TO: Denver City Council Members
cc: CASR
DATE: May 27, 2022
Re: WDCA Response to Waste Management’s Proposed Expanded Trash Program
Winston Downs Community Association (WDCA), a Registered Neighborhood Organization, held its annual meeting on April 26, 2022 which featured a presentation by Charlotte Pitt, Manager CASR, about the proposed expanded trash program also known as Cash for Trash. The meeting was “live” and open to all Winston Downs residents.
WDCA and its members favor reducing greenhouse gas and have no doubts that increasing recycling can have environmental benefits if done correctly; however, WDCA opposes the current proposed expanded trash program and asks that City Council vote “no” until such time that CASR can go back to the drawing board to address concerns expressed below.
There are significant concerns about the lack of transparency of the financing for the proposed program, which is split between the general fund and a new fee for residents. More specifically, we are concerned that the proposed waste service changes are being pushed through City Council too rapidly without sufficient due diligence.
The information provided to us about the proposal lacked detail and there is little supplemental information available for our tech-savvy board and residents to refer to; therefore, we conclude that the economic and environmental impacts of the proposed expanded waste services proposal have not been adequately evaluated against other alternatives with the rigor required to make an effective decision.
Examples of the type of supporting information that could support this proposal include documentation of the basis for program costs, case studies that specifically demonstrate that variable-rate cart options have resulted in the types of projected recycling rate increases needed, and mass balance diagrams that demonstrate the greenhouse gas implications of the proposed changes.
There are uncertainties that the proposed changes are the most effective alternative to pursue first given that the residential sector makes up only a small portion of the waste stream going to landfill. The CASR proposal only considers residential trash and recycling material, yet WMI reports that 80% of the volume of landfill is from commercial users from Denver; the same landfill that the City of Denver residential users’ trash is removed to, thus forcing a major cost onto Denver residents in order to make an insignificant change to the overall landfill which we find to be both inefficient and ineffective.
This proposal, by way of its own analysis, using fuel costs that are no longer valid and are understated, is a substantial revenue loss for the City of Denver, and seemingly the only way for the program to financially break-even is to raise the proposed fee structure substantially over the proposal, burdening the residents at a time of high inflation.
Additionally, much of the argument for the support for this program revolves around the fact that “other cities” charge for waste services and because of this have higher recycling rates. This argument is not convincing that “cash for trash” is the way to increase recycling and reduce greenhouse gas.
There are potentially significant unintended consequences to consider as well:
- Limitations on local markets for difficult to recycle materials – regardless of contractual terms preventing landfilling of collected materials – can increase the cost structure for waste disposal and reduce the likelihood that these materials stay out of landfills.
- Lack of available collection, processing capacity and infrastructure can result in increased costs for waste handlers, processors and ultimately, residents.
- Difficulties in implementing a complicated structure to reduce financial impacts on lower income residents will harm residents and result in more trash dumping in neighborhoods where residents need help the most.
- Increased pollution from added waste trucks on our streets is basically trading one pollution problem for another. The CASR proposal is not transparent in accounting for CO2 emissions, noise (also a “green” issue) and road pollution from the increased truck traffic, and it does not explain if the new system offsets the increased traffic, or if the increased traffic will offset the expected CO2 reduction.
- The CASR proposal calls for increased spending on education, inspection and drivers of vehicles yet makes the claim that no additional personnel need to be hired. If this claim is true, then will other City services need to be reduced in order to staff this new education, inspection and greatly expanded truck fleets and barrel distribution/maintenance?
In short, WDCA finds the CASR Proposal, although much time has already been spent on it, to be preliminary and not fully justified. The current system of tax-funded regular trash and recycling service with additional fee-based composting should be re-examined to understand how better to modify the existing system such as:
- Pick up recycling every week and trash every other week
- Change the fee structure for composting bins and for extra trash and recycling bins
- Fully understand and report residential impacts versa commercial impacts and costs
At minimum, we suggest a delay in the consideration of the passage of any City Council resolution related to the proposed changes until WDCA and other RNOs are better able to examine the proposal details, have adequate opportunity to ask questions and gain confidence that their interests are best served by the proposed program changes.
Respectfully submitted,
Winston Downs Community Association
Board of Directors
May 27, 2022