Another (unsustainable) Initiative

See p. 11 of the 2015 National Western Center Regeneration Framework  authored by ME Engineers:

9.4 Adding Renewable Energy – Waste to Energy

Instead of hauling off non-recyclable municipal solid waste (MSW) to landfills, there are several options to convert it to energy. NWC can incinerate it on-site. The waste heat can be used to generate steam. One option is to use steam turbines to produce electricity. The exhaust fumes of the incinerator must be controlled so it’s not contributing to local air pollution.

The other option: ‘gasification’ is a unique process that transforms any carbon-based material, such as MSW, into energy without burning it. Instead, gasification converts the materials into a gas by creating a chemical reaction. This reaction combines those carbon-based materials (known as feedstocks) with small amounts of air or oxygen, breaking them down into simple molecules, primarily a mixture of carbon monoxide and hydrogen, and removing pollutants and impurities. What’s left is a clean ‘synthesis gas’ (syngas) that can be converted into electricity and valuable products. With gasification, MSW and other types of wastes are no longer useless, but feedstocks for a gasifier. Instead of paying to dispose of and manage the waste for years in a landfill, using it as a feedstock for gasification reduces disposal costs and landfill space, and converts those wastes to electricity and fuels.


Denver Zoo “Ditches Plans to Convert Elephant Dung”

The Denver Post’s article (9/25/2015) on the Zoo’s plan to halt construction on its gasification-pyrolysis system – sited in an urban neighborhood – wrongly characterizes elephant dung as the only constituent of the (toxic) waste stream. The Post reports the Zoological Foundation is keeping construction on the “back burner” while it searches for additional funding:

Denver Zoo officials announced Friday they were scrapping a plan to convert elephant dung and other waste to power, blaming a lack of money for the decision.

At a press conference at the zoo, Shannon Block, the zoo’s chief executive officer, said they would be looking for a financial partner to “pick up the ball.”

Denver Zoo officials said their decision to shut down the project was a question of resources — not the vocal opposition the plan has drawn from a collection of passionate neighborhood activists.

George Pond, the senior vice president of design and campus management, said the employees working to get the equipment installed and tested, and then to run the waste-to-energy program once it was operational, were needed for other areas as the zoo embarks on an ambitious master plan that will remake the campus significantly in coming years.

Block called the surprise move a difficult decision that came down to a question about priorities for core zoo operations, while saying the project had gotten “to the 10-yard line.”

But the project may not be abandoned entirely. Pond says he has talked to potential partners, and it’s possible the machinery that’s already installed could be up and running at some point, reviving the project — but it would be off site.

“It will not operate here,” zoo spokeswoman Tiffany Barnhart said. She said officials hoped to see the zoo’s $3.7 million investment in the equipment and innovation of the technology put to use in some way.

This development does not mark the end of Zerowaste Denver. We will continue to post news on the Zoo’s machine and zerowaste principles, as well as any documents obtained under the Colorado Open Records Act.


Review the Facts

Review the facts on zoo incinerator
By Larry Ambrose   
My Turn (The Denver Post digital edition)
Re: “Let Denver Zoo transform waste,” September 13 editorial.

The Denver Post’s editorial endorsing firing up a very expensive, high-temperature incinerator in the middle of the Denver Zoo, in the middle of City Park, cites Inter-Neighborhood Cooperation’s (INC) “ill-advised” request that the Denver City Council conduct investigatory hearings.

 As a coalition of Denver’s Registered Neighborhood Organizations, INC is advocating for council hearings to determine if an incinerator is an appropriate use in Denver’s parks. Or is it an industrial use that better belongs in a zoned industrial area away from the zoo’s 4,000 animals, visiting school children, City Park visitors and the thousands of residents who surround the park?   

In 2009, INC vigorously but unsuccessfully protested a proposed zoning change that took charter authority over zoning in Denver’s parks from the City Council and gave it to the Manager of Parks and Recreation. INC expressed its concern that by taking away zoning powers from the Council, “any recourse of citizens now in effect under the Charter with regard to zoning changes would be absent” and “delegation of such powers to the Manager of Parks and Recreation, was contrary to the language and intent of the Charter.”   

In 2010, the zoning code that took charter authority over zoning in Denver’s parks from the City Council and gave it to the Manager of Parks and Recreation was approved. Another way to explain it is that the mayor’s executive Manager of Parks and Rec, an appointee serving at the mayor’s pleasure, has unquestionable power to decide what can or cannot be built in city parks without recourse for citizens.    In 2014, Denver’s parks manager, Lauri Dannemiller, unilaterally determined that an experimental, high-temperature incinerator, which will produce tons of toxic gases and particles and will deposit them in and around the Park, the zoo and the neighborhoods, was a “park use.”   

Burning elephant poop to heat the elephant habitat and save money on the utility bill sounds good, but it is not ecologically sound or cost-effective. What can be composted, recycled, reused and repaired is even better for the Earth, our citizens and animals.  INC is asking the City Council to conduct an in-depth review of the facts.

Larry Ambrose is president of Inter-Neighborhood Cooperation.


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.

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.