Out of State Waste

Collaborative Solid Waste Strategies is acutely aware of unmonitored loads of out of state waste being brought into our New Hampshire landfills every day. This is something that the Concord Monitor reported on December 31, 2022, written by Sruthi Gopalakrishnan; partially reprinted here with permission:

Landfill landscape: New Hampshire is an importer of solid waste from other states

…Millions of tons of trash end up in New Hampshire’s landfills each year, including municipal solid waste, construction and demolition debris, and ash. The waste stream includes countless items that consumers assume are being recycled and thousands of truckloads from other New England states.

It’s common to believe that all of the items in bright blue single-stream bins emblazoned with three chasing arrows is recycled. That, however, is not the case. Mixed materials like plastic-coated paper cartons and greasy pizza boxes can contaminate other clean recyclables, sending the whole lot into landfills. Moreover, as the market for unsorted recycling has collapsed, the companies that collect single-stream bins can send the contents directly to the dump if that’s the cheapest option, which is what Pinard Waste did for a time in Bow.

There’s little way to know if the recyclable bottles, cans and paper from your house are actually ending up in a landfill instead.

Different types of waste are disposed of in nine enormous landfills spread across the state. Most of these modern-day landfills are engineered with environmental safety in mind and are lined with low-permeable materials to keep contaminants from leaching into the groundwater or soil.

Until the mid-1970s, nearly every municipality in the state had its own dump – a hole in the ground with no protective lining where waste was thrown and left exposed to scavengers, rain, and heat. They harmed the environment and public health by spewing methane and leachate, a toxic soup that seeped into groundwater. When the state passed the Solid Waste Management Act in 1981, most open dumps were required to clean up and close.

While this was an important step forward in solid waste regulation, New Hampshire remains an importer of waste with little state oversight of companies that profit from dumping here.

A report from the state’s environmental department published in November shows that more than 45% of the trash comes from out-of-state sources. In 2020, more than 900,000 tons of solid waste were dumped in three commercial landfills.

The NHDES Solid Waste Management Bureau regulates solid waste in the state through a permit system. Landfills must obtain a permit to ensure that their operations are safe for public health and the environment.

The permit allows the state to oversee and regulate landfills, incinerators, recycling and composting plants. But limited resources make it difficult to carry out regulatory actions. The DES Waste Division lacks funding, leaving waste management initiatives frequently pinched for cash.

Another concern with the state’s waste management department is a lack of oversight. If prohibited materials are put in landfills, the state is unaware unless notified. The state hands over the responsibility of inspecting and rejecting banned materials to landfill operators, much like an honor-based system.

Emily Jones, compliance assurance section supervisor for the state’s solid waste management said each facility is authorized to accept certain types of waste and they are responsible for adhering to their permits.

“We wouldn’t know of something being delivered unless we’re contacted by the facility or we receive a complaint or when we are doing an inspection,” said Jones.

A plan for solid waste

After nearly two decades the state updated its solid waste management plan with goals to reduce in-state waste generation and trash toxicity. The plan lists strategies to maximize diversion strategies like recycling and composting to ensure the state has sufficient capacity for its own trash. However, it fails to address the escalating problem of out-of-state trash.

While updating the state’s antiquated waste management plan is a step in the right direction, environmental advocacy groups argue the plan itself does not commit to taking actual action to address the problem.

“It’s really hard to get excited about something when it’s very open-ended,” said Peter Blair, state policy director with Just Zero, a nonprofit working towards reducing and recycling waste. “It could easily become just a policy document that sits on a shelf and isn’t actually used to guide agency action over the long term.”

The Conservation Law Foundation, an environmental advocacy group, submitted comments on the plan, urging New Hampshire to develop a strategy to decrease out-of-state disposal. Heidi Trimarco, staff attorney with the foundation described the document as a “wish list” rather than an actual plan.

“There’s some good language in there, recognizing the concerns, but that’s kind of all the plan does,” said Trimarco. “It’s not good enough.”

As New Hampshire tries to achieve its goal of waste reduction through its new plan, other New England states have already taken firm steps to address waste disposal. In November, Massachusetts prohibited the dumping of mattresses and textiles in landfills. The state instead requires they be recycled. In April, Maine passed legislation prohibiting the disposal of out-of-state waste in the state’s landfill. Vermont has established aggressive standards for what can and cannot be disposed of in its landfills, for both in-state and out-of-state trash.

A ban on out-of-state trash may seem like an easy solution to New Hampshire’s waste problem, but it would violate the Interstate Commerce Clause, according to environmental experts. Having severe limits on the types of material that can be dumped in the state’s landfills, as Vermont did, can help to solve the problem.


Boscawen Corn Hill Road C & D Landfill

  • Town/City: Boscawen
  • Ownership: Public
  • Liner Status: Unlined
  • Waste Type: Construction and demolition debris
  • Remaining Life: 1 year
  • Remaining Capacity: N/A

Epping Bulky Waste Disposal Area

  • Town/City: Epping
  • Ownership: Public
  • Liner Status: Unlined
  • Waste Type: Yard Waste
  • Remaining Life: 25 years
  • Remaining Capacity: 30,000 cubic yards

Lebanon Regional Solid Waste Facility

  • Town/City: Lebanon
  • Ownership: Public
  • Liner Status: Lined
  • Waste Type: Municipal solid waste, construction and demolition debris
  • Remaining Life: 9 years
  • Remaining Capacity: 768,500 cubic yards

Lower Mt. Washington Valley Secure SW Landfill

  • Town/City: Conway
  • Ownership: Public
  • Liner Status: Lined
  • Waste Type: Municipal solid waste, construction and demolition debris
  • Remaining Life: 17 years
  • Remaining Capacity: 193,000 cubic yards

Merrimack Station Coal Ash Landfill

  • Town/City: Bow
  • Ownership: Private
  • Liner Status: Lined
  • Waste Type: Fly Ash, Slag
  • Remaining Life: 50+ years
  • Remaining Capacity: 92,660 cubic yards

Mt. Carberry Secure Landfill

  • Town/City: Success
  • Ownership: Public
  • Liner Status: Lined
  • Waste Type: Municipal solid waste, construction and demolition debris, ash
  • Remaining Life: 32.94 years
  • Remaining Capacity: 9,737,000 cubic yards

Nashua Four Hills Secure Landfill Expansion

  • Town/City: Nashua
  • Ownership: Public
  • Liner Status: Lined
  • Waste Type: Municipal solid waste, construction and demolition debris, ash
  • Remaining Life: 7.7 years
  • Remaining Capacity: 1,031,000 cubic yards

NCES Lined Landfill Stage 4, 5, 6

  • Town/City: Bethlehem
  • Ownership: Private
  • Liner Status: Lined
  • Waste Type: Municipal solid waste, construction and demolition debris, ash
  • Remaining Life: 5 years
  • Remaining Capacity: 623,500 cubic yards

Turnkey Landfill

  • Town/City: Rochester
  • Ownership: Private
  • Liner Status: Lined
  • Waste Type: Municipal solid waste, construction and demolition debris, ash
  • Remaining Life: 12.5 years
  • Remaining Capacity: 19,036,000 cubic yards

CSWS Responds in the following Letter to the Editor

Wake up, NH legislators

Kudos to the Concord Monitor for launching the Environmental Reporting Lab and selecting the solid waste dilemma in the Live Free or Die State for the inaugural topic. And kudos to Sruthi Gopalakrishnan of the Monitor staff for an accurate overview which should motivate Granite Staters to wake-up and address the urgency created by out-of-state trash filling our landfills. This new series contributes to New Hampshire’s environmental literacy while exposing the state’s failure to adopt restrictive legislation against indiscriminate dumping of other states’ trash.

The Old Man of the Mountain must be rolling over in disgust that our state has fallen into this abyss caused by careless disregard and apathy. While Vermont and Maine successfully legislate against uncontrolled invasion of their landfills, New Hampshire’s legislature continues to sleep at the switch. Why is this? What our state deserves is a genuinely pro-environment governor and enlightened legislature to jumpstart the overdue process of dealing responsibly and aggressively with long term solid waste challenges.

Here at Collaborative Solid Waste Strategies, we will keep you posted on pertinent developments in New Hampshire and the region regarding trash. We’re committed to advocate for efficient, socially equitable, economically and environmentally sustainable, regionalized approaches to solid waste management. Wake up, New Hampshire Legislature, and take control of the situation in 2023, not later.

Please, no more putting off to tomorrow what should have been dealt with yesterday.


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