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NSWMA Comments Page: 5 Despite this statement embodied in the report, the report goes on to cite unsubstantiated road wear and tear costs incurred due to the waste industry. Furthermore: a) It must be acknowledged that no data is available as to how much longer a city road will last if government managed collection is implemented. In the cities where it has been discussed, city staff has been unwilling to commit to a specific reduction in road repairs budgets. b) In fact, we believe, depending on the configuration of the trucks used, reducing the number of trucks running on the streets may increase road wear. For example, if you have 20 tons of waste in a community hauled by one truck versus having 4 trucks and 4 different haulers you are dividing the 20 tons into 4 loads instead of 1. c) If the goal is reduced truck traffic on City streets, the only responsible action is to regulate and reduce all types of traffic including lawn care, delivery vehicles and the postal service. To repeat what has been proved many times over, the cost/benefit equation of government managed collection does not work. The private sector waste industry would be decimated with family owned operations unable to stay in business, jobs would be lost, environmental innovation would slow to a crawl, and citizens would lose the ability to choose the best value in the market. 4) Survey Administration: a) The survey was administered to residents who may not understand or accurately report the information on the bill. This would result in errors. b) In reviewing rates in organized versus open systems, potential variables are difficult to take into consideration and may not be visible on the bill. In essence, you are comparing apples to oranges. In fact, the report states on page 36 that "potential variables include differences in service levels, distance to disposal locations and the corresponding tipping fees, surcharges, etc. The comparisons cited made efforts to control the variables or identify them and make adjustments." However, the report goes on to conclude that, "Nevertheless, the rates charged in open systems are typically higher than in organized systems." c) On page 51, the report notes that the survey was administered to Foth employees and that "It should be noted that this survey methodology was not a scientific process, and that there are many variables affecting pricing. This limits application to other areas of the state. Even so, the survey provides interesting data." This statement discounts any rate findings and conclusions that can be drawn about ratings in this report. d) The survey was not a scientific survey as stated in the Executive Summary. 5) Indepth Studies: Pertaining to information provided by City Departments, we question whether consistent information was provided, by what department, and whether the information included subsidies other than "direct subsidies received by the city", Direct subsidies received by the city may not include the city's own taxing authority, since these revenues are not "received by the city" from the state. Did the survey respondents understand "direct subsidy" to mean SCORE grants and/or state aid only, as mentioned in the report, or did they include other means of generating revenue to subsidize their solid waste system that included locally generated revenues? These subsidies, other than the direct subsidies, would not be captured in the data and would consequently affect the rate comparisons. Also pertaining to subsidies, on page 91, the report acknowledges that "the taxes and county fee charges were provided by some billing survey participants. In some cases, if the tax amount was not supplied and it was determined that tax was not included in the base rate for the service, the tax amount was calculated. In other cases, if the taxes and county charges were not provided separately by the survey participant, and if it wasn't clear whether or not these fees were included in the base cost, the amount paid to the hauler could not be determined." 6) On Increased Recycling rates in Organized Collection Systems: The Solid Waste Management Board's (SWMCB) RETRAC system has been in place for one year, so that the sample timeframe is too small to draw any conclusions about what 1163 E. Odgen Avenue, Suite 705, PMB 313, Naperville, IL 60563 800-679-6269 630-848-1101 630-848-1102 fx www.nswma.org