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October 21, 2011 Debra Kaufman Senior Program Manager StopWaste.org 1537 Webster Street Oakland, CA 94612 Dear Ms. Kaufman: Thank you for the opportunity to review the draft ordinance requiring action to reduce landfilling of recyclable and organic solid wastes from business, multi-family residences, and self haulers and the draft ordinance regulating the use of carryout bags and promoting the use of recyclable bags. We have completed our review and our comments are listed below. Comments concerning the ordinance requiring actions to reduce landfilling of recyclable and organic solid wastes from businesses, multi-family residences,and self-haulers 1. Adoption of the ordinance may lead to service cost increases for Pleasanton Garbage commercial and multi-family customers and users of the Pleasanton Transfer Station. While we have reviewed the Authority's economic analysis indicating that the ordinance will actually result in reduced collection costs,that analysis focuses on existing collection rate tiers that pass the cost of recycling programs to other collection tiers, and not the actual cost of providing the services. Because the proposed ordinance requires mandatory material separation,the cost of containers, bins,trucks and sorting services will be borne by either commercial and multi-family residential customers or spread over other collection tiers. In addition, because many residents using the transfer station will not have the capacity to source separate, requiring separate loads or containers,the 50%surcharge included in Section 6(b), represents a significant increase to our multi-family residents. We request additional analysis detailing actual costs of providing the services within each community. The HF&H report is based on costs of providing services, not existing rates, on a Countywide average basis. The HF&H report does not show lower collection costs, but rather lower overall system costs, when all major costs are considered (collecting, processing, disposal). HF&H found that collecting,transporting and processing recvclables and compostables,that would result from a mandatory recycling ordinance,would result in a lower net cost than collecting, transporting and disposing of that amount of solid waste as garbage, given avoided landfill disposal costs, commodity values for recyclables and higher efficiencies for organics collection.