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Mohegan Tribe of Indians of Connecticut

The Mohegan Tribe seal

The Mohegan Tribe of Indians of Connecticut has been extremely successful in its management of municipal solid waste (MSW). According to data submitted to the Connecticut Department of Environmental Protection, in fiscal year 1997, the Mohegan Reservation recycled 44 percent of its solid waste, twice the average recycling rate for towns and cities in Connecticut.

In 1997, the Tribe established an integrated MSW management program for the Mohegan Sun Casino and the tribal government. The program emphasizes waste reduction activities, such as source reduction, reuse, and recycling practices over waste disposal options. A tribal Pollution Prevention (P2) Team develops plans and strategies for the program, while the Mohegan Environmental Management Division (EMD) administers monitoring, education, and certification programs to ensure compliance with tribal MSW policy.

Source reduction activities are an important part of the MSW management program. These include water-conserving irrigation methods, the use of compost as a substitute for peat moss mulch. The use of native versus ornamental plants in landscaping reduces water and chemicals used for maintenance because the plants are better adapted to their environment. Other tribal waste reduction efforts include the adaptive reuse of old buildings for new facilities, integrated pest management practices, and the implementation of a toxicity reduction program to minimize chemical use and switch to less toxic products.

Recycling is also an important component of the overall Mohegan MSW management program. Selling recyclable materials produces revenue and reduces the cost of hauling and disposing of waste. The Tribe sells a variety of recyclable materials, including corrugated cardboard, paper, plastic, cans, glass, food waste, and cooking grease. Food waste is sent to a hog farm, and cooking grease is sold to a business in Massachusetts that uses it as an ingredient in animal feed. To further close the recycling loop, the Mohegan tribe makes “environmentally preferable procurement” decisions, buying products with recycled content whenever possible.

The Mohegan MSW management program is managed by EMD and implemented by the Mohegan Pollution Prevention (P2) Team, a multidisciplinary team made up of upper tribal management as well as managers and handlers of the waste stream. The P2 Team shares case studies, analyzes technical papers describing the economic and environmental impacts of various pollution prevention opportunities, sets policy and goals, develops strategies for implementation of activities, and recognizes those who have achieved outstanding results for the MSW management program. The Tribe keeps comprehensive purchase and disposal records to facilitate planning and decision-making by the P2 Team.

EMD conducts a variety of education activities to ensure that the MSW management program reaches the waste reduction goals set by the P2 Team. For example, at new employee orientations for the Mohegan Sun Casino, EMD explains the official tribal policy for waste management emphasizing the responsibility of all employees to carry out this policy. At the workplace, waste management information is posted on various bulletin boards, including electronic bulletin boards in the Mohegan Sun employee cafeteria. Designated recycling containers are clearly marked with signs. In addition, EMD places P2 information in weekly employee newsletters and in tribal newspapers. Through education, employees can more easily learn and comply with tribal policy, codes, and P2 performance expectations, and can better understand the financial and environmental risk reduction benefits that result from integrated MSW management.

The contractor certification program is also an important part of Mohegan MSW management. All contracts that involve solid waste handling require that both contractors and their staff receive P2 training and certification by EMD. To receive certification, contractors must agree to characterize their waste streams and to allow EMD to conduct site visits to their facilities. At site visits, EMD personnel photograph and videotape contractor MSW management activities to ensure compliance with tribal policy.

Another effective policy used to encourage compliance with the Mohegan MSW management plan involves requirements for trash pickup. If trash is not separated for recycling, haulers do not pick it up; instead, they leave a written notice explaining tribal policy and waste separation procedures.

According to Dr. Norman Richards of EMD, the key components of the Mohegan integrated MSW management plan can be summarized as follows:

Richards believes that the Tribe's MSW management plan is successful because everyone has been involved—Mohegan Sun staff, consultants, the Tribal Council, building maintenance personnel, architects and engineers, gaming interests, transportation and facility managers, food service operators, and health service sanitarians. EMD has a strong commitment to tribal policy, and the Tribe reaps substantial cost and space savings, as well as an overall environmental benefit resulting from integrated MSW management activities.

For more information contact Dr. Norman Richards at 860 204-6112 or by fax at 860 204-6129. The Mohegan Tribe, PO Box 488, Uncasville, CT 06382.

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