Response to the Denver Post

We recently read The Denver Post’s poorly thought out editorial titled “Let Denver Zoo convert animal waste to fuel.” The editorial is just that, an opinion piece that ignores facts regarding the Denver Zoo’s waste to energy machine. Below we dismantle select statements from The Post‘s opinion piece:

  • Let Denver Zoo convert animal waste to fuel.”

First, the title of the editorial indicates the authors show a weak understanding of the environmental regulatory process. “Let” implies allow. If the EPA and state regulators find the machine is not in compliance with environmental laws and regulations, the Zoo will not be granted final operating permits. All permits to date are draft.

Secondly, the Zoo’s proposed waste stream is not only animal waste. In fact, according to the Zoo’s own document, the waste stream is comprised of 90-92% organics (woodchips, all animal waste, cardboard, food waste, yard trimmings, alfalfa, hay, waste paper, paperboard) and 8-10% (PLA plastic, PET plastic, HDPE/LDPE plastic).

This “plant” would “convert” paper products (possibly chlorinated and containing formaldehyde),  PLA (compostable) plastics, and HDPHE/LDPHE plastics to pellets to make syngas. This process would possibly release toxic chemicals such as dioxin, considered a persistent organic pollutant. Through the Stockholm Convention, the international community is working towards a ban of these chemicals (Annex C).

  • The Denver Zoo has suddenly run into a buzz saw of ill-advised opposition over its endeavor to install a waste-to-fuel plant that would convert animal poop and other waste into a power source.

We are not sure what constitutes “a buzz-saw of ill-advised opposition.” In a representative democracy, citizens have a right and obligation to investigate and ask questions of their government, especially on matters that directly affect them.

The Post opinion piece ignores the fact there was opposition to the Zoo’s machine by a major neighborhood organization and citizens. There was also lack of public comment, which was recognized in an October 2014 memo to Councilman Christopher Herndon written by former Department of Environmental Health (DEH) Executive Director Doug Linkhart.

As we have pointed out, while we recognize the Zoo advertised the project, it did not educate. In fact, the Zoo appears to not understand the basic principles of risk communication.

We recommend The Post Editorial Board spend an afternoon, maybe two or three, reading the official documents we have provided at our expense to educate the public and City officials.

  • The inventive $3.3 million biomass gasification process would shred and dry the material into pellets that would be heated at temperatures up to 1,470 degrees in an oxygen-starved environment, creating a gas that would power generators.

The Post is correct the Zoo’s project is “inventive.” The machine is invented by two Zoo officials, who we speculate, may have something to gain from the adoption of this machine in settings besides the Denver Zoo. One need only read the patent to question this experimental technology projected for operation in a neighborhood setting. In July, 2014, the Zoo asked CDPHE for a waiver for reporting a “detailed engineering description of the incinerator” including air pollution control equipment.

  • The zoo expects the plant would eliminate 1.5 million pounds of waste it trucks every year to the landfill and cut the amount of electricity it pulls from the grid by 20 percent.

We have not completed a comprehensive review, but from our perspective, the Zoo could increase its composting by diverting PLA compostable plastics from the incinerator; it could also increase its composting of dung (the Zoo sends out about 20 yards of manure twice a week for composting). Currently, the Zoo includes PLA plastics in its waste stream for the OSWI (Other Than Solid Waste Incinerator). These plastics are designed for composting, not used as potentially toxic fuel.

Solar, wind, and net zero building principles might have been employed by the Zoo, as well as true zero waste principles, which emphasize “designing and managing products and processes to systematically avoid and eliminate the volume and toxicity of waste and materials, conserve and recover all resources, and not burn or bury them” (Zero Waste Alliance, 2009).  In addition, it is not clear why the Zoo ceased production of Zoop fertilizer, a partnership with A1 organics.

But the biggest elephant in the room, no pun intended, is the Zoo’s waste to energy project is completely disconnected from the City and County of Denver’s municipal solid waste plan. This is even more a source of concern for Denver citizens.

  • The main source of agitation is over potential air quality problems in the park and surrounding neighborhoods.

Agitation? We suggest that what The Post Editorial Team views as “agitation” is public participation and citizen oversight, both essential to the democratic process and necessary for government accountability.

  • The zoo has been open about its plans since 2009. An article about the plant was included in a zoo publication that went to 65,000 people and information about the plant has been featured on the zoo’s website, e-newsletter and through large scale public events. Zoo officials met with council members, held open houses and tours of the building, presented plans to neighborhood groups and the parks advisory board and even held its own public hearing.

To repeat, The Post ignores the facts. There was opposition to the Zoo’s machine. There was also lack of public comment and relatively low public attendance at the Zoo’s presentations. But the most disturbing fact that remains is that public officials did not fully question the environmental impact on the Denver neighborhoods that surround Denver Zoo, the Natural History Museum,  and City Park.

  • A 51-page engineering design and operations plan explained the project’s technical aspects.

We assume the editorial board refers to the Engineering Design and Operations Plan? If so, we have pointed out many deficiencies of this document and other official documents posted here at our blog.

In addition, we have not located any documents that explain how the Zoo’s machine escaped scrutiny on the matter of zoning. Perhaps The Post might concentrate – as the fourth estate – on investigative journalism to unearth how the waste-to-energy system was zoned in a densely populated urban setting.

  • The only way the council can officially withdraw its support is if something has gone wrong. And that hasn’t happened. The project should move forward. We hope that it will become a model for how institutions can deal with waste and generate energy without endangering the health of the public.

In our opinion, the entire process has “gone wrong.” Important questions remain as to

_ adequate health risk assessments;

_ a completed waste management plan that fully informs the public and regulators as to operations, waste streams, and possible risk;

_ concerted efforts to deal with waste in a truly sustainable way that avoids the release of toxic air pollutants and ash;

_ effect of Zoo’s system on property values;

_ funding of the project;

_ who benefits financially.

The Post Editorial Board is profoundly uniformed, and as such, its recommendations to “move forward” are simply based in opinion, not the facts and questions that would assist the public in understanding anything significant about the Zoo’s project and its impact on their neighborhood and quality of life.

This “editorial” could have just as well been written by one of the Zoo’s several paid public relations staff persons rather than by what should be a group of studied and experienced journalists.

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Finley / Zoo Faces Heat

Denver Post reporter Bruce Finley knocks it out of the (City) park with his article “Denver Zoo faces heat but pushes on with elephant poop-to-power plant.” From the Post article:

Zoo officials — aiming to fire up the plant by the year’s end — insist there will be no problem.

“I am not as comfortable as they are that this technology is proven and belongs in that location,” councilman Paul Kashmann said. “I don’t think anybody would be particularly concerned if this was in an industrial area. … Since it has never been tested and it is a proprietary technology, it makes sense that it be as objectively reviewed as possible.”

Zoo crews have installed hoppers, shredders, pellet-making machines and a “gasifier” — measuring 6 feet in height and 2 feet in diameter — in a long-empty building behind the elephant house and within 150 yards of City Park lakes, paths and the boathouse jazz pavilion. Waste processing would be done in low-oxygen chambers at temperatures up to about 1,470 degrees.

The idea is to cut reliance on coal-fired grid electricity by using waste to light buildings, melt snow on walkways and warm a pool where elephants soak during winter.

A construction permit granted by the Colorado Department of Public Health and Environment sets limits for plant air emissions covering particulates, sulfur dioxide, dioxins, cadmium and carbon monoxide. Zoo officials said they’ll comply, but because the plant isn’t tested, they cannot specify what it will put out.

In the article, Councilman Kashmann raises a significant point about the Zoo’s proposed machine as “proprietary technology.”  Elements of the patent are considered confidential business information (CBI), and as such, not available for public review. It not certain that regulators, such as the Denver Environmental Health Department, had an opportunity to review all relevant documents, including  those containing CBI. In addition to CBI, the Zoo as a foundation is not subject to the Colorado Records Act (CORA).

Quotes made by Zoo official George Pond, Vice President for Design and Campus Management and one of the inventors of the waste to energy machine, however, are troubling:

We have no interest in making something bad. … Look, there’s an elephant right there,” Pond said, noting one near the new machinery. “We care about that elephant. And there are zoo guests. We care about them. And here is a park. We don’t want anything bad for any of this. Is this going to ruin our park? We would never allow that.

We can break down the above comments as follows:

“We have no interest in making something bad.”

The concerned public might respond, especially after reading the Engineering Design and Operations Plan (EDOP ) with questions regarding the toxicity of the waste stream (e.g., chlorinated paper products, PLA plastics designed for composting) and stability of the syngas process.

The concerned public might also question the need for this machine in light of potential, sustainable gains from utilizing solar and wind energy, expanded composting of dung (the  Zoo sends out about 20 yards of manure twice a week for composting), possible redevelopment of manure products such as Zoop (formerly manufactured by A1 Organics with the Zoo), net zero building, and zero waste. The concerned public might also ask their Denver City Council members how the machine was zoned in a residential neighborhood.

“Look, there’s an elephant right there,” Pond said, noting one near the new machinery. “We care about that elephant.”

Holding up one elephant as a shining example of the Zoo’s “caring” and consideration towards elephants – or all critters that reside in the Zoo  – is endearing. But it is also flawed. These magnificent mammals will be exposed to approximately the same pollutants as their human neighbors offsite. Why do we say an approximately? Because at this time there is no air modeling and characterization of pollutants that tells the public (or regulators) what levels of pollutants that will be released. As Finley points out in his article,

Colorado Department of Public Health and Environment sets limits for plant air emissions covering particulates, sulfur dioxide, dioxins, cadmium and carbon monoxide. Zoo officials said they’ll comply, but because the plant isn’t tested, they cannot specify what it will put out.

The EDOP  has an approximation and description of chemicals that may be potentially be released.  We suggest the public read the EDOP (that also substitutes as a partial partial waste management plan, but to date, is incomplete), alongside other official documents such as the Permit application to construct the DZF waste to energy system and Revised air permit emission notice and application to construct the DZF waste to energy system, and ask their own questions of the Zoo, City Council, and regulators, including why they must accept any pollution from this machine.

Read the rest of the article.