...link to full Hardwick Landfill History and Document Summary
14.1 Gull Policy
GULL CONTROL PLAN
Submitted as part of Landfill Permit Modification Application
7/23/03
HARDWICK LANDFILL INC.
Hardwick, Massachusetts
GULL CONTROL PROGRAM AND PLAN
HARDWICK LANDFILL
1.0 INTRODUCTION
The Hardwick Landfill will comply with MDEP policy # BWP-98-003 on gull control at
landfills. These standards require that gulls be prohibited from feeding and that
opportunities for gulls to rest and roost should not be provided.
The Gull Control Program must prevent impacts to nearby water supplies from the
Hardwick Landfill and must prevent gull populations from impacting airports. There is a
surface water supply reservoir within gull commuting distance of the landfill. There are
no major airports within 10 miles that are registered with the Federal Aeronautics
Administration. There are two small landing strips within 10 miles that are registered
with the Massachusetts Aeronautics Commission.
This gull control program addresses the particular needs and situation of this landfill.
Landfills vary in characteristics that make them suitable or attractive to gulls, such as
location, size and operational methods. Consequently, some sites may only need to
implement minimal control methods to successfully control gulls, whereas other sites
may need more aggressive measures to achieve effective gull control.
This Gull Control Plan is implemented as part of the Operations & Maintenance Plan and
includes recommendations for standard site operations such as prompt use of daily cover,
limited mowing to prevent vegetation on unused landfill areas that may provide shelter,
procedures for gull harassment and the use of pyrotechnic devices.
2.0 SITE LOCATION
The Hardwick Landfill is located in a remote area of western central Massachusetts. The
Regional Map (Figure 1) shows the topography, surface water supply reservoir, and a
landing strip within the 5-mile radius. There are no major airports within 10 miles.
There are two small landing strips within 10 miles; the Barre-Hiller strip in Wheelwright
and a private strip on the Ware River in Ware, MA, that are registered with the
Massachusetts Aeronautics Commission. The Quabbin Reservoir is approximately 3
miles to the west of the landfill. The Locational Map (Figure 2) shows a 50-mile radius
around the landfill.
3.0 HISTORY AND EXTENT OF GULL ACTIVITY
The Hardwick Landfill has historically been a C&D landfill and has not had a problem
with gulls as long as it has been operating. The lack of gulls has been attributed to the
operational methods for MSW being disposed and the lack of hospitable habitat area
adjacent to the landfill. The small area of the landfill with trees close to the sides does
not provide the wide-open views that gulls prefer to avoid predators. The new gull
control program includes these continued Operational and Habitat Controls and is
designed to prevent conditions attractive to gulls from occurring.
4.0 GOALS AND OBJECTIVES OF PROGRAM
The objective of the Gull Control Program at the Hardwick Landfill is to prevent birds
from foraging at the landfill and to deny them places to rest or roost. If the gulls are
prevented from foraging, roosting and resting, operation of the facility will not result in
adverse impacts on water supplies or aircraft.
Thresholds of gull activity are discussed in Section 9.0.
5.0 NOTIFICATION OF THE DEPARTMENT
On the occasion that gull activities at the facility have resulted in complaints by any
abutter or public official on any three (3) consecutive days or any five (5) days within one
month period, the landfill operator will notify the MDEP within 48 hours.
6.0 ALTERNATIVES ANALYSIS
Landfill Operational Controls. Methods of unloading, spreading, compacting and
covering refuse need to be critically examined and evaluated. Possible methods to reduce
the likelihood of gulls feeding include minimizing the size of the daily active area (active
face), maintaining human presence at all times and cover material placement (type, depth
and frequency).
Habitat Controls. These focus on altering the landfill environment to keep it unattractive
to gull resting, loafing or roosting activity. Such control methods include maintaining
short grass areas.
Harassment Methods. These include the use of pyrotechnics, propane cannons, recorded
distress calls and trained dogs with the objective of actively trying to scare gulls away.
Lethal Methods. This primarily means the use of shooting to kill gulls. Reliance on
killing gulls can never be the primary means for gull control. Shooting or any lethal
method can only be used to reinforce other control methods. The implementation of lethal
methods will require a permit issued by the United States Fish and Wildlife Service
(USFWS), which generally limits the taking of gulls to between 50 and 200 a year at any
given facility.
7.0 DESCRIPTION OF GULL CONTROL STRATEGY
Vector attraction will be minimized through the continuous placement and compaction of
wastes in the active cell, a constant human presence at the disposal area, the daily
placement and compaction of cover material across the waste disposal cell at the end of
the day.
Active, direct methods include harassment and killing of birds. Passive, indirect methods
include habitat control. A short intense period of gull harassment can be very effective,
requiring only reinforcement thereafter. Daily records of gull activities and responses,
and a mix of active and passive control methods are included.
The operation of the daily waste disposal cell shall be conducted to minimize the gathering
of birds by providing for the continuous placement and compaction of incoming waste
materials. Once wastes are delivered to the facility, waste materials shall be unloaded
adjacent to the daily operating cell, placed and compacted in the cell. All exposed waste
materials at the end of the operating day shall be covered with daily cover material to
segregate the refuse from the surface environment. Continuous compaction and placement
of refuse, combined with the proper covering of wastes at the end of the operating day serve
to minimize the potential food source that incoming waste materials represent to birds.
If birds are attracted to the landfill and constitute a nuisance condition, the operator will
employ appropriate control measures at the landfill to curb the gathering of large numbers of
birds. Control measures may involve habitat control, the use of non-lethal pyrotechnic
devices designed to scare birds off the landfill and managed destruction following
appropriate depredation permits that are required from the U.S. Fish & Wildlife Service and
the Massachusetts Division of Fish & Wildlife.
Habitat Management is the primary effort/strategy in gull control. This involves
depriving the gulls of access to the things they want: places to feed and roost. The
following items will be incorporated as a part of the proposed project’s landfill
management plan for gull habitat management:
• Minimize the surface area of the active cell, decreasing the site’s
attractiveness to gulls and facilitating gull control on the remaining active
area.
• Cover the waste daily with approved daily cover that will discourage or
prevent feeding before closing the landfill operations. Staff should inspect
this activity daily. Alternate daily cover technologies have also been shown to
be gull detractors and may be used.
• Manage the inactive portions of the landfill so that exposed soil or mowed
areas are minimized as much as possible. Exposed soil should be seeded with
fast growing vegetation. Vegetation should be allowed to grow higher than
ten (10) inches where possible. One mowing per year is recommended.
• Eliminate on-site surface waters such as ponds, borrow pits, and puddles.
Surface waters that must remain (nearby wetlands or stormwater control
ponds) should be included in the dispersal/hazing patrols when appropriate.
• Physical barriers could be erected if necessary. Wire grids can be erected over
areas of the landfill where birds may congregate. These can be either
monofilament plastic line or stainless steel.
Harassment
Even if the site has been made as unattractive as possible to gulls, they may still come to
feed if they can, and thus must be actively discouraged. Habitat management and
harassment must go hand in hand. The following human activities will be incorporated
as part of the project formal gull management plan:
• Human Patrols are the cornerstone of the dispersal methods of the plan. The
patrols depend on the staff for success. Patrols will include reconnaissance
(counting any gulls on site and recording their behavior, checking the
condition of equipment and habitat management) and harassment. Patrols will
be on foot or from a vehicle and will be of sufficient coverage and intensity to
ensure that all gulls on the property are identified, counted, and put to flight.
The operator gull control personnel will patrol the landfill on an as-needed
basis to meet the DEP performance standard of keeping gulls from feeding. It
is particularly important to patrol during the times that have been noted to be
peak feeding periods, as well as all other times. Patrol protocols will be
developed which emphasize flexibility and the element of surprise, in order
that gulls do not learn how to avoid patrol times in order to feed. Gull Patrol
records will be maintained on the MDEP Form.
• Pyrotechnics - noisemaking devices shot from blank pistols, shotguns or even
canons may be used. The screamers and bangers may be easily fired from
a .22 caliber starter or blank pistol and have been found to be effective on
gulls. A firearm license may be required. The staff will patrol the landfill as
much as necessary, using these noise-makers as necessary to scare the gulls
from feeding. An intense effort will be required as the project begins. The
projectiles should be fired at birds whenever they are observed on the ground
or attempting to land. The same type of projectile should not be fired for
more than five consecutive days. The following equipment should be
maintained for this purpose: single-barreled breech-loading 12 gauge shotgun
with open choke; shotgun cleaning kit; .22 caliber starter pistol with 15 and
17 mm. adapters; stores of at least three types of projectiles. When not in use,
all firearms shall be stored in secure locked cabinets.
• Gull distress calls can be played in conjunction with pyrotechnics to enhance
their effectiveness.
• Visual frightening devices such as balloons painted to look like eyes can be
used also.
• Trained dogs- the harassment potential of dogs, along with the methods above
can be very useful.
The designated bird control staff should arrive at the landfill each day as early as possible.
Reconnaissance and record taking should be the first activity, followed by harassing any
gulls that attempt to land. Gulls will go to water bodies to roost for the night, but will fly
long distances to search for food. The staff should meet them each day to scare them off.
After the initial period, this should become somewhat routine.
Depredation
Reinforcement of harassing techniques may be necessary. This requires a permit from
the U.S. Fish and Wildlife and Massachusetts Division of Fish and Wildlife federal and
state agencies. Permit application would be made if needed. These permits commonly
allow the killing of up to two birds per day. Occasional exercise of this technique is
necessary to prevent habituation of the gulls to other methods and to eliminate problem
gulls. Use of this method will be at the discretion of the staff under advisement of the
Consultant. Safety is paramount. Shooting should only be done when reinforcement is
required, and must be done with great care. Permits are usually issued for 50-200 kills/
year.
8.0 REFERENCES
9.0 Massachusetts Department of Environmental Protection Bureau of Waste
Prevention Policy # BWP-98-003.
10.0 A Manual for Gull Control at Massachusetts Landfills
11.0 CONTINGENCY MEASURES
In general, the following criteria shall be used to determine if a facility has a gull control
problem:
1.gulls observed or otherwise known to be feeding at the site;
2.the number of gulls frequenting the site;
3.availability of a food source for the gulls;
4.compliance with good operational practices such as use of daily cover material;
5.location relative to:
a.surface water supplies;
b.airports;
c.abutters or other nearby receptors;
d.recreational waters;
e.endangered species habitat;
f.parks or other recreational facilities;
6.the frequency of use by gulls;
7.suitability of the site for resting, loafing or roosting; and
Complaints/problems resulting from the gull control program will be recorded through
use of a daily phone log. The log will include entries to indicate how complaints were
resolved.
12.0 STAFF AND RESOURCES
Implementation, monitoring and evaluation of the plan/program will involve a variety of
personnel in a team effort. These will include the Landfill Site Manager and landfill
operations staff.
Landfill Superintendent - responsible for entire landfill project, oversees gull
control, files periodic reports with Town and MDEP, other agencies as
required.on-site supervisor of landfill including on-site gull control
Designated Bird Control Officer - staff member for whom gull control is a
primary duty.
Other members of the landfill staff-assistance as necessary.
Landfill operations staff will be familiar with the goals and objectives of this plan and
with the importance of their being accomplished. Staff will be made aware that nothing
but maximum effort and effectiveness is acceptable in bird control measures. A wildlife
biologist will be retained on a consulting basis should aspects of the plan require change.
The superintendent is responsible on a daily basis to make sure that gull control activities
are being carried out with maximum effectiveness and will have ultimate oversight of the
entire project, and will be responsible for making sure that all aspects of the project run
smoothly, including gull control. The operator will meet with staff regarding gull control
on a regular basis to review activities, report progress and problems, and change actions
as needed. The operator will consult with the wildlife biologist when necessary.
The Bird Control Officer will be an on-site staff whose first duty is gull control. The
BCO or designated, trained alternate will be on site at all times when the facility is open,
and will be reachable by radio at all times. Duties will include undertaking daily gull
reconnaissance and reporting patrols, assuring that all equipment is in working order and
supplies are adequate. Implementing or directing habitat control and dispersal methods,
keeping detailed accurate records on methods used and responses. Communicating with
staff and management on a regular basis, alerting management if expert consultation is
required.
13.0 DAILY INSPECTION
Each day the landfill staff will fill out the MDEP policy Field Data Form that documents
gulls’ presence, activities, and control methods. Observations of gull behavior will be
made at least once each working day. Monitoring will document any gulls on or near the
site, as well as those on adjacent properties. Should other data be required, the
Consultant will prepare appropriate report forms. Staff will provide monthly reports to
the Operator, and when required, to MDEP. Yearly reports will be prepared,
summarizing the more detailed monthly reports.
14.0 NOTIFICATION OF MODIFICATION
Notice will be given for any change in the Gull Control strategies implemented to
abutters and those likely to be affected by the noise or displacement of gulls.
15.0 CONTACT
Hardwick Landfill, Inc. may be contacted at (413) 967-5985.
16.0 SCHEDULE FOR IMPLEMENTATION
Implementation of the Gull Control Plan will occur immediately with implementation of
control strategies occurring if gulls become an issue as defined in Section 9.0