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NSWMA Comments Page: 4 Attachment l: Specific comments pertaining to Reporting Methodologies: Because of the extensive nature of the report, NSWMA will not submit a comprehensive page by page list of comments on this report. We do, however, submit the following priority comments that support our concerns with the Report Methodologies and resulting conclusions that are drawn. Pertaining to: 1) Rates in organized collection versus open collection systems, page 6: The report acknowledges the many factors that go into establishing rates for different customers and states that "While there are exceptions and cost related issues can be very complex...." the report goes on to conclude that "residents in organized collection systems can and do pay less than residents of open collection systems". a) Our experience clearly shows, consumers are driven by the value equation and not simply the cheapest price. In the open market system, with a diversity of competitors cheap prices are available, but as in any market based system, the range of prices from high to low varies depending on commerce. There are many examples of how the free market system works with pricing, including the airline industry, which for a single airline can have different ticket prices for different seats on the same flight. This is analogous to the problem the Foth Report attempts to identify as problematic. b) The free market system works. It is amazing to observe the extreme interest and overt willingness to throw out a working market system. If the current system was not innovating or delivering environmentally sound solutions, we could understand the need for change. Clearly this is not the case. Here are two simple examples of recent program and policy decisions supported by the waste industry: i) Single Sort Recycling: The implementation of Single Sort recycling resulted in the amount of net material recycled increasing and participation has skyrocketed. The capital investment, based on a healthy open market, was committed without government mandate. This "analysis" radically changes the equation used to justify this investment. ii) Waste Policy: A current example is a bill that moved through the 2009 legislature regarding the requirement of compostable bags for curbside collection of yard waste. As Representative Gardner will attest, private industry has not opposed this bill, because we are already doing it. In open market cities, reusable containers or compostable bags are the norm. It is interesting to note, the only problem cited with the legislation was from a government managed system that needs extra time to implement their program. 2) Rate survey of residents, page 7: "It should be noted that this survey methodology was not a scientific process with random sampling. Also there are many variables affecting pricing. Even so, the survey results provide interesting data". (emphasis added). 3) Road wear and tear, page 16: "This study did not locate much documented information available that provides actual, quantifiable data regarding the issue (of impact of open hauling system on roads) on actual residential streets in Minnesota." Despite this statement, the report has numerous references to reduced wear and tear with organized collection systems, and that this is a cost savings advantage of organized collection. In fact the report later cites a memorandum from the Nick Landwer, P.E. from the consulting firm, URS to the City of Arden Hills (Attachment 3) that states "environmental factors are generally responsible for the majority of pavement wear and deterioration for Arden Hills streets and therefore significant extension of pavement life (through organized collection) are unlikely". The City hired URS (the recognized engineering expert on this issue) to analyze what causes road damage. Specifically, Nick Landwer P.E. from URS said the following: "Although vehicle types and loading contribute to the wear of the pavement section, environmental factors also contribute to the deterioration of the pavement section. A properly designed bituminous surface should be able to handle the traffic loading over its design life including heavy truck loadings experienced in Arden Hills. Reducing the number of heavy truck loadings should have positive effects on the lifespan and quality of local streets, however environmental factors are generally ponsible for the majority of pavement wear and deterioration for Arden Hills streets and therefore significant extensions of pavement life are unlikely 1163 E. Odgen Avenue, Suite 705, PMB 313, Naperville, IL 60563 800-679-6269 630-848-1101 630-848-1102 fx www.nswma.org