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06/20/1989 - Packet CITY OF TIGARD UTILITIES AND FRANCHISE COMMITTEE MEETING AGENDA June 20, 1989, - 7:00 P.M. Tigard City Hall - Town Hall Conference Room Members: BARRETT IRWIN v/ JACOBS r/ McREYNOLDS WALSH WOGEN Ex-Officio Members: Leichner_ Miller Schmidt 1. Call to Order and Roll Call. 2. Minutes of March 21, 1989 3. Reduction in Metro Dump Fee 4. Yard Debris update 5. Other business 6. Adjournment < � �C�✓�Pda%t :�'�'C f;;s'"�F'ey,'r"�,P -.�''" / ay Q ^> s"',..� do/0055s Pt� t C' ft JANET HOLMES 12215 S.W. 33rd. Ave. Portland, OR 97219 (503) 244-3629 June 16, 1989 Mr. Wayne Lowry, Finance Director City of Tigard P.O. Box 23397 Tigard, OR 97223 Dear Mr. Lowry: Re: City of Tigard' s High Cost Garbage Service to Businesses . This letter follows my recent telephone conversation with you regarding my concern with the high cost garbage service enforced on those using large containers (businesses) because of your franchise with Pride Disposal Company. I question why there is such a large mark-up with those companies doing franchises. The consumer in my opinion is not benefited as I feel that I am in a good position to judge as I have used four of the six com- panies listed below in my study. The results are as follows : COMPANY NAME MONTHLY RATES BASED ON CONTAINER SIZE/WEEKLY SERV. & PHONE # (2 yards) (1 yard) (1 can) 1 . DIANE' S DISPOSAL $ 45 . 00 $35 . 00 (lk yds . ) $ 8 . 50 curb (774-4935) $10.00 non- curb 2 . SALVI SANITARY SERV. $ 45 . 00 - 60. 00 $25 . 00 - 35 .00 $11 . 15 (232-8104) 3 . HOWARD SUNDE & SON $ 57 . 60 $28.80 $10.50 (246-2660) 4. S.W. SANITARY SERV. $ 60.00 $35.00 $11.00 (636-8874) 5 .*PRIDE DISPOSAL CO. $109.81 $60. 91 $10.80 (625-6177) 6. "ROSSMAN SANITARY $110.26 $76. 12 (14yds) $10.99 Mult. (636-3011) $ 9 . 13 L.O. *Franchise Companies I feel the numbers above speak for themselves when service and over- head are comparable. Those of us falling in franchise areas are paying unfair rates for same service given by the non-franchise companies . I would like you to carefully review this information and present it to the City Council in hope of a change in your franchising policy to benefit all your taxpayers. I would appreciate hearing from you in the near future regarding this matter. SiR,cerely yours , JVnet Holmes YARD DEBRIS RECYCLING IN THE WASHINGTON WASTESHED August 1989 EXECUTIVE SUMMARY . 1 Q w 7 Introduction The State of Oregon Environmental Quality Commission (EQC) on September 9, 1988 added yard debris to the list of principal recyclable materials for the Portland Metropolitan area. Originally an air quality issue, yard debris has transformed into an air quality and landfill issue. When backyard burning was first introduced in December 1980, the Department of Environmental Quality (DEQ) estimated that yard debris would "equate to 5% of the total municipal waste generation and would more than likely go unnoticed at the landfills" . Time has shown that estimate to be low. The Metropolitan Service District (Metro) , the regional government responsible for solid waste disposal, has demonstrated through waste composition studies that yard debris makes up 10.7% of the regional wastestream. When added to the estimated amount of yard debris composted, both at home and in commercial processing facilities, yard debris generated in the metropolitan region amounts to 175, 000 to 190, 000 tons. The Washington Wasteshed consists of the unincorporated areas of Washington County and the Cities of Banks, Beaverton, Cornelius, Durham, Forest Grove, Gaston, Hillsboro, King City, North Plains, Tigard, Tualatin, and Sherwood. Statistically representing 26% of the wastestream in the region, the jurisdictions in the Washington Wasteshed are responsible for addressing approximately 46, 800 tons of yard debris. Plan Objectives and Approach The goal of this plan is to create a cost effective yard debris collection system to complement a regionally based processing and marketing system driven by market demand. The objectives for this plan are: 1. Determine the amount of material generated in each jurisdiction. 2. Determine the amount of material presently being processed and marketed in the region. 3 . Determine potential growth in processing and marketing of yard debris in the region. 4 . Evaluate options for collecting and processing yard 2 debris. 5. Recommend options for collection and method of financing each option for each jurisdiction. 6. Work within the policies of the Regional Solid Waste Management Plan. This work coincided with the beginning of Metro's regional yard debris planning process and effort was made to accommodate concerns for yard debris collection and disposition. The planning committee attempted to create a plan that will conform to future Metro plans. The plan is a cooperative endeavor by the cities and Washington County. The Planning Committee consists of representatives of all the cities within the wasteshed and the County. Being outside the Urban Growth Boundary (UGB) and having a population smaller than 4, 000, the cities of Banks, Gaston, and North Plains are not affected directly by this rule change. Metro is represented as an ex-officio member of the committee. Technical advice was provided by the creation of two sub- committees. The Collection Sub-Committee consisted of members of the Planning Committee as well as representatives from the hauling industry, Metro, and the County' s Solid Waste Advisory Committee. The Processing/Marketing Sub-Committee also had members of the Planning Committee in addition to local private processors, local landfill operators, Metro, local agricultural business representatives and an agent of the Unified Sewerage Agency (USA) . Historical data as well as current programs were evaluated to determine the most appropriate system for recommendation to all jurisdictions involved. Findings were examined within the context of specific goals and objectives determined by the committee. This information then was applied to the Washington Wasteshed and particular recommendations are made for adoption. Section 1 of this report contains the system analysis of past and present programs for collection, processing and marketing. Programs in the metropolitan region are examined for cost and effectiveness in recycling yard debris from the wastestream. Section 2 proposes a program for yard debris recycling and the expected results. The plan outlined is a system approach for the entire wasteshed. 3 Findings: The following is a summary of information relating to yard debris recycling in the Washington Wasteshed. Since this program is dependent upon marketing a final product, the findings are categorized from markets backwards to the source. Markets: 1. Experience has shown that yard debris recycling is dependent on markets for the finished product. 2 . No market has ever been established for converting yard debris to hog fuel. 3 . The future of the existing yard debris compost market is at risk by development of a regional mixed solid waste (MSW) compost facility. 4. Landfills in Washington County have either shown a desire to expand their use or begin to use yard debris. 5. Dependent upon future EPA regulations covering the field application of sludge, USA has committed to expand their existing yard debris program. 6. Markets have demonstrated that yard debris compost is a viable soil amendment product. Processing: 1. Home composting as a disposition of yard debris represents a significant portion of the total debris generated, and should be encouraged. 2. The cost to collect and process yard debris is more economical than to collect for landfill. 3 . Regional processing capacity is presently being expanded to accommodate total yard debris generated in the metropolitan area. 4. A yard debris processing certification program is vital in the development of a responsible plan. 4 Collection: 1. Collecting yard debris for processing and marketing contributes to maintaining landfill space for other non-recyclable items. 2. An economic, convenient yard debris collection system will help prevent non-point pollution of the Tualatin River and its tributaries. 3 . Backyard burning is a major method of disposal for 4 of the 9 cities in the Washington Wasteshed. 4 . Yard debris collection has been shown to be needed predominately from March through November. 5. A successful collection program will involve manual labor to check loads for contaminates. 6. A weekly depot collection program can expect to recover 50% of the yard debris generated within 4 miles of the depot if a reasonable charge for disposal is maintained. 7. Tax supported weekly curbside collection provided to all residents can collect up to 95% of yard debris generated in a jurisdiction. 8. In a survey of jurisdictions involved, King City, Durham and Sherwood each indicated a preference for weekly curbside collection. 9. All the other jurisdictions preferred weekly self-haul depots complemented with an on-call pick-up service of source separated yard debris provided by the franchised hauler. 10. Existing businesses in the solid waste industry have expressed a desire to provide any depots that are needed to collect yard debris. Area haulers have committed to providing curbside collection to jurisdictions that have indicated such service needs. 11. As it is with any successful program in recycling, yard debris recycling will be dependent upon an active education and promotion program of the potential users. 5 Recommendations: The following are staff recommendations that will offer an initial system for yard debris recycling for the Washington Wasteshed. 1. Local rate setting authorities for county landfills and franchised haulers need to encourage yard debris separation through differential rates. 2 . All jurisdictions need to develop policies that encourage the use of yard debris compost in park improvements, road construction, building landscaping and other relevant uses. 3 . All jurisdictions need to address yard debris collection depots, processing centers and vending centers for final product in their comprehensive land use plans. 4 . A certification program for yard debris recycling depots needs to be adopted by all 13 local governments in the Washington Wasteshed through a jointly developed model ordinance. 5. Initiate a system of low density collection depots through the existing solid waste industry to provide five area depots open to the public and one commercial depot. 6. Direct local franchised haulers within the UGB to provide fee for service on-call source separated yard debris collection. 7 . Direct local franchised haulers serving the Cities of King City, Durham and Sherwood to provide appropriate on-route curbside collection of source separated yard debris. 8 . Initiate a wasteshed wide education program to increase amount of yard debris home composted. 9 . Develop and implement a wasteshed wide education and promotion program on yard debris recycling and use of yard debris compost. 10. Establish a plan for ongoing system evaluation that will obtain the necessary information to determine future direction of yard debris recycling in the 6 Washington Wasteshed. 11. Continue to work closely with Metro in the development of the regional yard debris recycling plan. The intent is to provide a basic service level that will allow augmentation in the future. Many questions remain concerning both markets for yard debris compost and the ability to collect yard debris from the wastestream in a county wide system. By instituting a base service level that will complement any future plan, this will allow time: 1) to gather data on use and cost of the initial system, 2) to raise public awareness to the problem of improper yard debris disposal and educate them of the solutions, 3) for markets to expand to accommodate increased flow of material for recycling and 4) to work with Metro on the regional yard debris recycling plan and adjust the Washington Wasteshed plan to conform. 7 YARD DEBRIS RECYCLING IN THE WASHINGTON WASTESHED August 1989 O O f Table of Contents Section 1 - Discussion and Analysis Introduction . . . . . . . . . . . . . . . 2 Plan Objectives and Approach . . . . . . . 2 Findings . . . . . . . . . . . . . . . . . 4 Pilot Projects . . . . . . . . . . . . 4 Jurisdictional Responsibilities . . . 7 Variables Affecting Recycling . . . . 10 Participation Rates and Costs . . . . 14 Section 2 - Plan Parameters Plan Parameters . . . . . . . . . . . . . . 17 Education and Promotion . . . . . . . . . . 22 Certification and Land Use . . . . . . . . 23 Implementation and Future Planning . . . . 23 Section 3 - Appendix Committee Memberships . . . . . . . . . . A Computer Analysis . . . . . . . . . . . . . B Metro Methodology . . . . . . . . . . . . . C Tables and Figures 1. (All graphs and tables will be presented at June 22, 1989 and will be included in the final report) Introduction• On Dec. 20, 1988, the Washington County Board of Commissioners met to address the EQC requirements that yard debris recycling be made available to county residents. Concern was expressed as to the relationship of yard debris disposal and non-point source water pollution within the Tualatin Basin. The Board of Commissioners approved the concept of developing a city/county planning team to work on writing a yard debris recycling plan for the Washington Wasteshed. This concept was presented to the cities of Washington County by Commissioner Steve Larrance on January 5, 1989 . Commissioner Larrance explained the concept of a Tualatin Basin Plan for yard debris. The EQC has set a compliance schedule for the Tualatin River that the County and the Unified Sewerage Agency must meet by June 1993 . A March 1990 deadline has also been established to have management authority in place to control non-point source pollution within the county. Commissioner Larrance's presentation centered on two ideas. The first was that the wasteshed needed to address its requirements for yard debris recycling. The second was the related topic of non-point source pollution and how a yard debris recycling program can affect this specific County concern. Plan Objectives and Approach: On January 26, 1989, representative of the 9 cities and the County met to discuss particulars for a city/county yard debris planning team. The following ideas were agreed upon in principle at that meeting: 1. This team would be called the Washington Wasteshed Planning Committee, to be chaired by the Wasteshed Representative. 2 . The Committee would be made up of the Wasteshed Representative and a representative from each of the 12 cities located within the Washington Wasteshed. 3 . That the objectives of this Committee would be to apply for a 6 month time extension from DEQ for plan submittal, and upon receiving such an extension, to develop a plan to collect, process and market yard debris within the wasteshed. 2 4 . The Committee would set up two sub-committees for technical advisement. These two sub-committees would report their findings back to the full Committee for consideration. The Committee will have sole responsibility to reach a consensus report that will then be taken to each individual City Council and Board of Commissioners for their review and decision. a. The Collection Sub-Committee would evaluate collection options for the Committee. Membership would be made up of select haulers, the county, Metro, any city representatives, and a representative from the County Solid Waste Advisory Committee. b. The Processing/Marketing Sub-Committee would review current processors and markets and evaluate potential processors and markets. Membership would be made up of the county, any city representatives, a USA representative, Metro, processors, nursery and other agricultural interests. 5. The Committee would have the Wasteshed Representative and any interested city representatives present at all Metro meetings concerning the regional yard debris plan. 6. The Committee and the two sub-committees would meet as often as necessary to make ensure that the plan is developed within the stated timeline. 7. The Wasteshed Representative would be the primary contact person for the Committee and will be responsible for keeping the cities informed. Timeline February 15, 1989 Deadline for cities to have indicated their intent for plan development. February 16, 1989 Determine make-up of sub-committees, set schedules for sub-committee meetings, and send letters to members. March - May 1989 Assess local collection methods, data collection on cost alternatives, .evaluate funding sources, determine amounts of debris generated, appraise 3 processing and marketing impacts. June 1989 Present findings to Committee for review and evaluation. Determine plan parameters that meet consensus of all members. Write wasteshed plan. July 1, 1989 Final yard debris report ready for approval of Committee and for presentation to jurisdictions for formal approval. August 15, 1989 Submit final Washington Wasteshed Yard Debris Recycling Plan to DEQ for approval. Findings: The action of the EQC in requiring yard debris recycling has a background in the Portland area backyard burning ban. Air quality concerns were the cause of the imposition of the burn ban in December 1980. Public and political pressure caused a brief lifting of the ban followed by reimposition of the burning ban. In considering a burn ban, concern was expressed for the ultimate disposal of yard debris. In the 111980 Portland Metropolitan Area Yard Debris Survey" conducted by the Department of Environmental Quality, estimates predicted that yard debris diverted to landfills would amount to 5% of the total municipal waste flow. Since that study, more consideration has been shown to amounts of all material being landfilled. With the closure of St. John's Landfill and the resultant shipment of regional waste to Eastern Oregon, the emphasis of yard debris has shifted to waste reduction in addition to air quality. Pilot Projects DEQ worked from the beginning of the burn ban to help establish yard debris collection and disposal alternatives. In February 1981, DEQ passed through to Metro an Air Pollution Control Program Grant to develop disposal alternatives for yard debris. Initially four processing alternatives as well as six collection alternatives comprised this demonstration project. A brief review of Metro's report "A Demonstration Project for Recycling Yard Debris" is needed to understand how the region evolved to its present position. 4 In 1983 , four private processors existed in the metropolitan region. In the ensuing 6 years, two processors went out of business. One of those processors was replaced briefly by a government operation that also failed. One of the two remaining processors is limited by the State in the amount of material that can be received until accumulated material has been marketed. This has left Grimm's Fuel as the predominate regional processor of yard debris. Metro's report based a planned regional processing system on three main processors, the fourth being eliminated due to high operating cost. These three companies, Waste By-Products, located at St. John's Landfill, McFarlane Bark of Oregon City and Grimm's Fuel of Tualatin established a geographic distribution of processors. The collection alternatives showed a similar survival rate. Of the 6 case studies, only 2 have continued to the present as viable collection methods. A review of these six programs and the reasons for success or failure is important in developing a workable plan for the Washington Wasteshed. They are: 1. Oregon City - This pilot project started out as an on- route curbside collection by city crews. It recovered up to 80% of yard debris generated but also sustained the second highest cost of the six programs. This program was eventually taken over by the franchised hauler and is currently a successful program. It is much the same as the City of Gladstone collection program. It is supported by property taxes, available to all city customers and has increased collection of yard debris to a 95% recovery rate. Oregon City and Gladstone are excellent examples of successful curbside collection programs for yard debris that work. The recovery rate is high and the acceptance by residents is positive. The issue that threatens the program is the inequitable portion of the tax that is paid by commercial property. Business property tends to have little yard debris or they contract with private landscapers to maintain properties. 2. Lake Oswego - An on call curbside pick-up program was initiated in the City of Lake Oswego by the franchised hauler. The program was of short duration during the winter and consequently was not very successful. The potential for such a system was demonstrated however and might be a mote acceptable program if properly implemented. 5 Routes for collection need to have enough paying customers to spread the cost of labor and equipment out to as wide a base as possible. This is the determining factor in any curbside collection based on economics. 3 . West Linn - The City of West Linn originally started yard debris collection with on call pick-up by city crews. This pilot program experienced the highest costs of all six programs. Residents were not charged for the service so acceptance was good although only woody wastes were collected. In 1985 West Linn began their present program of operating a weekly depot for collection and processing. Run by the city with partial volunteer labor, this depot collects 50% of the yard debris generated within the city. 4 . City of Portland - A neighborhood clean-up project was sponsored by the City of Portland for eight days. The project was run by volunteers and was free of charge to area residents. The material collected represented only a 3% participation rate. An ongoing program could not be realistically based upon volunteer labor and the cost of hauling the material recovered would need to be paid from some source. The last problem is that a 3% recovery is not acceptable for retrieving yard debris from the wastestream. 5. City of Beaverton - The City of Beaverton also sponsored a neighborhood clean-up project but used both city crews and a franchised hauler's crew. Participation for this one day event was higher than for the City of Portland project. Due to the volunteers, this was the least expensive of the six projects. The same problems experienced with the City of Portland's clean-up are present here. Much of the cost of this project was absorbed by the city and the franchised hauler. Participation rates are again the main problem of any neighborhood clean-up. For ongoing yard debris collection to be successful, more material must be retrieved. 6. City of Portland - The second pilot project in the City of Portland involved a one day curbside collection program provided by a non-franchised hauler. The project was well accepted considering the convenience and free cost. 6 This type of program never was adopted since their was no method to provide long term financing. Jurisdictional Responsibilities Yard debris recycling involves different government jurisdictions that have varying responsibilities for planning and implementing. A basic understanding of the roles of each government entity is essential in understanding the process for recycling yard debris. State of Oregon The State of Oregon through the EQC is empowered by the Legislature to ensure compliance with the intent of the "Opportunity to Recycle Act" . Oregon Revised Statue (ORS) Section 459 deals with solid waste control. Section 459. 165 to 459.200 specifically addresses recycling; setting standards, implementing guidelines, defining responsibilities and appeal processes. One section critically important to developing a viable yard debris recycling program is section 459.170 (2) (c) . It states that "In adopting rules or guidelines under this section, the commission shall consider availability of markets for recyclable material. " DEQ, under the authority of the EQC, is responsible for writing and implementing the Oregon Administrative Rules (OAR) pertinent to yard debris. Located in Division 60 are the recycling and waste reduction rules. The Washington Wasteshed was created in Section 340-60-025 based on a common solid waste disposal system. The intent was to provide a responsible party to oversee the implementation and to provide assistance in the education and promotion of recycling. On September 9, 1988 the EQC adopted rules identifying yard debris as a principal recyclable material in the Clackamas, Portland, Multnomah, West Linn and Washington Wastesheds. One of the criteria used in this decision was the waste composition study showing yard debris accounting for 10.70 of the entire regional wastestream. The EQC further established guidelines for developing and implementing a plan for yard debris recycling. DEQ has developed rules to implement yard debris recycling and to monitor it's success. An overview of these rules regarding planning and implementation is examined here. 7 Under OAR 340-60-120, Section (1) , the Washington Wasteshed shall submit a plan to DEQ on providing yard debris recycling to the residents of Washington County and the 9 Cities involved. Section (4) lists the parameters that such a plan will include: a. estimated amounts b. collection methods c. number of participants d. participation rate e. amount to be recovered f. process for recycling g. capacity of processors h. projected growth i. description of alternatives j . timeline of growth and use For implementation of the plan developed under the above criteria, DEQ has set the following guidelines on which it will judge a plan acceptable. OAR 340-60-125 gives three options in separate sections. Section (1) would require county haulers to provide curbside collection as defined under OAR 340-60-020. Thus yard debris would be in the same status as glass, tin cans, newsprint, cardboard, and motor oil. Section (2) suggests three alternative methods for collection that would be acceptable to the DEQ. They are: "a. Monthly or more often on-route collection of yard debris during the months of April through October, with a drop-off depot for noncollection service customers available at least monthly, or" "b. A biweekly or more often yard debris collection depot within one mile of the yard debris generators, or such that there is at least one conveniently located depot for every 25, 000 population. " "c. A monthly or more often yard debris collection depot, supplemented by a weekly or more often yard debris depot during the months of April through October, both within one mile of the yard debris generators, or such that there is at least one conveniently located depot for every 25, 000 population. " Section (3) gives the affected jurisdictions the opportunity to develop an alternative method that meets DEQ's approval. DEQ sets the criteria for approval of such an alternative plan on its ability to provide the service to residents and to reach the 8 final goal of DEQ. Section (5) sets the final goal of DEQ. In this section are the minimum performance standards for recovery of yard debris generated in each jurisdiction within the Washington Wasteshed. They are: "a. By July 1, 1989 recovery of at least 25% of the yard debris generated in the area. " "b. By July 1, 1990 recovery of at least 40% of the yard debris generated in the area. " "c. By July 1, 1991 recovery of at least 60% of the yard debris generated in the area. " "d. By July 1, 1992 recovery of at least 80% of the yard debris generated in the area. " A qualifier under OAR Section 340-60-120 (7) states that the above minimum standards shall be met: "except when it can be demonstrated to the Department's satisfaction, that a program which meets these minimum standards will produce more source separated yard debris than the processors or the local or regional government jurisdiction are capable of utilizing. " DEQ has testified and the rules state that the above standards shall be met "unless otherwise provided in an approved yard debris recycling plan" . Metropolitan Service District Metro was created to be the regional government for the three Portland metropolitan counties. Duties that have been delegated to Metro since its inception include; regional transportation planning, regional solid waste disposal, community zoo management. Within solid waste, Metro's tasks include regional waste reduction, regional recycling, solid waste planning, solid waste facility permitting, solid waste transportation and landfill operation. Additionally, it offers technical assistance to local jurisdictions on implementing solid waste programs. Metro's responsibility to yard debris is set down in the Oregon Administrative Rules Division 60. Section 340-60-120 (1) & (2) allows Metro to develop a regional plan that would meet each local government's requirement. Through intergovernmental 9 agreement, each local jurisdiction would be responsible to work with Metro in developing and implementing a regional plan. Local Governments For local jurisdictions within the Washington Wasteshed, three options were available. To develop a plan independently, to sign an agreement and work with Metro, or to work as a group within the wasteshed. The Cities of Banks, Gaston and North Plains are not required to provide yard debris recycling. The Cities of Beaverton, Cornelius, Durham, Forest Grove, Hillsboro, King City, Tigard, Tualatin, and Sherwood in concert with Washington County have signed a "Statement of Intent to Participate in Washington Wasteshed Yard Debris Recycling Plan" . Washington County, through the Department of Health and Human Services, is DEQ's designated Wasteshed Representative and as such is responsible for the annual Wasteshed Report. This report was submitted on February 15, 1989 with a 6 month extension request for development of a yard debris recycling plan. DEQ subsequently conditionally approved the annual wasteshed report with the provision that the yard debris recycling portion of the report be submitted by August 15, 1989. Local jurisdictions have till that date to approve a plan to implement yard debris recycling. In addition to rules requiring yard debris recycling by each jurisdiction, Washington County and the cities located within the Tualatin Valley need to be concerned about water pollution of the Tualatin River. Although a small contributor to non-point pollution in the Tualatin Basin, yard debris that is disposed of in gullies and waterways in the County eventually find its way into the Tualatin River. By providing a system for collection that finds acceptance by the residents of the county, one source of pollution could be eliminated. Variables Affecting Recycling There are a number items that directly or indirectly affect a yard debris recycling program. In order to better understand the problems associated with setting up such a program, these components need explanation. 10 Backyard Burning The backyard burning ban initiated by DEQ took in the majority of the metropolitan area. The Cities of Hillsboro, Forest Grove, Cornelius and Sherwood lie either totally or substantially outside the ban boundary. Portions of unincorporated Washington County also lie outside the burn ban. This is significant to these jurisdictions since the performance standards that DEQ will judge a plan acceptable are based on the amount of yard debris retrieved. Under Metro's methodology for determining a jurisdictions available material, burning is not taken into the equation. The only data available on percentage of people burning yard debris is from a ten year old survey by DEQ. In this survey, conducted regionwide before the burn ban took affect, 35% of respondents stated that they burned. By volume, the total burned was estimated at 13% of all yard debris. If the regional estimate of 1000 pounds of yard debris per single family household is reduced by these percentages, jurisdictions outside the burn ban are more realistically looking at 870 pounds to as low as 650 pounds per single family residence. This is a sizable reduction in the total amount of material to be recovered to meet the compliance standards. The survey, by including the entire region, averaged together areas opposed to the ban with areas that favored the ban. In order to reach this average, it would be reasonable to expect that the percentage burning in the areas left out of the burn ban area would be higher than 35%. Until more complete and current figures are available, an average amount between the number of people who burn and amount by volume will be used. The amount of material per single family residence will therefore be reduced to 770 pounds for jurisdictions outside the burn ban. Backyard Composting Home composting has been figured into Metro's methodology for amount of material generated regionwide. It is estimated that home composting accounts for 25-30% of the total amount of yard debris. Backyard composting is the most desireable alternative for disposal and should be encouraged in any plan. The advantages are 11 that the material never has to be collected, processed or marketed. All those functions are completed at the site of generation. Like backyard burning, the number of people who home compost is difficult to determine accurately. Also, like backyard burning, if a reasonable system for collecting yard debris is instituted, will this affect the number of people who compost or burn? It would be expected that home composters are more likely to continue composting yard debris even if provided a reasonable collection system. Processing In 1983 four processors started recycling yard debris in the metropolitan area. Today two processors remain. McFarlane's Bark in .Oregon City continues to process and market yard debris compost as well as Grimm's Fuel in Tualatin. McFarlane' s Bark is under DEQ restrictions to reduce the amount of material stored on site. Consequently, this processor is limited in the amount of material that may be disposed of on site. The Washington Wasteshed is projected to have the following processing capacities: Grimm's Fuel Expansion Project Operational in 1991 (26% of 100, 000 ton capacity) 26, 000 Lakeside Reclamation 1, 000 Hillsboro Landfill 8, 000 USA Sludge Program 9 , 000 Total 44, 000 Grimm's Fuel is the predominate processor for the region. In 1988, an expansion project was started to provide additional capacity for yard debris at Grimm's Fuel. Due for completion in 1990, the total capacity will be 1 million pounds per year. The Washington Wasteshed has 26% of Grimm's processing capacity. This amount to should be 260, 000 pounds or 26, 000 tons yearly. This is the only full processor in the county that both grinds and composts yard debris. Other partial processors of yard debris in the county are 12 Lakeside Reclamation, Unified Sewerage Agency and possibly Hillsboro Landfill. Lakeside Reclamation currently grinds material only, and projects doubling the amount of material processed to 1000 tons yearly. Lakeside Reclamation has been using yard debris as both ground cover and hog fuel . USA has been using yard debris since 1974 as a bulking agent for sludge in their field application program. This program has been very successful and well accepted in the agricultural community. USA anticipates increasing their grinding operation to 9000 tons annually. This is a considerable increase from their current 400 tons. This increase in yard debris usage is contingent on a continuing sludge application program on area farms. New EPA regulations are being adopted that may restrict field application of sludge. New processing capacity may begin at Hillsboro Landfill. If the planned expansion of the landfill is approved, 8000 tons annually may be chipped to be used as both intermediate cover and for final cover on the landfill. It has yet to be determined whether yard debris is appropriate intermediate cover. These operations have a projected total processing capacity of 44 , 000 tons annually with the wasteshed' s share of Grimm' s Fuel accounted for in the total. Certain safeguards will need to be addressed by all the jurisdictions concerning yard debris collection and processing. Problems have arisen within Washington County of the establishment of uncontrolled yard debris collection sites. With yard debris carrying a charge for disposal, the opportunity exists to collect a fee to dispose of yard debris on private land with or without the intention to process the material. The problem arises when an operation ceases, leaving the landowner or local government with a potential fire and health risk. Markets Local processors have developed markets over the last five years and have experienced a growth of 20% or more per year. Much of this market has been gained at the expense of other soil amendment products. Bark dust and peat moss are similar products against which yard debris compost must compete. Yard debris compost has penetrated the home, landscape and nursery markets and has been well accepted. Existing markets for recycled yard debris in Washington County is predominately material sold through Grimm's Fuel. Of the known estimates of yard debris being recycled, Grimm's Fuel accounts 13 for 86% of the material being marketed. The remaining material is accounted for by Lakeside Reclamation at 8% and USA's sludge program at 6% of the total. Grimm's Fuel is the only County processor marketing finished compost to individual and commercial customers. The Lakeside and USA programs are both only chipped products used in-house and not marketed to the public. Total known markets in the Washington Wasteshed for yard debris in 1989 are expected to be: Grimm's Fuel (26% of 22, 000 tons) 5,720 Lakeside Reclamation 500 USA Sludge Program 400 Total 6, 620 Tons The large growth of yard debris products that was experienced from 1983 to 1988 seems have to flattened out. A market that was sustaining growth over 50% per year experienced only 14% last year and is projected at a 13% growth next year. If the in-house programs at USA and Hillsboro Landfill can reach there projected yearly totals, this will add 17, 000 tons to the market capacity of the wasteshed. This will require a concerted effort on both programs to reach this goal. Grimm's Fuel took 6 years to build processing capacity and markets to handle a similar amount of yard debris. Other potential markets have been explored by various businesses. Since 1983 several attempts have been made to develop a hog fuel market for both yard debris and demolition debris. No ongoing viable program presently exist for either. The future of a hog fuel market is questionable and may only come through incentives to business or individuals. A large variable that could affect the yard debris markets is presently being developed in the region. Metro is initiating a mixed solid waste (MSW) compost facility with a capacity of 185, 000 tons annually for the metropolitan region. Although contractual restrictions on marketing of finished compost will be imposed, this project proposes giving away the final product. This government subsidized facility may infiltrate markets that been developed for yard debris compost by private industry over the past 6 years. 14 Participation Rates and Costs The current cost for disposal of mixed waste for the landfill at Metro South Transfer Station is $45.75 per ton. Disposal of source seperated yard debris at Grimm's Fuel is presently $14 .00 per ton. However, unlike the landfill option, the cost of processing yard debris can be distributed on the disposal cost and on the sale of the finished product. When the added revenue from sales is accounted for, the cost for processing is approxiamately $17. 65 per ton. Currently in the metropolitan area, three successful yard debris collection systems are in use. By analyzing these three very different programs, an appropriate, cost effective method for collecting yard debris can be determined. From the initial 6 pilot projects, today we have 3 basic types of yard debris collection. On-Route Curbside Collection The City of Gladstone has had a curbside collection program for yard debris since 1969. Oregon City has also instituted a curbside collection program. Both programs are based on property taxes, and are available to all local residents. At a respective cost of $27.00 and $25.46 per year for an average home, these programs are successful due to the broad based financial support and high participation rates experienced. Oregon City and Gladstone are excellent examples of successful curbside collection programs for yard debris that work. The recovery rate is high and the acceptance by residents is positive. The most recent data shows participation rates as high as 95%. The issue that threatens the program is the inequitable portion of the tax that is paid by commercial property. Business property tends to have little yard debris or they contract with private landscapers to maintain properties. In other curbside collection programs based on voluntary participation, costs were higher due to lower participation. Curbside collection works when the cost of the program can be spread over the largest user base as possible. It would appear that only through property tax or mandatory service that a sufficient base can be maintained. Self Haul Depot Since 1985, the City of West Linn has run a successful weekly 15 depot for the residents of the city. Run by city staff with volunteer labor through community corrections, the depot is open on Saturdays. Experience has demonstrated that an observer is necessary to guarantee that contaminates are not allowed to be discarded. Participation has shown that operating from March through November provides the optimum access for residents when that service is needed. This program has had good participation with estimates showing 50% of the yard debris in West Linn being recovered for processing. At a cost of $3.00 per yard to dispose, some of the cost of this program is subsidized by the city. Use of city equipment to chip and move compost piles as well as the occasional city crew for labor to run the equipment supports this program. Although no resident is more than 4.5 miles from the permanent depot site, many residents have no means of transporting material to the site. West Linn currently offers on-call service through the franchised hauler for source separated yard debris. This is a fee for service program. The city is attempting to initiate a delivery/pick-up system where trailers of yard debris compost will be delivered. After a suitable time full trailers of yard debris will be hauled away in the same trailer. This enables compost to be marketed to the same people producing yard debris. Neighborhood Clean-ups Many cities in the metropolitan area sponsor city or neighborhood clean-up days. Usually held in the spring or fall of the year, most programs collect any outdoor material. Attempts are made to keep yard junk and yard debris separate in order that the yard debris may be recycled. Generally these events are subsidized by the jurisdiction, at no direct cost to the residents, and use volunteer labor. The City of Beaverton provides such a service to city residents. It also sponsors through the city's franchised hauler a monthly yard debris collection depot. Conducted in a parking lot, material is loaded into garbage compactor trucks and then hauled to a local processor. Acceptance by the residents has been good for this type of program. The amount of material recovered accounts for 1.5% of the estimated 4783 tons generated in Beaverton. Costs for this program are subsidized through the franchised hauler. 16 An average of 3 .5 employees and 2 compactor trucks are provided by the hauler. The cost to residents, $3 .00 per yard, covers the expense of disposal at the local processor and part of the wages of the employee. Computer Analysis in order to understand a systematic approach to yard debris recycling versus individual collection by jurisdictions, a computer analysis by Metro in Section 3 provides data for each individual jurisdiction for a curbside collection program and indivdual depots. Metro's computer model did not have the capability to look at a county wide system of depots so a computer model was developed so material recovery and cost projections could be evaluated. This model is capable of performing "what if" problems for the wasteshed. 17 Plan Parameters: In developing a yard debris recycling plan under DEQ rules, ten points of information must be provided. These will be addressed as they relate to the Washington Wasteshed. The amounts for Washington County are for the unincorporated areas inside the UGB. 1 - Estimated Amounts City of Beaverton 4,783 Tons City of Cornelius 432 Tons City of Durham 132 Tons City of Forest Grove 1, 055 Tons City of Hillsboro 3 , 355 Tons City of King City 313 Tons City of Sherwood 433 Tons City of Tigard 3,806 Tons City of Tualatin 1,404 Tons Washington County 20, 600 Tons Wasteshed Total 36, 314 Tons These amounts are derived from the methodology (see Appendix C) developed by Metro that will be applied to all jurisdictions addressing yard debris recycling. For cities outside the backyard burning ban boundaries, an amount (23%) has been deducted that approximates the material burned in these jurisdictions. 2 - Collection Methods A low density depot system will be developed for the affected portion of the wasteshed. This will consist of 5 self-haul collection depots located throughout the urban portion of the wasteshed. This will allow the majority of the residents to be within 4 miles of a depot, or one depot per 53,000 population. The solid waste industry has committed to provide these depots and they will be open to the general public. Although contingent on sighting these depots, early commitments from the solid waste industry project the depots to be located at: Forest Grove March-Nov. , weekly service, Saturdays only Hillsboro Year round, daily service, Mon.-Sat. Beaverton Year round, daily service, Mon.-Sat. Garden Home March-Nov. , weekly service, Saturdays only Tualatin Year round, daily service, Mon.-Sat. Additionally, an existing depot located west of Beaverton for commercial recyclers will be incorporated into this plan. This facility will continue to be closed to the general public. 19 Complimenting the depots will be on-call source separated curbside service provided by the franchised haulers. This will be a fee for service program with rates set to provide incentive to recycle yard debris versus disposal to the landfill. To meet the particular needs of the Cities of Durham, King City and Sherwood, the local franchised hauler will provide source separated curbside service. This will be a fee for service program offered to residents in each of these cities from March through November. It will be at the minimum a monthly collection. These three cities will provide the entire Jre wasteshed an opportunity to evaluate the effectiveness of a fee for use curbside collection program. Data collected on the participation rates and amount of material retrieved will greatly assist the other jurisdictions future program planning. 3 - Number of Participants The goal of this program is to reach as many residents as economically as possible. Estimates for each jurisdiction are: City of Beaverton 21, 000 Residents City of Cornelius 1,959 Residents City of Durham 395 Residents City of Forest Grove 4, 666 Residents City of Hillsboro 12,444 Residents City of King City 1, 005 Residents City of Sherwood 1, 151 Residents City of Tigard 13,750 Residents City of Tualatin 6, 080 Residents Washington County 65, 975 Residents Wasteshed Total 114, 675 Residents Again, these figures take into account the substantial number of residents who burn yard debris in the cities outside the burn ban. 4 - Participation Rate This plan is based on the assumption that a convenient depot system will generate a 50% participation rate. This has been demonstrated to be attainable under similar conditions. However, this plan addresses a county wide collection program rather than a city wide collection program. It is further expected that the fee for service curbside collection program in the three cities will attain a 50% participation rate. This would appear to be the minimum rate needed to make this program economically realistic as costs of 20 such a program increase dramatically if such a rate is not maintained. Because this plan is based on the development of new markets, participation rates are expected to increase over the next 4 years. Since several factors affect future market development, it is judicious to look at two sets of participation rates. One is the rate projected from all planned programs reaching maximum potential. The second is a median rate based on more realistic growth projections in programs that presently do not exist. These rates do not take into consideration the considerable effect that Metro's MSW compost facility may have on markets. Projected rates are: Maximum median 1989 19% 19% 1990 32% 23% 1991 44% 29% 1992 50% 39% 5 - Amount to be Recovered Like participation rates, the amount of yard debris to be recovered will be determined upon market availability for finished product. - This plan involves the development of new markets. The amount of yard debris to be recovered is expected to increase over the next 4 years. since several factors affect future market development, again it is judicious to look at two sets of recovery amounts. One is the amount projected from all planned programs reaching maximum potential. The second is Median rate based on more realistic growth in programs that do not even exist as yet. These amounts again do not take into consideration the considerable effect that Metro's MSW compost facility may have on markets. Projected recovery amounts in tons of yard debris are: Maximum Median 1989 6, 120 6, 120 1990 11, 000 8, 050 1991 15,780 10, 380 1992 18, 337 14,260 6 - Processors for Recycling Four facilities will be used in Washington County for processing. Three are currently processing yard debris and the fourth has 21 made a commitment to begin processing under this plan. They are: Grimm's Fuel Tualatin Grind and compost Hillsboro Landfill Hillsboro Grind only Unified Sewerage Agency Hillsboro Grind only Lakeside Reclamation Beaverton Grind only 7 - Processor Capacity The capacities break down as follows: Washington Washington Washington Washington County Wasteshed Wasteshed Wasteshed Projected Potential Utilized Present Grimm's 100, 000 tons 26, 000 tons 8, 060 tons 5, 018 tons Hillsboro 8, 000 tons 8, 000 tons 3, 000 tons 0 tons USA 9, 000 tons 9, 000 tons 3,200 tons 400 tons Lakeside 1, 000 tons 1, 000 tons 1, 000 tons 500 tons Total 118, 000 tons 44 , 000 tons 15, 260 tons 5, 918 tons The four listed processors located in Washington County have projected combined capacity of 118,000 tons of yard debris yearly. This figure needs to studied closer. Since Grimm's Fuel is a regional facility, the Washington Wasteshed has to recognize that only 26% of the total capacity is available. This second column offers total Washington Wasteshed potential capacity. But yard debris needs to be utilized either internally or through markets to be considered recyclable. The third column is the projected capacity based on market development and utilization by the processors. These figures are again based upon realistic projections for processors that will need to sustain 100% yearly increases in capacity for the next four years to meet these goals. Present capacity is measured by amount of material utilized or marketed in 1988 and is represented in the fourth column. This demonstrates the importance of market development for yard debris compost. 8 - Projected Growth over the next four years, it can be expected that considerable growth will be experienced under this plan. Again dependent upon market development for any growth, the following shows the maximum growth projected and a realistic growth projection. 22 Maximum Median Percent Percent Increase Increase Participation Rate 229% 294% Amount Recovered 338% 263% Utilized Capacity 424% 258% 9 - Alternatives for Collection This alternative plan founded on low density depots can expect to provide the opportunity to recycle to residents of the Washington Wasteshed. Supplemented by a fee for service curbside collection of source separated yard debris, this plan offers a basic recycling level while markets for finished material are expanded. 10 - Timeline Projecting over the next four years the growth of this program can best be visualized in Figures y and z. By equalizing out the amount of yard debris collected with the amount of yard debris processed and utilized, low density depots can expect to meet the projected demand. Figure Y shows demand versus collection under maximum market development over the next four years. As can be seen, the collection system based on 50% retrieval rates begins to lag behind processing capacity by 1992. Graph y shows this more dramatically. Figure Z takes the more realistic approach that a more median market development will take place up to the 50% retrieval rate. Graph Z shows a strong steady growth in utilized yard debris. Education and Promotion: All successful recycling plans need an education and promotion program. Yard debris recycling in the Washington Wasteshed will have an emphasis on collecting and using yard debris compost. Home composting will be stressed in the education and promotion program. The more material that remains at the site of generation means less material to collect, process and market. All those tasks are completed at no cost to the system through home composting. A wasteshed wide program will be developed to education the community on the advantages to backyard composting. This will include a part time compost educator that will be available to 23 school, civic and other interested groups. The compost educator will also be responsible for promoting the beneficial aspects of yard debris compost. This will require coordination with processors in the wasteshed. Promotional material will be distributed supporting the use of the depot system for yard debris collection, the availability of a fee for service curbside collection of source separated yard debris, and the benefit of yard debris compost in the residential soil amendment market. A community educational display will be created that will promote yard debris recycling and use. This will made available for libraries, schools, community special events and fairs within the wasteshed. Part of the commitment of the cities and the County will be to promote the in-house use of yard debris compost. Written policies within each jurisdiction directing parks, roads and building maintenance to use yard debris compost where appropriate would establish a leadership role for the general public to follow. Certification and Land Use: Jurisdictions in the Washington Wasteshed will develop a model ordnance for certification of yard debris collection depots. The need to set standards for performance is in the public interest as uncontrolled depots can become public nuisances requiring county or city enforcement. This is in conformance with DEQ rules pertaining to permit requirements for disposal sites. A certification program will also ensure compliance were applicable with Metro's permit system for collection sites. Land use planning will need to be addressed in those jurisdictions were depots or processors are planned and in those jurisdictions that may be considered in the future. Incorporating standards for depots and processors into the comprehensive plan will allow these functions to take place in that zone. Implementation and Future Planning: Although this plan is based on major participation of the solid waste industry, commitments have been made that implementation will occur in a timely manner. After DEQ approval and contingent on land use and Metro approval, 4 of the 5 depots should be open 24 for business by March 1990. This will coincide with the beginning of the heavy demand period for yard debris dispcsal. The fee for service curbside collection of source separated yard debris would be implemented at the same time by local franchised haulers after rate review and approval by local jurisdictions. The education and promotion program would begin prior to the startup of the main program to ensure good public awareness of yard debris recycling. Several factors will be assessed during the implementation and evolution of the Washington Wasteshed yard debris recycling program. Data collection from all parties involved will assist in program evaluation toward meeting plan objectives. As markets for yard debris evolve this plan will allow the wasteshed to accommodate such changes. This plan will precede Metro's regional yard debris plan and will necessitate an appraisal at the time of -approval of the regional plan to assure compliance by the Washington Wasteshed Plan. This may require revision of this plan and submittal of any changes to DEQ for approval. The Washington Wasteshed has been active in plan development of the regional plan from the beginning and will maintain an active role through Metro in future planning. It is the wasteshed's intent to work within a regional framework for yard debris recycling. 25 Washington Wasteshed Planning Committee Bill Martin, Chair Washington County Robert Prickett City of Banks Beth Erlendson City of Beaverton Jerald Taylor City of Cornelius Jeanne Percy City of Durham Jeff Hecksel City of Forest Grove Marilyn Begert City of Gaston Cecilia Petrocco City of Hillsboro Lenore Akerson City of King City Karen-Lee Stolte City of North Plains Clifford Scott City of Tigard Jan Nelson City of Tualatin James Rapp City of Sherwood Ex-officio Member Becky Crockett Metro Appendix A Yard Debris Recycling Sub-Committee for Processing and Marketing Gary Clapshaw Hillsboro Landfill Hillsboro Larry Depree Farmer Hillsboro Mike Edera Landscape Contractor Banks Bill Fuller Tualatin Vineyards Forest Grove Howard Grabhorn Lakeside Reclamation Beaverton Rod Grimm Grimm' s Fuel Tualatin Sandy Gurkewitz Analyst-Resource Recovery Metro Dan Leonard Manager, West Basin Unified Sewerage Agency Gill McLain Schlegel 's Sunridge Farm Banks Members of the Washington Wasteshed Planning Committee Appendix A Yard Debris Recycling Sub-Committee for Processing and Marketing Gary Clapshaw Hillsboro Landfill Hillsboro Larry Depree Farmer Hillsboro Mike Edera Landscape Contractor Banks Bill Fuller Tualatin Vineyards Forest Grove Howard Grabhorn Lakeside Reclamation Beaverton Rod Grimm Grimm's Fuel Tualatin Sandy Gurkewitz Analyst-Resource Recovery Metro Dan Leonard Manager, West Basin Unified Sewerage Agency Gill McLain Schlegel 's Sunridge Farm Banks Members of the Washington Wasteshed Planning Committee Appendix A Yard Debris Recycling Sub-Committee for Collection Becky Crockett Project Manager Metro Keith Eldein Aloha Garbage Aloha Bill Gildow Solid Waste Advisory Comm. Washington County Estle Harlan Harlan Business Consultants Milwaukie Bosti Rebagliati Forest Grove Disposal Forest Grove Dave Tonges West Beaverton Sanitary Beaverton Buzz Walker Walker Garbage Service Portland Members of the Washington Wasteshed Planning Committee Appendix A (Computer analysis will be presented at June 22, 1989 meeting and will be included in final report) Appendix B (Metro methodolgy for yard debris generation will be included in final report) Appendix C MEMORANDUM TO: Wayne Lowry, Finance Director FROM: Keith Liden, Senior Planner RE: Pride Disposal service DATE: April 18, 1989 In the past few weeks, I have received two calls regarding the service provided by Pride Disposal. Could you please relay these comments to Pride at your next Utility and Franchise Committee meeting. 1. Mr. Whiting (ph. 245-6475) Said that recyclable material (esp. cat food cans) prepared in a manner advised by METRO has been rejected by Pride as not being properly prepared. 2. Mr. Knebel (ph. 639-1223) The dumpster at Twality Jr. High is being emptied around 3am and on behalf of the neighborhood, he requested that this trash pick-up time be changed to a more civilized hour. Also, some time ago I received a complaint from Libby Durbin (ph. 684-4486) because the rates for alternate week service is more expensive than weekly pick-up. April 28, 1989 Larry Schmidt Schmidt's Sanitary Service, Inc. 8325 S.W. Ross Street Tigard, OR 97223 RE: Operation of trucks Dear Larry: I have received a request that the operation of trucks on your property be modified so that they are not parked along the eastern property line. The noise and diesel fumes are found to be objectionable in the early morning hours and on weekends. As we discussed earlier this year, your business is considered a non-conforming use in the R-4.5 (Residential, 4.5 units/acre) zone and I must respond to complaints, particularly if they appear to be related to the expansion of such a use. I will be out of town next week, but feel free to contact John Acker in our office if you have any questions. I shall be available after May 8th. Sincerely, Keith S. Liden Senior Planner c: John Acker ;l j CUSA Mrs. S.M. Holmes _ 12215 S.W. 33rd. Portland, OR 97219 Mr . Wayne Lowry, Finance Director City of Tigard P.O. Box 23397 Tigard, OR 97223 MEMORANDUM CITY OF TIGARD' 0KEC0N ' TO: Pat Reilly' City Administrator Respond 8y 17-R0M: Wayne Lowry' Finance Director For Your Information DATE: March 23^ 1989 S�gn and Return SUBJECT: Review of Waste Haulers Annual Reports The Utility and Franchise Committee met on Tuesday, March 21, 1989' to discuss and review the financial reports submitted by the solid waste haulers for the year ending December 31 , 1988. Tigard Municipal Code Section 11 .04 requires the Committee to review the reports and to report back to the City Council by April 1, on whether or not the results of the evaluation of the reports requires an adjustment to the garbage rates charged to Tigard citizens . In August of 1987' the Council approved a procedure to be followed in reviewing the reports . The procedure allows for an adjustment to the garbage rates if the aggregate profit percentage of the haulers is less than 0 percent or greater than 12 percent. Upon review of the annual reports, the Utility and Franchise Committee found the profit percentage of the solid waste haulers to he within the limits yet forth in the procedure, and therefore, recommends that no adjustment be made to the garbage rates charged within the city of Tigard. Z believe that passing this memo on to the City Council will meet the reporting requirements of the TMC. ke/9]h6D t I I i r I I i j t F y-,wrl' fi25-6777' i I i I t i I I