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.

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.

INC Approves Resolution on the Incinerator

On August 11, 2015, INC (Inter-Neighborhood Cooperation) passed a resolution on the proposed incinerator at the Denver Zoo. The solution calls for the following:

1.) the Denver Zoo to document relevant, substantive technical and operational details of its OSWI Incinerator and release this information to the public, and

2.) the Denver City Council to conduct a substantive and technical review of the Zoo’s OSWI Incinerator plant through hearings before its designated Infrastructure and Culture Committee, and when necessary, using its full subpoena powers, taking testimony from Denver Zoo Foundation administrators, engineers, scientists, environmental experts including qualified and credible third parties along with representation from environmental justice groups, Registered Neighborhood Organizations and City Park neighbors to determine the safety and health risks posed by the use of the incinerator, before it be allowed to proceed and to operate.

The resolution can be read in its entirety here.

Paul Connett Talk in Denver

Please join us for a unique opportunity to share an evening with one of the world’s foremost experts on incineration and zero waste, Dr. Paul Connett. Dr. Connett will address health and safety concerns of incineration and waste to energy,  as well as discuss the benefits of zero waste.

This topic is timely in view of Denver Zoo’s plans to build and operate an incinerator at the Denver Zoo.

Ford Warren Branch, Denver Public Library
6:00 -8:00 p.m.
Thursday, July 30, 2015
2825 High Street, Denver CO 80205

RSVP here.

 

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.