We work with the residents of Lincoln Heights, who are strongly opposed to the city’s consideration of a solid waste transfer station on Hinson Street.  The location of a facility near Lincoln Heights would disproportionately impact this historic African American neighborhood which has already been burdened with Roanoke Rapids’ garbage since 1959.

Despite the assertions a waste transfer station could create additional revenue for the city, the need for it has not been established and the projections seem optimistic.  Nothing suggests that Roanoke Rapids and Halifax County’s current agreement with Waste Industries is insufficient to handle the waste stream from Roanoke Rapids through current disposal methods.  Nor is it evident that the proposed transfer station will necessarily generate additional revenue.  To be profitable, projections assume an annual waste stream of at least 28,000 tons.  Roanoke Rapids only generates 7,000 tons and the remainder is an estimate of commercial waste.  The city’s projections assume that commercial waste haulers in Roanoke Rapids would use the new transfer station rather than existing facilities they have presumably been using for years.  As the Council was warned in 2003 by Bill Drietzler of Marlow, Dreitzler and Associates, a predecessor of MS Consultants, “it would probably be more expensive for the City to build and operate a waste transfer station than it would be to haul the solid waste to another location.”

As you may know, North Carolina General Statute § 130A-294(a)(4) requires the Department of Environment and Natural Resources to deny any permit for a solid waste facility if “[t]he cumulative impact of the proposed facility, when considered in relation to other similar impacts of facilities located or proposed in the community, would have a disproportionate adverse impact on a minority or low-income community.”  At least three of Roanoke Rapids’ previous landfills, most recently the yard-waste site on Hinson St., have been located in or immediately adjacent to Lincoln Heights. It is past time for the city to stop burdening this excluded African American community, already denied basic municipal services and lacking representation in the city government, with the adverse health and environmental impacts of the city’s waste disposal.

According to the National Environmental Justice Advisory Council, a Federal Advisory Committee to the U.S. Environmental Protection Agency (EPA), “Waste Transfer Stations are disproportionately clustered in low-income communities and communities of color.”  The committee noted that Waste Transfer Stations can create issues of “noise, odor, litter, and traffic,” and environmental problems like “poor air quality . . . and disease-carrying vectors such as rodents and roaches.”  (A Response to a Recurring Environmental Justice Circumstance:  The Siting of Waste Transfer Stations in Low-Income Communities and Communities of Color).  These issues already plague this community due to the prior Roanoke Rapids’ municipal landfills in this area, including the two off Hinson Street, and one in the middle of Lincoln Heights on Godley Street.

We urge the city to solicit meaningful community input before proceeding with site selection or establishing the site selection criteria.  As the EPA suggests in its manual, Waste Transfer Stations:  A Manual for Decision Making, “The public must be a legitimate partner in the facility siting process to integrate community needs and concerns and to influence the decision-making process .”   The first step to do this, as suggested by the EPA, is to create a community advisory panel to establish the site selection criteria and oversee the site selection.  The committee should not only include elected officials and solid waste professionals, but “community and neighborhood groups,” and “environmental organizations,” and “should seek gender balance and racial diversity.”

We hope Roanoke Rapids will follow EPA’s recommendations and engage the community in the process.  Lincoln Heights look forward to working with the city  to develop criteria that reflect the concerns of the neighborhood, EPA’s recommendations and statutory requirements.

Mark Dorosin

Senior Managing Attorney, UNC Center for Civil Rights

Florine Bell

Executive Director, Lincoln Heights Community Development Coalition, Inc.