction and Diversion ........................................................30
8.4.1

Source Reduction ................................................................................................................30
8.4.1.1
8.4.1.2
8.4.1.3

8.4.2

Reuse .......................................................................................................................................31
8.4.2.1
8.4.2.2
8.4.2.3

8.4.3

CTCLUSI_ISWMP_Nov 2024

Residential Reuse ........................................................................................31
Reuse for Facilities ......................................................................................33
Reuse Methods for Enterprises ..............................................................33

Recycling ................................................................................................................................34
8.4.3.1
8.4.3.2
8.4.3.3

8.4.4

Residential Source Reduction Methods .............................................30
Government and Facilities Source Reduction Methods ...............30
Source Reduction Methods for Enterprises ......................................31

Residential Recycling .................................................................................34
Facilities Recycling ......................................................................................34
Enterprise Recycling ...................................................................................35

Composting ...........................................................................................................................35
Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page iv

8.4.4.1
8.4.4.2
8.5
9.0

Residential Composting............................................................................35
Facilities and Enterprises Composting ................................................35

Cost Savings Opportunities from Waste Diversion and Reduction ...................................35

CONCLUSIONS AND RECOMMENDATIONS ..........................................................................................37

10.0 REFERENCES ........................................................................................................................................................39

LIST OF FIGURES
Figure 1.

Location Map

Figure 2.

Tribal Properties and Solid Waste Management Facilities

Figure 4

Tribal Properties and Solid Waste Management Facilities, Coos Bay, Oregon

Figure 3.

Figure 5.

Tribal Properties and Solid Waste Management Facilities, Florence, Oregon

Tribal Properties and Solid Waste Management Facilities, Coos Head, Oregon
LIST OF TABLES

Table 1.

Waste Categories Used in the Waste Stream Composition Analysis

Table 3.

Estimate of Waste Generation Quantities by Enterprise

Table 2.

Table 4.

Table 5.

Table 6.

Table 7.

CTCLUSI Residential and Commercial Waste Stream Generation and Composition

Estimate of Waste Stream Generation Quantities and Composition by Enterprise

CTCLUSI Residential Projected Growth

Projected Future Waste Generation due to Enterprise Expansion

Cost Savings Opportunities from Waste Diversion
LIST OF APPENDICES

Appendix A.

Waste Reduction Tips for Hotels and Casinos

Appendix B.

Compostable Food Service

Appendix D.

Laboratory Waste Management Information

Appendix F.

Strategic Implementation Plan

Appendix C.

Appendix E.

Appendix G.

Appendix H.

CTCLUSI_ISWMP_Nov 2024

Composting Basics and Methods

Photographs from CTCLUSI Site Visit
Resources and Funding Sources

Responses to USEPA Review Comments

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page v

LIST OF ABBREVIATIONS AND ACRONYMS

BIA

Bureau of Indian Affairs

CHAMP

Coos Head Area Master Plan

degrees F

degrees Fahrenheit

CTCLUSI

HUD

ISWMP
IHS
IT

ITEP

ODEQ
PRO
PSU
RV

SWAC

SWIFR
Tribes

USEPA

CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
U.S. Department of Housing and Urban Development
Integrated Solid Waste Management Plan
Indian Health Service

Information technology

Institute for Tribal Environmental Professionals
Oregon Department of Environmental Quality
Producer Responsibility Organization
Portland State University
Recreational Vehicle

Solid Waste Advisory Committee

Solid Waste Infrastructure for Recycling

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
U.S. Environmental Protection Agency

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page vi

1.0 INTRODUCTION
This Integrated Solid Waste Management Plan (ISWMP) was prepared to guide and support the

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians (CTCLUSI or Tribes) in

maintaining and improving environmental quality through proper management of solid waste. It
is designed to provide a strategic approach that will allow the Tribes to answer three basic

questions about solid waste management: (1) Where are we now? (2) Where do we want to go?
(3) How do we get there?

This ISWMP builds on the previous ISWMP which the Tribes developed in 2013 (CTCLUSI, 2013),

and considers changes in the Tribes’ population, land base, facilities, and enterprises. It

considers changes in Oregon state laws and policies and changes in available waste

management options and costs associated with solid waste collection, handling, and disposal.
1.1

Goals and Objectives

The objective of this ISWMP is to maintain and improve Tribal environmental quality through
proper management of solid waste.

Goals that support and will lead to the accomplishment of this objective are:
•

Describe current waste management practices and challenges and identify potential
actions and initiatives to improve the current situation.

•

Identify waste management needs for Tribal facilities and residents, develop options,
and identify cost-effective approaches to address these needs.

•

Identify opportunities to reduce waste generation by promoting waste reduction and
diverting reusable, recyclable, and compostable materials out of the current waste

stream.
•

Review existing Tribal codes and regulations and recommend potential management

and enforcement measures to address illegal dumping and disposal of solid waste on
Tribal lands and properties.

1.2

Climate Change

There are several aspects of solid waste management that contribute to climate change, many of
which can be addressed and altered to lessen their impact. Hauling and disposal of solid waste

requires significant amounts of energy and releases harmful emissions into the atmosphere. The
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Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 1

equipment used to collect, haul, and handle solid waste is fueled by gasoline and diesel. Burning
these fuels in internal combustion engines releases carbon dioxide and other greenhouse gases
into the atmosphere. These gases contribute to an increasingly dense atmosphere that holds

solar heat in the thin layer of air that surrounds the earth, increases global temperatures, and
contributes to adverse climate change. By reducing the volume of solid waste that must be
collected, hauled, and handled, emissions of these greenhouse gases can be reduced thus
reducing the adverse effects of climate change.

Greenhouse gases are emitted into the atmosphere whenever solid waste is burned in

incinerators, open dumps, and burn piles. Landfills also generate and emit methane gas as waste
decomposes. Due to its chemical composition, methane is 80 times more detrimental to the

atmosphere than an equal volume of carbon dioxide (MIT, 2023). By working to reduce solid
waste generation and to divert waste away from landfills and into composting or recycling
facilities, lower volumes of greenhouse gases will be released into the atmosphere, thus

reducing human impacts on climate change.

However, recycling and composting also have some climate change impacts, as they also require
hauling of waste to transfer stations and recycling and composting centers; therefore, reduction
of overall waste volumes by reducing consumption and increasing reuse and repair of used
goods is the best way to reduce climate change impacts.

Integrated solid waste management planning serves to develop systems that reduce waste

generation and allow for management of solid waste collection, handling, and disposal in a

more environmentally sound manner. Changing not only the waste disposal methods but

reducing the waste stream volume and composition is the most effective way to reduce climate
change impacts.
1.3

Waste Generators

This ISWMP addresses the waste generation from several sources within the Tribes’ traditional

territory, properties, and facilities. This section is organized by types of Tribal facilities,
properties, and areas.
•

Residences
o

Tribally owned housing




CTCLUSI_ISWMP_Nov 2024

Qa’aich Development (Florence)

Qaxas Heights (North Bend)

Tribal housing in Coos Bay

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 2

o
•

Tribal facilities
o
o
o
o
o
o
o
o

•

Privately owned housing occupied by Tribal members

Tribal Hall and Community Center (Coos Bay)

Government Offices (Coos Bay)

Housing Department (Coos Bay)

Laboratory (Coos Bay)

Dental Clinic (Coos Bay)

Community Garden (Coos Bay)

Wastewater Treatment Plant (Florence)

Outreach Office (Florence)

Tribal enterprises
o
o

Three Rivers Casino (two locations: Florence and Coos Bay)

Golf Course (Florence)

During September 2023, a Ridolfi field team visited these locations to conduct reconnaissance

within the Tribes’ properties and facilities and obtain information from Tribal managers on waste

collection practices, goals for waste management, potential improvements, and future

expansion plans. Photographs from the Ridolfi field team site visit are included in Appendix E.

CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
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2.0 CTCLUSI TRUST LANDS AND FEE LANDS
2.1

History

The history of the Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians (CTCLUSI) is
summarized in this section. A more detailed history is available at https://ctclusi.org/history/.

The CTCLUSI are made up of three Tribes that trace their ancestry to the aboriginal inhabitants
of what is now the South-Central Oregon Coast. The people lived in villages of cedar plank

houses along the Siuslaw, Umpqua, and Coos Rivers and moved seasonally for hunting, fishing,
and gathering, staying in seasonal camps.

Non-indigenous traders first came to the region in the early 1800s, followed by settlers. In 1855,
the U.S. government wrote a treaty with the Tribes that would allow U.S. settlers to occupy the
Tribes’ traditional lands, and would compensate the Tribes with food, clothing, employment,

education, and health benefits. The Tribes signed, but Congress failed to ratify the treaty and in
1856, the U.S. government forcibly incarcerated the Coos and Lower Umpqua people in a

military fort.

In 1860, the U.S. government forced the Tribes to move to a reservation in Yachats, give up their
traditional hunting, fishing, and gathering culture, and farm on land that was ill suited for

agriculture. During this period, 50 percent of the Tribal members died due to the harsh
conditions and disease.

In 1916, the Tribes established an elected Tribal government.
In 1941, the Bureau of Indian Affairs established a small set of Tribal facilities in Coos Bay,
including a Tribal Hall, offices, and clinic.

In 1954, the U.S. Government unilaterally terminated recognition of the Confederated Tribes. In

1984, federal recognition was restored.
2.2

Land Use

The lands of the CTCLUSI Ancestral Territory encompasses 1.6 million acres of lands at or

adjacent to the Pacific Ocean. The landscape ranges from beaches to coastal lakes to rivers to

dunes and forests. The area remains relatively low in population density and contains some of

North America’s most extensive forests. The region contains a diversity of natural resources for
industries such as mining, logging, fishing, agriculture, and tourism.
CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 4

Figure 1 through Figure 5 show CTCLUSI lands, including trust lands and fee lands. These lands
are spread across portions of the Tribes’ Ancestral Territory, but do not comprise a contiguous
reservation. The five counties of Coos, Curry, Douglas, Lane, and Lincoln comprise the FiveCounty Service Area in which CTCLUSI provides services to Tribal members.

The territory includes urban areas (Coos Bay, Reedsport, and Florence), rural areas with low
population density, and natural areas (forests, beaches, and other natural habitats).
2.3

Demographics

Of the 1,331 enrolled Tribal members, 733 live in Oregon, and 499 live in the Five-County Area
of Coos, Curry, Douglas, Lane, and Lincoln counties. Most members are concentrated in Coos
and Lane Counties (data provided by CTCLUSI, October 2023).
Location

Population

Oregon

733

All enrolled CTCLUSI members

1,331

Five-County Area

499

Coos County

223

Coos Bay

96

North Bend

90

Curry County

3

Douglas County

38

Lane County

209

Eugene

78

Springfield

54

Florence

32

Lincoln County
2.4

26

Residential

The Tribes own two residential housing developments known as Qa’aich and Qaxas Heights.
•

Qa’aich Development is located in Florence and consists of two fourplexes that provide
homes for approximately 11 residents.

•

Qaxas Heights is located in North Bend and consists of houses, duplexes, and fourplexes

that provide homes for approximately 65 residents.
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Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 5

The Tribes owns a single residential property in Coos Bay (1370 Neese).
In addition, approximately 18 Tribal members live in housing provided by U.S. Department of

Housing Urban Development (HUD) consisting of four residential properties on Clay Street,
Harriet Street, and Flanagan Street in Coos Bay.

There are approximately 400 Tribal members in the Five-County Area who live in private

housing. This ISWMP addresses waste management practices and options for these members

who live in private housing. To provide a focused scope for evaluation and planning within the

Five-County Area, this ISWMP does not directly address waste management for Tribal members
who live outside the area; however, the guidance and recommendations in this ISWMP should

be shared with all Tribal members and will probably benefit Tribal members who live outside the

Five-County Area.
2.5

Tribal Services

Most Tribal services facilities are in Coos Bay. Tribal facilities in Coos Bay include the Tribal Hall
and Community Center, Tribal administrative offices, Housing Office, healthcare center, dental

clinic, laboratory, library, Plank House, and Community Garden. Tribal departments that operate

from facilities in Coos Bay include financial, health and human services, forest management,

facilities maintenance, information technology (IT), Tribal police and emergency management,
and department of culture and natural resources.

The Tribes hosts annual events and gatherings at the Coos Bay facilities. Additionally, the Tribes

operate an outreach center in Florence.

The Tribes also own a house at Coos Head that is currently not occupied but is designated as an
administration building.
2.6

Tribal Enterprises

The main Tribal enterprises are the Three Rivers Casino and Resort and the Ocean Dunes Golf
Links. The Casino has two locations. The larger casino is in Florence and includes a casino,

restaurants, 93 rooms for lodging, and recreational vehicle (RV) parking. The golf course is also
located in Florence. The newer, smaller casino is located in Coos Bay adjacent to the Tribal
Community Center. It does not include lodging but has a restaurant and gift shop.

CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 6

3.0 CURRENT SOLID WASTE GENERATION RATES AND COMPOSITION
The quantities of solid waste generated by the Tribes were estimated based on consultation with
the casino management, data from other casinos, and waste generation data compiled by the
Oregon Department of Environmental Quality (ODEQ).

ODEQ publishes an annual Oregon Material Recovery and Waste Generation Rates Report. The
most recent was published in 2023 with data from 2021 (ODEQ, 2023). It showed increased

waste generation compared to the previous year, and similar but somewhat reduced recovery
rates.

The solid waste from CTCLUSI sources can be divided into three major categories: residential

sources, Tribal facilities, and Tribal enterprises. The waste quantities from the enterprises (casino,

resort, and golf course) are estimated based on typical waste generation rates from similar

enterprises owned by other tribes. Waste quantities from residential sources are estimated

based on an estimated residential disposal rate of 0.32 tons per person per year (Cascadia,
2021). Waste quantities attributable to the Tribal facilities are estimated using the cost

information described in Section 4.5 of this report and typical costs per ton for waste

management. Table 2 summarizes the estimated waste quantities generated by each source.

These estimates are provisional, based on the data available, and may be revised if more specific
information including volumes and weight becomes available.

The recovery rate is defined as the percentage of waste that is recycled, composted, or burned
to generate energy. The statewide recovery rate in 2021 was 37.7 percent, down from 42.0

percent the previous year. The reduction is due in large part to large amounts of nonrecoverable
debris generated by wildfires in 2021 (ODEQ, 2023).

The most recent waste composition survey available for Oregon is from 2016 – 2017. 1 The most

relevant data to the CTCLUSI Five-County Area is the “Downstate” data that includes all counties
in the state except for the Portland metropolitan area. Table 1 describes the waste categories
used to classify solid waste. Table 2 uses data from the Oregon waste composition survey to
estimate the quantity of solid waste generated in each waste category from each source
(residential, facilities, enterprises, and self-haul).

1

In 2023 and 2024, ODEQ updated its waste composition study. Preliminary results were presented at a

conference but the data have not yet been published as of November 2024. A future revision of this
ISWMP could use the updated data. https://www.oregon.gov/deq/mm/Pages/Waste-CompositionStudy.aspx

CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 7

3.1

Residential

The chart below shows the types of solid waste generated from residential pickups and
transported to disposal facilities.

Metal - non-recyclable,
0.59%
Metal - recyclable,
2.89%

Electronics/Small
Appliances, 0.68%

Cardboard - recyclable,
2.31%

Other Inorganics,
10.46%

Paperrecyclable,
6.85%

Paper- non-recyclable,
10.06%

Glass, 3.11%

Plastic- recyclable,
3.83%
Carpets, textiles,
roofing, furniture,
insulation, 10.59%

Plastic - non-recyclable,
8.63%

Diapers, 8.91%

Tires and Rubber,
0.49%
Non-edible food scraps,
9.46%

Yard debris, 4.59%

Wood, 2.88%

Edible food, 13.72%

Food waste is the largest category (green) followed by paper and plastic (blue and purple).

Diapers (white) represent 9% of residential solid waste, a significant proportion. Glass and metal
are relatively small percentages of the total. Dirt, rocks, and pet litter are combined and
represent about 11% of residential solid waste, another significant proportion.

Recyclable materials (paper, plastic, glass, and metal) total approximately 20% of the solid waste
stream. Compostable materials (food, yard debris, and some wood waste—depending on its
condition) total approximately 30%.

CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 8

Some residential waste is taken to self-haul facilities for disposal, rather than being picked up by
garbage collection trucks. The composition of this self-haul waste includes more wood, building
materials, and furniture. It contains less food waste, plastic, and paper compared to the

residential pickup waste (ODEQ, 2023). Some residential waste is burned in burn piles rather

than transported to disposal facilities. The composition of the waste being burned is similar to

the composition of self-hauled waste and includes wood, yard debris, and household garbage,

including plastics. Reducing the frequency of burning and the quantity of waste being burned is
a high priority of the Tribes.
3.2

Tribal Facilities

Based on ODEQ waste composition data, the composition of the solid waste stream from Tribal

facilities was estimated. These results are generally similar to the waste generated by

households; however, the facilities waste stream contains higher proportions of medical waste,

wood, and glass and lower proportions of diapers, yard debris, dirt, and rocks.

CTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 9

Electronics/Small
Appliances, 0.98%
Metal - non-recyclable,
0.83%

Medical wastes, 2.37%
Other Inorganics,
3.57%

Metal - recyclable,
1.83%
Glass, 8.32%

Paperrecyclable,
5.60%

Cardboard - recyclable,
3.34%
Paper- non-recyclable,
10.44%

Plastic- recyclable,
4.27%

Carpets, textiles,
roofing, furniture,
miscellaneous, 9.24%
Plastic - non-recyclable,
10.36%

Diapers, 2.70%

Non-edible food scraps,
9.68%

Edible food, 11.73%

3.3

Yard debris, 1.55%

Wood, 12.78%

Tribal Enterprises

Information from a tribal casino and golf course in Washington State was used to estimate the
waste generation rates for the Casinos and Golf Course, and data from the ODEQ waste

composition survey was used to estimate waste stream composition. 2 These assumptions and

estimates are supported by observations and publicly available photographs of the casino, hotel,
and golf course from Google Maps and the casino’s website. Table 3 and Table 4 provide

estimates of the waste generation quantities and composition for each Tribal enterprise. The

casino's food and beverage director and controller reviewed and confirmed these estimates.

2

Average waste composition for commercial waste was used in the absence of site-specific data, and it

was assumed that the golf course would generate proportionally more yard waste and lawn clippings than
other types of waste.
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Landscaping of the golf course and gardens containing flowers, shrubs, and trees near the

parking area and outside the casino generates yard waste. The golf course plant clippings are

disposed of as compostable materials at the transfer station in Florence. The casino’s

landscaping service provider takes away the landscaping clippings for disposal. Specific

information regarding where this waste is disposed of was not available, but it is probably

combined with other plant clippings and composted.

Photographs of the restaurant show that they use reusable plates, silverware, napkins, and

glasses at the restaurant tables. Disposable plastic cups and straws and paper napkins are used

for drinks from the bar. Photographs of the hotel rooms show K-cup coffee brewing machines,
individually wrapped bars of soap, and other items that would generate non-recyclable trash.

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4.0 CURRENT SOLID WASTE MANAGEMENT SYSTEMS
4.1

Oregon

State authority over activities on Indian reservations is generally limited; however, tribes are

required to comply with federal laws and regulations. In the absence of specific federal laws and
regulations, tribes may, at their discretion, adopt or incorporate state laws and regulations to

address environmental issues.

ODEQ is the agency responsible for waste management in the State of Oregon. Oregon has

shifted its approach from “solid waste management” (focused on diverting waste from garbage
to recycling and composting) to “materials management” (a full lifecycle approach, including

reducing waste, promoting reuse, minimizing packaging, and substituting materials that have
less environmental impacts than alternatives).

4.1.1 Current Conditions
Currently, Oregon sets recycling goals for each “wasteshed” (county). Oregon law requires cities
with population over 4,000 people to provide a recycling program. Over 80% of the CTCLUSI

residents of the Five-County Area live in municipalities of over 4,000 people. Currently, different

counties and municipalities have different recycling programs that allow for recycling of

different materials, depending on the capabilities and preferences of recycling service providers.
One standard statewide recycling program is driven by the Oregon Bottle Bill, which establishes
collection programs for recycling of aluminum cans, glass, and plastic bottles and supports a

payment of 10 cents per bottle to encourage recovery. Compared to commingled recycling in

curbside bins or transfer stations, the bottle collection centers allow for more efficient recycling
since the incidence of contamination with other materials is minimized when bottles are

recycled alone. Two facilities in the CTLUSI service area are:
o
o

North Bend/Coos Bay Redemption Center - BottleDrop

Fred Meyer Florence - Partner Retailer Drop Location - BottleDrop

Smaller-scale bottle drop locations are located at local grocery stores throughout the Five-

County Area; however, these smaller bottle drop locations are often overcrowded, overloaded,
and inefficient.

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4.1.2 Anticipated Changes
Oregon passed the Plastic Pollution and Recycling Modernization Act in 2021. ODEQ is

conducting studies and preparing for the law to take effect in 2025. The law is intended to

promote recycling by expanding and standardizing the list of materials that can be recycled to
make it consistent statewide. The law aims to ensure that recycling is done responsibly to

address problems with materials being shipped overseas to unregulated facilities. The law

creates producer responsibility organizations (PROs) that are intended to incentivize waste
reduction (for example, changing food packaging to use less materials or less impactful

materials). Based on their waste production, the PROs will be required to provide funding to
local governments for recycling.
4.2

Counties

Waste management services vary by county as described in this section. Of the five counties,

only Lane County has a published Waste Management Plan (Good Company, 2019). The other
counties provide some resources and information on their websites.

4.2.1 Coos County
Coos County has a transfer site open Tuesday through Saturday for drop-off of trash and

recycling. Fees are charged based on the quantity and type of waste, with temporary fee waivers
granted periodically. For example, in Fall 2023, the facility waived fees for appliances and scrap

metal. Fee information is listed at https://www.co.coos.or.us/solid-waste/page/solid-waste-fees
The cities of Coos Bay and North Bend have trash and recyclable materials pickup but do not
collect yard waste or food waste for composting.

4.2.2 Curry County
Curry County has trash and recyclable materials pickup for residential and commercial

customers. Users can select various sizes of bins or dumpsters. Most areas have weekly pickup,

but collection is less frequent in some areas. Recyclable materials can be dropped off at transfer
stations at no charge. Disposal fees are charged for hazardous materials such as electronic
waste, tires, and batteries. https://www.currytransferrecycling.com/home/

4.2.3 Douglas County
Douglas County has transfer stations for the public to drop off trash, recyclable materials, and

yard waste (https://douglascountyor.gov/396/Solid-Waste).

Douglas County also has a Free Materials Exchange to help with reuse, recycling, and disposal of
materials such as cooking oil, antifreeze, scrap metal, batteries, building materials, light bulbs,
clothing, tires, and Styrofoam.

https://douglascountyor.gov/BusinessDirectoryII.aspx?lngBusinessCategoryID=31).

https://douglascountyor.gov/DocumentCenter/View/22123/DCSW-Recycle-Options-PDF?bidId=
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Roseburg Disposal Company provides collection of trash and recyclable materials in some areas
within Douglas County.

4.2.4 Lane County
Lane County has a solid waste management plan dated 2019. Lane County has the highest waste
recovery rate in the State of Oregon. This recovery rate is the percentage of waste that is

recycled or otherwise diverted from landfill disposal (Good Company, 2019). Lane County has a

goal of 63% recovery by 2025. Lane County has transfer stations for the public to drop off trash,
recyclable materials, and yard waste, and accepts appliances and other materials for a fee. Lane
County has several organics processing facilities that convert post-consumer food waste to
energy.

Springfield and Eugene have residential pickup service for garbage, commingled recyclable
materials, and yard waste.

https://springfield-or.gov/city/development-public-works/recycling/ , https://www.eugeneor.gov/2932/Residential

Florence has pickup service for garbage and recyclable materials but does not have a separate

collection service for yard waste and food waste. They advise residents to dispose of yard waste

and food waste in the trash or to drop off yard waste and garden trimmings at a transfer station.
https://www.countytransferandrecycling.com/

4.2.5 Lincoln County
Lincoln County has curbside pickup in some areas and has transfer stations for disposal of waste
and recyclable materials.

https://www.co.lincoln.or.us/387/Solid-Waste-District
4.3

Tribal Departments Involved in Waste Management

Currently, waste management is decentralized within Tribal departments. Each Tribal

department generally handles its own solid waste, and each facility manages waste differently.
The following Tribal departments have a role in waste management and planning.
Housing Department

This department contracts for residential trash disposal for Tribal housing areas and deals with

illegal dumping within or near the residential areas.
Finance Department

This department pays for waste pickup and disposal services and maintains cost accounting
records for Tribal departments.

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Tribal Police Department

The police department investigates illegal dumping and enforces laws that prohibit illegal
dumping.

Compliance Department

This department generates substantial amounts of paper waste and is working towards a
paperless system to reduce and minimize wastepaper.
Forestry Department

This department deals with illegal dumping on Tribal forest lands that it manages.
Department of Culture and Natural Resources

This department generates yard waste as it clears vegetation (trees and brush) and constructs

habitat restoration projects. Most of this organic waste is currently landfilled; however, a large

portion could probably be reused or composted. This department currently manages the

ISWMP, promotes waste and recycling initiatives, investigates contaminated lands and waters,
and protects cultural and natural resources from contamination and other impacts.
Facilities and Maintenance Department

This department has a burn pit for wood waste, much of which is generated during housing

construction and demolition of buildings. This department also manages waste generated from
landscaping and illegal dumping. The Facilities and Maintenance Department cleans up

homeless encampments from which a large volume of solid waste is removed, and this results in
substantial waste disposal costs.
Health Department

This department generates medical waste and dental waste that must be collected, handled, and
disposed of by specialized contractors. This department handles a substantial volume of laundry
associated with uniforms and rags and is interested in improving laundry operations to increase
efficiency and reduce cost.
IT Department

This department must handle and properly dispose of electronic waste on a regular basis.

Electronic waste includes computers, monitors, docking stations, printers, batteries, chargers,
and related IT equipment.

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Laboratory

The laboratory generates packaging waste (including Styrofoam and plastic) and special wastes
including materials classified as biohazards.
Casino Operations

Casino operations management collects, handles, and disposes of solid waste from the casinos

including the hotel and restaurants.
Wastewater Treatment Plant

The treatment plant in Florence treats wastewater from the casino and resort and generates

biosolids which are disposed of on farmlands in the region.

CTCLUSI currently does not have Tribal regulations related to waste management. In 2013, the
Tribes prepared a Solid Waste Management Plan. This document serves as an update to that

plan and reflects changes in land base, areas served, updated goals and objectives, and current
waste management options and costs.

The City of Coos Bay collects and disposes of wood waste and construction and demolition

debris for a fee. Although the monetary cost of collection and disposal is higher than the cost of

burning, using the City’s services offers the advantage of reducing or eliminating toxic emissions

that threaten the health of people and degrade air quality.
4.4

Residential

The Tribes pays for pickup of garbage and recyclable materials and occasional dump runs for
Tribal housing and HUD residences. As needed, the Tribes assist Tribal members to cover the

costs of garbage collection, handling, and disposal. The following information was provided by

the CTCLUSI Controller based on payment records from 2021 through 2023.
•

Qa’aich in Florence has a garbage dumpster that is shared by the entire complex. It is
picked up weekly, and the cost of pickup and disposal is $230 per month. Recycling

service is not provided to Qa’aich.
•

At Qaxas Heights, each house has its own waste collection bin. North Bend Sanitation

picks up the waste bins for disposal, and the cost is approximately $1,000 per month. Bin
sizes vary based on the size of each household, and pricing for pickup depends on the

size of the bins. Recycling service is not provided to Qaxas Heights.
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•

CTCLUSI pays approximately $35 per month to Les Sanitary for waste pickup from Tribal
housing at 1370 Neese in Coos Bay.

•

At the HUD housing areas in Coos Bay (Clay Street, Harriet Street, and Flanagan Street),
each house has its own waste bin and the Tribes pay Les Sanitary approximately $230

per month for the four residences. The cost has varied over time. Most of the time, it has

been in the range of $50 per month per house; however, there have been significant

outliers: 909 Flanagan Street has several monthly bills that were over $600. 3 The Tribes

paid for two dump runs for the HUD housing in 2021 but has not received recent billings
for dump runs (Coos County Solid waste bill).

The Tribes have paid approximately $1,000 to Les Sanitary over the past several years to assist
Tribal members to cover disposal costs. 4

Average monthly costs for each housing area are summarized below:
Residential

Cost per

Number of

Monthly Cost

Qa'aich
Qaxas
Neese
HUD

$230
$1,000
$35
$230

11
65
45
18

$ 20.91
$ 15.38
$ 8.75
$ 12.78

Area

Month

Residents

per Person

Services
Trash only
Trash and recycling
Trash and recycling
Trash and recycling

Qa’aich has the highest per person cost, and this cost is for garbage pick and disposal only. The

costs shown in this table do not include occasional dump runs, only the costs for regular pickup
and disposal services.

For Tribal members living in private housing, waste management practices depend on their

location and county waste management services provided in that area, as described in Section

3

These abnormally high bills are probably due to tenant changeover and associated high disposal costs

for removing bulky items, such as furniture and appliances. Cost savings could be realized in future if

these bulky items could be donated for reuse. Section 6 of this document provides further discussion on

waste management options.
4

The Tribes could evaluate these costs with respect to alternatives for disposal that would meet similar

needs in the future.
5

Number of residents at Neese housing is estimated 4 residents for this single-family home.

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4.2. Most Tribal members live in cities where residential collection services are provided for

garbage and recyclable materials; however, regular pickup services for yard waste and food

waste for composting are not provided.
4.5

Tribal Facilities

4.5.1 Coos Bay and Florence Tribal Administrative Offices
The administrative offices dispose of paper waste using a shredding service: I Secure picks up
the waste on an as needed basis. The average cost during 2021 – 2023 was $100 per month.

Solid waste from the administrative offices is picked up by Les Sanitary. The average cost during
2021-2023 was $688 per month. Monthly billings for this service include separate invoices for
multiple locations: Fulton, Wallace, and Coos Head. (Les Sanitary, code 150-1080).

Dump runs from the administrative offices to a disposal facility occur as needed. The average

monthly cost for dump runs is $30 (Coos County Solid Waste, code 150-1050).

For the unoccupied house at Coos Head, CTCLUSI pays approximately $95 per month to Charles
Sanitary.

Food waste from the kitchen in the community center is composted in the community garden.
The Facilities Maintenance Department has a burn pile near the Coos Bay administrative

buildings to dispose of wood waste and wood debris. Some of the discarded wood can be used
for firewood, landscaping, and other purposes; however, these alternatives to burning and

landfill disposal are currently limited. The maintenance crew collects debris from land clearing,

building demolition, and construction and, when a sizeable amount has accumulated, they burn
this material.

4.5.2 Laboratory
The laboratory disposes of trash and recyclable materials by combining its waste stream with
waste from the administrative offices. The waste stream from the lab is predominately

cardboard, plastic, and Styrofoam. For chemical and biohazard waste, the laboratory is currently
evaluating options for collection, handling, and disposal. Laboratory analyses include

conventional chemistry, microscopy, bacteria, metals, organics, environmental DNA, and

radiocarbon. These analyses generate the following types of wastes: non-hazardous aqueous
waste that might require analysis prior to disposal, corrosives (strong acids and bases),
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potentially high concentrations of metals in aqueous solution, flammable and non-flammable

solvents, biohazards, and sharps from injections. Solid waste generation quantities are estimated

at 2.3 tons per year. A small amount of hazardous waste is anticipated initially. As the laboratory
ramps up operations, the quantity is expected to increase to a small-quantity-generator level

(400 pounds per month or 2.4 tons per year). Separate on-site storage will be required for
specific classes of chemicals, like strong acids and bases. Laboratory waste management
information is included in Appendix D.

4.5.3 Dental Clinic
The dental clinic currently contracts with Stericycle for pickup and disposal of special waste. Data
on current generation quantities and costs of collection, handling, and disposal are not available
at this time. This information can be added to this ISWMP when it is available.
4.6

Tribal Enterprises

Used items from the casino such as bedding and furniture are given to the Tribal administration
to make available to Tribal members and staff for free (CTCLUSI, 2013). This reduces the cost to
the casino of disposing of these items as waste, and benefits users.

Other than composting the landscaping plant clippings, the casinos do not separate materials

from the solid waste stream for recycling and composting. All solid waste, including food waste

from the kitchens and restaurants, is collected, handled, and transported for landfill disposal.
Field observations at the RV resort noted containers for garbage but no recycling bins.

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5.0 PROJECTED FUTURE WASTE GENERATION
This section estimates future waste quantities and generation rates for each service area based

on projected population growth during the next 10 years. Key variables related to this projection

are expected population changes in the service area and the expansion of Tribal facilities,

services, and enterprises.
5.1

Residential

The population in the Five-County Area of Oregon is relatively stable. The population in some

towns and cities, such as Florence, is growing. Population in other cities, such as Coos Bay, is
decreasing.

Since 2013, CTCLUSI enrollment has increased from 1,051 to 1,331 people—an increase of about
25 percent. The enrollment includes members living in other counties and states. Based on data

available, it is not known whether growth was primarily among local residents or among
members living remotely; however, it’s reasonable to assume that growth was relatively

consistent among the counties. If this trend continues, the population would be expected to
increase by a similar percentage over the next 10 years. If per capita waste generation rates

remain close to current rates, CTCLUSI should expect its total residential waste generation and

associated disposal costs to increase by 25 percent in 10 years. The per capita waste generation

rates and the disposal costs could increase as well, compounding the effect of this increase. If
concerted efforts are made to reduce waste generation and develop cost effective disposal

options, the increases could be reduced. Table 5 summarizes estimated increases in residential
waste generation over the next 10 years.

Based on communications with the Tribes’ Planning Department, the Tribes plan to add single

family units to its Tribal Housing supply at a rate of approximately two to four units per year.
5.2

Tribal Facilities

The Tribes are planning to open a medical clinic during 2024. A dental clinic began operating in
2023. These facilities will generate biohazards and sharps that will require special handling and

disposal. Similarly, the laboratory will begin generating chemical and biohazard waste that

requires special handling and disposal. The laboratory is currently evaluating options to

determine the most appropriate and cost-effective methods of handling and disposal of these
special wastes. Indian Health Service (IHS) and Bureau of Indian Affairs (BIA) may provide

funding for solid waste management at the clinics.
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The estimated solid waste generation rate for the dental clinic and medical clinic is

approximately 8.76 tons of waste per year. The laboratory will generate approximately 2.3 tons

of solid waste per year and approximately 2.4 tons of special waste (including hazardous waste)

per year. This special waste will require specialized management, handling, and disposal.
5.3

Tribal Enterprises

Table 6 summarizes the projections of increased waste generation due to enterprise expansion.
5.3.1 Florence Casino RV Parking Expansion
The Florence casino plans to add 50 to 60 RV parking spaces to its existing RV parking area

during the next 2 to 3 years. This would more than double the size of the RV park and

potentially add 44 tons of solid waste per year.

5.3.2 Coos Head Development
The U.S. Navy transferred a large portion of the former Coos Head Air National Guard property

to the Tribes. The property that was acquired by the Tribes includes derelict buildings and

potential contamination that are legacies of former U.S. Navy facilities and operations. The

Tribes intends to develop the property for new facilities including a cultural center and RV park.

A Coos Head Area Master Plan (CHAMP) has been developed that establishes a development

plan for Coos Head. The CHAMP includes an interpretive center, conference center and hotel,
and Tribal center. It also considers developing 20 to 30 spaces for RVs and tent camping. The

CHAMP does not, however, include planning to address remaining environmental concerns,

such as the derelict buildings and residual contamination, and waste management (CTCLUSI,

2018). The planned development could add approximately 80 tons per year to the current solid

waste stream.

5.3.3 Hanisiich Village
A project to develop a waterfront property in Coos Bay as a cultural center and vacation lodging
was proposed, but there are currently no plans to develop the site.

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6.0

WASTE MANAGEMENT OPTIONS AND OPPORTUNITIES FOR IMPROVEMENT

The U.S. Environmental Protection Agency (USEPA) developed the non-hazardous materials and
waste management hierarchy, recognizing that no single waste management approach is

suitable for managing all materials and waste streams in all circumstances (USEPA, 2023). The
hierarchy ranks the various management strategies from most to least environmentally
preferred. The hierarchy places emphasis on reducing, reusing, and recycling as key to
sustainable materials management.

Source Reduction Most efficient, least wasted economic value, least ecological impacts
Reuse
Recycling
Composting
Incineration
Land Disposal Least efficient, most wasted economic value, most ecological impacts
Each waste management strategy is described below, followed by methods that CTCLUSI may
employ to promote use of the optimal strategies.
6.1

Source Reduction

Source reduction should be given first consideration because it conserves natural resources,
reduces pollution, and promotes conservation and pollution prevention. Source reduction

involves informing the public on methods and strategies to reduce the amount of materials that

must be handled as waste. In 1989, the USEPA gave source reduction the highest priority as a

method for addressing solid waste issues. Source reduction offers cost savings by avoiding the
expenses associated with waste collection, transportation, and disposal.

Successful source reduction methods include regulations and educational programs directed

toward changing habits, and usually involve minimal capital costs (or even capital savings) and
low operating and maintenance costs. For example, some communities ban certain non-

recyclable products and excess packaging, such as Oregon’s ban of single-use plastic bags in
2020 (https://www.oregon.gov/deq/mm/production/pages/bags.aspx).

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6.2

Reuse

The second option in USEPA's hierarchy is reuse. Reuse is a better option than recycling because

the items are not reprocessed before becoming useful again. Items such as appliances, furniture,
clothing, books, toys, paint, lumber, and household cleaners can be exchanged among

households and businesses rather than thrown away. Resources recovered from reuse can also
support local community and social programs while reducing disposal fees.
6.3

Recycling

Recycling is the process whereby materials that are normally disposed of are collected,

reprocessed, or remanufactured for reuse. This reduces use of materials to manufacture new

products and reduces the volume of waste requiring disposal. Recycling relies on the public to

participate by separating materials selected for recycling from the waste stream before disposal.
Recycling programs must be designed with public convenience and support as a primary

objective. The two greatest challenges to developing a successful recycling program are public
participation and contamination of recyclable materials.

Participation by a majority of Tribal members provides the volume of recyclable materials
necessary to make the program cost-effective and creates peer pressure on other Tribal
members to recycle. Participation is often greater when steps are taken to make it easy.

Users will be less likely to recycle if they must sort materials into four different bins, and then
haul it to a central facility. Effective public outreach and educational programs can also
encourage participation.

Contamination occurs when an unacceptable item is placed into a recycling container.

Contamination hinders and sometimes ruins otherwise good recyclables, increases cost, and

sends recyclable materials to the landfill. If the materials (particularly paper) are

contaminated and do not meet quality guidelines, they will be rejected and sent to the
landfill or incinerator.

Recycling services vary by location. Residential pickup of recyclables generally encourages

higher participation rates than requiring residents to bring their recyclables to a central drop-off
point. However, Ridolfi observed some recycling services in the CTCLUSI service area provided
uncovered plastic containers for residential recycling bins. In a rainy climate like Oregon’s, this
can lead to contamination and destruction of recyclable materials, especially paper and
cardboard.

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6.4

Composting

Composting is an environmentally sound and beneficial means of recycling organic matter.
Composting is the biological decomposition of organic materials to produce a humus-like

product that can be used as a soil amendment. Depending on the sources of materials and the
availability of siting and labor, composting can be done on a scale of operation ranging from
micro (household) to macro (fish waste composting). “Browns” (carbon sources such as hay,

manure, biosolids, dry vegetation, newspaper, and non-recyclable paper) are layered or mixed
with “greens” (nitrogen sources such as fresh grass clippings, uncooked vegetables, and fruit

wastes) to promote decomposition. The ideal carbon to nitrogen (browns to greens) ratio is 30
to 1 by volume. Efficient composting is possible at ratios as low as 15 to 1; however, odor

problems are more likely at this lower ratio. Typical carbon to nitrogen ratios (C:N) in common
organic materials are presented below:
Leaves

60:1

Fruit Wastes

35:1

Grass Clipping

19:1

Paper

170:1

Food Wastes

15:1

Sawdust

500:1

Fish Waste

5:1

Wood

700:1

Cow Manure

20:1

Cardboard

560:1

It is important that temperature and aeration are monitored during composting. Properly

aerated compost should range from 105 to 150 degrees Fahrenheit (degrees F) for composting
to be effective. Temperatures above 170 degrees F can create an opportunity for spontaneous

combustion. Aeration involves turning the pile either manually or mechanically with equipment
such as a backhoe or windrow turner. Aerobic decay, which takes place with oxygen present, is
the preferred biological process. Anaerobic decay takes place without oxygen and is prone to

odor problems. Aerobic decomposition can be tracked by monitoring the internal temperature
of the compost pile. When the temperature drops below 105 degrees F, turning the pile will
reestablish oxygenation and heating.

Information and guidance about composting is provided in Appendix C.
6.5

Landfill Disposal

The total generation of municipal solid waste in the United States in 2018 was 292.4 million tons,
more than 50% of this was landfilled (USEPA, 2022). Modern landfills are facilities for the

disposal of solid waste. They are designed to protect the environment from contaminants that

may be present in the waste stream. There are different types of landfills including municipal
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solid waste landfills, designed for household waste and other nonhazardous waste; industrial

waste landfills, designed for commercial and institutional waste; and hazardous waste landfills.
Landfills pose several problems. One of the major concerns with landfills is their release of

methane gas. As organic matter in landfills decomposes it releases methane gas. Methane is one
of the most potent greenhouse gases and a huge contributor to climate change. Landfills also

take up large amounts of space, typically destroying natural habitats for wildlife. Landfills are
required to have linings to protect the underlying ground, but these can leak, producing

leachate. This leachate can contaminate nearby water sources and habitats. Landfills are a
societal necessity but utilizing other waste management practices can reduce reliance on
landfills and thus their environmental and societal impact.
6.6

Incineration

Incineration is widely used to reduce the volume of municipal solid waste, medical waste, and
hazardous waste, and to reduce the potential toxicity of medical and hazardous waste.

Incineration is a waste treatment process that involves the combustion of substances contained

in waste materials. In 2018, about 12% (35 million tons) of municipal solid waste was combusted
nationwide (USEPA, 2022). Incineration facilities are commonly referred to as waste-to-energy
facilities. Waste-to-energy facilities work by releasing heat through the burning of waste that
turns water into steam in a boiler. The high-pressure steam turns the blades of a turbine

generator to produce electricity. The primary products of waste incineration are carbon dioxide,
water vapor, ash byproducts, and trace organic and inorganic compounds in the exhaust gases.
A major concern of incineration processes is the potential risk to human health from the

emission of pollutants generated by the incineration process. The composition of these residues
is determined by the waste steam, combustion process, and reaction occurring in waste gases.

Emissions from incineration facilities can be reduced by choosing advanced combustion designs
and emission-control technologies for the pollutant of concern (NRC, 2000). The ash that is

produced as a byproduct from the combustion process is commonly disposed of in landfills.
Alternative reuse methods for the ash are being assessed by researchers.

6.7

Backyard Burning

Backyard burning involves the burning of household waste, wood, and yard debris. Household
waste includes paper, cardboard, food scraps, and plastics. Burning usually occurs in a burn

barrel or open pit. Air emissions from burning are released directly into the atmosphere without

filtering or treatment to reduce harmful particulates, toxic vapors, and fumes in these emissions.
Backyard burning is a recognized health hazard that produces harmful quantities of dioxins, a
group of highly toxic chemicals, and other harmful chemicals. Burning waste can cause longCTCLUSI_ISWMP_Nov 2024

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 25

term health problems including increasing the risk of heart disease, aggravating respiratory

ailments, and causing rashes, nausea, and headaches. Backyard burning should be avoided and
other waste management options should be used. Outreach and education on hazards and
alternatives to burning waste are important in discouraging this practice.
6.8

Hazardous Waste Management

Specific categories of waste require special management due to their hazardous nature. This

includes highly flammable materials such as batteries. Recently, an Oregon landfill had a fire –
the cause is unknown but was suspected to be started by a lithium battery. Lithium batteries
should not be disposed in the trash because of their flammability hazard.

https://www.bakercityherald.com/news/local/fire-smothered-at-baker-sanitary-servicelandfill/article_7166a36c-66cb-11ee-84c7-336d083f1d84.html

https://roguedisposal.com/resources/education/environment/standing-the-benefits-anddangers-of-lithium-batteries

The counties offer occasional free collection services for household hazardous waste drop off at
transfer stations. For example, Beaver Hill Transfer Site (Coos County) held such an event on
September 16, 2023. Batteries used at home and in offices should not be disposed of with

garbage. Batteries should be disposed of as household hazardous waste. Establishing battery
collection events for Tribal members would encourage proper disposal of batteries.

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7.0 PUBLIC OUTREACH AND EDUCATION
Goals and Objectives

7.1

Goals for outreach and education include:
1. Make Tribal members and staff aware of the waste management options that are
available (recycling, composting, source reduction, reuse)

2. Make Tribal members and staff aware of the benefits of recycling, composting, and
source reduction and reuse (cost savings, reduced impacts on natural resources).

3. Reduce the volume of waste generated by the Tribes that is being landfilled or burned.
Reductions may be achieved through source reduction, recycling, composting, or a
combination of methods.
Outreach Methods

7.2

Consider the media and events listed below as possible outreach tools:
•

Solid Waste Advisory Committee (SWAC)

•

Exchange Center or Bulletin Board (Physical or Digital)

•

Flyers and posters with Tribal artwork and culturally appropriate messaging placed in

community locations such as Tribal housing, community centers, health centers, and
schools
•

Social media and websites

•

Collection Events

•

Outreach and Education with Youth Groups

•

Recycling 101 Pamphlet

•

Staff Workshops

•

Tribal artwork on containers to encourage recycling and proper garbage collection

•

Newspapers and newsletters

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November 2024 Page 27

•
7.3

Public Information Booths
Measuring Effectiveness

Surveys can be conducted to assess current baseline awareness of waste management options

and benefits, and repeated after outreach has been conducted to assess the effectiveness of the
outreach in reaching the target audience and communicating the intended message.

Effectiveness in reducing waste volumes landfilled may be measured by tracking disposal costs.

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8.0 IMPLEMENTATION
8.1

Roles and Responsibilities of Tribal Personnel

Responsibilities associated with implementing and administering the ISWMP include planning,

development, contracting, record keeping, staffing, and public outreach. The Tribes could

designate a solid waste manager or coordinator who would have the responsibility and authority
to implement a strategic implementation plan and lead the Tribes’ efforts and initiatives aimed

at improving solid waste management for the Tribes. Since all departments generate solid waste
and are involved in solid waste management, periodic meetings and coordination would be
helpful to implement this ISWMP and facilitate continuous improvement in solid waste
management.
8.2

Strategic Implementation Plan

A Strategic Implementation Plan is provided in Appendix F to guide and support the Tribes’

accomplishment of solid waste management goals and objectives. The purpose of the Strategic
Implementation Plan is to provide a relatively simple and useful roadmap that will guide the
Tribes during the next five years (2024 – 2028).

A strategic plan is designed to answer three basic questions:
(1) Where are we now?

(2) Where do want to go?
(3) How do we get there?

The ISWMP contains the information needed to answer the first question. The Strategic

Implementation Plan provides the structure, framework, and guidance for the Tribes to answer

the second and third questions.
8.3

Resources and Funding Sources

Various resources and funding sources to support the Tribes’ solid waste management program
from EPA, County, State, and private sector sources are provided in Appendix G.

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8.4

Recommendations for Waste Reduction and Diversion

8.4.1

Source Reduction

8.4.1.1 Residential Source Reduction Methods
As shown in Section 3.1, edible 6 food waste is the largest category of residential waste, at nearly

14 percent, which translates to roughly one pound per person per day of edible food waste.

Planning meals to use leftover food quickly before it spoils, and planning grocery shopping to
only buy what is needed could decrease the amount of waste. Storage to avoid spoilage can

reduce the amount of food wasted: EPA has tips on food storage, such as freezing food that will
not be consumed before it goes bad, delaying washing fresh produce until just before eating

(damp foods spoil faster), and keeping food in airtight containers in the refrigerator.
https://www.epa.gov/sustainable-management-food

Diapers are a large category of residential waste (9%). Typical disposable diapers contain plastic

and take a long time to break down in a landfill. Alternatives to disposable diapers include cloth
diapers (though they require water and energy use for cleaning) and compostable diapers,

which work like typical disposable diapers, but are made of bamboo fiber and do not contain
plastic, thus can decompose faster in a landfill, or can be sent to a commercial composting

facility. The downside to compostable diapers is that they are commonly more expensive than
typical plastic disposable diapers, and are not as widely available.
Additional methods to reduce waste include:
•
•

Purchase household items in bulk to reduce packaging waste.

Purchase items with minimal packaging; reduce mail order purchasing where possible to
avoid excess packaging waste.

•
•

Call direct mailers to remove your name from their mailing lists.

Rent or borrow items that are only used occasionally or obtain used items when
appropriate.

8.4.1.2 Government and Facilities Source Reduction Methods
For tribal administration and offices, the following actions can be taken to reduce waste:
6

The definition of “edible” food includes food that is spoiled or contaminated (no longer safe to eat) but

was intended for eating. “Non-edible food” is scraps such as peels, shells, cores, husks, and bones,

associated with food but not intended for eating. The non-edible portion of the food waste is difficult to
address via source reduction but is discussed in the composting section below.
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•

Minimize the number of documents that are printed – use electronic versions when

possible.
•

Establish a double-sided copying policy. Set all printers to print double sided
automatically.

•
•
•
•
•

Print only the number of copies necessary.

Circulate documents and memoranda rather than making multiple copies.

Use electronic media for document and data archival rather than paper.

Use central bulletin boards and e-mail for broadcast communications.

Work with suppliers to minimize the amount of packaging used. Establishing this

priority in CTCLUSI management and procurement policies could facilitate
discussions with suppliers.
•

Return shipping materials such as crates, cartons, and pallets for reuse; alternatively,
save the packaging and reuse it for outgoing shipments.

•
•

Promote the purchase of items in bulk to reduce packaging.

Purchase durable equipment and supplies. High-quality, long-lasting supplies and

equipment can be repaired and result in fewer discards. These items will stay out of
the waste stream longer, and the higher initial costs are often offset by lower
maintenance and disposal costs.
•

Reuse products and supplies; for example: use reusable office supplies such as

refillable pencils and rechargeable printer cartridges; encourage employees to reuse

common items such as file folders, interoffice envelopes, and report binders; and use
ceramic mugs rather than disposable cups.
•
•

Rent equipment for limited or short-term uses.

Promote the use of less hazardous cleaning products that perform well and are safer

for human health and the environment. This reduces the amount of hazardous waste
that will need to be managed.

8.4.1.3 Source Reduction Methods for Enterprises
The source reduction methods recommended for Government and Facilities also apply to

enterprises. Tips for waste reduction in hotels and casinos is included in Appendix A. Information
on compostable food ware is included in Appendix B.
8.4.2

Reuse

8.4.2.1 Residential Reuse

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Reusing goods within a household and sharing goods for reuse in a broader community are
both important ways to increase reuse and decrease waste generation. To promote reusing
goods within a household, the Tribes could sponsor or facilitate classes on repair and

maintenance to help members fix items in need of mending or promote to its members classes
given by others. King County in Washington has a similar program:

https://kingcounty.gov/en/legacy/depts/dnrp/solid-waste/programs/ecoconsumer/repairevents)

Also, community colleges offer classes in home repair and maintenance. To facilitate sharing

goods for reuse among households, there are several organizations that allow people to offer or
request items for free through online bulletin boards and social networks, such as Buy Nothing

and Freecycle groups. In addition, Craigslist and other online marketplaces facilitate selling and
buying used items. Many types of goods can be reused, such as furniture, appliances, clothes,

sports equipment, etc. This can be particularly applicable for children’s items that are outgrown
quickly before being worn out; or for people who rent or move frequently and need to replace
belongings.

The Tribes could encourage members to use one of these existing platforms to give and request
items, to avoid the need to create a new website or system. Local Freecycle groups already exist
for Florence and Coos County. Buy Nothing groups exist for Coos Bay and Florence. Or, if Tribal
members would be especially interested in sharing within the Tribal community, they could

create their own groups within these platforms or on a separate online or print platform such as
the Tribal website or newsletter. This requires someone to act as the group
moderator/administrator.

The Tribes could also provide an in-person location for giving/receiving used items, such as a
thrift store. This requires volunteers or staff to manage donations and requires a publicly

accessible location to store and organize the used items. An easier approach might be to start
with items that do not require indoor storage, such as construction materials, lumber, and
working appliances.

Dirt and rocks are a large portion of residential waste and might be able to be diverted from
garbage for reuse in building projects.

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8.4.2.2 Reuse for Facilities
Similar to residential reuse, Tribal facilities can promote reuse both within a department and

across departments. For example, an inventory of available equipment could reduce unnecessary
purchases by ensuring that multiple departments don’t buy redundant equipment that is already

available in storage. This could include generic office equipment such as desks and chairs, and
specialized equipment for the dental and medical offices and laboratory.

Additionally, the Tribes could establish a preference for purchasing reused/refurbished

equipment when appropriate. For example, when purchasing IT equipment such as computers
and smartphones, there can be significant cost savings as well as a reduction in natural
resources consumption when buying refurbished models.
8.4.2.3 Reuse Methods for Enterprises
Used items from the casino such as bedding and furniture are given to the Tribal administration
to make available to Tribal members and staff for free (CTCLUSI, 2013). This reduces the cost to
the casino of disposing of these items as waste, and benefits users.

Uncontaminated and unspoiled excess food from the restaurants at the casinos could be

donated to food banks; this would require transportation and safe handling. Food waste that is
not fit for human consumption (for example, table scraps that are left on patrons’ plates in the

restaurant, and food scraps such as vegetable peels from the restaurant kitchen) could be fed to
animals. The Chumash Casino Resort managed by the Chumash Indians received an EPA

recognition for diverting food waste from landfills, including feeding food scraps to animals

https://www.epa.gov/archive/epa/newsreleases/epa-recognizes-santa-ynez-band-chumashindians-achievements-zero-waste-and-food.html

Restaurant kitchen grease (such as frying oils) can be recycled into biodiesel.
The enterprises could also follow the recommendations for government/facilities regarding
reuse of office furniture and equipment, and purchase preferences for refurbished items.

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8.4.3

Recycling

8.4.3.1 Residential Recycling
At the Qa’aich Development, recycling services are not provided: a dumpster for garbage is the

only option for waste disposal. Adding a second dumpster to collect recyclables separately

could reduce the quantity of waste in the garbage dumpster. Dumpsters specifically designed
for recycling with designated openings for each type of recyclable material can help reduce
contamination of recyclable materials.

Most other residences where tribal members live have recycling options. As shown in Section

3.1, about 16% of residential waste is curbside recyclables, and should be targeted for recycling.
There is no current data on what percent of recyclable materials are already being recycled. The
16% reported by ODEQ may include recyclable materials that are thrown in the trash as well as
those that are recycled.

Many of the curbside recycling containers that are currently being used are too small to contain

and cover the amount of cardboard and other discarded recyclable materials that are being

generated. These containers do not have lids to keep cardboard and paper dry. If cardboard and
paper are not contained in an enclosed bin between pickups, these materials often get wet. Wet
cardboard and paper cannot be recycled and will be disposed of as garbage. Obtaining larger
recycling containers with hinged lids that will store large amounts of recyclable materials and

keep those materials dry will increase recycling and divert more cardboard and paper out of the
waste stream. Grant funding from the USEPA Solid Waste Infrastructure for Recycling (SWIFR) is

probably available to support purchase of recycling equipment.

Currently the recycling capability varies by county; ODEQ is planning to harmonize it statewide.
8.4.3.2 Facilities Recycling
As described in Section 4.5, the administrative offices use I-Secure shredding to dispose of

paper. It is not known whether this method is used for all paper or only for sensitive documents.
For routine paper disposal, other paper recycling options are probably less costly.

Aluminum cans and glass bottles are eligible for refunds when delivered for recycling under

Oregon law. Currently the government facilities are collecting aluminum cans and glass bottles

but need a designated person responsible for bringing these to a drop off point and collecting
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the deposit. This could reduce the Tribes’ monthly pickup costs from Les Sanitary and could also
provide revenue.

8.4.3.3 Enterprise Recycling
EPA suggests that recycling should be available throughout casinos and hotel rooms to provide
staff and guests the opportunity to divert waste from the landfill. https://www.epa.gov/green-

building-tools-tribes/greening-tribal-casinos
8.4.4

Composting

8.4.4.1 Residential Composting
The Tribes can encourage the community to develop household compost bins and worm bins

for kitchen food waste. The Tribes could provide home composting bins and information for
interested members. Collection dates for compostable materials could be communicated to

Tribal members, and these materials could be used to make compose for the community
garden.

For materials that cannot be readily composted, like tree branches and brush, yard waste
disposal is available at some of the county transfer stations.

Some of the paper waste that is not recyclable may be compostable: for example, Seattle
accepts pizza boxes for compost/yard waste pickup. Pizza grease contamination on the

cardboard makes it ineligible for recycling, but the cardboard can break down relatively quickly
in a compost pile.

8.4.4.2 Facilities and Enterprises Composting
The Community Garden has composting bins and capacity to handle more food waste, and

could partner with the casino or Tribal Center kitchen. Landscaping waste from the golf course
and casino could potentially be used for composting at the community garden; however, the
volumes generated might be more than the Community Garden can handle.
8.5

Cost Savings Opportunities from Waste Diversion and Reduction

Table 7 provides estimates of potential cost savings opportunities assuming various levels of
waste diversion and reduction. Depending on the percentage of waste that is already being
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recycled and composted, the Tribes may be able to reduce disposal costs for certain waste
streams by 30% to 90%.

Summary Avoided Costs
Residential

$

Enterprises

Potential Diversion Rates

30%

3,152

$

$

18,069

$

Total Avoided Costs/Year $

23,348

$

Facilities

$

2,128

$

50%

5,253 $

70%

90%

7,354

$

30,114 $

42,160

$

54,206

38,914

54,479

$

70,045

3,546 $

$

4,965

$

9,456
6,383

The total avoided costs shown in Table 7 apply to all 499 Tribal residents in the Five-County

Area, not only those living in Tribal housing for whom the Tribes pays directly for waste disposal.

Approximately 20 percent of these residents live in Tribal housing; therefore, the Tribes would
realize about 20 percent of the residential cost savings.

As shown in Table 7, the Enterprises generate most of the Tribes’ solid waste and therefore offer

the largest opportunity for waste reduction and cost savings.

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9.0 CONCLUSIONS AND RECOMMENDATIONS
The best opportunities for waste reduction and associated cost savings are probably within

Tribal enterprises due to the volume of solid waste generated by these operations. Composting
or recycling a fraction of the waste generated at the casinos and golf course could significantly

reduce the Tribes’ costs and adverse effects on the environment. To pursue these opportunities,
the Tribes would need to obtain and evaluate site-specific information including solid waste

generated within each category at each enterprise. The site-specific waste stream could then be

evaluated with respect to current waste management approaches and options to develop a plan

of action for improvement. For example, if disposable plates and utensils are being used,

compostable materials are preferable to Styrofoam and plastic. Recycling should be made

available, accessible, and easy for restaurant and casino guests, many of whom expect their
accommodations to provide recycling. Policies and procedures for purchasing can lead to
decisions that promote reuse and source reduction.

The Strategic Implementation Plan included in Appendix F provides a relatively simple and

useful roadmap that will guide the Tribes during the next five years (2024 – 2028) as they

endeavor to implement initiatives to support the accomplishment of solid waste management
goals. Within the Strategic Implementation Plan the following conclusions and

recommendations are provided along with a framework and timeline for implementation.
Promoting source reduction (through purchasing decisions) and reuse (through facilitating

materials exchanges for used items) are the best ways for residents and Tribal facilities and

services to reduce solid waste generation rates, waste disposal costs, and environmental
impacts.

Recycling and composting are also beneficial. The method of recycling is important: mixed or
uncovered recycling collection is convenient for users but can lead to contamination of the

recyclable materials. For example, cardboard and paper in open containers often get wet from

rain and cannot be recycled. This recyclable material then becomes garbage and is disposed of

in a landfill. The Tribes could promote more successful recycling by working with the solid waste
service providers to supply covered bins for recyclable materials. Promoting these waste

management strategies and providing education on the hazards of backyard burning could

move the Tribes toward their goal of reducing the practice of burning garbage and other debris.
Special waste categories such as medical, dental, and laboratory waste require specialized

handling and disposal. The Tribes’ laboratory will be handling multiple categories of special
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wastes and will need to engage a specialized service provider for proper management of special
and hazardous wastes. Efficiencies of scale may be realized by combining the waste from the
laboratory and the medical and dental facilities.

The Tribes are encouraged to consider ordinances and regulations to control illegal dumping

and enable Tribal police to enforce laws and regulations when violations occur. Deterrent efforts
such as landscaping, educational resources, and culturally relevant signage may also discourage
illegal dumping.

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10.0

REFERENCES

California Department of Resources Recycling and Recovery (CalRecycle). 2006. Estimated Solid
Waste Generation Rates. Available:

https://www2.calrecycle.ca.gov/WasteCharacterization/General/Rates. Accessed
November 15, 2023.

Cascadia Consulting Group (Cascadia). 2021. 2020-2021 Washington Statewide Waste

Characterization Study. Document reference number Publication 21-07-026. Prepared for
State of Washington Department of Ecology. August.

CTCLUSI. 2013. Tribal Integrated Waste Management Plan.
CTCLUSI. 2018. Coos Head Area Master Plan. Accessed at https://ctclusi.org/wpcontent/uploads/2020/09/CHAMP-002.pdf on September 22, 2023.

United States Environmental Protection Agency (USEPA). 2022. National Overview: Facts and

Figures on Materials, Wastes and Recycling. Accessed at https://www.epa.gov/facts-and-

figures-about-materials-waste-and-recycling/national-overview-facts-and-figuresmaterials on November 15, 2023.

United States Environmental Protection Agency (USEPA). 2023. Sustainable Materials

Management: Non-Hazardous Materials and Waste Management Hierarchy. Accessed at
https://www.epa.gov/smm/sustainable-materials-management-non-hazardous-

materials-and-waste-management-hierarchy on November 17, 2023.

Good Company, LLC. 2019. Lane County Solid Waste Management Plan. Prepared for Lane
County Public Works Waste Management Division. Accessed at https://cdnsm5-

hosted.civiclive.com/UserFiles/Servers/Server_3585797/File/Lane_Co_SWMP-2019-07-26FINAL.pdf on September 21, 2023.

Massachusetts Institute of Technology (MIT). 2023. MIT Climate Portal. Accessed at

https://climate.mit.edu/ask-mit/why-do-we-compare-methane-carbon-dioxide-over-

100-year-timeframe-are-we-underrating on October 16, 2023.

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Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
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National Research Council (US) Committee on Health Effects of Waste Incineration (NRC). 2000.
Waste Incineration & Public Health. Available from:
https://www.ncbi.nlm.nih.gov/books/NBK233627/

Oregon Department of Environmental Quality (ODEQ). 2017. Small Quantity Hazardous Waste
Generator Checklist. Accessed at

https://www.oregon.gov/deq/FilterDocs/SQGChecklist.pdf on November 17, 2023.
Oregon Department of Environmental Quality (ODEQ). 2023. 2021 Oregon Material Recovery
and Waste Generation Rates Report. Accessed at

https://www.oregon.gov/deq/recycling/Documents/2021MRWGRatesReport.pdf on

September 22, 2023.

Spangler, Teresa. Director of Guest Services, Three Rivers Casino Resort. Email to Janet Niessner
dated October 16, 2024.

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Figures

Canada
USA

Legend
Tribal Property - Fee
Tribal Property - Trust

_Portland
^
_
^

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Lower Umpqua, and Siuslaw Indians
Path: M:\Projects\2001_CTCLUSI\Mapfiles\2001D\2001D_SWMPlan_Fig01_Location_231023.mxd

November 2024

Figure 1

Location Map

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Integrated Solid Waste Management Plan
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Lower Umpqua, and Siuslaw Indians
Path: M:\Projects\2001_CTCLUSI\Mapfiles\2001D\2001D_SWMPlan_Fig02_SiteInfo_231222.mxd

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November 2024

Figure 2

Site Features

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Integrated Solid Waste Management Plan
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Lower Umpqua, and Siuslaw Indians
Path: M:\Projects\2001_CTCLUSI\Mapfiles\2001D\2001D_SWMPlan_Fig03_Florence_231023.mxd

November 2024

Figure 3

Tribal Properties and

Solid Waste Management Facilities
Florence, Oregon

Legend

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Tribal Properties - Trust

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Solid Waste Transfer Station

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±

2 Miles

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)

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)
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50 Miles "

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)

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(Temporarily Closed)

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1360 Neese St

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Integrated Solid Waste Management Plan
Prepared for the Confederated Tribes of Coos,
Lower Umpqua, and Siuslaw Indians
Path: M:\Projects\2001_CTCLUSI\Mapfiles\2001D\2001D_SWMPlan_Fig04_CoosBay_231023.mxd

Prefoutaine Drive

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Storage Bldg

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GIS Bldg

Laboratory

Greenhouse
Burn
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Building

November 2024

Figure 4

Tribal Properties and

Solid Waste Management Facilities
Coos Bay, Oregon

Legend

Coos
Bay

"
)
"
)
"
)
"
)
"
)"
"
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"
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Coos Head

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Coos Head

)
"
Coal Bank
Slough

West Coast
Recycle
& Transfer

Cape Arago
Light Station

Talbot

Coos County
Solid Waste Beaver Hill

)
"

Integrated Solid Waste Management Plan
Prepared for the Confederated Tribes of Coos,
Lower Umpqua, and Siuslaw Indians
Path: M:\Projects\2001_CTCLUSI\Mapfiles\2001D\2001D_SWMPlan_Fig05_CoosHead_231026.mxd

November 2024

Figure 5

Tribal Properties and

Solid Waste Management Facilities
Coos Head, Oregon

Tables

Table 1. Waste Categories Used in the Waste Stream Composition Analysis
Waste Category *

Description

Paper – Recyclable

Newspaper; magazines; packaging paper; egg cartons; phone books; mixed/lowgrade recyclable papers (cereal and cracker boxes, notebook paper); high-grade
paper (copy machine paper); poly-coated packaging (milk and juice containers,
paper soup cartons); low-grade paper (junk mail, envelopes, construction paper,
sticky notes)

Cardboard- Recyclable

Cardboard containers and boxes (unless poly-or foil-laminated); brown paper
bags; wine boxes

Paper – Non-recyclable

Non-recyclable packaging paper (waxed corrugated cardboard, photos, carbon
paper, foil containing wrapping paper, wall paper, foil lined fast food papers,
microwave paper food trays, individual cigarette packages, paper with large thick
plastic windows, paper containers that held hazardous products, thin bound
reports with plastic covers, and non-food poly-coated boxes); compostable nonrecyclable paper (tissue, paper towel, napkins, paper plates without plastic lining,
molded paper plant pots)

Plastic – Recyclable

Deposit beverage bottles (beer, soft drink, water bottles, wine, milk, infant
formula, juice); No-deposit bottles (small beverage, non-beverage food,
medicines, vitamins, laundry supplies, hair and bath products); 5-gallon buckets;
flower pots; other plastic materials meeting definition of Rigid Plastic Container ;
plastic grocery and garbage bags; packaging film plastic (newspaper bags, bread
bags, product wrap, zip-close bags, furniture wrap, building wrap, cling wrap,
bubble wrap); plastic non-bag film (plastic tarps)

Plastic – Non-recyclable

Other rigid plastic containers that are not acceptable for curbside recycling
(cookie trays, flowerpots, clamshell containers); plastic beverage pouches; plastic
garbage bags; non-recyclable plastic film (stand-up pouches, plastic strapping)

Yard Debris

Natural vegetative material (grass clippings, leaves/weeds, prunings, stumps)

Wood

Manufactured wooden lumber and other items excluding sawdust (unpainted
lumber, clean engineered wood, painted lumber, chemically treated lumber,
wood pallets and crates, wood furniture, pencils, coat hangers, mostly wood
items combined with other materials)

Edible Food

Edible food includes any food, even if spoiled, that was originally produced to be
eaten. Non-packaged bakery goods; packaged bakery goods; non-packaged
vegetative; packaged vegetative; non-packaged meat, eggs, dairy; packaged
meat, eggs, dairy; mixed unpackaged and packaged foods

Non-Edible Food

Non-packaged vegetative food (contains no animal products, fruit pits, corn
husks, carrot tops, coffee grounds); non-packaged animal food-related products
(bones, shells, gristle)

Tires and Rubber

Automotive tires and other tires (bicycle tires, off-road vehicle tires, cart tires,
shredded automotive tires); other rubber (toys, inner tubes, rubber mats, rubber
carpet padding)

Table 1_waste_categories.docx

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 1 of 2

Waste Category *

Description

Diapers

Disposable diapers, including fecal materials contained within

Carpet, Textiles, Roofing,
Furniture, Insulation

Carpet; rugs; polyurethane foam carpet/rug pads; asphalt shingles and tar
roofing paper (recyclable and non-recyclable); mattresses (box springs, futons);
furniture and furnishings; paper composite ceiling tires; other miscellaneous
organics (hair, soap, dead animals)

Glass

Clear or colored glass containers; plate glass (windows, mirrors); other types of
glass products (light bulbs, glassware, glass plates)

Metal - Recyclable

Aluminum (beverage cans, foil, scrap); steel/bimetal beverage cans; tinned cans;
non-ferrous metal; food cans; large household appliances; ferrous metal (things
made from metal to which a magnet will adhere); items made of mixture of
ferrous and non-ferrous metals or items made from a mixture of metal and nonmetallic materials

Metal – Non-recyclable

Other aluminum not acceptable curbside (Furniture, house siding, cookware, and
scrap); Other non-ferrous not acceptable at curbside (insulated copper wire,
pieces longer than 30” or not being pure metal); other ferrous metals not
curbside acceptable (household, industrial, and commercial products derived
from iron); mixed ferrous/non-ferrous not curbside acceptable (mainly metal
items such as electric motors, old lawnmowers, engines); white goods (discarded
stoves, washer, dryers, refrigerators and other large household appliances), used
oil filters; empty aerosol cans

Electronics/Small
Appliances

Computer monitors; computer main central processing units (CPU); printers;
computer mice and keyboards; microwaves; TV’s; other consumer electronics
(DVD, calculators, stereos); non-electronic small appliances (fans, can openers,
blenders)

Other Inorganics

Rock, concrete and brick; soil, dirt, sand; pet litter, animal feces; gypsum
wallboard; fiberglass insulation; other inorganics (plaster, ash, ceramics, china,
and porcelain)

Medical Waste

Syringes, tubing, gauze, blood-containing. Bags and containers with medical
waste are not sorted further. Other non-medical waste that is contained with
medical waste is sorted as medical waste.

Hazardous and Special
Waste

Lead-acid batteries, dry-cell batteries; latex paint, oil-based paints; motor oil;
other flammables (thinners, solvents, fuels, hair spray); Pesticides, herbicides, or
fungicides; fertilizers; corrosive cleaners; asbestos; mercury-containing items; live
ammunition and explosives; compressed gas cylinders; hazardous chemicals;
unlabeled hazardous

* Waste categories from the State of Oregon Department of Environmental Quality Material Categories
for the 2016 Waste Composition Study, Field Sorting Categories

Table 1_waste_categories.docx

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
November 2024 Page 2 of 2

Table 2. CTCLUSI Residential and Commercial Waste Stream Generation and Composition
Generation Rate from all sources
Estimated Residential Generation Rate
Population*

1.5
0.32
499

Amount of Solid Waste Generated by Source
Generators
Tons
Residential
159.7
Facilities
90.5
Enterprises
768.9
1019.1

tons per person per year Average for five-county area (ODEQ, 2023)
tons per person per year (Cascadia, 2021)
persons

Percent
16%
9%
75%
100%

Estimate of Solid Waste Generated by Source
Residential
Tons
Facilities
Tons
Enterprises
Tons Total Tons Total Percent
Paper - Recyclable
6.85%
10.94
5.60%
5.07
5.60%
43.07
59.08
5.80%
Cardboard - Recyclable
2.31%
3.69
3.34%
3.03
3.34%
25.69
32.40
3.18%
Paper - Non-recyclable
10.06%
16.07
10.44%
9.45
10.44%
80.27
105.79
10.38%
Plastic - Recyclable
3.83%
6.11
4.27%
3.87
4.27%
32.83
42.81
4.20%
Plastic - Non-recyclable
8.63%
13.77
10.36%
9.38
10.36%
79.65
102.81
10.09%
Yard Debris
4.59%
7.33
1.55%
1.40
1.55%
11.92
20.65
2.03%
Wood
2.88%
4.60
12.78%
11.57
12.78%
98.26
114.43
11.23%
Edible Food
13.72%
21.91
11.73%
10.62
11.73%
90.19
122.72
12.04%
Non-Edible Food Scraps
9.46%
15.10
9.68%
8.76
9.68%
74.42
98.29
9.65%
Tires and Rubber
0.49%
0.78
0.78
0.08%
Diapers
8.91%
14.22
2.70%
2.44
2.70%
20.76
37.43
3.67%
Carpet, textiles, roofing, furniture, insulatio
10.59%
16.91
9.24%
8.36
9.24%
71.03
96.31
9.45%
Glass
3.11%
4.96
8.32%
7.53
8.32%
63.97
76.46
7.50%
Metal - Recyclable
2.89%
4.62
1.83%
1.66
1.83%
14.07
20.34
2.00%
Metal - Non-recyclable
0.59%
0.95
0.83%
0.75
0.83%
6.38
8.08
0.79%
Electronics/Small Appliances
0.68%
1.09
0.98%
0.89
0.98%
7.52
9.49
0.93%
Other Inorganics
10.46%
16.71
3.57%
3.23
3.57%
27.45
47.39
4.65%
Medical Wastes
2.37%
2.15
2.37%
18.22
20.37
2.00%
Hazardous Materials
0.48%
0.77
0.22%
0.20
0.22%
1.69
2.66
0.26%
Totals
100.5%
160.54
100%
90.37
100%
767.39
1018.29
100%
**
Notes:
* Enrolled CTCLUSI members living in the Five-County Area
** Total differs slightly from 100% due to rounding and exclusion of very minor waste categories
Blanks in table indicate percentage was negligible
lbs = pounds
Material

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
2001_Tables_2-7_ISWMP_241125.xlsx/Table 2

November 2024 Page 1 of 1

Table 3. Estimate of Waste Generation Quantities by Enterprise
Casino: Florence Casino: Coos Bay
Golf Course
RV Park
Generator
Use (unit)
Rate
Quantity Waste* Quantity Waste* Quantity Waste* Quantity Waste*
Casino Space (sf)**
0.0061
76,000 463.60
15,500 94.55
Food and Beverage (sf)
0.0064
6000
38.40
Retail (sf)
0.0064
7500
48.00
Other/Office (sf)
0.0013
15,500 20.15
1500
1.95
RV Spaces (count)
0.7300
40
29.20
Hotels (room)
0.7300
100 73.00
Total tons for Enterprises 768.85
556.75
94.55
88.35
29.20
Percent of Waste Stream by Enterprise:
72.4%
12.3%
11.5%
3.8%
Notes:
* Waste in tons per year
** Casino space includes gaming space, food and beverage, entertainment, and retail. Casino Space Rate is average of these uses.
Rate = Generation Rate (tons/unit/year) (CalRecycle 2006)
sf = square feet
All quantities based on publicly available information (Google Earth Pro and casino website)

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
2001_Tables_2-7_ISWMP_241125.xlsx/Table 3

November 2024 Page 1 of 1

Table 4. Estimate of Waste Stream Generation Quantities and Composition by Enterprise
Quantities of Solid Waste
Current Enterprises (total)
Florence Casino
Coos Bay Casino
Golf Course
RV Park

Material

769
556.8
94.6
88.4
29.2

tons
tons
tons
tons
tons

Composition Enterprises

Florence

Coos Bay

Golf

Casino
5.30
3.16
9.87
4.04
9.80
1.47
12.08
11.09
9.15
2.55
8.74
7.87
1.73
0.78
0.92
3.38
2.24
0.21

Course
4.95
2.95
9.22
3.77
9.15
1.37
11.29
10.36
8.55
2.39
8.16
7.35
1.62
0.73
0.86
3.15
2.09
0.19

94.37

88.18

Paper - Recyclable
Cardboard - Recyclable
Paper - Non-recyclable
Plastic - Recyclable
Plastic - Non-recyclable
Yard Debris
Wood
Edible Food
Non-Edible Food Scraps
Diapers
Carpet, textiles, roofing, furniture, insulation
Glass
Metal - Recyclable
Metal - Non-recyclable
Electronics/Small Appliances
Other Inorganics
Medical Wastes
Hazardous Materials

5.60%
3.34%
10.44%
4.27%
10.36%
1.55%
12.78%
11.73%
9.68%
2.70%
9.24%
8.32%
1.83%
0.83%
0.98%
3.57%
2.37%
0.22%

43.07
25.69
80.27
32.83
79.65
11.92
98.26
90.19
74.42
20.76
71.03
63.97
14.07
6.38
7.52
27.45
18.22
1.69

Casino
31.19
18.60
58.12
23.77
57.68
8.63
71.15
65.31
53.89
15.03
51.44
46.32
10.19
4.62
5.44
19.88
13.19
1.22

Totals (percentage, tons)

100%

767.39

555.69

RV Park
1.64
0.98
3.05
1.25
3.03
0.45
3.73
3.43
2.83
0.79
2.70
2.43
0.53
0.24
0.29
1.04
0.69
0.06
29.14

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
2001_Tables_2-7_ISWMP_241125.xlsx/Table 4

November 2024 Page 1 of 1

Table 5. CTCLUSI Residential Projected Growth
Material and Percent

Year
Pop.*
TPY
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons
tons

2023
499
160
11
4
16
6
14
7
5
22
15
1
14
17
5
5
1
1
17
1
160

2033
624
200
14
5
20
8
17
9
6
27
19
1
18
21
6
6
1
1
21
1
200

Laboratory Waste Generation
Use (unit)
Rate (TPY)
Hazardous waste SQG (year)
2.4
Other office (sf)
0.0013

Quantity Waste (tons)
1
2.40
1800
2.34
Total Tons
4.74

Paper - Recyclable
6.9%
Cardboard - Recyclable
2.3%
Paper - Non-recyclable
10.1%
Plastic - Recyclable
3.8%
Medical Clinic Waste Generation
Plastic - Non-recyclable
8.6%
Use (unit)
Rate (TPY) Quantity Waste (tons)
Yard Debris
4.6%
Hospital (beds)
2.92
3
8.76
Wood
2.9%
Total Tons
8.76
Edible Food
13.7%
Non-Edible Food Scraps
9.5%
Tires and Rubber
0.5%
Diapers
8.9%
Carpet, textiles, roofing, furniture, insulation 10.6%
Glass
3.1%
Metal - Recyclable
2.9%
Metal - Non-recyclable
0.6%
Electronics/Small Appliances
0.7%
Other Inorganics
10.5%
Hazardous Wastes
0.5%
Totals 100.5%
***
Notes:
* Population - Enrolled CTCLUSI members living in the Five-County Area
*** Total differs slightly from 100% due to rounding and exclusion of very minor waste categories
Pop. - population (estimated to increase 25% in 10 years)
sf - square feet
SQG - Small Quantity Generator
TPY - tons per year
TPY =( [population] x [lbs/person/day (from Table 2)] x [days in year] )/2000 lbs/ton
Laboratory hazardous waste is estimated at 400 pounds per month (Oregon DEQ 2017)
Laboratory nonhazardous waste is estimated based on the rate for retail uses
Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
2001_Tables_2-7_ISWMP_241125.xlsx/Table 5

November 2024 Page 1 of 1

Table 6. Projected Future Waste Generation due to Enterprise Expansion
Florence Casino
Coos Head
Generator
RV Park
Development
Use (unit)
Rate Quantity Waste* Quantity Waste*
Retail (sf)
0.0064
12000
76.80
RV Spaces (each)
0.7300
60
43.80
20
14.60
Cottages (each)
0.7300
Total tons for Enterprises 135.20
43.80
91.40
Notes:
* Waste in tons per year
sf = square feet
Rate = Generation Rate (tons/unit/year) (CalRecycle 2006)
RV Park - hotel room rate used for RV spaces and cottages

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
2001_Tables_2-7_ISWMP_241125.xlsx/Table 6

November 2024 Page 1 of 1

Table 7. Cost Savings Opportunities from Waste Diversion
Amount of Solid Waste Generated by Source

Potential Diversion Rates

Summary Avoided Costs

Generators

Tons

Residential

159.7

Residential

$

3,152 $

5,253 $

7,354 $

Facilities

90.5

Facilities

$

2,128 $

3,546 $

4,965 $

6,383

Enterprises

768.9

Enterprises

$

18,069

$

30,114 $

42,160 $

54,206

Total

1019.1
Total Avoided Costs/Year $

23,348

$

38,914

54,479

70,045

Disposal cost per ton estimate 1

30%

50%

70%

$

90%

$

9,456

$132.54

Residential Estimated Waste Generation & Potential Diversion

30%

Avoided

Disposal

50%

Potential Diversion
Avoided
70%

Disposal

Avoided

Disposal

90%

Avoided

Disposal

Residential

Tons

Recycle

Paper - Recyclable

6.85%

10.94

3.28

Costs
$/ton
$132.54 $
434.92

5.47

$/ton
$132.54 $

724.87

7.66

Costs
$/ton
$132.54 $ 1,014.81

9.84

Costs
$/ton
$132.54 $ 1,304.76

Cardboard - Recyclable

2.31%

3.69

1.11

$132.54 $

146.68

1.84

$132.54 $

244.46

2.58

$132.54 $

342.25

3.32

$132.54 $

440.04

Paper - Non-recyclable

10.06%

16.07

Plastic - Recyclable

3.83%

6.11

1.83

$132.54 $

243.12

3.06

$132.54 $

405.20

4.28

$132.54 $

567.28

5.50

$132.54 $

729.36

Plastic - Non-recyclable

8.63%

13.77

Material

Compost

Recycle

Compost

Costs

Recycle

Compost

Recycle

Compost

Yard Debris

4.59%

7.33

2.20

$132.54 $

291.60

3.67

$132.54 $

485.99

5.13

$132.54 $

680.39

6.60

$132.54 $

874.79

Wood

2.88%

4.60

1.38

$132.54 $

182.87

2.30

$132.54 $

304.79

3.22

$132.54 $

426.70

4.14

$132.54 $

548.62

Edible Food

13.72%

21.91

6.57

$132.54 $

871.24

10.96

$132.54 $

1,452.06

15.34

$132.54 $

2,032.89

19.72

$132.54 $

2,613.71

Non-Edible Food Scraps

9.46%

15.10

4.53

$132.54 $

600.57

7.55

$132.54 $

1,000.96

10.57

$132.54 $

1,401.34

13.59

$132.54 $

1,801.72

Tires and Rubber

0.49%

0.78

Diapers

8.91%

14.22

Carpet, textiles, roofing, furniture, insulation

10.59%

16.91

Glass

3.11%

4.96

1.49

$132.54 $

197.30

2.48

$132.54 $

328.84

3.47

$132.54 $

460.38

4.47

$132.54 $

591.91

Metal - Recyclable

2.89%

4.62

1.39

$132.54 $

183.61

2.31

$132.54 $

306.01

3.23

$132.54 $

428.42

4.16

$132.54 $

550.83

Metal - Non-recyclable

0.59%

0.95

$ 3,151.91

15.16

$

5,253.18

21.22

$

7,354.46

27.29

$

9,455.73

Electronics/Small Appliances

0.68%

1.09

Other Inorganics

10.46%

16.71

Medical Wastes
Hazardous Materials
Totals

0.48%

0.77

100%

160.54

9.10

14.68

24.47

34.26

44.05

Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians
Integrated Solid Waste Management Plan
2001_Tables_2-7_ISWMP_241125/Table 7

November 2024 Page 1 of 3

Facilities Estimated Waste Generation & Potential Diversion

30%

Avoided

Disposal

50%

Potential Diversion
Avoided
70%

Disposal

Avoided

90%

Avoided

Disposal

Tons

Recycle

Paper - Recyclable

5.60%

5.07

1.52

Costs
$/ton
$132.54 $
201.68

2.54

$/ton
$132.54 $

336.14

3.55

Costs
$/ton
$132.54 $
470.59

4.57

Costs
$/ton
$132.54 $
605.05

Cardboard - Recyclable

3.34%

3.03

0.91

$132.54 $

120.29

1.51

$132.54 $

200.48

2.12

$132.54 $

280.68

2.72

$132.54 $

360.87

Paper - Non-recyclable

10.44%

9.45

Plastic - Recyclable

4.27%

3.87

1.16

$132.54 $

153.72

1.93

$132.54 $

256.20

2.71

$132.54 $

358.68

3.48

$132.54 $

461.16

Plastic - Non-recyclable

10.36%

9.38

Compost

Recycle

Compost

Costs

Disposal

Facilities

Material

Recycle

Compost

Recycle

Compost

Yard Debris

1.55%

1.40

0.42

$132.54 $

55.80

0.70

$132.54 $

93.00

0.98

$132.54 $

130.20

1.26

$132.54 $

167.40

Wood

12.78%

11.57

3.47

$132.54 $

460.08

5.79

$132.54 $

766.80

8.10

$132.54 $

1,073.52

10.41

$132.54 $

1,380.24

Edible Food

11.73%

10.62

3.19

$132.54 $

422.28

5.31

$132.54 $

703.80

7.43

$132.54 $

985.32

9.56

$132.54 $

1,266.84

Non-Edible Food Scraps

9.68%

8.76

2.63

$132.54 $

348.48

4.38

$132.54 $

580.80

6.13

$132.54 $

813.12

7.89

$132.54 $

1,045.44

Tires and Rubber
Diapers

2.70%

2.44

Carpet, textiles, roofing, furniture, insulation

9.24%

8.36

Glass

8.32%

7.53

2.26

$132.54 $

299.52

3.77

$132.54 $

499.20

5.27

$132.54 $

698.88

6.78

$132.54 $

898.56

Metal - Recyclable

1.83%

1.66

0.50

$132.54 $

65.88

0.83

$132.54 $

109.80

1.16

$132.54 $

153.72

1.49

$132.54 $

197.64

Metal - Non-recyclable

0.83%

0.75

Electronics/Small Appliances

0.98%

0.89

Other Inorganics

3.57%

3.23

Medical Wastes
Hazardous Materials

2.37%
0.22%

2.15
0.20
$ 2,127.73

10.58

$

3,546.22

14.81

$

4,964.71

19.04

$

6,383.20

Totals

100%

90.37

6.35

9.71

[Text truncated at 120,000 characters. The full text is on the page linked above.]

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Aconfederated_clusi%3Ac94cb25af12beba4. Public record. Not legal advice.
