Deconstruction of the CD

A  certificate of designation (CD) is

a document issued by the local governing body authorizing the use of land for a solid waste disposal site or facility. The CD is issued if it has been determined that the technical standards set out in regulation are met and after local issues are considered and satisfied. Anyone operating a facility for solid waste disposal where processing, treatment, or final disposal of solid waste is performed must obtain a certificate of designation (6 CCR 1007-2 Section 1.3.3).  Examples of such facilities include municipal solid waste landfills, certain private solid waste landfills, composting facilities, and solid waste incinerators.


The Zoo’s undated Executive Summary – Certificate of Designation Application — Denver Zoo Waste-to-Energy System  (submitted by Denver Zoological Foundation, Inc., as Applicant) is an interesting public document for several reasons.

First, the Denver Zoo describes the “machine” as “part of an innovative waste to energy system.”

Secondly, the Zoo’s CD acknowledges an existing incinerator housed at the Denver International Airport (DIA), permitted by an 8/28/2000 Denver City Council Bill 0652, Ordinance 2000-0696);  the Zoo’s Executive Summary states “the last CD application that was reviewed and approved by Denver City Council was Denver International Airport CD September 5, 2000. Ordinance #696 Council Bill 652.”  By mentioning the DIA incinerator in its Executive Summary, are we to take the Zoo is justifying the use of a polluting technology?

Third, the Zoo’s public outreach process has failed.  We find there is a distinction between between advertising /marketing and public education on pollutants and potential harm to individuals and nature from the “waste to energy system.”  While the Zoo is correct in its CD that it “has been sharing the story of the planned waste to energy system publicly for several years” and probably utilized “used far-reaching communication channels including a member publication reaching $65,000 area,” we pose that if a poll was done of residents who live in the Zoo-City Park vicinity, would they be aware of the Zoo’s plans? How upset conditions (when the flare or gasifier malfunctions) would impact residential neighborhoods?

Furthermore, the Zoo is mistaken about Inter-Neighborhood Cooperation’s (INC) support of the project, including its actions that “formally voted to support the project.” INC did not support the waste to energy project. In fact, on its Web site, INC states “we did not have enough information to make an informed decision.”

Lastly, the CD is interesting for its list of appendices to the Engineering Design and Operations Plan (EDOP). Some of the Appendices are available at the City Council’s site. Some are not. None of the “appendices” are labeled as appendices to the EDOP, making learning about the Zoo’s project increasingly difficult.


Also see draft bill CB 14-0941 dated December 10, 2014 Ordinance granting a certificate of designation for the “waste to energy system,” which is unsigned; the Zoo created a handout (no date) describing the certificate of designation process to the Denver City Council. In this “process” document, the Zoo states the project is  “planned for no effects on nearby surroundings.”