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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Waste Management in the Mile Hi City

We wonder why the Denver Zoo is launching what appears to be their own waste management plan separate from the city of Denver. The City’s Master Plan for Managing Solid Waste in the Mile High City, when considered alongside the Zoo’s proposal to utilize Other Than Solid Waste Incinerator/Gasification-Pyrolysis to “manage” its waste, raises questions as to Denver’s overall management of its solid waste. Solid waste is defined as “garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, air pollution control facility, or other discarded material; including solid, liquid, semisolid, or contained gaseous material resulting from industrial operations, commercial operations or community activities” (6 CCR 1007-2 Part 1). Denver also encourages composting to keep trash out of landfills.

The Denver Zoo’s EDOP, which details the proposed project, lists the waste stream categories as a “mixture of biomass and operations waste, material that can be beneficially processed into a viable solid fuel and has an energy value, paper/cardboard, urban forest residue from Denver Parks and Recreation” (p. 16-17). Biomass and operations waste and urban forest residue are not defined, and there is no discussion in the EDOP of analyzing “urban forest residue” for pesticides, herbicides, and nitrates before it is “pyrolyzed,” converted into pellets and syngas. Paper and cardboard, often bleached and containing formaldehyde based glues, are also not discussed in the EDOP in terms of testing.

In the end, we are concerned there exists no unified plan that addresses city-wide waste management from a zero waste perspective.

Several Documents

In various news articles and official documents, the Denver Zoo’s proposed “machine” is called a:

The Zoo’s patent and the Engineering Design and Operations Plan (EDOP) are two documents that discuss the proposed plan to use different types of wastes, including compostable PLA (polylactic acid, polylactide plastics), to form “pellets” that will then be used to fuel the Toyota Elephant Passage Exhibit.

There are three editions of the EDOP (2/6/14), (9/4/14), and (10/10/14). The revised, latest edition is not publicly available. The EDOP has a July 16, 2014 EDOP Supplement #2: EDOP amendments in response to City and County of Denver Comments. (We have not located Supplement #1: Update, “Composite” EDOP with supplements 1 and 2).

Versions of the EDOP do not define:

  • Operations waste (p.17)
  • Sustainability (sprinkled throughout the document)
  • Urban forest residue (p.8)
  • Zero waste (sprinkled throughout the document)

The EDOP raises many questions, from what types of specific wastes are “fed” into the system and incinerated, to a detailed description of pollutants and risk of pollution into surrounding neighborhoods that encircle Denver Zoo and City Park. In addition to these problems, confidential business information (CBI) about the machine is withheld from public inspection.