2022-032 CSWMS Completion and ImplementationDate: May 27, 2022 Report No. 2022-032
INFORMAL STAFF REPORT
TO MAYOR AND CITY COUNCIL
SUBJECT:
The City of Denton Comprehensive Solid Waste Management Strategy Acceptance and
Implementation
BACKGROUND:
In October 2020, the Denton City Council approved the development of a Comprehensive Solid
Waste Management Strategy (CSWMS.) The CSWMS is a Denton-centric document designed to
help the Solid Waste and Recycling Department make informed decisions to maximize waste
reduction and drive diversion from ultimate disposal to the greatest extent possible, including, but
not limited to residential and commercial programmatic recycling, yard and organic waste
management, construction and/or demolition debris, non-programmatic recyclable and reusable
material. Over the past two years, the Solid Waste and Recycling Department, along with its
contracted consultants Burns and McDonnell, has been working with the community and technical
experts, with updates to the Public Utilities Board and the Denton City Council on progress and
programs receiving feedback on diversion goals and potential programs, including organics
diversion.
The purpose of this report is to announce the completion of the CSWMS and layout the process of
acceptance, by ordinance, and implementation of the CSWMS.
DISCUSSION:
According to the U.S. Census Bureau, North Texas is the fastest-growing region in North
America.1 In the last decade, the population of Denton has increased by over 30%, which is
consistent with population growth in the region. As the population of the region continues to grow
so will the need to ensure adequate and appropriate disposal activity coupled with a robust
diversion program generated waste.
The development of the CSWMS has been completed in three (3) phases; the completion of Waste
Characterization Study, a Visioning and Public Outreach exercise, and the submission of the final
CSWMS document, which was submitted to the Solid Waste and Recycling Department on May
25, 2022 (copy attached).
The Waste Characterization Study was completed between November 5 – 8, 2020. Garbage and
recycling samples were collected from residential, multi-family, and commercial customers and
the material was “dissected” to determine the make-up of each segment (i.e. recyclable material in
trash, contamination in recycling, weight and composition of each waste stream.) Currently, the
1 https://www.census.gov/newsroom/press-releases/2022/population-estimates-counties-decrease.html
Date: May 27, 2022 Report No. 2022-032
City diverts approximately 28% of material collected from residential and commercial customers
in the City, consisting of single-stream material (paper, plastic, metal containers, and cardboard)
and yard waste. As the City looks to increase its diversion potential with the creation and
implementation of the Comprehensive Solid Waste Management Strategy (CSWMS), we will be
examining opportunities to increase diversion across the scales through incentives, partnerships,
and contracts.
The Visioning and Public Outreach portion of the CSWMS development was completed in May
2021. This exercise started with a public survey, of which 883 persons responded distributed
across age ranges of 18 to 80 years of age. Survey results indicate:
• A shared vision is enjoyed across all respondents,
• Denton residents desire a solid waste management system that is sustainable,
• They seek significant waste diversion and recycling goals,
• Implemented programs must be cost-effective, and
• Programs should be designed and implemented to preserve the useful life of the landfill.
Following the completion of the survey, a future visioning think-tank was assembled to help build
coherency around a vision for initial future planning for solid waste management and recycling to
guide the community over the next twenty years. Scenarios evaluated showed that the group
supported a rapid transition from current programs (defined as “Trash Troubles) to an aggressive
system of solid waste management (“Change the future now”.) This is evidenced by Denton
striving to be a leading role-model community.
The completion of the Comprehensive Solid Waste Management Strategy documents builds upon
the Waste Characterization study and public input to define and evaluate best practices, and
cutting-edge considerations for consideration in the City of Denton to maximize diversion and
minimize waste generation and disposal.
In March 2022, a discussion was held with the City Council to outline and define programmatic
goals and metrics. Programmatic goals describe the overarching, end goals the program defines
to achieve in the short term and over the life of the program, which is 30% overall diversion of
waste by 2030, 40% diversion by 2040, and 75% diversion by 2075. Incremental progress and
improvements are defined by program metrics, which include:
CSWMS Metric Descriptor Goal
Waste Generation Rate Amount of waste produced, in
pounds, per capita in the City of
Denton
Decrease
Residential/Commercial
recycle rate
The percentage of net program
material collected and destined for
third party management and reuse
Increase
Residential/Commercial
contamination rate
The percentage of net program
material contamination and destined
for ultimate disposal
Decrease
Capture Rate The percentage of diversion of
programmatic and, non-
Increase
Date: May 27, 2022 Report No. 2022-032
programmatic recycling and organics
material removed from the waste
stream
Landfill life The amount of time the landfill has
available capacity for the ultimate
disposal of material
Minimize consumption
Increase landfill life
Organics diversion In tons and percent, the amount of
yard and food waste collected and
beneficially reused
Increase
Upon formal acceptance of the CSWMS, the Solid Waste and Recycling Department will be
working on an implementation plan, focused on diversion while remaining cost-effective to payers.
In addition to focusing on programmatic “quick wins” (expansion of our field auditing program,
regionalization of the City’s Home Chemical Collection program, etc.), much of FY 2022/2023
will focus on managing the administrative controls required to ensure program success, including:
• Updates to Chapter 24 of the City of Denton Code of Ordinances,
• Development of a Comprehensive Diversionary Ordinance,
• Enhanced Public Education and Outreach,
• The development and implementation of Request for Information to identify third party
providers of recycling and diversionary programs,
• Increased internal and external data analytics and reporting,
• Increased Grant applications and management,
• Local partnership developments
o School Districts
o Universities
o County and municipal governments
Once the foundation of administrative controls is in place, much of FY2023/24 and beyond will
be focused on the implementation and monitoring of anticipated and potential diversionary
programs, including, but not limited to:
• Organics diversion
o Commercial and residential food waste avoidance and diversion
o Yard Waste and tree trimming management
o Commercial sludge optimization
• Bulk material and appliance reuse
• Non-Programmatic material metal recycling
• Construction and Demolition Debris and Shingle Management
o Reuse
o 3rd party recycling
o Cost incentivized permit rebate program
• Non-Programmatic material recycling
o Textiles
o Shoes
o Home items
Date: May 27, 2022 Report No. 2022-032
▪ Kitchen items
▪ Furniture
▪ Lawn maintenance equipment
• Enhancement of diversion from City facilities and programs
o Day-to-day programmatic material recycling from City operations
o Procurement protocols
o Grounds Maintenance
o Impact fees and requirements
▪ League Play
▪ Special Events permit updates
The watchwords embraced during the development, and through the implementation of the
CSWMS include, in no particular order, Sustainability, Opportunities, Scaling, and Cost-
effectiveness. Changing circumstances, resources, and global and local recycling/diversion
markets will define and drive programs and implementation throughout the City of Denton’s Solid
Waste and Recycling efforts. Program goals, metrics, and progress will be posted to a dashboard,
which will be made available through the City of Denton Solid Waste and Recycling website.
Additionally, quarterly program updates will be reported through the City’s Friday Report.
STAFF CONTACT:
Brian Boerner
Solid Waste and Recycling Director
Comprehensive Solid Waste
Management Strategy (CSWMS)
City of Denton, Texas
Project No. 128365
Final Report
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-1 Burns & McDonnell
TABLE OF CONTENTS
EXECUTIVE SUMMARY
Page No.
1.0 OVERVIEW, PRIORITIES AND OBJECTIVES ................................................. 1-1
1.1 Purpose ................................................................................................................. 1-1
1.2 Guiding Principles ............................................................................................... 1-1
1.3 Project Approach ................................................................................................. 1-2
1.3.1 Goals and SWOT Analysis ................................................................... 1-3
1.3.2 Stakeholder Engagement ...................................................................... 1-4
1.4 Key Terms ............................................................................................................ 1-4
1.5 Guide to the CSWMS Sections ............................................................................ 1-7
2.0 SOLID WASTE AND RECYCLING TRENDS, POLICIES AND
REGULATORY REIVEW .................................................................................. 2-1
2.1 Review of Relevant Planning Studies .................................................................. 2-1
2.2 Regulatory and Policy Review............................................................................. 2-2
2.2.1 Role of the Federal Government in Regulating Solid Waste ................ 2-2
2.2.2 Role of the State Government in Regulating Solid Waste .................... 2-5
2.2.3 Recent State Legislative Trends............................................................ 2-8
2.2.4 Role of the City of Denton in Regulating Solid Waste ......................... 2-9
2.3 Solid Waste Management Industry Trends ........................................................ 2-10
2.3.1 Landfill Waste Reduction, Diversion and Zero Waste Philosophies .. 2-10
2.3.2 Material Waste Diversion and Alternative Metrics ............................ 2-13
2.3.3 Alignment with National Solid Waste Reduction Goals .................... 2-18
2.3.4 Promotion of Ingenuity in Reuse and Recycling ................................ 2-19
2.3.5 Alternative Waste Management Technologies ................................... 2-20
2.3.6 Landfill Management .......................................................................... 2-23
3.0 PLANNING AREA CHARACTERISTICS ......................................................... 3-1
3.1 Demographic Characteristics ............................................................................... 3-1
3.1.1 Historical and Current Populations ....................................................... 3-1
3.1.2 Single-Family and Multifamily Household Distribution ...................... 3-3
3.1.3 Population Projections .......................................................................... 3-5
3.2 Economic Characteristics..................................................................................... 3-7
3.2.1 Current Employment and Industry Characteristics ............................... 3-8
3.3 Solid Waste Generation, Recycling, and Disposal .............................................. 3-8
3.3.1 Residential Generation, Recycling, and Disposal ................................. 3-9
3.3.2 Commercial Generation, Recycling, and Disposal ............................. 3-11
3.3.3 C&D Generation, Recycling, and Disposal ........................................ 3-13
3.3.4 Total Generation, Recycling, and Disposal ........................................ 3-14
3.3.5 Residential and Commercial MSW Forecast ...................................... 3-16
3.4 Waste Characterization ...................................................................................... 3-17
3.4.1 Regional Capture Rate ........................................................................ 3-20
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-2 Burns & McDonnell
3.4.2 Recycling Contamination.................................................................... 3-23
4.0 FACILITIES AND INFRASTRUCTURE ............................................................ 4-1
4.1 Current System Review ....................................................................................... 4-1
4.1.1 Landfills ................................................................................................ 4-3
4.1.2 Materials Recovery Facilities ............................................................. 4-11
4.1.3 Transfer Stations ................................................................................. 4-14
4.1.4 Organics Processing Facilities ............................................................ 4-16
4.1.5 C&D Processing Facilities .................................................................. 4-19
4.1.6 Home Chemical Collection and Other Special Wastes ....................... 4-21
4.2 Regional Partnerships ........................................................................................ 4-22
4.3 Land Use and Growth ........................................................................................ 4-26
4.3.1 Current and Projected Growth in the City of Denton ......................... 4-27
4.3.2 Projected Growth in Surrounding Communities................................. 4-35
4.4 Current System Findings.................................................................................... 4-37
5.0 PUBLIC EDUCATION, OUTREACH AND COMPLIANCE ............................... 5-1
5.1 Education, Outreach and Compliance Evaluation ............................................... 5-1
5.1.1 Components of a Successful Education, Outreach and Compliance
Program ................................................................................................. 5-1
5.1.2 Overview the City’s Education, Outreach and Compliance Efforts ..... 5-3
5.1.3 Evaluation of the City’s Education, Outreach and Compliance
Efforts ................................................................................................... 5-8
5.2 Case Studies ....................................................................................................... 5-10
5.2.1 Regional Education and Outreach Campaign ..................................... 5-10
5.2.2 Cart Auditing Programs ...................................................................... 5-11
5.2.3 Compliance Incentive Policies ............................................................ 5-12
5.2.4 Commercial Recycling Support .......................................................... 5-13
5.2.5 Strategically Allocate Resources ........................................................ 5-14
5.3 Key Findings and Recommendations ................................................................ 5-15
6.0 ORGANICS MANAGEMENT ............................................................................ 6-1
6.1 Evaluation Criteria ............................................................................................... 6-1
6.1.1 Food Waste Recovery Hierarchy .......................................................... 6-2
6.1.2 Pre-consumer versus Post-consumer Food Waste ................................ 6-3
6.2 Generation and Diversion Summary .................................................................... 6-3
6.3 Organics Management Infrastructure .................................................................. 6-4
6.4 Yard Waste – Residential and Commercial ......................................................... 6-5
6.4.1 Yard Waste Options .............................................................................. 6-5
6.5 Residential Food Waste ....................................................................................... 6-7
6.5.1 Residential Food Waste Options ........................................................... 6-7
6.5.2 Residential Food Waste Case Studies ................................................. 6-10
6.6 Commercial Food Waste.................................................................................... 6-10
6.6.1 Commercial Food Waste Options ....................................................... 6-11
6.6.2 Commercial Food Waste Case Studies ............................................... 6-13
6.7 Biosolids ............................................................................................................ 6-15
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-3 Burns & McDonnell
6.8 Wood Waste and Other Organic Wastes ........................................................... 6-15
6.9 Key Findings and Recommendations ................................................................ 6-16
6.9.1 Residential Organics Recommendations ............................................ 6-16
6.9.2 Commercial Organics Recommendations ........................................... 6-17
7.0 LANDFILL DISPOSAL ...................................................................................... 7-1
7.1 Landfill Pricing Strategies ................................................................................... 7-1
7.1.1 Gate Rates ............................................................................................. 7-1
7.1.2 Guaranteed Tonnage Contracts ............................................................. 7-5
7.1.3 Landfill Disposal Surcharges ................................................................ 7-7
7.2 Other Approaches to Increase Diversion and Extend Landfill Life .................... 7-8
7.2.1 Landfill Bans for Certain Materials ...................................................... 7-8
7.2.2 Other Incentives and Disincentives .................................................... 7-10
7.3 Key Findings and Recommendations ................................................................ 7-10
8.0 PLANNING FOR FUTURE GROWTH & INFRASTRUCTURE ......................... 8-1
8.1 Future Transfer Station Evaluation ...................................................................... 8-1
8.1.1 Operational Appropriateness Evaluation .............................................. 8-1
8.1.2 Financial Feasibility Evaluation ........................................................... 8-2
8.1.3 Long-Term Considerations for a Transfer Station ................................ 8-6
8.2 Development Code and Community Planning .................................................... 8-7
8.2.1 New Urbanism and Development Trends ............................................. 8-7
8.3 Recycling Program and Policy Options to Address Growth ............................... 8-9
8.3.1 Residential Recycling Options .............................................................. 8-9
8.3.2 Multifamily Recycling Options .......................................................... 8-10
8.3.3 Commercial Recycling Options .......................................................... 8-13
8.3.4 C&D Recycling Options ..................................................................... 8-15
8.4 Data Needs for Licensed Hauler Reporting ....................................................... 8-18
8.4.1 Case Studies: Hauler Reporting .......................................................... 8-18
8.5 Key Findings and Recommendations ................................................................ 8-20
9.0 RECYCLING PROCESSING ............................................................................. 9-1
9.1 Minimizing Challenging Materials in the Recycling Stream .............................. 9-1
9.1.2 Plastic Film and Bags............................................................................ 9-4
9.1.3 Styrofoam .............................................................................................. 9-4
9.1.4 Food ...................................................................................................... 9-6
9.1.5 Glass ...................................................................................................... 9-6
9.1.6 Sharps .................................................................................................... 9-8
9.1.7 Batteries ................................................................................................ 9-9
9.1.8 Tanglers and Explosives ....................................................................... 9-9
9.1.9 Home Chemical Waste ....................................................................... 9-10
9.1.10 Shredded Paper ................................................................................... 9-11
9.1.11 Textiles ................................................................................................ 9-12
9.1.12 Furniture and Other Bulky Items ........................................................ 9-12
9.2 Recycling Processing Agreement Overview ..................................................... 9-13
9.2.1 Recycling Processing Agreement Best Management Practices .......... 9-13
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-4 Burns & McDonnell
9.2.2 Evaluation of Lease and Recycling Processing Agreement ............... 9-16
9.3 Recycling Agreement Procurement Considerations .......................................... 9-20
9.4 Key Findings and Recommendations ................................................................ 9-22
10.0 MATERIAL END MARKETS & PARTERNSHIP OPPORTUNITIES .............. 10-1
10.1 Current Markets for Typical Recyclables .......................................................... 10-1
10.1.1 Paper Markets ..................................................................................... 10-4
10.1.2 Metals Markets.................................................................................... 10-5
10.1.3 Plastics Markets .................................................................................. 10-6
10.1.4 Glass Markets...................................................................................... 10-6
10.2 Current Markets for Organics ............................................................................ 10-7
10.3 Current Markets for C&D Debris ...................................................................... 10-7
10.4 Value of Additional Recycling Opportunities ................................................... 10-9
10.5 Role of Local Government in Recycling Market Development ...................... 10-11
10.6 Partnerships Options for Increased Diversion ................................................. 10-12
10.6.1 Partnerships with City Departments ................................................. 10-12
10.6.2 Partnerships with Other Community Entities ................................... 10-15
10.6.3 Partnerships with Neighboring Communities ................................... 10-19
10.7 Key Findings and Recommendations .............................................................. 10-22
11.0 STRATEGY DEVELOPMENT AND ANALYSIS ............................................. 11-1
11.1 Enhance Education, Outreach and Compliance ................................................. 11-1
11.1.1 Tactics and Recommendations ........................................................... 11-1
11.1.2 Financial Impacts ................................................................................ 11-3
11.1.3 Environmental Impacts ....................................................................... 11-3
11.2 Implement Innovative Organics Management ................................................... 11-4
11.2.1 Tactics and Recommendations ........................................................... 11-5
11.2.2 Financial Impacts ................................................................................ 11-6
11.2.3 Environmental Impacts ....................................................................... 11-7
11.3 Efficiently Use Landfill Capacity ...................................................................... 11-8
11.3.1 Tactics and Recommendations ........................................................... 11-8
11.3.2 Financial Impacts ................................................................................ 11-9
11.3.3 Environmental Impacts ....................................................................... 11-9
11.4 Planning for Future Growth and Infrastructure ............................................... 11-10
11.4.1 Tactics and Recommendations ......................................................... 11-11
11.4.2 Financial Impacts .............................................................................. 11-12
11.4.3 Environmental Impacts ..................................................................... 11-15
11.5 Optimize Recycling Processing ....................................................................... 11-15
11.5.1 Tactics and Recommendations ......................................................... 11-15
11.5.2 Financial Impacts .............................................................................. 11-17
11.5.3 Environmental Impacts ..................................................................... 11-17
11.6 Support New Markets and Leverage Partnerships ........................................... 11-18
11.6.1 Tactics and Recommendations ......................................................... 11-18
11.6.2 Financial Impacts .............................................................................. 11-20
11.6.3 Environmental Impacts ..................................................................... 11-20
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-5 Burns & McDonnell
12.0 IMPLEMENTATION PLAN ............................................................................. 12-1
APPENDIX A - GOAL AND SWOT ANALYSIS
APPENDIX B - VISION FOR DENTON THINK-TANK REPORT
APPENDIX C - WASTE CHARACTERIZATION MEMO
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-6 Burns & McDonnell
LIST OF TABLES
Page No.
Table 2-1: Status Summary for Landfill Waste Reduction, Diversion, and Zero Waste
Philosophies ......................................................................................................... 2-13
Table 2-2: Texas Cities with High Diversion or Recycling Goals ........................................ 2-14
Table 2-3: Alignment of Metrics to Zero Waste Principles ....................................................... 2-15
Table 2-4: Alternative Metric Evaluation for City of Denton Single-Family MSW ................. 2-17
Table 2-5: Status Summary for Material Waste Diversion and Alternative Metrics ................. 2-18
Table 2-6: Status Summary for Alignment with National Solid Waste Reduction Goals ......... 2-19
Table 2-7: Status Summary for Promotion of Ingenuity in Reuse and Recycling..................... 2-20
Table 2-8: Summary of Texas Cities’ Efforts to Evaluate Conversion Technologies ........... 2-22
Table 2-9: Status Summary for Alternative Waste Management Technologies........................ 2-23
Table 2-10: Average Per-ton Landfill Tipping Fees ................................................................ 2-24
Table 2-11: Status Summary for Landfill Management ............................................................ 2-25
Table 3-1: City, County, and State Historical Population & Growth, 2010-2020 ....................... 3-2
Table 3-2: Household and Population Distributions by Household Type, 2019 ..................... 3-4
Table 3-3: City of Denton Future Population Growth Scenarios to 2045 ............................... 3-6
Table 3-4: Residential and Commercial Management, 2018-2020 (pounds per person
per day) ................................................................................................................. 3-15
Table 3-5: Regional Single-Family Capture Rate by Individual Recyclable Materials ............ 3-21
Table 3-6: 2020 Participating City and Denton Single-Family Capture Rate ........................... 3-23
Table 3-7: Recycling Contamination by Generator Type .......................................................... 3-23
Table 3-8: Reported Single-Family Recycling Contamination Rates........................................ 3-24
Table 4-1: NCTCOG Type I Landfill Disposal and Remaining Capacities, FY 2020 ................ 4-3
Table 4-2: Disposal Rates at Landfill Facility (2020) ................................................................. 4-7
Table 4-3: Denton Landfill Disposal Tons by Customer Category, 2016-2020 ...................... 4-9
Table 4-4: NCTCOG Materials Recovery Facilities and Accepted Residential Materials ....... 4-11
Table 4-5: NCTCOG Transfer Stations and Tonnage Handled, FY 2020 ................................. 4-14
Table 4-6: NCTCOG Organics Processing Facilities and Accepted Materials ..................... 4-16
Table 4-7: City of Denton Organics Management Tons by Source, 2016-2020 ................... 4-17
Table 4-8: NCTCOG Type IV Landfill Disposal and Remaining Site Lite, FY 2020 ......... 4-20
Table 4-9: Common Home Chemical Collection (HCC) Program Options .............................. 4-22
Table 4-10: City of Denton Home Chemical Collection and Other Special Waste
Tons, 2016-2020 ................................................................................................... 4-22
Table 4-11: Examples of Public-Private Partnership Options for MSW Operations ................ 4-23
Table 4-12: Advantages and Disadvantages of Approaches to Finance and Operate
Processing Facilities .................................................................................................24
Table 4-13: Comparison Matrix of Denton and Largest 10 Texas Cities Service
Provision1 ............................................................................................................. 4-25
Table 5-1: Evaluation Matrix of City’s Education, Outreach and Compliance Efforts ............... 5-9
Table 6-1: Evaluation Matrix of the City’s Yard Waste Programs ......................................... 6-7
Table 6-2: Evaluation Matrix of the City’s Residential Food Waste Programs ...................... 6-9
Table 6-3: Evaluation Matrix of the City’s Commercial Food Waste Programs ...................... 6-12
Table 7-1: Disposal Rates at the Denton Landfill (2022) ............................................................ 7-2
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-7 Burns & McDonnell
Table 7-2: City Put-or-Pay Contract Terms ................................................................................. 7-5
Table 7-3: Historical McCommas Bluff Landfill Gate Rate (Dallas)..................................... 7-6
Table 7-4: Landfill Discount Matrix ........................................................................................ 7-7
Table 7-5: Alternatives to Landfill Bans ................................................................................... 7-10
Table 8-1: Transfer Station Direct Costs1 .................................................................................... 8-3
Table 8-2: Estimated Financial Feasibility of a Transfer Station Compared to Direct
Haul ........................................................................................................................ 8-6
Table 9-1: Current and Available Management Strategies for Challenging Materials at
MRFs1 ..................................................................................................................... 9-3
Table 9-2: Evaluation Matrix of City’s Current Lease and Recycling Processing
Agreement ............................................................................................................ 9-17
Table 9-3: Recommended Schedules for Recycling Processing Procurements..................... 9-21
Table 10-1: Current and Five-year Average Commodity Prices ............................................... 10-4
Table 10-2: Estimated Value of Recyclables in the City’s Landfilled Waste Stream ............. 10-10
Table 10-3: Example Community Collection and End Use Opportunities.............................. 10-17
Table 11-1: Planning-Level Cost Estimate for Commercial Organics Pilot.............................. 11-6
Table 11-2: Anticipated Impacts of Sector-Specific Options .................................................. 11-14
Table 11-3: Planning-Level Cost Estimate for C&D Warehouse Program ............................. 11-14
Table 11-4: Planning-Level Cost Estimate for EPS Densifier Program .................................. 11-17
Table 11-5: Planning-Level Cost Estimates for Regionalized HCC Program ......................... 11-20
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-8 Burns & McDonnell
LIST OF FIGURES
Page No.
Figure ES-1: U.S. EPA’s Waste Management Hierarchy ................................................................1
Figure 1-1: City of Denton CSWMS Development Process ..................................................... 1-3
Figure 2-2: U.S. EPA’s Waste Management Hierarchy ............................................................ 2-10
Figure 2-3: Circular Economy ................................................................................................... 2-11
Figure 3-1: Historical City Population Growth, 1970 – 2020 ..................................................... 3-2
Figure 3-2: Recent City, County and State Population Growth Rates, 2010-20201 .................... 3-3
Figure 3-3: City of Denton Population Growth Scenarios Through 2045 ................................ 3-6
Figure 3-4: City of Denton Population Projection, 2020-2040 .................................................... 3-7
Figure 3-5: City of Denton Employment by Industry, 2019 ..................................................... 3-8
Figure 3-6: Residential Solid Waste and Recycling Generation Trends, 2018-2020
(Tons)1, 2 ............................................................................................................... 3-10
Figure 3-7: Residential Solid Waste Generation and Disposal Trends, 2018-2020
(Pounds per Household)1 ...................................................................................... 3-11
Figure 3-8: City-Collected Commercial Waste by Material Type, 20191 ................................. 3-12
Figure 3-9: Commercial and Multifamily Refuse Distribution, 2019 (Tons) ......................... 3-13
Figure 3-10: City of Denton Landfill C&D Debris Disposal Trends, 2018-2020 (Tons)1 ....... 3-14
Figure 3-11: City of Denton Residential & Commercial Generation by Material Type,
2020 ...................................................................................................................... 3-15
Figure 3-12: Projected City-Managed Residential and Commercial Waste Generation,
2019-20401 ........................................................................................................... 3-17
Figure 3-13: Single-Family Residential Garbage and Recycling Composition, 2020............... 3-19
Figure 3-14: Multifamily Residential Garbage and Recycling Composition, 2020 .................. 3-19
Figure 3-15: Commercial Garbage and Recycling Composition, 2020 ..................................... 3-19
Figure 4-1: MSW Management Facility Locations within the City of Denton ........................... 4-1
Figure 4-2: MSW Facility Locations within Denton County and Neighboring
Counties .................................................................................................................. 4-2
Figure 4-3: Trends in Annual Regional Disposal, Type I and IV Landfills (Tons) ..................... 4-4
Figure 4-4: Projected NCTCOG Remaining Regional Types I and IV Landfill Capacity,
2021-2045 ............................................................................................................... 4-5
Figure 4-5: Denton Landfill Scalehouse ...................................................................................... 4-6
Figure 4-6: Denton Landfill MSW Tonnage by Broad Customer Category, 2020 ................... 4-8
Figure 4-7: Denton Landfill Annual Tonnage by Customer Category, 2016-2020 .................. 4-9
Figure 4-8: Projected Denton Landfill Capacity Based on Forecasted Scenarios, 2021-
2080 ...................................................................................................................... 4-10
Figure 4-9: Pratt Industries Material Recovery Facility ............................................................ 4-12
Figure 4-10: City of Denton Recycling Process Flow Overview.............................................. 4-13
Figure 4-11: City of Denton Dyno Dirt Composting Facility.................................................... 4-17
Figure 4-12: City of Denton Pecan Creek WWTP .................................................................... 4-19
Figure 4-13: Champion Construction MRF Materials Processing Line .................................... 4-20
Figure 4-14: Manual Sorting of Building Materials for Recover .............................................. 4-21
Figure 4-15: Compact Growth Scenario (Preferred Scenario from Denton Plan 2030) ............ 4-27
Figure 4-16: Denton Population Distribution in Relation to City Solid Waste Facilities ......... 4-29
Comprehensive Solid Waste Management Strategy Table of Contents
City of Denton, Texas TOC-9 Burns & McDonnell
Figure 4-17: Projected City of Denton 2040 Population in Relation to City Solid Waste
Facilities ............................................................................................................... 4-30
Figure 4-18: Population Areas Greater Than 6,000 Persons in City of Denton ........................ 4-31
Figure 4-19: New Residential Communities and Number of Platted Lots in Relation to
City Solid Waste Facilities ................................................................................... 4-34
Figure 4-20: Population Change Through 2040 for City of Denton and Surrounding
Communities ........................................................................................................ 4-36
Figure 5-1: Example of Messaging Communicating Service Information .................................. 5-4
Figure 5-2: Example of Messaging Communicating General Environmental
Information ............................................................................................................. 5-5
Figure 6-3: Waste Wizard ............................................................................................................ 5-6
Figure 6-4: Brochure Mailer ........................................................................................................ 5-7
Figure 5-5: Example of Regionally Collaborative Messaging .................................................... 5-8
Figure 7-1: U.S. EPA’s Food Recovery Hierarchy...................................................................... 6-2
Figure 6-2: Organic Material Managed by the City in 2020 (Tons) ......................................... 6-4
Figure 6-3: Non-Residential Excess Food Generating Sectors ............................................... 6-13
Figure 7-1: Average Gate Rates Charged in the NCTCOG Region (2020)1 ............................... 7-4
Figure 9-1: Densified Briquettes of EPS Foam ........................................................................... 9-5
Figure 9-2: RFP Process Description ......................................................................................... 9-20
Figure 10-1: Single Stream Material Revenue (per Ton) .......................................................... 10-2
Figure 10-2: Regional HCC Brochure1 .................................................................................... 10-21
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas i Burns & McDonnell
LIST OF ABBREVIATIONS
Abbreviation Term/Phrase/Name
AD Anaerobic digestion
AEGB Austin Energy Green Building
ASL Automated Side Loader vehicles
BMR Building Materials Recovery program
BOPA Battery, Oil, Paint, and Antifreeze
Burns & McDonnell Burns & McDonnell Engineering Company, Inc.
C&D Construction and Demolition Debris
CAA Clean Air Act of 1976
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CHaRM Center for Hard to Recycle Materials
the City The City of Denton
COGs Councils of Governments
Composting Facility The Dyno Dirt Composting Facility
CPI Consumer Price Index
CSWMS Comprehensive Solid Waste Management Strategy
CVAD UNT’s College of Visual Arts and Design
CY Cubic Yard
DFW Dallas-Fort Worth
DISD Denton Independent School District
DTV Denton TV
EPP Environmental procurement programs
EPR Extended Producer Responsibility
EPS Expanded polystyrene, "Styrofoam"
EREF Environmental Research and Education Foundation
FL Front Loader vehicles
FOG Fats, oils, and greases
FTEs Full time employees
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ii Burns & McDonnell
Abbreviation Term/Phrase/Name
FY Fiscal year (October through September)
GHG Greenhouse gas
GRC Glass Recycling Coalition
HCC Home Chemical Collection
HDPE High density polyethylene
HHW Household hazardous waste
HOAs Homeowner Associations
ICI Industrial, commercial and institutional sector
LCA Life-cycle assessment
LDPE Low density polyethylene
LEED Leadership in Energy and Environmental Design
LLDPE Linear Low-Density Polyethylene
MPCs Master Planned Communities
MRF Materials recovery facility
MSW municipal solid waste
NCTCOG North Central Texas Council of Governments
NGO Non-Governmental Organization
NRDC The Natural Resources Defense Council
NTMWD North Texas Municipal Water District
OCC Old Corrugated Cardboard
ONP Old Newspapers
PAYT Pay-as-you-throw
PET Polyethylene terephthalate
PP Polypropylene
PPP Public-private partnerships
Pratt Pratt Industries
PS Polystyrene
PSA Processing Service Agreement
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas iii Burns & McDonnell
Abbreviation Term/Phrase/Name
PSAs Public Service Ads
PVC Polyvinyl Chloride
RAP Rubberized Asphalt Paving
RCRA Resource Conservation and Recovery Act
Recycling Agreement Lease ad Regional Recycling Processing Agreement
RFB Requests for Bids
RFI Request for Information
RFP Requests for Proposals
RFQ Request for Qualifications
RMDP Recycling Market Development Plan
RMDZs Recycling Market Development Zone
RNG Renewable Natural Gas
SARA Superfund Amendments and Reauthorization Act of 1986
SL Side Loader vehicles
SMM Sustainable Materials Management
STA US Composting Council’s Seal of Testing Assurance
STaND Statistical Trends and News of Denton
STAR The State of Texas Alliance for Recycling
SWDA Solid Waste Disposal Act
SWOT Strengths, Weaknesses, Opportunities, and Threats
SWR The Solid Waste and Recycling Department
TASWA Texoma Area Solid Waste Authority
TCEQ Texas Commission on Environmental Quality
TPH tons per hour
TPY tons per year
TWU Texas Women’s University
TxDOT Texas Department of Transportation
U.S. EPA U.S. Environmental Protection Agency
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas iv Burns & McDonnell
Abbreviation Term/Phrase/Name
USDA United States Department of Agriculture
UNT University of North Texas
UNT University of North Texas
URP Universal Recycling Ordinance
WARM Waste Reduction Model
WWTP Wastewater Treatment Plant
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-1 Burns & McDonnell
EXECUTIVE SUMMARY
Purpose
Developing a Comprehensive Solid Waste Management Strategy (CSWMS) is a critical step in
purposefully shaping the future of the City’s material management system. The City and its consultant,
Burns & McDonnell Engineering Company, Inc. (Burns & McDonnell), developed this CSWMS by
evaluating existing programs, policies and infrastructure as well as the local, regional, and national
emerging trends and technologies for sustainable materials management. As cities throughout the United
States pursue solutions to their solid waste management challenges, it is apparent that no single method,
technology, or program offers a complete solution; rather, a combination of methods is required to
provide for appropriate and cost-effective management of all material types, while continuing to build an
integrated management system. The unique purpose of the CSWMS is to provide a framework to guide
the City’s future solid waste/materials management system and to develop infrastructure, programs, and
policies necessary to manage materials in alignment with the Guiding Principles of the CSWMS.
Guiding Principles
The Solid Waste and Recycling (SWR) Department established Guiding Principles to direct the
development of specific strategies presented throughout the CSWMS. The four Guiding Principles are:
1. Develop innovative municipal solid
waste (MSW) management methods
consistent with the waste management
hierarchy to achieve as much MSW
reduction, reuse, and diversion from
landfill disposal as sustainably feasible
[based on economic, regulatory,
environmental and social constraints].
2. Provide MSW services that are convenient,
environmentally conscious, and cost-
effective for customers and the City.
3. Balance landfill revenue with capacity preservation, and collaborate with third-party landfill
customers to implement efforts consistent with the waste management hierarchy.
4. Strategically utilize program data and technology for informed decision-making.
Figure ES-1: U.S. EPA’s Waste Management Hierarchy
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-2 Burns & McDonnell
Alignment with Other Strategic Efforts and Goals
The CSWMS was developed to align with the City’s current and ongoing strategic efforts, including the
City’s Simply Sustainable Framework. The City adopted the Simply Sustainable Framework in June
2020, and provides a framework, goals, and sustainability metrics for many of the City’s activities
including Material Resource Management. Established goals relevant to the CSWMS are to reduce solid
waste generation and divert material away from landfill and leverage the City’s purchasing power through
sustainable procurement. The strategies presented in the CSWMS align with these Material Resource
Management objectives.
The City has also recently initiated the process to establish Citywide diversion goals to be ambitious (to
reflect the City’s commitment to sustainable materials management) while also realistically accounting
for the types of materials generated in the City and the level of control the City has over how these
materials are managed. While the City is the refuse service provider for residential, multi-family and
commercial sectors, both multi-family and commercial sector generators may contract with third parties
for recycling service (or provide no recycling service at all). This limits the City’s ability to track
recycling in these sectors, which comprise an estimated 71 percent of generated wastes. Various programs
and ordinances can influence and increase recycling from these entities.
The following summarizes potential additional diversion opportunities identified as part of the CSWMS:
Maximizing the recovery of residential recyclable programmatic materials. Currently, 54
percent of single-stream recyclable materials are successfully collected for recycling (rather than
disposed to landfill ) from single family generators. Improvements to the well-established
program to increase participation and capture rate could theoretically divert an additional 4,295
tons, if every recyclable item were successfully diverted from the waste stream.1 A small quantity
of yard waste is disposed from single family households. Together, an additional ~5,000 tons of
recyclables and yard waste could be captured from the single family sector, at current generation
rates. If all of this material could be captured,1 it could add an additional three percentage points
to the Citywide diversion rate.
Targeting commercial and multi-family recycling. The commercial and multi-family sectors
are significantly larger than the single family sector, but with less City control over how materials
are managed. An estimated 11,200 tons of single-stream recyclable material was landfilled by the
1 Currently, no cities are known to have achieved capture rates nearing 100 percent. Seattle, Washington has
achieved an 85 percent capture rate for single-family recyclables and King County has achieved an 80 percent
capture rate for accepted commercial recyclables. Achieving 100 percent capture rate in intended to serve as a
theoretical maximum.
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-3 Burns & McDonnell
commercial and multi-family sectors in 2020. If all of this material could be captured,1 it could
add an additional seven percentage points to the Citywide diversion rate.
Implementing food waste diversion programs. Food waste is the largest divertible component
of the landfilled waste stream in the City, with an estimated 30,400 tons of commercial food
waste and 11,800 tons of residential food waste landfilled in 2020. If all of this material could be
captured,1 it could add an additional 27 percentage points to the Citywide diversion rate.
Based on data presented in this CSWMS, the City managed a total of 158,909 tons material through its
residential and commercial collection services in 2020, including a total of 7,062 tons of recycling and
30,600 tons of organics which were recovered from residential and commercial generators. A small
quantity of HCC, electronics, drug kiosk and C&D metals were also reported as recycled. In total, this is
equivalent to approximately a 24 percent diversion rate.
In the near term (e.g., by 2030), increasing the capture rate of current program materials will result in
increased diversion; however, achieving a Citywide diversion rate above 24 percent will likely be
challenging without implementing new programs targeting large quantity materials such as commercial
food waste. Longer-term, achieving higher diversion rates (e.g., 40-50 percent) could be considered
achievable through strong residential and commercial recycling programs that include significant food
waste diversion. Achieving diversion rates above 60 percent could be considered aspirational, though as
materials and technology continue to evolve and the policy and regulatory landscape may change,2 higher
diversion rates (calculated based on recycling and organics diversion) could become more achievable.
Stakeholder Engagement
The CSWMS development process engaged stakeholders from the community and multiple City
departments. Community stakeholders engagement included a survey of Denton residents and other
community members (e.g., business owners) and a community Think Tank group. The stakeholder
engagement process included 883 responses to the community survey, and a series of three Think Tank
workshop meetings. Responses from the survey and visioning results from Think Tank group provided a
data-driven approach to were used to understand the key emergent trends and vision for the City of
Denton, specifically:
2 For example, future technology development may support cost-effective recycling of additional types of containers
or packaging; or policy or market factors may result in manufacturers phasing out non-recyclable packaging, thereby
increasing diversion rates by reducing total landfilled material.
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-4 Burns & McDonnell
There was a strong Think Tank vision for “Change the future now!” indicating a clear direction of
change toward sustainability and the integration of policy and technology to achieve increased
diversion.
The Think Tank and survey responses show community support for near-term action for
recycling and solid waste management.
The community survey responses identified three top trends/needs: recycling education;
population growth and increased waste; and landfill capacity.
The full results of the stakeholder engagement process are presented in the Vision for Denton Think-Tank
Report (Appendix B).
Guidance for Reading the CSWMS
The CSWMS is organized into three overall sections: (1) introduction, (2) strategy evaluation and
recommendations, and (3) the implementation plan. The introductory sections provide key context about
the CSWMS, materials management trends, regulations, projected material management needs, and
regional facilities and infrastructure. Strategy evaluation and recommendation sections are dedicated to
defining, evaluating and developing recommendations for each of the six strategies presented as part of
the CSWMS. The implementation plan presents the tactics and recommendations for the City to
implement each of the six strategies, as well as an evaluation of the financial and environmental impacts
The six strategies of the CSWMS are described below.
The Strategy to Enhance Education, Outreach and Compliance. Providing effective public
education and outreach to residential and commercial customers is critical for the ongoing and
future success of the City’s solid waste and recycling programs. The City currently provides a
robust education and outreach program for residents, complemented by cart tagging and
contamination tracking. This strategy evaluates and recommends enhancements to these programs
to address system challenges and improve program performance (i.e., contamination rate,
participation rate, diversion rate), which can drive increased sustainability.
The Strategy to Implement Innovative Organics Management. Organic materials comprise a
significant amount of the total waste stream generated from the residential, commercial, and
industrial sectors and present an opportunity for diversion. Effective organics management can
reduce the amount of waste that is sent to the landfill, generate renewable energy through
anaerobic digestion, create a valuable compost product, and return nutrients to the soil. This
strategy evaluates and recommends tactics to implement innovative organics management
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-5 Burns & McDonnell
focused on two-pronged approach: to increase the diversion of food waste recovery from
commercial generators where clean food waste materials can be collected and processed
efficiently, and to increase awareness and technical assistance City-wide of reduction and
diversion strategies.
The Strategy to Efficiently Use Landfill Capacity. Landfills will play a necessary role in
materials management through the 2040 planning horizon, even with increasing rates of
recycling, waste reduction efforts, and technological advancement. Regional growth and facility
closures will increase landfill demand and value in the future. The City owns and operates the
Denton Landfill, placing it in a position of self-determination regarding refuse disposal and
capacity planning. This strategy evaluates and recommends tactics to efficiently use landfill
capacity that are focused on efforts to balance the need to preserve airspace while meeting short-
and long-term revenue needs.
The Strategy to Plan for Future Growth and Infrastructure. While the local and regional
infrastructure and capacity is currently sufficient to meet the City’s current needs, the City is
experiencing rapid growth, including concentrated growth in the Hunter Ranch and Cole Ranch
Mater Planned Communities (MPCs). This growth will result in increased waste generation
(residential, commercial, and construction and demolition (C&D) materials) as well as potential
operational challenges when continuing to provide cost-effective and efficient waste and
recycling services. This strategy evaluates and recommends tactics to plan for future growth that
are focused on actions the City can take to continue to safely and efficiently manage the materials
generated in the City and to increase diversion as more materials are generated from increasing
population and associated construction and development.
The Strategy to Optimize Recycling Processing. Many recycling facilities, including the Pratt
MRF which processes the City’s single-stream recyclables, receive materials that are not suitable
for processing at the facility or could be managed through alternatives. The City has programs to
divert many of these challenging materials, however there are opportunities to expand diversion
and increase processing efficiency. This strategy evaluates and recommends tactics to optimize
recycling processing that are focused on considerations to improve MRF processing by diverting
challenging or hard-to-recycle materials before they reach the MRF as well as securing sufficient
recycling processing capabilities.
The Strategy to Support New Markets and Leverage Partnerships. Many valuable materials
(e.g., furniture) can be diverted for reuse prior to entering the solid waste management system.
Increasing the diversion of these materials through reuse can address community and recycling
market needs while increasing diversion. This strategy evaluates and recommends tactics to
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-6 Burns & McDonnell
support new markets and leverage partnerships that are focused on actions the City can take to
increase the supply and demand of reusable items and recycled products through partnerships and
other methods outside of the City’s solid waste program.
Key Findings and Priority Next Steps
The following summarizes the most salient key findings and recommendations related to each of the six
strategies in the CSWMS. The implementation and funding plan (see Section 12.0) prioritizes
recommendations and next steps developed as part of the CSWMS.
The City’s current education and outreach program is robust, however program metrics
can be enhanced to provide a clear and measurable definition of success. For the City,
material capture rate, recycling contamination rate, and waste reduction rate can serve as valuable
metrics to understand how well education and outreach program content impacts residents and
others in the City to participate in recycling programs (through material capture rate), recycle the
right materials (through contamination rate), and engage in other sustainable behavior for waste
reduction (through waste reduction rate). With these metrics, it is essential to have quality data to
benchmark and track the progress of education, outreach and compliance efforts and goals. The
City currently tracks data related to its waste and recycling programs from a variety sources,
including the quantities of material collected through its curbside programs (primarily residential
data), information on collection activity from on-board technology, and estimates of recycling
contamination from the Pratt recycling facility. The City has also participated in NCTCOG waste
composition studies, which provide insight into the composition of its waste and recycling
streams and resulting capture rates of recyclable materials.
The City’s current cart audit and “oops” tag cart-tagging programs have been successful in
decreasing contamination in highly contaminated routes. Incorporating compliance incentives
into the existing program can help further deter contamination and improve recycling behavior.
The City has the opportunity, infrastructure, and financial support to pilot a commercial
organics composting or co-digestion program at Pecan Creek Wastewater Treatment Plant
(WWTP). The commercial sector presents the greatest food waste diversion potential for the
City with over 30,000 tons of commercial food waste generated in the City and subsequently
disposed in landfill in 2020. The City has existing anaerobic digestion infrastructure and biogas
upgrading experience, providing the potential to convert clean source-separated commercial
organics to energy in partnership with the Pecan Creek WWTP. Recent support through a North
Central Texas Council of Governments (NCTCOG) grant provides financial support for the City
to pilot this new organics management approach.
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-7 Burns & McDonnell
The recent landfill expansion provides long term capacity for the City. If diversion rates do
not improve, the City currently has sufficient capacity through at least 2057 and potentially
through 2077. The City’s landfill space will only increase in value over time as the area continues
to grow and more landfills reach capacity. As a City-owned and operated landfill, the City
maintains control over its disposal needs and should consider the Denton Landfill a valuable
resource. The City should anticipate increased interest from third-party haulers and private waste
management companies to operate or acquire the facility; however, the City should seek to
maintain its status as owner-operator.
Landfill pricing and contract structures could be leveraged to support the City’s costs of
services while also encouraging diversion in surrounding communities. The Denton Landfill
is an important disposal resource not just for the City but also for north and west areas of the
region where disposal alternatives and diversion programs are limited (e.g., Wise County). While
the City provides essential sanitary service to these communities through the safe disposal of non-
recyclable wastes, there is an opportunity to divert material from these communities as well. The
City can leverage its pricing structures to incentivize third-party communities to divert by
contracting directly with communities (rather than their contracted hauler) and implementing a
discount structure that provides an increase discount rate based on documented diversion
tonnages. This approach could be used to attract increased volumes of recycling material to the
Pratt MRF (or future expanded regional MRF) as well as the potential regionalization of other
City programs for improved economies of scale to help facilitate recycling of City-generated
materials.
There is opportunity and need for decreased contamination, increased recycling
participation and diversion, and standardized services in the multifamily and commercial
sectors. As residential and commercial activity increases in the City as a result of growth, it is
important for the City to develop sector-specific plans to address key challenges or needs,
including to: (1) address contamination through education and outreach and additional
ordinance(s) such as contamination limits and reclassification of highly contaminated commercial
or multifamily recycling loads and refuse; (2) develop a multifamily recycling implementation
plan, including expanded opportunities (e.g., drop-off programs) and ordinances (as desired) to
expand multifamily recycling access and requirement as warranted by program performance; and
(3) develop a commercial recycling implementation plan, including expanded opportunities (e.g.,
partnerships) and ordinances (as desired) to expand commercial recycling access and requirement
as warranted by program performance.
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-8 Burns & McDonnell
As residential and commercial activity increases in the City as a result of growth, it is
important for the City address the opportunities and needs for construction & demolition
(C&D) material management. While C&D recycling infrastructure exists in the area, many
C&D materials can be reused rather than recycled. There is opportunity for the City to establish a
City-operated C&D Reuse Warehouse at Building 651, to provide an opportunity for the
diversion of re-use quality C&D materials. Additionally, the City can develop a C&D recycling
implementation plan, and desired ordinance(s) to incentivize C&D recycling through existing
regional capacity and reuse through the City-operated facility.
The City has programs that divert many challenging materials in the recycling stream, but
there are opportunities to expand recovery. The City’s home chemical collection (HCC),
curbside yard waste, and bulky collection programs provide for the proper collection of materials
that would become contamination at the Pratt MRF. The City should leverage its education and
outreach program to further increase the awareness of how to divert these materials, including the
use of existing resources (e.g., NCTCOG “Know What to Throw” and NRDC food waste source
reduction). New programs or services that the City should consider in the near- or long-term to
increase diversion of challenging materials include recycling facility upgrades for improved
processing capabilities, drop-off recycling for expanded polystyrene (EPS, “Styrofoam”)
partnerships with other entities for safe sharps disposal and reusable furniture/household items,
and hosting paper shredding events to capture this material for recycling.
Explore recycling processing options that include a regional recycling approach. Given the
limited recycling processing capacity in Denton and Collin Counties and anticipated growth in
the region, it is important for the City to plan appropriately for any efforts to increase recycling to
identify options for new capacity and/or facilities. Options for developing additional recycling
processing capacity include exploring expanded recycling at the Pratt recycling facility and
alternatives such as accepting responsibility for the processing of recycling materials either solely
or through partnerships with other cities in the area (e.g., McKinney, Plano) once the current
recycling processing agreement with Pratt ends in 2028.
There are coordination opportunities for the SWR Department with other City
departments to increase diversion through sustainability initiatives, programs, and services.
As the service provider, SWR may be department most associated with waste and recycling;
however, other departments can plan important roles in enacting initiatives and policies to
advance sustainable materials management. These include collaboration with:
o Parks & Recreation to address opportunities to increase public space recycling
o Pecan Creek WWTP to advance a long-term strategy related to organics diversion
Comprehensive Solid Waste Management Strategy Executive Summary
City of Denton, Texas ES-9 Burns & McDonnell
o Procurement & Compliance to develop environmental procurement programs to support
recycling markets
There are community needs that could be met through coordination with local entities to
recover specific materials. By directly partnering or supporting and facilitating programs
established by local universities or non-profits, the City can help divert materials that would
otherwise be collected and landfilled through City-provided disposal service. Potential examples
include reuse and donation drop-off at college move out to support shelters and homelessness
services, including the Loop 288 Building/Our Daily Bread initiative; and food waste diversion
efforts to support food banks and soup kitchens.
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-1 Burns & McDonnell
1.0 OVERVIEW, PRIORITIES AND OBJECTIVES
1.1 Purpose
Developing a Comprehensive Solid Waste Management Strategy (CSWMS) is a critical step in
purposefully shaping the future of the City of Denton’s (City) solid waste/material management system as
economic and population growth continue and market factors evolve. Planning and implementing an
integrated solid waste management strategy is a complex and challenging endeavor encompassing a host
of issues: technological, institutional, legal, social, economic, and environmental. As cities throughout
the United States pursue solutions to their solid waste management challenges, it is apparent that no
single method, technology, or program offers a complete solution; rather, a combination of methods is
required to provide for appropriate and cost-effective management of all material types, while continuing
to build an integrated management system. The purpose of the CSWMS is to provide a framework to
guide the City’s future materials management system and to develop infrastructure, programs, and
policies necessary to manage materials in alignment with the Guiding Principles of the CSWMS (Section
1.2).
1.2 Guiding Principles
The Solid Waste and Recycling Department established the Guiding Principles to direct the development
of specific strategies presented throughout the CSWMS (refer to Section 1.5). The four Guiding
Principles are:
5. Develop innovative municipal solid waste (MSW) management methods consistent with the
waste management hierarchy to achieve as much MSW reduction, reuse, and diversion
from landfill disposal as sustainably feasible [based on economic, regulatory, environmental
and social constraints]. The materials management hierarchy (see Section 2.3 for further detail)
describes the environmentally preferred methods for managing materials, ranking the various
methods of diversion, with disposal (landfilling or incineration) as the least preferred. The
CSWMS is focused on increasing the effectiveness of traditional recycling and exploring options
for increased organics diversion where these options can be feasibly implemented based on
economic, regulatory, environmental and social constraints. Source reduction is another
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-2 Burns & McDonnell
environmentally-preferred method of diversion, focused on reducing consumption, that the City
may further explore in the long-term in subsequent CSWMS updates.3
6. Provide MSW services that are convenient, environmentally conscious, and cost-effective
for customers and the City. There are many approaches the City could implement in working
toward its goals of increased diversion and sustainable materials management, and all have
inherent costs. The strategies included in the CSWMS are intended to strike a balance between
maintaining a cost-effective management system for both the City and its customers, while taking
meaningful steps toward a sustainable and environmentally responsible future.
7. Balance landfill revenue with capacity preservation and collaborate with third-party
landfill customers to implement efforts consistent with the waste management hierarchy.
The importance of Guiding Principle 1 is emphasized by Guiding Principle 3. With the
recognition that landfill capacity is a finite resource in the region and will become increasingly
valuable for the City in the future, it is important for the City to continuously seek or improve
upon methods of landfill diversion. This CSWMS recognizes that the Denton Landfill is an
important disposal resource not just for the City but also for north and west areas of the region
where disposal alternatives and diversion programs are limited (e.g., Wise County). While the
City provides essential sanitary service to these communities through the safe disposal of non-
recyclable wastes, there is an opportunity to divert material from these communities as well.
8. Strategically utilize program data and technology for informed decision-making.
Strengthening the City’s mechanisms for consistent data tracking and increasing diversion
activities within the commercial and institutional sector is a key objective of the CSWMS. In the
past, the primary focus has been on the single-family residential sector, resulting in an effective
program. Enhancing the City’s ability to obtain commercial and institutional generation and
recycling data, and integrating key generation, recycling, and contamination data into outreach
and engagement, is an essential step in developing and implementing targeted and effective
strategies for future materials management.
1.3 Project Approach
During the CSWMS planning process, Burns & McDonnell worked with the City of Denton to evaluate
current systems and programs to identify potential strategies and options for key solid waste and resource
3Material bans (i.e., banning materials such as single-use bags from sale within the City) are an example of source reduction
programs that could be enacted by local government; however, such policies currently cannot be enforced due to the Texas
Supreme Court ruling in City of Laredo, Texas v Laredo Merchants Association.
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-3 Burns & McDonnell
recovery issues, as presented in subsequent sections of the CSWMS. The CSWMS was developed to
evaluate current programs and identify key near- and long-term trends influencing recycling and solid
waste management in the City. The CSWMS process included external stakeholder engagement
(including a community Think Tank process described in more detail in Section 1.3.1), City Council
communications, detailed evaluation of strategies, and development of a detailed implementation plan.
Figure 1-1 presents the planning process the City and its consultant, Burns & McDonnell, utilized in
developing the CSWMS.
Figure 1-1: City of Denton CSWMS Development Process
The CSWMS development process engaged select stakeholders within the City’s departments and
included meetings and workshops between the Solid Waste & Recycling Department, Burns &
McDonnell, and other relevant City Departments and programs (e.g., Water Utilities, Sustainable
Denton).
1.3.1 Goals and SWOT Analysis
As part of the CSWMS project approach, City Staff participated in a project kick-off workshop to identify
goals (e.g., increase diversion, be cost-effective) and conduct a SWOT (strengths, weaknesses,
opportunities, and threats) analysis. Findings from the kick-off workshop were used as background
information to guide the CSWMS development, including setting the guiding principles (see Section 1.2).
The full results of the goalsetting and SWOT analysis are provided in Appendix A.
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-4 Burns & McDonnell
1.3.2 Stakeholder Engagement
The stakeholder engagement approach for the CSWMS was comprised of two components, a survey of
Denton residents and other community members (e.g., business owners) and a resident Think Tank group.
The stakeholder engagement process included 883 responses to the community survey, and a series of
three Think Tank workshop meetings. Responses from the survey and visioning results from Think Tank
group provided a data-driven approach to were used to understand the key emergent trends and vision for
the City of Denton, specifically:
There was a strong Think Tank vision for “Change the future now!” indicating a clear direction of
change toward sustainability and the integration of policy and technology to achieve increased
diversion.
The Think Tank and survey responses show community support for near-term action for
recycling and solid waste management.
The community survey responses identified three top trends/needs: recycling education;
population growth and increased waste; and landfill capacity.
The full results of the stakeholder engagement process are presented in the Vision for Denton Think-Tank
Report (Appendix B).
1.4 Key Terms
This section presents definitions of a selection of key terms utilized throughout the CSWMS that are
necessary for a comprehensive understanding of the current MSW management system and strategies that
will be implemented in the future.
Sectors. This section defines the terminology utilized throughout this CSWMS to discuss the five
distinct generation sectors or MSW customer types (as well as other MSW management topics) that the
City engages through its solid waste and recycling systems and programs.
Single-family residential. The single-family residential sector is defined as single-family
households and the materials generated by these households. In Denton, the single-family
residential sector also includes residential properties having four or fewer housing units.
Multifamily residential. The multifamily residential sector is defined as residential properties
having greater than four individual housing units (e.g., apartment complexes, condominiums,
etc.) and the material generated by these households. Multifamily MSW is collected, processed,
and reported in combination with commercial material. Generally, MSW data specific to the
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-5 Burns & McDonnell
multifamily sector is not available. Estimates regarding multifamily generation were developed,
as described in Section 3.3.2.
Commercial and institutional. The commercial and institutional sector refers to commercial
(offices, retail and wholesale establishments, restaurants, etc.) and institutional (schools, libraries,
hospitals, local government, etc.) entities and the material generated by these entities. Distinction
between the commercial and institutional sector and the multifamily sector is made throughout
this CSWMS, where applicable.
Construction and demolition (C&D) material. C&D material is defined as materials that are
generated by construction, demolition, or renovation projects and includes, but is not limited to,
materials such as brick, roofing materials, wood, flooring, drywall, insulation, concrete, and
asphalt. C&D material is not included in the category of MSW as defined below and was
included in this CSWMS as a distinct sector because it is generated by multiple customer types,
including single-family, multifamily, commercial, and the public sector (e.g., municipal, state, or
federal).
Events and public spaces. The events and public spaces sector is defined as materials that are
generated through activities and special events taking place in various public locations throughout
the City, such as parks, sports facilities, pedestrian areas, and various events held by the City each
year.
Material types. This section defines the terminology utilized throughout this CSWMS to discuss the
varying material types that the City manages through its solid waste and recycling systems and programs.
Municipal solid waste (MSW). MSW refers to the entirety of the material stream (refuse and
recycling) that is generated by everyday activities in homes, commercial businesses, institutions,
and public spaces. MSW can be further categorized by material types including refuse,
recyclables, bulky items, organics, and home chemical collection (HCC) and other special wastes,
as defined below. MSW does not include commercial hazardous waste or industrial, agricultural,
or mining wastes.
Refuse. Refuse is the portion of MSW that cannot practically be recycled, reused, or otherwise
diverted from disposal. True refuse has no viable handling methods other than disposal.
However, in most communities, a portion of the material disposed as refuse has the potential to be
recycled or otherwise diverted.
Recyclables. Recyclables includes single-stream recyclables, or programmatic recyclables, which
refers to materials that are typically accepted through municipal curbside recycling programs or at
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-6 Burns & McDonnell
drop-off locations, processed through materials recovery facilities (MRF), and sold as
commodities to markets where the material is then repurposed. These programmatic recyclables
include, but are not limited to, items such as plastic and glass containers, aluminum and steel
cans, cardboard, and other various paper products. Recyclables also includes other materials that
can be recycled, such as textiles, electronics, appliances, and film plastic, which can also be
referred to as hard-to-recycle materials.
Bulky items. Bulky items generated by households or commercial customers that are too large to
be placed inside a customer’s regular collection container. Bulky items include items such as
furniture, mattresses, metal, cardboard, and limited quantities of carpet and fencing.
Organics. Organics include plant or animal-based materials. Organics have the potential to be
diverted from landfill disposal through composting or mulching processes. Within the category
of organics there are many sub-categories of materials including:
o Yard trimmings. Vegetative material generated from property maintenance or
landscaping is categorized as yard trimmings and includes grass clippings, leaves, plants,
small cuttings, brush, and tree limbs.
o Food scraps. Food scraps are materials such as fruit, vegetables, meat and dairy
products. Often, processing of food scraps also includes food-soiled biodegradable items
such as napkins, paper plates, and compostable food containers.
o Biosolids. Solid, semi-solid, or liquid residue generated during the treatment of domestic
sewage in treatment works (sewage sludge that has been treated or processed to meet
Class A, Class AB, or Class B pathogen standards for beneficial use).
o Wood waste. Non-C&D items such as pallets.
o Other. Items such as natural textiles, material pumped from septic tanks (septage), water
treatment plant residuals, fats, oils, and greases (FOG), dead animals, and manure.
Home chemical collection (HCC) and other special wastes. HCC programs include common
household chemicals or other household materials that should not be disposed of in MSW
landfills due to their potential for adverse environmental and human health impacts. They require
special disposal by an entity that is permitted by the Texas Commission on Environmental
Quality (TCEQ). HCC program materials include, but are not limited to, materials such as paints,
fertilizers, pesticides and poisons, pool chemicals, household cleaners, and automotive products.
HCC does not include chemicals or other materials generated by commercial or industrial entities.
Construction & demolition (C&D) debris. C&D debris is defined as solid waste resulting from
the construction, remodeling, repair, and demolition of structures, roads, sidewalks, and utilities.
Material is generated from residential, commercial, and public sector (e.g., municipal, state, or
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-7 Burns & McDonnell
federal) projects. It includes, but is not limited to, materials such as brick, roofing materials,
wood, flooring, drywall, non-asbestos insulation, concrete, and asphalt. Most C&D debris is
disposed in separate C&D permitted landfills. Smaller amounts may be recycled or reused.
Material management. This section provides definitions regarding the total amount of materials
generated within the City and the material disposal or processing streams that comprise total generation
quantities.
Generation. Total material generated is the quantity of material that the City must manage
through its various disposal and recycling programs and services. Generation is the total quantity
of material disposed plus the total quantity of material recycled or otherwise diverted from
disposal.
Diversion. Within this CSWMS, diversion refers to the proportion of generated material that is
collected and diverted from landfill disposal. Diversion methods include single-stream recycling,
organics diversion though composting or mulching, HCC recycling, reuse, and other diversion
methods. Currently, yard trimmings accounts for most of the City’s diverted material. For
Denton, single-family residential diversion quantities of single-stream, HCC, and yard trimmings
materials through City services (curbside and drop-off collection) are tracked and the City
currently has a residential diversion rate of approximately 23 percent. Commercial and C&D
diversion quantities for the City are not available. Some cities also include reuse materials in
landfill diversion rates; however, reuse materials are not currently included in the City’s diversion
rates discussed in this CSWMS because reuse material quantities are small and difficult to
quantify. There are various methods for measuring diversion (as discussed in the “Material
Waste Diversion and Alternative Metrics” portion of Section 2.3).
Disposal. Disposal refers to all remaining material placed in landfills that has not been recycled,
composted, or otherwise diverted. Disposed materials include some quantities of materials that
were not recovered prior to disposal but could potentially be recovered through improvement of
recycling and other diversion programs, infrastructure, or education. City and regional waste
characterization and potential for increased recovery of materials from materials currently
disposed in landfills is further addressed in Section 3.4 and Appendix C.
1.5 Guide to the CSWMS Sections
Sections 2.0 through 4.0 of the CSWMS each present discussion and analysis of current trends,
infrastructure and programs relevant for identifying and defining the six strategies of the City’s CSWMS,
which were developed to align with the Guiding Principles. Specifically, these six strategies are to:
Comprehensive Solid Waste Management StrategyRevision Rev. No. or Ltr Overview, Priorities and Objectives
City of Denton, Texas 1-8 Burns & McDonnell
Enhance Education, Outreach, and Compliance
Implement Innovative Organics Management
Efficiently Use Landfill Capacity
Plan for Future Growth and Infrastructure
Optimize Recycling Processing
Support New Markets and Leverage Partnerships
Sections 5.0 through 10.0 of the CSWMS each present a detailed discussion of one strategy, including
evaluation of the City’s current program or approach to the strategy, benchmarking or case studies
considered in the development of the CSWMS, and the identification of key findings and
recommendations for the City to implement each strategy.
Section 11.0 presents the tactics and recommendations for the City to implement each of the six
strategies, as well as an evaluation of the financial and environmental impacts. Section 12.0 is a complete,
high-level implementation plan, compiling the strategies presented and evaluated in Sections 5.0 through
10.0. The implementation plan presents the following information for each of the six strategies of the
CSWMS:
Strategy recommendations and tactics
Priority
Increased diversion potential
Financial impact
Potential funding sources
Implementation timing
Responsible party
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
2.0 SOLID WASTE AND RECYCLING TRENDS, POLICIES AND REGULATORY
REIVEW
This section provides a broad perspective of the historic and current state of the MSW management
environment in which the City is developing this CSWMP. It provides a review of relevant existing
planning studies, a summary of relevant laws and regulations, and information on key trends in MSW
management. Discussion for each key trend also includes information on the City’s activities and progress
related to the trend, identification of any challenges or threats to implementing actions related to the trend,
and recommendations for how the City could address the trend moving forward.
2.1 Review of Relevant Planning Studies
Understanding prior MSW and community planning projects completed at the local, regional, and state
levels is a critical step in effectively and efficiently developing the CSWMS for the City. To inform
development of this strategy, Burns & McDonnell reviewed the following studies and plans presented
chronologically.
• Simply Sustainable: A Framework for Denton’s Future4 This plan was adopted in June 2020,
and provides a framework, goals, and sustainability metrics for many of the City’s activities
including Material Resource Management. Established goals are to reduce solid waste generation
and divert material away from landfill; and leverage the City’s purchasing power through
sustainable procurement.
• City of Denton Plan 20305 This plan was adopted in 2015 and is a comprehensive plan to
address the anticipated growth in the City and the DFW Metroplex. The plan examines current
and potential land use and growth strategies, and recommends goals, policies, and actions to
guide the City’s growth in areas such as mobility, urban design, community health, and
infrastructure. Recommendations related to solid waste and recycling focus on three areas: waste
minimization and reuse, efficient solid waste and recycling collections, and environmental
protection and disposal capabilities.
• North Central Texas Council of Governments (NCTCOG) Regional Solid Waste
Management Plan 2015 - 2040. This plan was approved in 2015 and covers a 25-year planning
4 City of Denton 2020. “Simply Sustainable: A Framework for Denton’s Future” Available online:
https://www.cityofdenton.com/CoD/media/City-of-
Denton/Residents/Make%20a%20Difference/Sustainable%20Denton/Exhibit-2-Simply-Sustainable-Framework-
Final-Copy_1.pdf
5 City of Denton 2015. “Denton Plan 2030: Our path to the future” Available online:
https://www.cityofdenton.com/CoD/media/City-of-Denton/Government/Denton_Plan_2030.pdf
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
period for the NCTCOG, the 16-county regional planning area in the North Central Texas region.
The primary purposes of this plan are to inventory closed landfills, quantify regional landfill
capacity in relation to projected future growth in waste generation, identify the region’s most
prominent needs and problems, and outline activities and priorities to be initiated throughout the
planning period.6 NCTCOG is currently in the process of updating this regional planning effort.
• City of Denton Solid Waste Comprehensive Plan.
• TCEQ Study on the Economic Impacts of Recycling. This 2017 study, completed by the
Texas Commission on Environmental Quality (TCEQ) as outlined in House Bill 2763,
documented the quantities of MSW recycled and landfilled in Texas. The report provides a state-
level understanding of 2015 recycling and landfill disposal quantities and composition and
provides key economic and market trend data.7
• TCEQ Recycling Market Development Plan. The TCEQ recently published the Recycling
Market Development Plan (RMDP) to promote the use of recyclable materials as feedstock in
processing and manufacturing. Similar to the Study on the Economic Impacts of Recycling, the
RMDP will provide state-level estimates of recycling and landfill disposal quantities statewide
and estimates the resulting economic benefits of recycling. The RMDP will also provide a plan to
increase recycling, developed based on the key barriers and opportunities identified across the
State. Plan development began in February 2020, and a final report was published in September
2021.8
2.2 Regulatory and Policy Review
Prior regulations and policies related to material management, as well as trends and the current regulatory
climate, have largely shaped the state of material management and defined the environment in which this
CSWMS was developed. This section provides a summary of federal and state regulations, policies, and
trends.
2.2.1 Role of the Federal Government in Regulating Solid Waste
The federal government sets basic requirements for regulations that protect public health and the
environment, which helps to provide consistency among states. The United States Environmental
6 North Central Texas Council of Governments (NCTCOG). 2015. “Planning for Sustainable Materials Management
in North Central Texas 2015-2040.” Available online: https://www.nctcog.org/envir/materials-
management/materials-management-plan
7 Texas Commission on Environmental Quality (TCEQ). July 2017. “Study on the Economic Impacts of Recycling.”
Available online: https://www.tceq.texas.gov/p2/recycle/study-on-the-economic-impacts-of-recycling.
8 TCEQ. August 2021. “Recycling Market Development Plan.” Available online:
https://www.tceq.texas.gov/assets/public/assistance/P2Recycle/Recyclable-
Materials/2021%20Recycling%20Market%20Development%20Plan.pdf
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Protection Agency (U.S. EPA) is responsible for hazardous and non-hazardous solid waste management
through the Office for Solid Waste and Emergency Response. There are three major pieces federal
legislation pertaining to solid waste management:9
1. Prior to 1965, solid waste management was entirely dependent on the judgement and decisions of
individuals or local departments of health and sanitation. In 1965, Congress made its first attempt
to define the scope of the nation’s waste disposal problems by enacting the Federal Solid Waste
Disposal Act (SWDA), which financed statewide surveys of landfills and illegal dumps.
2. The first significant federal legislation governing the disposal of non-hazardous and hazardous
waste was passed in 1976 under the Resource Conservation and Recovery Act (RCRA). RCRA
established landfill construction, management, and closure guidelines. It also regulates hazardous
waste management facilities that treat, store, or dispose of hazardous waste. RCRA has been
amended three times since its inception:10
o 1984 Hazardous and Solid Waste Amendments, requiring the phasing out of land
disposal of hazardous wastes and granting the U. S. EPA regulatory authority over
landfills (Subtitle C Hazardous Waste and Subtitle D Non-hazardous waste)
o 1992 Federal Facility Compliance Act, strengthening enforcement of RCRA at federal
facilities
o 1996 Land Disposal Program Flexibility Act, providing regulatory flexibility for land
disposal of certain wastes
3. The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) of
1980, known as Superfund, was enacted by Congress to address abandoned hazardous waste sites
in the United States. CERCLA was subsequently amended by the Superfund Amendments and
Reauthorization Act of 1986 (SARA) to stress the importance of permanent remedies, provide for
increased state involvement, and increase federal funding.11 The Office of Air and Radiation
regulates solid waste-related air emissions, enforcing the Clean Air Act of 1976 (CAA) and its
subsequent amendments.12
In addition to federal legislation, there are national policies in place and under development to guide
lawmakers to develop and implement future legislation. On November 17, 2020 the U.S. EPA established
9 Texas Center for Policy Studies. 1995. “Texas Environmental Almanac.” Available online:
http://www.texascenter.org/almanac/
10 U.S. Environmental Protection Agency (U.S. EPA). 2017. “History of the Resource Conservation and Recovery
Act (RCRA).” Available online: https://www.epa.gov/rcra/history-resource-conservation-and-recovery-act-rcra
11 U.S. EPA. 2017. “Superfund: CERCLA Overview.” Available online: https://www.epa.gov/superfund/superfund-
cercla-overview
12 U.S. EPA. 2020. “Summary of the Clean Air Act 42 U.S.C. §7401 et seq. (1970).” Available online:
https://www.epa.gov/laws-regulations/summary-clean-air-act
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
the National Recycling Goal of 50 percent by 2030 to provide the benchmarks needed to evaluate the
success of the collective efforts to significantly improve the nation’s recycling system. The metrics
identified in the National Recycling Goal are based on the broad objectives of the draft National
Recycling Strategy and are divided into four categories: assessing recycling performance, reducing
contamination, increasing processing efficiency and strengthening recycled material markets. The
National Recycling Goal aims to create standardized definitions for the recycling industry to keep pace
with today’s diverse and changing waste system. The following lists the measures that will be used to
track the progress toward the National Recycling Goal.
o Measure 1: Reduce contamination in recycling. This will be calculated by examining the
percentage of contaminants in the recycling stream.
o Measure 2: Make the national recycling processing system more efficient. This will be
measured by tracking the percentage of materials successfully recycled through recycling
facilities compared to the inbound material.
o Measure 3: Strengthen the economic markets for recycled materials. This will be
measured by tracking the average price per ton of recycled material on the secondary
materials commodity market.
The related National Recycling Strategy identifies objectives and actions needed to create a more resilient
and cost-effective recycling system nationwide. The draft National Recycling Strategy was open for
public comment until December 4, 2020 and is expected to be finalized in late 2021. The National
Recycling Strategy will be aligned with and support implementation of the National Recycling Goals.
To address food loss and waste nationwide, the U.S. EPA established a national goal on September 16,
2015 to reduce food loss and waste by 50 percent by 2030. The Food Loss and Waste Reduction Goal
was a joint effort with the U.S. Department of Agriculture to address food insecurity and reduce landfill
methane emissions. The goal aims to reduce the amount of food waste generated and subsequently
managed (e.g., through landfilling, composting, anaerobic digestion, etc.), and was updated in September
2021 to align with the United Nations’ Sustainable Development Goals. Achieving the target 50 percent
reduction is equivalent to reaching a total generation rate of 164 pounds of food waste per person per year
(including food waste recycled through composting or anaerobic digestion).
National organizations other than the federal government also play a role in national solid waste policies
and trends. The Recycling Partnership has been working to develop an initiative called the Circular
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Economy Accelerator Policy13 to support the collective U.S. residential recycling collection system to
develop a collaborative public-private policy solution that includes:
o A packaging and printed paper fee paid by private-sector brands to support residential
recycling infrastructure and education.
o A disposal surcharge on waste generators to help defray recycling operational costs for
communities.
Packaging and printed paper fees would be based on a needs assessment and data-driven plan. Fees would
be calculated to address the level of investments that are needed to provide recycling access to residents
on par with disposal, provide education and outreach to residents to reduce rates of inbound
contamination, and enhance MRF capabilities to efficiently sort and process collected materials. A third-
party Non-Governmental Organization (NGO) would set and collect fees based on the established needs
and disburse funds in order to meet statutory goals.
Combined, this dual-policy solution is intended to bring key stakeholders together to create funding
mechanisms that could address the infrastructure, education and operational challenges facing the
recycling collection system.
2.2.2 Role of the State Government in Regulating Solid Waste
Texas has a long-standing solid waste material management regulatory program, initiated with the Texas
Solid Waste Disposal Act and passed by the state legislature in 1969. This Act required the Texas Health
Department to adopt regulations pertaining to the design, construction, and operation of landfills and
other processing facilities. Today, the TCEQ holds jurisdiction over solid waste material management.
Several other major pieces of state legislation from the state Senate and House of Representatives have
been enacted:
1. The 1983 Comprehensive Municipal Solid Waste Management, Resource Recovery, and
Conservation Act, which established the Municipal Solid Waste Management and Resource
Recovery Advisory Council, prescribed criteria and procedures for regional planning agencies
and local governments that wanted to develop solid waste management plans.
2. The 1987 House Bill 2051 established a preferred hierarchy via state policy for the management
of hazardous waste, municipal waste, and municipal sludge.
13 For more information on the Accelerator Policy see the report “Accelerating Recycling: Policy to Unlock Supply
for the Circular Economy” here: https://recyclingpartnership.org/accelerator-policy/
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
3. The 1989 Senate Bill 1519 established a solid waste disposal fee program to fund the state’s
MSW regulatory programs. It required the state’s regional planning agencies (Councils of
Governments, COGs) to develop regional solid waste management plans and to provide grand
funding to support development of local plans.
4. The 1991 Omnibus Recycling Act (Senate Bill 1340), set a statewide recycling goal of 40 percent
of its MSW by January 1, 1994 and directed several state agencies to develop a joint market study
and strategies to stimulate markets for recycled goods.
5. The 1993 Senate Bill 1051 expanded state recycling programs and amended the state’s 40 percent
recycling goal. The goal became a 40 percent waste reduction goal, aimed at reducing the total
amount of material disposed of in the state through recycling as well as source reduction.
6. The 1993 House Bill 2537 addressed the risks associated with methane gas release from closed
landfills by establishing a process for the TCEQ to review proposals and issue permits to build
atop closed MSW landfills.14
7. The 2007 Texas Computer Equipment Recycling Law required manufacturers to establish and
implement a recovery plan for collection, recycling, and reuse of computer products.15
8. The 2013 House Bill 7 reduced the disposal fees that landfills are required to pay to TCEQ from
$1.25 per ton to $0.94 per ton and reduced the percentage allocated to Councils of Governments
(COGs) to 33.3 percent.
9. The 2015 House Bill 2736 required the TCEQ to conduct a study to quantify the amount of
materials being recycled in the state, assess the economic impacts of recycling, and identify ways
to develop new markets to increase recycling. The TCEQ completed Study on the Economic
Impacts of Recycling in 2017.
10. The 2019 House Bill 61 was the “Slow Down to Get Around” legislation that established a
misdemeanor violation for vehicles that do not adhere to the Transportation Code’s requirements
of slowing and moving 2 lanes away from a solid waste collection vehicle.
11. The 2019 Senate Bill 649 required the TCEQ to produce a plan to stimulate the use of recyclable
material as feedstock in manufacturing. The bill also requires the TCEQ to develop an education
program outlining all the ways that recycling provides economic benefits to the state.
12. The 2019 House Bill 1435 authorized the TCEQ to inspect the facility or site before a permit for a
proposed MSW management facility is issued, amended, extended, or renewed.
14 Texas Center for Policy Studies. 1995. “Texas Environmental Almanac.” Available online:
http://www.texascenter.org/almanac/
15 Texas Commission on Environmental Quality. “Guidance for the Texas Recycles Computers Program” Available
online: https://www.tceq.texas.gov/p2/recycle/electronics/computer-recycling.html
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
13. The 2019 House Bill 1953 prohibited TCEQ from treating post-use polymers or recoverable
feedstocks as solid waste if the substances are converted (by pyrolysis or gasification) into other
valuable products.
The state procurement office requires that state agencies give preference to specific types of products
known as “first choice purchasing options.” These preferred products have a 10 percent price preferential
(meaning they should be preferred even if they cost up to 10 percent more than products that do not
contain recycled content) and must suit the needs of the purchasing agency. Preferred products include:
Re-refined oils and lubricants (to be 25 percent recycled content, if quality similar)
Certain paper products, including paper towels, toilet paper, toilet seat covers, printing, computer
and copier paper, and business envelopes (a state agency is to procure the highest recycled
content that meets their needs and is offered by the Comptroller)
Certain plastic products including trash bags, binders, and recycling containers
Steel products
Additionally, the state comptroller may give priority to Rubberized Asphalt Paving (RAP) material made
from scrap tires by a facility in this state if the cost, as determined by life-cycle cost-benefit analysis, does
not exceed the bid cost of alternative paving materials by more than 15 percent. (Texas Government Code
§2155.443).
In addition to state legislation, the Governmental Entity Recycling Program became effective July 2, 2020
and requires local government entities in Texas to create and maintain a recycling program for their
operations, as well as create a preference in purchasing for products made of recycled materials when the
cost difference is less than 10 percent.
o As part of the Governmental Entity Recycling Program, entities must give preference to products
made with recycled materials, so long as the products meet applicable specifications as to quantity and
quality and the average price of the product is not more than 10 percent greater than the price of
comparable non-recycled products. The TCEQ rules require municipalities to:
Separate and collect all recyclable materials
Provide procedures for collecting and storing recyclable material and making contractual or other
arrangements with buyers of recyclable materials
Evaluate the amount of recyclable material recycled and modify the recycling program as
necessary to ensure that all recyclable materials are effectively and practicably recycled
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Establish educational and incentive programs to encourage maximum employee participation
To establish a Governmental Entity Recycling Program, municipalities should review purchasing
procedures, prioritize purchasing products that are recyclable or contain recycled content, encourage the
community buy recycled, and leverage the Texas Smart Buy Membership program (State of Texas
Cooperative Purchasing program).
2.2.3 Recent State Legislative Trends
The Texas Legislature meets on a biennium, or every other year. When the Texas Legislature is in
session, a variety of Senate and House bill proposals relating to solid waste material management are
introduced. During the recent 2021 legislative sessions, the Texas Legislature passed the following bills
that could have an impact on the solid waste industry:
1. House Bill 1322 requires agencies such as TCEQ to provide plain-language summaries of any
proposed rules.
2. House Bull 1869 amends the definition debt in the Tax Code to include debt for “designated
infrastructure” including landfills.
3. House Bill 1118 increases cybersecurity requirements for state and local entities, including
compliance with cybersecurity training.
4. House Bill 2708 provides some municipalities access to certain hazardous waste remediation fees
for reimbursement related to environmental cleanup at used battery recycling facilities.
5. House Bill 3516 requires TCEQ to adopt rules for the treatment and beneficial use of oil and gas
waste, including permitting standards for commercial recycling.
6. House Bill 4110 increases recordkeeping requirements and documentation needed when a person
attempts to sell a catalytic converter to a metal recycling facility.
7. Senate Bill 211 creates a 30-day deadline to file a petition on a TCEQ ruling, such as a permit
issuance or other decision under the Solid Waste Disposal Act.
8. Senate Bill 1818 defines liability and reasonable care criteria for scrap metal recycling
transactions with an end user/manufacturing facility.
Throughout the recent 2021 session and subsequent special sessions, additional topics of interest to state
legislators based on proposed bills include16:
16 North Central Texas Council of Governments. 2021. “87th Session Legislative Matrix.” Available online:
https://nctcog.org/nctcg/media/Environment-and-Development/Documents/Materials%20Management/87th-
Legislative-Matrix_Solid-Waste.pdf
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Regulations related to restricting local government ability to enact prohibitions on the sale or use
of a container or package
Regulations that for any product listed as recycled, remanufactured, environmentally sensitive be
certified as accurate
Regulations relating to municipal solid waste management services that cap the fee of gross
receipts of a collection service provider to two percent17
Regulations relating to the authority of certain municipal employees to request the removal and
storage of certain abandoned or illegal parked or operated vehicles
Creation of an eight-member council that advises state agencies and local governments on
environmental justice issues (15-member review board advises the council) and the creation of an
Office of Environmental Justice within the TCEQ
Development of the Texas Clean and Healthy program, a rebate system for recyclable materials
with verified end markets and direct economic relief18
Amendment of the water code to restrict direct discharge or waste or pollutants into a classified
stream segments that has had low phosphorus level at or below 0.06 mg/L in 90% or more of
water quality samples for 10 years
Regulation to allow a county to regulate solid waste services and ability to establish a mandatory
program to collect a fee for solid waste services through the county tax assessor-collector’s office
Stricter regulations for locations of new landfills or the horizontal expansion of existing landfills
in environmentally sensitive areas, such as over sole source aquifers or within special flood
hazard areas
Regulation related to the discharge of preproduction plastic, including prompt and
environmentally responsible containment and cleanup, additional stormwater permit
requirements, monitoring and implementation of best management practices
2.2.4 Role of the City of Denton in Regulating Solid Waste
Chapter 24 of the City of Denton Ordinances relate to solid waste management and defines the City as
“the exclusive provider of municipal solid waste collection and disposal services for all premises within
the city” (Ord. No. 2005-256 §24-4) for residential, multi-family, and industrial, commercial and
17 North Central Texas Council of Governments. 2021. “House Bill 753 One-Pager.” Available online:
https://www.nctcog.org/nctcg/media/Environment-and-Development/Committee%20Documents/RCC/FY2021/HB-
753-One-Pager.pdf
18 North Central Texas Council of Governments. 2021. “Texas Clean and Healthy Initiative.” Available online:
https://www.nctcog.org/nctcg/media/Environment-and-
Development/Committee%20Documents/RCC/FY2021/Texas-Clean-and-Healthy-Initiative_Summary.pdf?ext=.pdf
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
institutional (ICI) generators. The City is not the exclusive provider of special waste and recycling
services, and Chapter 24 also outlines the annual permit requirements for recyclables and special waste
haulers. City ordinance also includes provision for the City to establish and amend tipping fees at the
City’s landfill.
2.3 Solid Waste Management Industry Trends
This section provides an overview of key MSW management industry trends, including an overview of
efforts occurring in other communities to reduce waste disposal. Tables throughout the trends overview
provide a summary of the City’s current progress and recommended next steps in each area.
2.3.1 Landfill Waste Reduction, Diversion and Zero Waste Philosophies
Current landfill waste reduction, diversion, and zero waste philosophies center around the following
concepts.
Sustainable Materials Management (SMM). SMM is a systematic approach to using and reusing
materials more productively over their entire life cycles.19 SMM encourages changes in how
communities think about the use of natural resources and environmental protection and emphasizes the
consideration of a product’s life from manufacturing to disposal and the need to make sustainable choices
throughout that life cycle. It has become a trend for the material management industry to apply the broad
view of SMM to better plan for their community’s economic and environmental future.
Waste management hierarchy. The waste
management hierarchy, developed by the U.S.
EPA, has been adopted by many communities as
a guide to managing MSW. This hierarchy is
used as a tool in implementing an SMM approach
to waste management. It was developed in
recognition that no single waste management
approach is suitable for managing all materials
and all waste streams in all circumstances. The
hierarchy ranks various management strategies
19 U.S. Environmental Protection Agency (U.S. EPA). 2017. “Sustainable Materials Management Basics.”
Available online: https://www.epa.gov/smm/sustainable-materials-management-basics
Figure 2-1: U.S. EPA’s Waste Management Hierarchy
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
from most to least environmentally preferred. It places emphasis on reducing, reusing, and recycling as
key to SMM.20
Circular Economy. Like an SMM approach to
planning for a community’s future, the concept of a
circular economy considers environmentally and
economically sustainable decision-making
throughout a material’s life cycle. It offers a shift
from the traditional linear manufacture-use-dispose
concept of materials to a circular economy model
that keeps resources in use for as long as possible,
maximizes life and extracted value, and emphasizes
that used materials are recovered and regenerated
for other uses. This economic approach allows the
cycle to begin again while minimizing material
disposal.
Zero Waste. Zero waste is a philosophy that encourages the redesign of resource life cycles so that all
products are reused. Zero waste is not a static, defined benchmark of eliminating landfill disposal of
waste, but is rather a vision or philosophy around which communities and society should develop and
adapt their materials management systems and culture. A number of industry organizations, states, and
cities have begun setting zero waste goals. While diversion rate is a common metric used to evaluate zero
waste progress, 100 percent diversion is not the ultimate goal of zero waste principles. Rather, the focus
is on continuous improvement and progressively working toward maximizing use of resources, and
minimizing adverse environmental impacts and material disposal.
A comparison of the accepted municipal and industry definitions of zero waste shows that there are a
number of prominent or key concepts across zero waste philosophies:
Zero Waste as a guiding vision, philosophy, or set of principles (rather than a numeric goal); Zero
Waste as striving for continuous improvement, not an absolute term or goal
System and material life cycle approach
Minimize waste generation and promote waste prevention
20 U.S. Environmental Protection Agency. 2017. “Sustainable Materials Management: Non-Hazardous Materials
and Waste Management Hierarchy.” Available online: https://www.epa.gov/smm/sustainable-materials-
management-non-hazardous-materials-and-waste-management-hierarchy
Figure 2-2: Circular Economy
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Circular economy
Supporting economic value, stimulation, and job creation
Minimization of environmental and health impacts (e.g., greenhouse gas emissions, landfill
burial, water pollution)
View used materials as resources, not waste and maximize recovery of materials
Extended producer responsibility (EPR)
Adherence to the materials management hierarchy
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Table 2-1: Status Summary for Landfill Waste Reduction, Diversion, and Zero Waste Philosophies
Status and
Evaluation
The City has not defined a SMM or zero waste philosophy or set a recycling
goal. Defining a SMM or zero waste philosophy can be an effective tool to
incorporate waste reduction, reuse and recycling into program metrics and
goals, as well as raise awareness of the importance of SMM principles.
However, it is also important to recognize that several Texas cities, as
discussed in Section 2.3.2, have set high zero waste goals and are well below
their recycling rate goals. For cities that set these types of goals, it is important
to distinguish between aspirational (e.g., an 80 percent recycling rate) and
rational (e.g., increasing the recycling rate by 10 percent over the next five
years) goals.
Future The Denton Plan 2030 and Simply Sustainable: A Framework for Denton’s
Future reports include recommendations to incorporate actions relevant to
waste reduction and minimization into the City’s sustainability practices.
Key
Accomplishments
The City’s recycling and composting programs divert material from residential,
commercial, and other sources for beneficial uses. The City’s ReUse Store
provides waste reduction opportunities to residents, which aligns with waste
reduction and zero waste principals of reuse and waste reduction. In addition to
the City programs, the City partners for diversion with community non-profits.
The Denton community also includes many reuse-focused entities aligning with
zero waste principles (e.g., Thistle Creative Reuse, thrift stores). Reuse is
discussed in more detail in Section 2.3.4.
Impediments
One key challenge in implementing a zero waste philosophy is collecting the
data necessary for tracking progress and continuous improvement. As the sole
provider of municipal solid waste disposal services, the City currently collects
data to measure disposal trends. Diversion data can be harder to obtain,
especially from multi-family and ICI sources as this material is typically
collected by private haulers and may be processed at various recycling and
composting facilities in a region.
Recommendations
Recommendations for the City to address landfill waste reduction, diversion,
and zero waste philosophy trends are to:
o Establish a waste reduction or zero waste statement and/or goal to
highlight the importance of waste reduction and reuse (in addition
to diversion);
o Continue to incorporate the hierarchy and SMM into planning
efforts.
2.3.2 Material Waste Diversion and Alternative Metrics
Zero waste or high diversion goals by other Texas cities. Over the last 10 years, several cities in Texas
have developed MSW management plans that include goals to recycle or divert a high percentage of
material from being landfilled. Some of these cities have specifically developed “zero waste” plans,
while others have preferred to use terminology such as “high diversion.” Zero waste is a philosophy that
encourages the redesign of resource life cycles so that all products are reused. The goal for zero waste is
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
that no MSW be sent to landfills or waste-to-energy facilities. Zero waste is more a goal or ideal rather
than a hard target, as multiple cities with zero waste plans set maximum goals that still include some
MSW going to landfills (e.g., 80% landfill diversion).
It has become common for cities to set short-, mid-, and long-term goals for recycling and diversion and
to develop progressive programs and strategy implementation plans to meet those benchmarks. Texas
cities that have established high diversion or zero waste goals include but are not limited to those
presented in Table 2-2. Recently published diversion rates for these cities range from 20-42 percent. The
City’s recent single-family diversion rate was approximately 30 percent in 2018 and 2019.
Table 2-2: Texas Cities with High Diversion or Recycling Goals
City Goal
Recently Published
Diversion Rate
Percent Year
Dallas1
40% recycling rate by 2020
60% recycling rate by 2040
Zero Waste by 2060
20% 2020
Austin2
20% reduction in per capita solid waste
disposal by 2012
75% diversion by 2020
90% diversion by 2040
42% 2015
Fort Worth3
30% residential recycling rate by 2021
40% total City recycling rate by 2023
50% total City recycling rate by 2030
60% landfill diversion by 2037
80% landfill diversion by 2045
30% 2018
San
Antonio4
60% single family residential recycling rate
by 2025
36% 2019
1. City of Dallas, 2011-2060 Local Solid Waste Management Plan. City is currently in the process of updating
the LSWMP.
2. City of Austin, Zero Waste Strategic Plan. The city of Austin is currently in the process of updating their
plan. While these figures may not change, the metrics to evaluate progress toward them may be adjusted as
part of the plan update.
3. City of Fort Worth, 2017-2037 Comprehensive Solid Waste Management Plan.
4. City of San Antonio, Recycling and Resource Recovery Plan, 2013 Update.
While diversion rate is commonly used in zero waste goals, there is growing recognition that diversion
rate may not be an ideal measure of SMM or zero waste progress. For example, San Francisco is a zero
waste leader and has recently discontinued use of diversion rates as a means of measuring diversion and
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
progress towards zero waste. Instead, San Francisco tracks total waste generated and the proportion
landfilled and incinerated with the goal of 15 percent reduction in generation and 50 percent reduction in
disposal by 2030.
As described above, incorporating additional metrics such as capture rate and disposal rate allows for
additional program evaluation aligning with SMM and zero waste principles. Table 2-3 presents the
calculation method for three metrics associated with zero waste principles.
Table 2-3: Alignment of Metrics to Zero Waste Principles
Zero Waste
Principle
Metric for
Evaluation Calculation Method1
Indicators of
Progress
Reducing the
generation of
wasted
materials at the
source
Per-capita
waste
generation rate
(𝑇𝑜𝑡𝑎𝑙 𝐷𝑖𝑣𝑒𝑟𝑡𝑒𝑑+𝑇𝑜𝑡𝑎𝑙 𝐷𝑖𝑠𝑝𝑜𝑠𝑒𝑑)
𝑃𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑆𝑒𝑟𝑣𝑒𝑑 Decreasing trend
in per-capita
generation
Maximizing
diversion
methods
Capture rate For each recyclable material (e.g., aluminum cans):
𝐴𝑚𝑜𝑢𝑛𝑡 𝑅𝑒𝑐𝑜𝑣𝑒𝑟𝑒𝑑
(𝐴𝑚𝑜𝑢𝑛𝑡 𝑅𝑒𝑐𝑜𝑣𝑒𝑟𝑒𝑑+𝐴𝑚𝑜𝑢𝑛𝑡 𝐷𝑖𝑠𝑝𝑜𝑠𝑒𝑑 )
Capture rate
approaching 90
– 100 percent2
suggesting
recycling is
maximized
Avoiding
landfill and
incinerators
Per-capita
waste disposal
rate
𝑇𝑜𝑡𝑎𝑙 𝐷𝑖𝑠𝑝𝑜𝑠𝑒𝑑
𝑃𝑜𝑝𝑢𝑙𝑎𝑡𝑖𝑜𝑛 𝑆𝑒𝑟𝑣𝑒𝑑 Decreasing per-
capita disposal
rate
1. For population-based calculations, the population served should be equivalent to the population represented by the
tonnage of material in the numerator (e.g., tons disposed, tons diverted).
2. In current practice, capture rates of 100 percent are likely unattainable due to contamination and inefficiencies during
product use and within the recovery system (e.g., incorrect sorting by residents, limits to equipment, food-soiled
materials).
Recycling Measurement. Traditionally, a recycling rate has been calculated as a means to measure
recycling efforts. A recycling rate indicates the percentage of MSW generated that is recycled. In
support of the use of transparent and consistent methods to measure materials recycled, SWANA’s
technical policy for Measuring Recycling (T-6.4), published in 2018, defines recycling rate as the
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
proportion of generated MSW that is recycled and is typically calculated utilizing the following formula,
where totals are measured by weight in tons21.
𝑡𝑜𝑡𝑎𝑙 𝑟𝑒𝑐𝑦𝑐𝑙𝑒𝑑
𝑡𝑜𝑡𝑎𝑙 𝑟𝑒𝑐𝑦𝑐𝑙𝑒𝑑+𝑡𝑜𝑡𝑎𝑙 𝑑𝑖𝑠𝑝𝑜𝑠𝑒𝑑× 100% =𝑟𝑒𝑐𝑦𝑐𝑙𝑖𝑛𝑔 𝑟𝑎𝑡𝑒 𝑝𝑒𝑟𝑐𝑒𝑛𝑡𝑎𝑔𝑒
Over the past decade, the weights and composition of materials in MSW streams have changed. For
example, there is now typically less newspaper but more cardboard, and individual plastic bottles and
aluminum cans weigh less. Some consumer packaging contains multiple materials, making recycling
more challenging. Due to these factors, some communities are considering alternative methods to
recycling measurement, other than recycling rates as described above:
Single-stream recycling collected. The amount of residential recyclables collected annually on a
pounds per household basis.
Capture rate. Percentage of recyclable material that is recycled versus disposed
Disposal rate. Based on per capita/employee disposal quantities
Contamination rate. The amount of contamination (i.e., material that is not accepted by the
City’s contract recycling processing facility) present in the residential recycling program on a
percentage basis. Contamination rate includes both non-recyclable contaminants and MRF
process residue.
Participation rate. Based on how frequently a resident or business recycles over a defined time
period (e.g., monthly)
Life cycle analysis. Analysis of the total environmental impacts associated with a product or
process and evaluation of opportunities to reduce impacts throughout its life cycle, using methods
such as replacing virgin material inputs with recycled material
Carbon footprint. Quantification of greenhouse gas reductions through increased use of recycled
materials as product inputs (life cycle analysis) and reduction of material landfilled, which
reduces the generation of greenhouse gases due to decomposition
Table 2-4 summarizes the City’s current single-family recycling activities using four recommended
alternative metrics. Section 3.0 provides detailed information and discussion on the amount of recycling
collected, capture rate, disposal rate, and contamination rate for material managed by the City.
Environmental impacts are discussed and evaluated in Section 8.3.
21 Solid Waste Association of North America Technical Policy T-6.4, Measuring Recycling, available at
https://swana.org/TechnicalandManagementPolicies.aspx
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Table 2-4: Alternative Metric Evaluation for City of Denton Single-Family MSW
Metric City of Denton Evaluation
Recycling Collected
(lb/HH)
287 lb/HH (2020)
316 lb/HH (2019)
362 lb/HH (2018)
Based on a 2016 survey by The Recycling
Partnership, the national average for single-
stream recycling is 357 lb/HH annually.
The City’s recycling rate was at the national
average in 2018. Multiple factors likely
contributed to decreases since then, including the
coronavirus pandemic, challenging recycling
markets, and increasing contamination rates.
Capture Rate 49% (2020)
The City’s capture rate for single-stream
recycling is lower than the combined capture rate
for NCTCOG (59%).
Disposal Rate
2,086 lb/HH (2020)
1,856 lb/HH (2019)
1,740 lb/HH (2018)
Recent data suggests an increasing disposal rate
for single family residential; however, shifts in
disposal patterns due to the coronavirus
pandemic contributed to increases in 2020.
Contamination Rate
44% (2020)
35% (2019)
21% (2018)
Based on the survey for the TCEQ’s Recycling
Market Development Plan, the average MRF
contamination rate was 22.4% in 2019, with
reported rates ranging from 10-60%.
The City’s single-stream contamination rate has
increased in recent years, and is above the
reported statewide average. The increase in
contamination may also be associated with
processing limitations at the MRF.
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Table 2-5: Status Summary for Material Waste Diversion and Alternative Metrics
Status and
Evaluation
The City has not established a formal public diversion goal.
Data necessary to calculate diversion rate and alternative recycling
metrics such as capture rate and disposal rate is currently collected from
City-provided programs and services.
Future While a recycling or diversion rate provides insight into material
recovery, additional metrics should be incorporated to assess program
performance holistically.
Key
Accomplishments
The City’s 2020 residential diversion rate was 30.4 percent, which
exceeds the statewide average of 27.5 percent as communicated in the
TCEQ’s Recycling Market Development Plan.
The City has set a contamination rate goals and tracks residential and
commercial contamination rates to track progress toward reducing
contamination.
Impediments
As the sole provider of municipal solid waste disposal services, the City
currently collects data to measure disposal trends. Diversion data can be
harder to obtain, especially from multi-family and ICI sources as this
material is typically collected by private haulers and may be processed at
various recycling and composting facilities in a region.
Recommendations
Recommendations for the City to address material waste diversion and
alternative metrics are to:
o Set performance goals that include alternative metrics (e.g.,
disposal rate and capture rate) to reflect progress toward
SMM and zero waste principles.
o Incorporate reporting requirements into the recyclables
hauler annual permits to gather key data to measure progress
2.3.3 Alignment with National Solid Waste Reduction Goals
As described in Section 2.2.1, current national policies and priorities related to solid waste management
include recycling measurement and food waste diversion. Through the National Recycling Strategy, the
EPA is focused on reducing contamination, increasing recycling rate, and strengthening economic
markets for recycled materials. Recommended measures include tracking contamination rates at the curb
and in the processing system. These efforts are meant to align with the National Recycling Goal of 50
percent by 2030. Additionally, through the Food Loss and Waste Reduction Goal, the EPA is focused on
reducing the amount of food waste sent to landfill by 50 percent by 2030.
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Table 2-6: Status Summary for Alignment with National Solid Waste Reduction Goals
Status and
Evaluation
The City has established programs targeting recycling contamination and
organics diversion.
The City’s focus on improving recycling system performance through reduced
contamination (e.g., “Lift the Lid” program) and organics diversion (including
food waste) align with national priorities.
Future The City has set contamination rate goals. Continued evaluation and goalsetting
can be used to monitor efforts to reduce contamination.
Key
Accomplishments
The City’s cart tagging and targeted outreach has helped to reduce
contamination.
The City received grant funding from the NCTCOG to expand commercial food
waste diversion in the downtown valet area. The City also collects commercial
food waste from a select number of large quantity generators.
Education and outreach messaging includes the importance of waste reduction
behaviors such as reduce, reuse, and refuse.
Impediments Tracking contamination and material recovery rates requires data which can be
difficult to obtain, especially for generators or activities not directly tracked by
the City (e.g., private commercial recycling haulers, food donation).
Recommendations
Recommendations for the City to address alignment with national solid waste
reduction goals are to:
o Continue to incorporate waste reduction messaging in education and
outreach content, especially for food waste reduction.
2.3.4 Promotion of Ingenuity in Reuse and Recycling
As cities incorporate SMM and zero waste principles into material management programs, additional
focus and emphasis is placed on waste reduction and reuse. Cities may use a variety of strategies to
promote waste reduction and reuse behavior, including:
Education and Outreach. Education and outreach campaigns can encourage waste reduction and
reuse behavior change, for example promoting the use of reusable shopping bags and water
bottles.
Material Directories and Exchanges. Online directories (such as “material marketplaces” or
“material exchanges”) can connect material generators with entities or individuals who can reuse
or recycle unwanted materials. These directories can encourage creative reuse or repurposing of
raw materials. Cities may develop these databases in partnership with local non-profits.
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Reuse Centers. As part of municipal drop-off programs, cities may facilitate reuse through
ReUse stores or “share sheds.” Commonly, these programs address hard-to-recycle or HCC
materials such as paint. Some cities are expanding the services offered at these facilities to further
promote reuse and recycling. Examples include:
o Establishing partnerships to accept additional materials (e.g., yoga mats, textiles) desired
by local companies for their products
o Hosting workshops and clinics to educate residents on reduce and reuse behavior such as
backyard composting, material repair workshops (e.g., textiles, electronics)
o Facilitating a tool lending library or similar “library of things” to reduce the need for
residents to purchase common one-time or rarely-used items
Table 2-7: Status Summary for Promotion of Ingenuity in Reuse and Recycling
Status and
Evaluation
The City’s ReUse Store makes reusable items collected through the HCC
program available to residents. Waste reduction and reuse behavior is promoted
through Sustainable Denton.
Future
There are opportunities for the City to expand reuse opportunities, facilitate
creative reuse/recycling, and expand awareness among residents. A detailed
evaluation of the City’s education and outreach and enforcement efforts, and
recommendations in provided in Section 6.0.
Key
Accomplishments
The City’s ReUse store facilitates the reuse of a variety of materials
Impediments If residents or businesses are not aware of reuse programs and resources,
success will be limited.
Recommendations
Recommendations for the City to address the promotion of ingenuity in reuse
and recycling are to:
o Increase education and outreach efforts related to reuse and waste
reduction
o Expand the types of materials accepted through the City’s ReUse
store
o Establish a C&D reuse facility to facilitate reuse of these materials
o Partner with entities such as local universities and homeless
shelters to facilitate the reuse of bulk items (e.g., furniture)
2.3.5 Alternative Waste Management Technologies
While recycling and disposal have been considered traditional MSW management methods in Texas,
some components of the MSW stream can be converted into energy or further processed. Over the past
several years, many local governments in the United States have considered various technologies (e.g.,
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
mass burn combustion, mixed waste processing, gasification, etc.) to manage their disposed MSW stream.
Anaerobic digestion (AD) of organic wastes is a growing trend for managing diverted pre- and post-
consumer organics. Options for anaerobic digestion include stand-alone facilities designed to manage
MSW and co-digestion of organic MSW streams at wastewater treatment plants or agricultural AD units.
An estimated 209 AD facilities manage organic MSW in the U.S., including 68 stand-alone and 141 co-
digesters.22
From a SMM perspective, waste-to-energy incineration is considered distinct from diversion in the waste
management hierarchy (Figure 2-1), and is less preferred than activities such as recycling, composting,
and mulching. However, some states have defined waste-to-energy to be a form of recycling. Based on
the U.S. EPA’s Food Recovery Hierarchy, AD of food scraps is considered to be more preferred than
diversion through composting. It is unclear where emerging chemical conversion technologies such as
gasification and pyrolysis belong on the established hierarchy, though multiple states, including Texas,
have passed legislation to define the pyrolysis of plastic wastes to be a form of recycling.23
The cities included in Table 2-8 have considered and evaluated various technologies for their
communities, but none have implemented any waste-to-energy or other conversion technology. Key
reasons for deciding against implementation of these technologies included preferring to focus on more
traditional recycling (e.g., single-stream) and organics diversion programs and the relatively low cost of
landfill disposal.
22 US EPA. Jan 2021. Anaerobic Digestion Facilities Processing Food Waste in the United States (2017 & 2018).
Available online at: https://www.epa.gov/sites/default/files/2021-
02/documents/2021_final_ad_report_feb_2_with_links.pdf
23 The Texas Solid Waste Disposal Act was updated in 2019 to consider gasification or pyrolysis of recovered
plastics as recycling. HB 1953 (2019) expanded the definition of recycling in Section 361.421 of the Solid Waste
Disposal Act to include post-use polymers and recoverable feedstocks (e.g., plastics) that are converted through
gasification or pyrolysis into valuable raw, intermediate, or final products such as new plastics, chemicals, wax,
lubricant, fuels, and other products.
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Table 2-8: Summary of Texas Cities’ Efforts to Evaluate Conversion Technologies
City Year Summary
San
Antonio 2011
Evaluated the feasibility of waste-to-energy and concluded that those
technologies are not economically feasible “at this time or in the
foreseeable future.” City decided to focus zero waste
implementation efforts on traditional recycling strategies.
Waco 2013
Issued request for proposals for waste-to-energy and received five
responses. City declined to further pursue proposals as none of the
companies were in commercial operation in the U.S. at the time.
Killeen 2013
While the City entered into negotiations for a gasification facility,
the private company did not secure financing and the project was
terminated.
Dallas 2014
Following adoption of its zero waste plan, City evaluated the
feasibility of technologies such as single-stream processing, mixed-
waste processing, anaerobic digestion and gasification. Elected to
focus on the more proven single-stream recycling.
Fort Worth 2016
City’s request for proposals for recycling processing included
consideration of alternative technologies. However, City decided to
continue contracting for recycling via single-stream processing.
Houston 2017
Evaluated “One Bin for All” approach, where all MSW would be
collected together (i.e., mixed waste), but City declined to enter into
contract for “One Bin for All” concept.
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Table 2-9: Status Summary for Alternative Waste Management Technologies
Status and
Evaluation
Waste-to-energy and other refuse conversion technologies are not currently used
to manage MSW in Denton.
The feasibility of waste-to-energy and other emerging technologies has been
evaluated by multiple Texas cities, and these projects did not move forward.
There has been success in the U.S. for using AD to manage organics.
Future The City is exploring options to divert commercial food waste through anaerobic
digestion at the City’s Pecan Creek Wastewater Treatment Plant (WWTP)
Key
Accomplishments
The City collects and diverts food waste from multiple commercial entities
within the City.
The City recently received a grant from the NCTCOG to support diversion of
commercial food waste, which presents a potential opportunity for anaerobic
digestion.
Impediments Potential impediments to anaerobic digestion include pre-processing needs (e.g.,
de-packaging) and challenges associated with contamination.
Recommendations
Recommendations for the City to address alternative waste management
technology trends are to:
o Establish a pilot program for commercial wood waste generators in
the valet area for co-digestion of targeted commercial organics
streams for the production of renewable energy
2.3.6 Landfill Management
Landfill trends. As regulations become more restrictive and it becomes increasingly more challenging to
obtain permits for new landfills, the MSW industry is seeing an increase in the vertical and horizontal
expansion of established landfills. Owners are more commonly seeking to extend the useful life of their
landfill by expanding the landfill footprint, improving operations, or implementing additional
technologies such as enhanced leachate recirculation (a process in which liquids or air are added into a
landfill to accelerate degradation of the waste and prolonging its useful life).
Landfill tipping fees. The Environmental Research and Education Foundation (EREF) has conducted
annual studies comparing landfill tipping fees across the country since 2016. In 2019, average per-ton
landfill tipping fees in Texas are lower than both the national average and the South Central Region
(Arkansas, Louisiana, New Mexico, Oklahoma, and Texas) average. In 2020, the average landfill tipping
fees in Texas remained below the national average but rose slightly higher than the regional average. The
average tipping fees in Texas increased while both the regional and national averages decreased slightly
in the year from 2019-2020.24 This increase could be attributed to differences in economic growth across
24 Environmental Research & Education Foundation (EREF). March 2020 and January 2021. “Analysis of MSW
Landfill Tipping Fees.” Available online from EREF: https://erefdn.org/bibliography/datapolicy-projects/
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
regions and landfill capacity, as well as that EREF received responses from a slightly different set of
landfills from one year to the next. The multi-year trends developed by EREF show increasing tip fees
nationally and in all regions over the period from 2016-2020.
The tipping fees shown in Table 2-10reflect the average of posted tipping fees at surveyed landfills.
Negotiated tipping fees between a landfill and individual haulers may be lower.
Table 2-10: Average Per-ton Landfill Tipping Fees
2019 2020 Difference Percent Increase
Texas $40.18 $42.22 +$2.04 +5.1%
South Central Region $40.92 $39.66 ($1.26) -3.1%
United States $55.36 $53.72 ($1.64) -2.9%
Source: Environmental Research & Education Foundation (EREF)
In the North Central Texas region, multiple landfills are nearing capacity which may result in increased
landfill tipping fees in the region. The closures also have the potential to shift the flow of disposed
materials throughout the region, including more material to the City of Denton Landfill. A detailed
analysis of landfill capacity and tip fees specific to the North Central Texas region and the City of Denton
Landfill is presented in Section 4.0.
Comprehensive Solid Waste Management Strategy Solid Waste and Recycling Trends, Policies and
Regulatory Reivew
Table 2-11: Status Summary for Landfill Management
Status and
Evaluation
The City owns and operates the City of Denton Landfill, which plays a crucial
role in managing wastes not recovered through various City diversion programs,
as well as wastes from neighboring communities without disposal infrastructure.
In addition to being a revenue source for the City, landfill tip fees can be a tool
to encourage material recovery. TCEQ’s Recycling Market Development Plan
identifies the low cost of disposal as a key barrier to recycling market
development in the state.
Future The City should continue to evaluate its use of put-or-pay contracts and the tip
fee structure to preserve valuable airspace, encourage recycling, and stay
competitive in the marketplace.
Key
Accomplishments
The TCEQ approved the expansion of the City’s Landfill, securing disposal
capacity for non-recoverable materials into the future. This capacity can be
further extended through continued diversion and waste reduction practices.
The City’s landfill gas-to-energy system provides environmental benefits
through responsible landfill management and the production of pipeline quality
renewable natural gas (RNG).
Impediments Community perception of landfill activities can present challenges to
implementing new strategies or modifying landfill operations.
Recommendations
Recommendations for the City to implement landfill management trends are to:
o Explore revisions to put-or-pay contracts to encourage recycling in
neighboring communities, which would include regional
collaboration on recycling collection and processing programs
o Routinely evaluate tip fees and potential rate changes as landfills in
the NCTCOG region
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-1 Burns & McDonnell
3.0 PLANNING AREA CHARACTERISTICS
To effectively plan for the City’s future materials management needs, an understanding of the factors that
will impact those needs is important. This section describes the City’s current demographic and
economic characteristics as well as anticipated future growth. To the extent that data is available, the
material generation in the City is presented, including material disposed and recycled or diverted. As the
population of the City and region continue to grow, the volume of materials generated will increase
accordingly. Anticipated growth of residential population, businesses and continued development in the
City is one of the primary factors the City and North Central Texas region must consider in planning for
future materials management. Following description of the demographic and economic characteristics of
the City, this section summarizes waste characterization information for the City and the North Central
Texas region.
3.1 Demographic Characteristics
The population and economic growth the City experiences in the coming years will be the primary factor
impacting the quantities and quality of material generated in the City. Anticipated material generation
quantities will influence future materials management approaches addressed throughout this CSWMS,
including infrastructure development, public-private partnership opportunities, and appropriate timing of
continued system and program development. This section presents a selection of existing population data
and projections and economic development information to provide an understanding of the planning area
considerations under which this CSWMS has been developed.
3.1.1 Historical and Current Populations
The City of Denton is among the 25 largest Texas cities, by population, and is situated in the center of the
sixth most populous county in the state. Historically, Denton has seen high levels of growth (Figure 3-1).
Over the past two decades, the City’s population has grown substantially, from a population of
approximately 80,500 in 2000 to 147,500 in July of 2020 – an 83 percent increase.25 Table 3-1 presents
population growth of the City, Denton County, and the State of Texas from 2010 to 2020 and compares
the average annual growth rate of each entity during that period. Both the City and Denton County are
growing at a faster rate than the State of Texas overall for the last decade. As shown in Figure 3-2, the
population growth has been accelerating for the City and Denton County since 2018, with a 4.2 percent
25 Sources: Year 2000 population estimate as reported in the Denton Plan 2030, available online at
https://www.cityofdenton.com/CoD/media/City-of-Denton/Government/Denton_Plan_2030.pdf; Year 2020
population estimate as reported by the U.S. Census Bureau, City and Town Population Totals: 2010-2020, available
online at https://www.census.gov/programs-surveys/popest/technical-documentation/research/evaluation-
estimates/2020-evaluation-estimates/2010s-cities-and-towns-total.html
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-2 Burns & McDonnell
growth rate for the City from 2019 to 2020 and a 3.6 percent annual growth rate for Denton County
during the same period. In contrast, growth statewide has been slowing since 2015.
Figure 3-1: Historical City Population Growth, 1970 – 2020
Table 3-1: City, County, and State Historical Population & Growth, 2010-2020
2010 2015 2020 4
Annual
Growth
Rate5
City of Denton1
Population 117,010 131,154 147,515 2.67%
Denton County2
Population 666,760 779,584 919,324 3.33%
State of Texas3
Population 25,241,971 27,470,056 29,360,759 1.5%
1. City of Denton population estimates 2010-2019: U.S. Census Bureau. Annual Estimates of the Resident Population for
Incorporated Places in Texas: April 1, 2010 to July 1, 2019 (SUB-IP-EST2019-ANNRES-48), U.S. Census Bureau,
Population Division, Release date May 2020; available online at https://www.census.gov/data/datasets/time-
series/demo/popest/2010s-total-cities-and-towns.html
2. Denton County population estimates 2010-2019: U.S. Census Bureau. Annual Estimates of the Resident Population for
Counties in Texas: April 1, 2010 to July 1, 2019 (CO-EST2019-ANNRES-48), U.S. Census Bureau, Population Division,
Release date March 2020; available online at https://www.census.gov/data/datasets/time-series/demo/popest/2010s-
counties-total.html
3. State of Texas population estimates 2010-2019: U.S. Census Bureau. Annual Estimates of the Resident Population for the
United States, Regions, States, and Puerto Rico: April 1, 2010 to July 1, 2019 (NST-EST2019-01), U.S. Census Bureau,
Population Division, Release date December 2019; available online at https://www.census.gov/data/tables/time-
series/demo/popest/2010s-state-total.html
39,874 48,063
66,270
80,537
117,010
147,515
0
20,000
40,000
60,000
80,000
100,000
120,000
140,000
160,000
1970 1980 1990 2000 2010 2020
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-3 Burns & McDonnell
4. All 2020 population estimates: U.S. Census Bureau, City and Town Population Totals: 2010-2020, available online at
https://www.census.gov/programs-surveys/popest/technical-documentation/research/evaluation-estimates/2020-
evaluation-estimates/2010s-cities-and-towns-total.html
Figure 3-2: Recent City, County and State Population Growth Rates, 2010-20201
1. Annual growth rates based on data from the U.S. Census Bureau
Historical population growth trends over the past decade illustrate the elevated growth rate of the City and
county populations when compared to the state as a whole. Denton County’s total population has
increased at a higher rate than the City itself, owing to the significant central and southeastern portions of
the county that are part of the larger Dallas-Forth Worth metroplex, which is experiencing rapid growth.
Considering the growth trends of not only the City but other surrounding entities within the area serviced
by the Denton Landfill, is essential in future landfill capacity planning. The area and entities served by
the Denton landfill and landfill capacity planning are discussed further in Section 4.0.
3.1.2 Single-Family and Multifamily Household Distribution
Many municipal planning efforts, including materials management, categorize residential populations into
two general categories – single-family and multifamily. The City’s total residential population is
distributed between these two categories. In Denton, residential refuse and recycling collection services
are provided to residents residing in a single-family housing unit and multifamily structures with four or
fewer housing units (referred to as single-family residential throughout this CSWMS).26 All other
26 Based on service definitions provided in the recent solid waste and recycling collection rates (Ordinance 20-
1551). This differs from the single-family definition used in the Statistical Trends and News of Denton (STaND)
reports by the City’s Planning and Building Inspections Departments.
0.0%
0.5%
1.0%
1.5%
2.0%
2.5%
3.0%
3.5%
4.0%
4.5%
2010 2012 2014 2016 2018 2020Annual Population Growth RateCity of Denton Denton County State of Texas
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-4 Burns & McDonnell
multifamily housing units (e.g., apartment complexes and dormitories) receive services through the
commercial collection system.
The distinction between household categories is important because generation, disposal, and diversion
patterns differ between single-family and multifamily and each category requires different planning
considerations and management strategies. Multifamily-generated material is generally collected and
managed in combination with commercially-generated material, and services and information are often
provided directly to multifamily property owners and managers, rather than directly to multifamily
residents.
In 2019, approximately 75 percent of the City’s total residential population lived in single-family housing
units and the remaining quarter of the population lived in multifamily housing units. Table 3-2 presents
the 2020 estimated single-family and multifamily populations and household distributions for the City. It
should be noted that the average persons per household is typically higher for single-family households
than for multifamily households. Therefore, the total population would not be proportionately spilt
between the two household types.
Table 3-2: Household and Population Distributions by Household Type, 2019
Single-Family Multifamily Total
Occupied Households1
Number 33,525 14,622 48,174
Distribution 69.6% 30.4%
Population2
Number 109,981 37,534 147,515
Distribution 74.6% 25.4%
1. The total number of households and distribution of single-family and multifamily households
are based on estimated occupied housing units (U.S. Census Bureau 2019 1-year ACS
Estimates for the City of Denton). Average residential customer counts differ slightly from
census data for occupied households and averaged 33,623 for calendar year 2019.
2. Population distribution between single-family and multifamily households was estimated
based on average persons per household, and an adjustment factor to account for the typical
differences between population per household for single-family and multifamily households.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-5 Burns & McDonnell
For purposes of current and projected waste generation estimates, presented in Section 3.3, residential
sector quantities include materials generated only by single-family households and multifamily units with
four or fewer housing units. Commercial sector material generation estimates and projections are
inclusive of multifamily households with more than four units and commercially-generated materials.
3.1.3 Population Projections
Based on the City’s historical population trends, as presented in Section 3.1.1, and robust planned housing
growth for both single- and multifamily dwellings, the City expects that its population will continue to
expand at a significant rate. However, the timing of population growth and ultimate population realized
are dependent on various factors.
Figure 3-3 presents three potential growth scenarios of the City’s population from 2010 to the 2045,
developed by separate entities using the 2010 Census data as a basis. NCTCOG previously developed a
2045 forecast to provide estimated number and distribution of population by member city for the North
Central Texas region, which presents a relatively low projected annual growth rate of 0.99 percent. 27
Burns & McDonnell developed a relatively moderate potential future growth scenario (2.67 percent) by
calculating the average annual growth rate, based on U.S. Census Bureau population estimates, and
holding that growth rate constant through 2045. The population growth scenario developed by the
University of North Texas (UNT) Center for Economic Development and Research assumes the highest
annual growth rate (3.44 percent) of the three scenarios, through 2030. 28 Burns & McDonnell
extrapolated this growth scenario through 2045. Table 3-3 presents the average annual growth rate and
projected 2045 City population for each scenario.
27North Central Texas Council of Governments. Regional Data Center. NCTCOG 2045 Forecast City
Approximations. Available online at: https://data-nctcoggis.opendata.arcgis.com/documents/NCTCOGGIS::nctcog-
2045-forecast-city-approximations/explore
28 Obtained from the Statistical Trends and News of Denton (STaND) Third Quarter Fiscal Year 20/21 report
compiled by the Denton Economic Development Department.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-6 Burns & McDonnell
Figure 3-3: City of Denton Population Growth Scenarios Through 2045
Table 3-3: City of Denton Future Population Growth Scenarios to 2045
Growth
Projection
Scenario
Annual
Growth Rate
Projected Population
Basis 2040 2045
High 3.44% 290,800 344,400 UNT Forecast
Moderate 2.67% 250,100 285,400 2010-2019 Census Estimates
Low 0.99% 168,400 177,000 NCTCOG Forecast
To create a single population estimate for the City through the 2040 CSWMS horizon, Burns &
McDonnell produced a blended growth projection based on the UNT and Census-based forecasts.
Population growth through 2030 is based on the high growth scenario as forecasted by UNT. This
scenario aligns with growth projections used in the Denton Plan 2030, recent growth rates, and known
and anticipated residential development. From 2030-2040, Burns & McDonnell projected the population
using the moderate growth scenario annual growth rate based, reflective of the Denton Plan 2030 land use
vision to reduce sprawl while “much of the land within approved Master Planned Communities (MPCs)
will likely not buildout in the next 20 years” 29 and therefore continue to support growth from 2030-2045.
29 City of Denton 2015. “Denton Plan 2030: Our path to the future” pg 19. Available online:
https://www.cityofdenton.com/CoD/media/City-of-Denton/Government/Denton_Plan_2030.pdf
0
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
2005 2010 2015 2020 2025 2030 2035 2040 2045 2050PopulationNCTCOG Forecast
UNT Forecast
Census-based Forecast
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-7 Burns & McDonnell
Figure 3-4 shows the resulting single-family and multifamily population growth for the City through
2040. The allocation between single- and multifamily households was held constant through the
projection based on current housing data; however, the Denton Plan 2030 documented the community’s
preference towards compact growth which would shift development trends to more new multifamily
housing units than new single-family households.
Figure 3-4: City of Denton Population Projection, 2020-2040
3.2 Economic Characteristics
The City of Denton is part of the larger Dallas-Fort Worth (DFW) metroplex, the largest metropolitan
area in Texas and the fourth largest is the country.30 A primary driver of the population growth the City
has experienced (refer to Section 3.1) is the economic development that has taken place.
30 New Census Bureau Estimates Show Counties in South and West Lead Nation in Population Growth, U.S. Census
Bureau Press Release April 18, 2019. Retrieved September 2021 from https://www.census.gov/newsroom/press-
releases/2019/estimates-county-metro.html
0
50,000
100,000
150,000
200,000
250,000
300,000
PopulationSingle-Family Multifamily
Multifamily: 37,600
Single-Family: 110,200
Multifamily: 68,700
Single-Family: 201,300
2020 BaselineTotal: 147,800
2040 Projection
Total: 270,000
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-8 Burns & McDonnell
3.2.1 Current Employment and Industry Characteristics
Based on U.S. Census Bureau data,31 the City’s workforce was approximately 77,500 employees in 2019,
an increase of 13.4 percent in the five-year period since 2014. Figure 3-5 presents the City’s 2019
employment by industry. The largest four industries account for approximately 67 percent of total
employment, each with near ten percent or greater of the total employees within the City.
Figure 3-5: City of Denton Employment by Industry, 2019
3.3 Solid Waste Generation, Recycling, and Disposal
Understanding current and projected future MSW generation allows for appropriate planning for solid
waste and recycling system needs, including services, programs, and infrastructure. This section presents
available data regarding the City’s solid waste and recycling material generation on a sector basis
(residential, commercial, and C&D) and by material type. Refer to the Key Terms in Section 1.0 for
definitions of sectors addressed in this CSWMS, material types, and material generation, recycling, and
31 Source: U.S. Census Bureau, 2019 ACS 1-Year Estimates. U.S. Census Bureau data does not include self-
employed individuals, employees of private households, or government employees (public administration).
Retrieved July 2021 from
https://data.census.gov/cedsci/table?q=denton%20city%20employment&tid=ACSDP1Y2019.DP03
1.1%
1.2%
2.8%
3.1%
3.3%
3.5%
4.5%
6.0%
7.6%
9.8%
10.0%
14.9%
32.2%
0.0% 5.0% 10.0% 15.0% 20.0% 25.0% 30.0% 35.0%
Agriculture, forestry, fishing and hunting, and mining
Information
Transportation and warehousing and utilities
Public administration
Other services
Wholesale trade
Finance and insurance, and realesate and rental and leasing
Construction
Manufacturing
Retail trade
Professional, scientific, and management, and administrative and
waste management services
Arts, entertainment, and recreation, and accomodation and food
services
Educational services, and health care and social assistance
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-9 Burns & McDonnell
disposal. All annual tonnage and material generation data included in this CSWMS refers to the fiscal
year (FY) in which it was generated (October through September), unless otherwise specified.32
As described in the following sections, the data currently available for each sector varies. The City has a
near-complete understanding of residential materials generated, disposed, and recycled because most
residential materials are managed directly by the City. Disposal in multifamily and commercial sectors is
also well understood as the City is the exclusive provider of solid waste collection and disposal services
for these generators. The City is not the exclusive provider of special waste and commercial recycling
services in Denton, and as a result the recycling quantities for the multifamily, commercial and C&D
sectors are not well-known. While annual permits are required for recycling and special waste haulers
operating in the City, this does not include a reporting mechanism for obtaining consistent data from
hauler permitees.
3.3.1 Residential Generation, Recycling, and Disposal
Residential solid waste and recycling refers to materials generated by the City’s single-family residential
customers. Multifamily-generated material quantities are addressed along with commercial material
generation presented in Section 3.3.2.
In 2020, a total of approximately 46,500 tons of single-family City of Denton residential MSW was
collected and managed through City services and facilities, equating to a total of 2,707 pounds of MSW
per household on an annual basis. Approximately 77 percent of residential material was collected and
disposed as refuse in the City of Denton Landfill. Approximately 11 percent was collected and recycled
through the Pratt MRF and 12 percent was brush and yard waste that was composted at the City’s Dyno
Dirt facility. Small quantities (less than 0.2 percent each) of electronics, HHW, and prescription drugs are
collected through additional City diversion programs. As shown in Figure 3-6, the distribution of refuse
and recyclables generated by the residential sector has changed over the past three years, from 2018
through 2020. Compared to the prior two years, 2020 data show an increase in disposal tonnage and
decreases in recycling tonnage and diversion rate. These changes are likely the result, in part, of a shift in
waste disposal trends due to the coronavirus pandemic due to shifting work and school patterns. The
amount of material generated by residents has increased and the amount of material generated by
commercial establishments has decreased. This has led to additional demands on residential collection
routes, and a decrease in commercial collection activity. Additionally, the recent trends in lightweighting
of material and decreased paper usage have accelerated due to this shift in behavior related to social
32 For example, tonnage indicated as generated in 2018 typically refers to fiscal year (FY) 2018, which includes the
months of October 2017 through September 2018.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-10 Burns & McDonnell
distancing, and working/schooling from home (e.g., more lightweighted products are being consumed and
less paper is being generated for use of digital media). This has contributed to decreases in recycling
tonnages and rates both locally and nationwide. Additionally, weather events (e.g., tornadoes, winter
storms) often result in temporary increases in the recovery of materials such as brush and yard waste due
to storm debris management, and can contribute to annual variation in organics quantities.
Figure 3-6: Residential Solid Waste and Recycling Generation Trends, 2018-2020 (Tons)1, 2
Figure 3-7 further illustrates the trend in generation and refuse disposal on a household basis. Based on
tonnage and customer count information provided by the City, both residential MSW generation and
disposal rates increased in 2020, with the generation increasing four percent to an average of 226 pounds
per household per month and disposal increasing 16 percent to an average of 175 pounds per household
per month.
30% Diversion
40,441
29% Diversion
43,550
23% Diversion
46,490
0
10,000
20,000
30,000
40,000
50,000
60,000
70,000
2018 2019 2020Tons
Refuse Recyclables Brush & Yard Waste
1 Recyclables tonnage reflects net tonnage, with recycling residuals included in Figure 3-6 as refuse.
2 Small quantities of electronics, and HHW (less than 0.5 percent of total generation for each year) are also included in
the totals shown in Figure 3-6.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-11 Burns & McDonnell
Figure 3-7: Residential Solid Waste Generation and Disposal Trends, 2018-2020 (Pounds per
Household)1
1 Per-capita values (pounds per person per month) are based on average monthly residential customer
data provided by the City.
3.3.2 Commercial Generation, Recycling, and Disposal
The City of Denton is the exclusive provider of commercial refuse collection and disposal services in the
City. Commercial entities can also contract with the City for recycling services, including typical
recyclables, brush/yard waste, and food waste. Multiple permitted haulers also operate within the City to
provide for the collection, transportation, and processing of commercial recyclables; and because of this,
quantities of commercially generated recyclables are not fully known. Tonnages summarized in this
section are based on data available to and reported by the City.
In 2020, approximately 86,700 tons of commercial sector refuse was collected by the City, including
approximately 2,100 tons of recycling and 300 tons of organics. Due to impacts of the coronavirus
pandemic, less material was generated in the commercial sector than is typical and tonnages were down
about 11 percent from the previous year (2019) and the City experienced an 11.5% decrease in
commercial roll-off pulls in 2020. In 2019, approximately 97,500 tons of material was collected by the
city from commercial and multifamily generators, including 3,300 tons of recycling and approximately
525 tons of organics (Figure 3-8). An additional approximately 21,900 tons of additional organics were
0
50
100
150
200
250
2018 2019 2020Pounds/HH-monthRefuse Total Generation Recyclables Brush & Yard Waste
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-12 Burns & McDonnell
recovered from facilities and wastewater treatment activity, comprised of 16,917 tons of facilities brush
and 4,934 tons of wastewater treatment sludge were diverted as organics in 2019.
Figure 3-8: City-Collected Commercial Waste by Material Type, 20191
Similar to many other Texas cities, the multifamily residential sector in Denton receives services in a
similar manner as the commercial sector. Commercial refuse quantities include material generated from
both commercial entities and multifamily residents because these waste streams are often collected
together and data is not tracked separately.
Burns & McDonnell developed a planning-level estimate of multifamily refuse quantities generated in
Denton by first calculating single-family per-capita refuse generation and using multifamily household
size to estimate multifamily refuse generation. The per-household multifamily refuse generation estimate
was then multiplied by the total number of occupied multifamily households to estimate the City’s total
annual multifamily refuse quantities. This estimated multifamily refuse generation figure was subtracted
from total commercial generation to get the estimated refuse generated by commercial businesses.33
33 Based on the U.S. Census Bureau’s 2019 ACS, it was estimated that, on average, multifamily households have 0.5
fewer persons per household than single-family households. To estimate total multifamily annual refuse generation,
Burns & McDonnell multiplied per-capita refuse generation rates by 2.57 persons per multifamily household,
multiplied by the total occupied multifamily households in the City. Based on this, an estimated 11,100 tons of
refuse per year may be generated by the multifamily sector, or approximately 12 percent of total commercial refuse
generation.
Refuse
93,700
78%
Recyclables
3,300
3%
Organics
22,400
19%
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-13 Burns & McDonnell
Figure 3-9 shows the estimated total commercial refuse generation in Denton in FY18-19, distributed
between commercial businesses and multifamily households. Since commercial dumpsters may be
serviced between one and six times per week, the distribution in tonnage between multifamily and
commercial entities differs from the distribution of customer count. Currently, an estimated 16 percent of
dumpster service accounts are multifamily customers.
Figure 3-9: Commercial and Multifamily Refuse Distribution, 2019 (Tons)
3.3.3 C&D Generation, Recycling, and Disposal
Denton’s C&D debris management previously included the Building Materials Recovery (BMR) program
to recycle materials such as concrete, metal, and wood. C&D debris intended for disposal is managed at
the City of Denton Landfill. C&D services are provided via an open market system and C&D generators
that choose to recycle may contract independently with a hauler. Under this current system, the City
tracks and provides data for total C&D debris disposed but the City is not able to comprehensively track
recycled C&D quantities. Figure 3-10 shows how C&D debris disposal at the City of Denton Landfill has
varied for the last three years. It’s important to note that not all of this material was generated in the City.
Quantities of C&D disposal declined in 2020, which may be the result of the coronavirus pandemic as
well as competition with the recently opened 380 McKinney C&D Landfill.
Commercial
83,134 Tons
89%
Multifamily
10,567 Tons
11%
Total Commercial &
Multifamily Refuse Tons:
93,701
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-14 Burns & McDonnell
Figure 3-10: City of Denton Landfill C&D Debris Disposal Trends, 2018-2020 (Tons)1
3.3.4 Total Generation, Recycling, and Disposal
In 2020, City managed a total of 158,909 tons material through its residential and commercial collection
services, with 46,490 tons (29 percent) generated by the single-family residential sector and 112,419 tons
(71 percent) generated by the commercial sector (including multifamily households, facilities, and
wastewater treatment). As shown in Figure 3-11, a total of 7,062 tons of recycling and 30,600 tons of
organics were recovered from residential and commercial generators which is equivalent to approximately
24 percent diversion for these generators. A small quantity of HCC, electronics, drug kiosk and C&D
metals were also reported as recycled.
30,531 29,563
15,222
-
5,000
10,000
15,000
20,000
25,000
30,000
35,000
2018 2019 2020
1. C&D debris disposal tonnage data from TCEQ annual reports for the City of Denton Landfill.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-15 Burns & McDonnell
Figure 3-11: City of Denton Residential & Commercial Generation by Material Type, 2020
Table 3-4 communicates the combined residential and commercial MSW tonnages on a per-capita basis
for the last three years. In 2020, the City managed a total of 5.9 pounds per person per day of MSW, with
4.5 pounds per person per day landfilled. These generation and disposal rates are higher than the U.S.
EPA nationwide estimates, at 4.9 and 2.4 pounds per person per day respectively for 2018; however, other
nationwide estimates suggest that U.S. EPA may underestimate landfill disposal and actual disposal rates
are higher.34
Table 3-4: Residential and Commercial Management, 2018-2020 (pounds per person per day)
Category
Pounds per Person per Day U.S. EPA
(2018) 2018 2019 2020
Landfill Disposal 4.5 4.8 4.5 2.4
Material Diversion 1.5 1.5 1.4 1.6
Total Generation 5.9 6.2 5.9 4.0
34 Other nationwide MSW management studies, including those published by BioCycle magazine, the
Environmental Research & Education Foundation, and multiple U.S. universities suggest the methodology used by
the U.S. EPA likely underestimates MSW disposal and generation tonnage and rates.
Refuse
120,119
76%
Recyclables
7,062
5%
Organics
30,600
19%
Total Residential & Commercial
Generation Tons1: 158,909
1. Total generation also includes small amounts of HCC, electronics, and drug kiosk
tonnage.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-16 Burns & McDonnell
Based on recent trends, the City has strong residential recycling and diversion programs in place. While
the City has programs and relationships in place that actively encourage commercial and C&D debris
recycling, no formal reporting mechanisms are in place to track diversion activities from third-party
haulers in these sectors. As a result, non-residential recycling activity is difficult for the City to routinely
track. Waste composition data collected for the strategy development (and presented in Section 3.4 and
Appendix C) provides additional insight into the opportunities is increase diversion in the residential and
commercial sectors. Further evaluation of these opportunities in presented in Sections 5.0 through 10.0.
3.3.5 Residential and Commercial MSW Forecast
Currently, the City develops six-year planning forecasts for materials managed by the City based on
recent year trends, known contract conditions, and anticipated development. To facilitate strategy long-
term development, Burns & McDonnell developed solid waste projections through 2040 for City-serviced
residential and commercial services based on current and projected population, employment, and land
development. The impact of projected regional disposal quantities and landfill life projections for the City
of Denton Landfill are presented separately in Section 4.0.
As with any long-term planning activity, the development of the MSW generation projections requires a
number of assumptions to be made. Figure 3-12 presents the forecasted tons of material generated in the
residential and commercial (including multifamily) sectors and managed by the City on an annual basis
using a 2019 baseline. The developed projections conservatively assume constant per-capita and per-
employee waste generation rates, based on a 2019 baseline.35 The City may be able to drive decreased
waste generation and/or increased recycling rates through its continued programs and initiatives such as
waste reduction and diversion education and policies implemented by cities and entities within the region.
35 2019 baseline data was selected as a baseline for long-term planning based on the availability of detailed
demographic data. This baseline inherently assumes that that short-term shifts in solid waste generation and disposal
due to the coronavirus pandemic are temporary. Based on data provided by the City for the first part of 2021,
commercial and residential generation rates have begun to return to pre-pandemic trends.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-17 Burns & McDonnell
Figure 3-12: Projected City-Managed Residential and Commercial Waste Generation, 2019-20401
3.4 Waste Characterization
In addition to understanding the quantity of material generated, the relative fraction of material types is
critical to estimating potential recycling, diversion, waste reduction, and refuse disposal. As part of the
CSWMS development, Burns & McDonnell performed a 3-day waste characterization study to better
understand the composition of both recycling and refuse from single-family residential, multi-family
residential, and commercial generators. A memo summarizing the study results is provided in Appendix
C. Residential waste and recycling composition for the City was also evaluated as part of the NCTCOG
Regional Recycling Survey and Campaign. Combined results are summarized below for both the City and
0
50,000
100,000
150,000
200,000
250,000
300,000
Total Tons GeneratedCommercial
Residential
Residential: 43,600
Residential: 83,100
Commercial:
122,000
Commercial:
191,300
2019 BaselineTotal: 165,600
2040 Projection
Total: 274,400
1. Commercial includes material generated by commercial, multifamily, and ICI generators including wastewater
treatment sludge and facilities brush.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-18 Burns & McDonnell
the NCTCOG region. Figure 3-13,
Figure 3-14, and Figure 3-15 present the compositions results for single-family residential, multifamily
residential, and commercial generators, respectively. Notable variations exist in both garbage and
recycling composition based on generator, underscoring the importance of considering streams
independently when evaluating diversion programs success and opportunities. For example, commercial
recycling is primarily cardboard leaving a higher percentage of recoverable metals and plastics in the
refuse stream.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-19 Burns & McDonnell
Figure 3-13: Single-Family Residential Garbage and Recycling Composition, 2020
Figure 3-14: Multifamily Residential Garbage and Recycling Composition, 2020
Figure 3-15: Commercial Garbage and Recycling Composition, 2020
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-20 Burns & McDonnell
3.4.1 Regional Capture Rate
As part of the NCTCOG Regional Recycling Survey and Campaign, the capture rate was a key metric of
the data collection and analysis, rather than the traditional recycling rate, to generate a more impactful
education and outreach campaign. A capture rate provides insight on individual types of recyclable
materials to target for increased recovery and supports the development of focused education/outreach
campaign materials. Capture rate is calculated using the following formula:
𝑃𝑜𝑢𝑛𝑑𝑠 𝑜𝑓 𝑅𝑒𝑐𝑦𝑐𝑙𝑎𝑏𝑙𝑒 𝑀𝑎𝑡𝑒𝑟𝑖𝑎𝑙𝑠 𝑖𝑛 𝑅𝑒𝑐𝑦𝑐𝑙𝑖𝑛𝑔
(𝑃𝑜𝑢𝑛𝑑𝑠 𝑜𝑓 𝑅𝑒𝑐𝑦𝑐𝑙𝑎𝑏𝑙𝑒 𝑀𝑎𝑡𝑒𝑟𝑖𝑎𝑙 𝑖𝑛 𝑅𝑒𝑐𝑦𝑐𝑙𝑖𝑛𝑔+𝑃𝑜𝑢𝑛𝑑𝑠 𝑜𝑓 𝑅𝑒𝑐𝑦𝑐𝑙𝑎𝑏𝑙𝑒 𝑀𝑎𝑡𝑒𝑟𝑖𝑎𝑙 𝑖𝑛 𝐺𝑎𝑟𝑏𝑎𝑔𝑒 )
The capture rates from the NCTCOG waste characterization study were derived by using the composition
profile of hand-sorted single-family refuse and recycling to calculate the capture rate of between four and
12 samples delivered by each city, where each recycling sample represented about 100 pounds of material
and each refuse sample represented about 250 pounds of material.
Low capture rate indicates where opportunities exist to increase material recovery through single-stream
recycling and provides an understanding of how effectively a curbside recycling program operates. Table
3-5 compares the capture rate on a material-by-material basis for recyclables among the North Central
Texas region for 2019 and 2020 on a region-wide basis.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-21 Burns & McDonnell
Table 3-5: Regional Single-Family Capture Rate by Individual Recyclable Materials
2019
Regional
Capture
Rate
2020
Regional
Capture
Rate
Year-over-
Year
Change
Recyclable OCC 58.8% 62.4% 3.6%
Mixed Paper 34.1% 27.7% (6.3%)
Paper Subtotal 41.1% 38.0% (3.2%)
PET Containers 24.9% 26.5% 1.6%
HDPE Containers - Natural 28.0% 34.2% 6.1%
HDPE Containers - Colored 25.8% 26.1% 0.4%
#3-#7 Containers 11.3% 12.7% 1.4%
Plastic Subtotal 22.2% 23.7% 1.5%
Aluminum Used Beverage Containers 26.1% 31.0% 4.8%
Ferrous Metal Food Containers 14.2% 18.4% 4.2%
Metals Subtotal 19.5% 24.4% 4.8%
Recyclable Glass 34.4% 33.9% (0.5%)
Glass Subtotal 34.4% 33.9% (0.5%)
Regional Capture Rate 29.8% 28.7% (1.3%)
Approximately 435,000 tons of recyclables are sold to market annually in the North Central Texas region
and among all of these material categories the recycling system is operating at a capture rate of less than
30 percent.
Burns & McDonnell also developed the capture rate for the samples provided by each participating city
on an aggregated and individual basis.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-22 Burns & McDonnell
Table 3-6 shows the capture rate for the aggregated participating cities compared to the City for the
single-family residential samples.
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-23 Burns & McDonnell
Table 3-6: 2020 Participating City and Denton Single-Family Capture Rate
Recyclable Material
2020 Denton
Capture Rate1
2020 Participating
Cities Capture Rate
Recyclable OCC 84% 84%
Mixed Paper 47% 52%
PET Containers 37% 51%
HDPE Containers - Natural 55% 58%
HDPE Containers - Colored 44% 52%
#3-#7 Containers 36% 31%
Aluminum Used Beverage Containers 37% 57%
Ferrous Metal Food Containers 11% 41%
Recyclable Glass 50% 59%
Total 49% 59%
1. Capture rate is reflective of the combined results (a total of 12 samples of garbage and
recycling) from the samples provided both during the City’s sorting event and the NCTCOG
sorting event intended to show results with an increased level of confidence.
The capture rate for the City at 49 percent is lower than the capture rate of the aggregated NCTCOG
samples at 59 percent. Based on these results, there is opportunity for the City to improve in the capture
of key and highly valuable recyclable materials including mixed paper, PET, HDPE and ferrous metal.
3.4.2 Recycling Contamination
Table 3-7 shows the recycling contamination present in the City’s aggregate sort samples from each
generator type. Contamination rates are calculated as the weight of all non-recyclable materials collected
from a sample divided by the total weight of that sample. Contamination categories include non-
recyclable Old Corrugated Cardboard (OCC), other non-recyclable paper, non-recyclable plastic, non-
recyclable glass, organics, other C&D, problem material, and other material.
Table 3-7: Recycling Contamination by Generator Type
Single-Family1 Multi-Family Commercial
Contamination 35% 25% 21%
1. Contamination in the single-family recycling shown is reflective of the combined results (a total of
12 samples of garbage and recycling) from the samples provided both during the City’s sorting
event and the NCTCOG sorting event intended to show results with an increased level of
confidence.
Contamination rates shown in Table 3-7 for single-family residential differ notably from those reported in
the City’s data and presented in Table 3-8. There are multiple potential explanations for this, including
Comprehensive Solid Waste Management Strategy Planning Area Characteristics
City of Denton, Texas 3-24 Burns & McDonnell
that contamination rates determined through a waste sort do not account for sorting at the MRF which
may not always capture all of a recyclable material due to a number of factors including material size or
equipment. It is important to note that each ton of contamination that is managed by the City represents
increased operational costs associated with material handling, hauling costs, and MRF tipping fees.
Table 3-8: Reported Single-Family Recycling Contamination Rates
2018 2019 2020 2021 YTD1
Recycling Tonnage (gross) 7,456 8,091 8,749 5,804
Recycling Tonnage (net) 5,866 5,973 4,937 2,009
Difference 1,590 2,819 3,812 3,795
Contamination Rate 21% 35% 44% 65%
1. Partial year data (October 2020 through May 2021)
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-1 Burns & McDonnell
4.0 FACILITIES AND INFRASTRUCTURE
This section provides an overview of existing MSW processing facilities and infrastructure in the City
and North Central Texas region including landfills, transfer stations, MRFs, C&D facilities, organics
processing facilities, and home chemical collection. Planning for future disposal and processing options
now will provide the City with sufficient time to meet the future needs of the Denton community.
4.1 Current System Review
Figure 4-1 shows the City of Denton solid waste facilities, which include the City of Denton Type I
landfill, Dyno Dirt composting facility, and Home Chemical Collection (HCC) facility. Additionally,
through a public-private partnership, Pratt Industries operates a recycling materials recovery facility
(MRF) at the Denton Landfill complex. The MSW facilities in the broader North Central Texas region are
shown in Figure 4-2.
Figure 4-1: MSW Management Facility Locations within the City of Denton
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-2 Burns & McDonnell
Figure 4-2: MSW Facility Locations within Denton County and Neighboring Counties
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-3 Burns & McDonnell
4.1.1 Landfills
This section provides an overview of existing landfills in the City and region, analysis of historic and
projected regional landfill capacities, and a discussion of future disposal considerations.
There are presently 18 active Type I landfills (landfills that accept all types of MSW, including C&D
materials and special waste) in the NCTCOG region among Collin, Dallas, Denton, Ellis, Johnson,
Navarro, Parker, and Tarrant County. Table 4-1 identifies the Type I landfills currently in operation in the
region and provides disposal and remaining capacity data, as reported by the TCEQ for FY 2020.36
Information about active Type IV landfills in the NCTCOG region is provided in Section 4.1.5.
Table 4-1: NCTCOG Type I Landfill Disposal and Remaining Capacities, FY 2020
Permit Permit Holder/Site Name Owner County
Tons
Disposed1
Remaining
Capacity
(Tons)
Remaining
Site Life
(Years)2
1590B City of Denton Landfill3 City of Denton Denton 388,067 27,677,394 72
1025B DFW Recycling and
Disposal Facility
Waste Management Denton 915,892 2,139,153 2
1312B Camelot Landfill Republic/Farmer’s
Branch
Denton 716,332 32,006,486 45
2294
121 Regional Disposal
Landfill
North Texas
Municipal Water
District
Collin 946,399 72,081,975 76
218C South East Landfill City of Fort Worth Tarrant 732,522 16,244,574 22
358B City of Arlington Landfill City of Arlington Tarrant 933,193 34,493,232 37
62 McCommas Bluff Landfill City of Dallas Dallas 1,617,121 59,891,574 35
996C City of Grand Prairie
Landfill
City of Grand
Prairie
Dallas 244,567 4,940,267 32
1394B Hunter Ferrell Landfill City of Irving Dallas 192,161 3,114,830 33
1895A Charles M Hinton Jr
Regional Landfill
City of Garland Dallas 586,097 17,707,706 30
42D Skyline Landfill &
Recycling Facility
Waste Management Ellis 1,772,283 21,205,467 15
1209B CSC Disposal and Landfill Republic Ellis 20 17,184,946 100
1745B ECD Landfill Republic Ellis 154,599 29,260,015 160
1195B Republic Maloy Landfill3 Republic Hunt 139,346 19,559,746 100
36 Texas Commission on Environmental Quality (TCEQ). September 2021. “Municipal Solid Waste in Texas: A
Year in Review; FY 2020 Data Summary and Analysis.” https://www.tceq.texas.gov/downloads/permitting/waste-
permits/waste-planning/docs/187-21.pdf
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-4 Burns & McDonnell
Permit Permit Holder/Site Name Owner County
Tons
Disposed1
Remaining
Capacity
(Tons)
Remaining
Site Life
(Years)2
534 City of Cleburne Landfill City of Cleburne Johnson 525 7,143 14
1417C Turkey Creek Landfill3 Waste Connections Johnson 663,541 8,247,586 5
2190 City of Corsicana Landfill City of Corsicana Navarro 101,539 11,121,239 110
47A Weatherford Landfill City of Weatherford Parker 125,686 112,811 2
Total4 10,229,890 376,996,143 37
1. Tons disposed in the region does not reflect total MSW generation, as a certain amount of MSW is recycled and diverted as well as
imported and exported from the region each year.
2. Remaining years are calculated based on the annual airspace utilization factors reported to TCEQ for each landfill in pounds per cubic
yard. The remaining years reported by TCEQ shown in this table do not take population growth into account. Discussion about the
remaining landfill capacity taking population growth into account is provided in Section 4.1.1.2.
3. Reflects landfill expansions approved by TCEQ during 2020 and 2021.
4. Total may not sum exactly due to rounding.
4.1.1.2 Historic and Projected Regional Landfill Capacities
Figure 4-3 illustrates how remaining regional landfill capacity disposal has changed from 2009–2020.
During this time, total annual regional disposal has trended upward, from 8.1 million tons in 2009 to 10.8
million tons in 2020. Data is based on past annual TCEQ summary reports.37
Figure 4-3: Trends in Annual Regional Disposal, Type I and IV Landfills (Tons)
37 Texas Commission on Environmental Quality (TCEQ). Annual Summary of Municipal Solid Waste Management
in Texas archive. https://www.tceq.texas.gov/permitting/waste_permits/waste_planning/wp_swasteplan.html
0
2,000,000
4,000,000
6,000,000
8,000,000
10,000,000
12,000,000
2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-5 Burns & McDonnell
Based on data from the TCEQ’s 2020 annual review of MSW generation and facilities in Texas, the
region has approximately 37 years of total Type I Landfill capacity remaining at current reported annual
disposal rates. However, this estimate does not account for future population and economic growth.
Actual total remaining landfill life, given current remaining capacities, is likely to be lower.38 Based on
population projections from the NCTCOG,39 the population of the region is projected to grow at an annual
rate of 2.2 percent from 2020–2045. Figure 4-4 shows the projected remaining NCTCOG region landfill
capacity through 2045, taking into account future population and economic growth and assuming no
landfill capacity is added through existing landfill expansion or new permitted landfills.
Figure 4-4: Projected NCTCOG Remaining Regional Types I and IV Landfill Capacity, 2021-2045
As of 2020 the estimated the remaining landfill capacity of the region is approximately 386.3 million
tons. If annual disposal quantities, totaling approximately 10.8 million tons in 2020, were to increase at
the same rate as regional population projections, the remaining NCTCOG regional landfill capacity would
be fully depleted in the year 2047. This equates to total remaining landfill life of 27 years for the region,
from the year 2020.
38 Data from the TCEQ’s 2020 MSW annual report, presented in Table 4-1 and discussed in this section, is reflective
of the way data has traditionally been presented by TCEQ in its MSW annual reports. TCEQ data provides an
understanding of facilities and capacities at a given point in time and does not incorporate population and economic
growth projections.
39 2040 NCTCOG Demographic Forecast. NCTCOG Regional Data Center. Accessed February 2021. https://data-
nctcoggis.opendata.arcgis.com/datasets/6e99f37880d845758788c18f5a2c36f2_10
27 Years
7 Years
2 Years
0
50,000,000
100,000,000
150,000,000
200,000,000
250,000,000
300,000,000
350,000,000
400,000,000
450,000,000
2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030 2031 2032 2033 2034 2035 2036 2037 2038 2039 2040 2041 2042 2043 2044 2045Total Remaining Regional Landfill Capacity (Tons)
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-6 Burns & McDonnell
As landfills in the region close and the total disposal capacity decreases, tonnage flows will shift to the
available disposal capacity and market pressure will cause the value of airspace to increase over time.
Further discussion and strategy in response to decreasing regional disposal capacity is provided as part of
the Strategy to Efficiently Use Landfill Capacity (see Sections 7.0 and 11.3).
4.1.1.3 City of Denton Landfill
The City of Denton Landfill (owned and operated by the City) is located at 1527 S. Mayhill Road,
Denton, TX. It began operation in 1984 under TCEQ permit number 1590. According to the TCEQ
permit issued in July 2021 (1590B), the Denton Landfill consists of a total permit boundary of 404.4 acres
and a waste disposal footprint of 258.0 acres with a total waste disposal capacity of 51.88 million cubic
yards. This includes recent approval of a vertical and lateral expansion, which added 40 million cubic
yards disposal capacity. Prior to the expansion, the site had an estimated 7.27 million cubic yards
remaining in 2020 (11.5 years of capacity). This increase provides an additional 60 years of landfill life,
giving the site an estimated 72 years of site life remaining (Table 4-1).
All refuse collected within the City limits is disposed at the Denton Landfill, which serves both City and
non-City customers. All customers pass through the scalehouse facility which records the tonnage of
material and customer category (Figure 4-5).
Figure 4-5: Denton Landfill Scalehouse
Customer types are defined as follows, with brief descriptions:
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-7 Burns & McDonnell
Residential. The City collects refuse material from residential customers set out at the curb in 64- and 96-
gallon rolling carts on a weekly basis using Automated Side Loader (ASL) vehicles.
City Hauled Commercial. The City collects refuse material from commercial customers set from four,
six, eight and ten cubic yard (CY) bins at a frequency determined by the customer (i.e., once per week,
twice per week, etc.) using both Front Loader (FL) or Side Loader (SL) vehicles.
City Hauled Commercial Open Top. The City provides open top containers to commercial customers
and services them at a frequency determined by the customer (i.e., once per week, twice per week, etc.)
using roll off trucks.
City Hauled Commercial Compactors. The City provides compactors and compacting units to
commercial customers and services them at a frequency determined by the customer (i.e., once per week,
twice per week, etc.) using roll off trucks.
Wholesale. The City accepts and disposes non-City collected materials from private haulers, primarily
under “Put-or-Pay” contracts including refuse and C&D material from residential and commercial
generators. Put-or-Pay contracts guarantee a specified amount of waste annually at a negotiated price.
Retail. The City accepts material from self-haul customers including refuse and C&D material from
residential and commercial sources.
The City-collected residential tons are not charged a disposal fee, City-collected open tops and
compactors are charged and the fee that is passed through to the customer, and retail tons are charge the
applicable gate rate. Table 4-2 shows the per ton rates for each customer and/or material type.
Table 4-2: Disposal Rates at Landfill Facility (2020)
Customer/Material Rate per Ton
Gate Rate (City Residents/Businesses) $44.00
Gate Rate (Non-Denton Residents/Businesses) $48.00
City Hauled Commercial Open Top and Compactors $40.00
Wholesale Put-or-Pay Contracts1 $27.00-34.00
Figure 4-6 provides the fiscal year (FY) 2020 disposal distribution by broad customer category40.
40 Source: Data provided by the City of Denton.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-8 Burns & McDonnell
Figure 4-6: Denton Landfill MSW Tonnage by Broad Customer Category, 2020
In 2020, City hauled material accounted for 31 percent of the total tonnage disposed and non-City hauled
material comprised 71 percent, where put-or-pay contracts account for over half of the disposed material
at the landfill. Materials not hauled by the City may have been generated within the City (e.g., self-haul)
or in a neighboring community.
Figure 4-7 summarizes the annual tonnage by source from FY 2015 through FY 2020. Most source
categories have remained steady each year, however, the wholesale customer tonnage significantly
increased from 2019 to 2020 due to an increase in put-or-pay contracts with private haulers.
Residential
8%
Commercial
21%
Wholesale
Customers
51%
Retail Tons
through
Scalehouse
20%
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-9 Burns & McDonnell
Figure 4-7: Denton Landfill Annual Tonnage by Customer Category, 2016-2020
Table 4-3 shows the historical tonnages disposed at the Denton Landfill by customer category.
Table 4-3: Denton Landfill Disposal Tons by Customer Category, 2016-2020
FY 15-16 FY 16-17 FY 17-18 FY 18-19 FY 19-20
Residential 25,338 26,270 26,592 28,146 32,015
Commercial 83,931 86,080 83,765 93,701 84,309
Wholesale Customers 100,760 101,156 106,240 110,536 204,399
Retail Tons through Scale House 41,632 59,917 59,768 74,309 78,590
TOTAL 251,661 273,424 276,364 306,692 399,313
Based on current disposal rates, the recently approved vertical and lateral expansion increases the
expected capacity of the Denton Landfill to 72 years (Table 4-1). As described in Section 3.0, population
and economic growth are forecasted to result in increased City-hauled landfill disposal tonnages.
Population growth in Denton County and other surrounding areas using the Denton Landfill will likely
result in an increase in demand from retail and wholesale customers as well.
-
50,000
100,000
150,000
200,000
250,000
300,000
350,000
400,000
450,000
FY 15-16 FY 16-17 FY 17-18 FY 18-19 FY 19-20
Residential Commercial Wholesale Customers Retail Tons through Scalehouse
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-10 Burns & McDonnell
Figure 4-8 shows estimated capacity for the Denton Landfill under various future waste acceptance
scenarios:
Proportional growth. The City accepts an increasing amount of City-hauled, retail and
wholesale/put-or-pay tonnage based on forecasted population growth in the City and surrounding
communities.
Capped put-or-pay. The City renews existing put-or-pay contracts at current tonnage levels and
accepts an increasing amount of City-hauled, retail, and other wholesale tonnage based on growth
within in the City.
Maximum airspace preservation. The City ceases the use of put-or-pay contracts after current
contracts expire in 2023 and accepts only material from the City of Denton and the Pratt MRF.
Figure 4-8: Projected Denton Landfill Capacity Based on Forecasted Scenarios, 2021-2080
Estimates suggests that, depending on the City’s approach to utilizing airspace, the current capacity of the
Denton Landfill could be fully depleted as early as 2057, or 36 years currently remaining (as of FY 2021)
without increases in diversion rates. The capped put-or-pay scenario provides approximately 45 years of
life currently remaining, with capacity being depleted in 2066 without increases in diversion rate. If only
materials generated within City of Denton and from Pratt MRF were accepted to maximize airspace
preservation, landfill life would be depleted in 2077 or 56 years currently remaining.
0
5,000,000
10,000,000
15,000,000
20,000,000
25,000,000
30,000,000
2020 2025 2030 2035 2040 2045 2050 2055 2060 2065 2070 2075 2080Total Remaining Denton Landfill (Tons)Proportional Growth
Capped Put-or-Pay
Maximum Airspace
Preservation
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-11 Burns & McDonnell
Further description and evaluation of using put-or-pay contracts and tonnage guarantees in the future are
provided as part of the evaluation of the Strategy to Efficiently Use Landfill Capacity (see 7.0 and 11.3).
The City Landfill has a renewable natural gas (RNG) project planned to make beneficial use of landfill
gas. Gas will be collected through wells, cleaned to pipeline quality, and injected into the pipeline.
4.1.2 Materials Recovery Facilities
This section provides an overview of Materials Recovery Facilities (MRFs) in the region and provides a
high-level overview of the Pratt MRF located at the Denton Landfill.
MRFs are designed to receive, process, segregate and bale various recyclable materials and prepare them
for sale on the secondary material commodity market. There are presently 11 active MRFs in the
NCTCOG region, located among Collin, Dallas, Denton, Ellis, Johnson, Navarro, Parker, and Tarrant
Counties. Table 4-4 identifies the MRFs currently in operation in the region and provides the owner
and/or operator, and location.
Table 4-4: NCTCOG Materials Recovery Facilities and Accepted Residential Materials
Permit Holder/Site Name Owner/Operator County
Residential
Materials Accepted1
Pratt – Denton Pratt Industries Denton Gen 1
Waste Connections MRF – McKinney Waste Connections Collin Gen 1
Plano Recycle Center Republic Services Collin Gen 2
North Texas Recycling Complex Republic Services Tarrant Gen 2
Waste Management – Arlington Waste Management Tarrant Gen 2
CWD Recycling Facility CWD Dallas Gen 2
FCC – Dallas FCC Environmental Services Dallas Gen 2
Champion MRF2 Champion Waste Services Dallas -
Dallas Recycling Facility Dallas Waste & Recycling Inc Dallas -
Balcones – Dallas2 Balcones Dallas -
Waste Management Dallas Metroplex2 Waste Management Dallas -
1. Based on 2018 interviews with the respective residential MRF operators. First generation MRFs (Gen 1) report accepted
materials as: cardboard, mixed paper, kraft bags, paperboard, office paper, glass bottles and jars, aluminum cans, steel cans,
PET bottles and HDPE bottles and jugs. Upgraded or second generation MRFs (Gen 2) report accepting all Gen 1 materials
plus cartons, clean pizza boxes, aerosol cans, aluminum foil, PP #5 containers, and bulky plastics.
2. Commercial MRF processing little to no residential recycling.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-12 Burns & McDonnell
Across the NCTCOG region, there is a reported total of nearly 600,000 tons per year (TPY) of MRF
processing capacity currently installed. There is approximately 65,600 TPY of installed processing
capacity at the two MRFs closest to the City (Pratt MRF in Denton and Waste Connections MRF in
McKinney), with both facilities reportedly operating at or near capacity. Compared to other MRFs in the
region, these two facilities also accept a more limited set of materials; while other MRFs in the region
accept items such as cartons, pizza boxes, and aluminum foil, these facilities do not. As a result, recycling
processing opportunity in the northern portion of the North Central Texas region is more limited.
4.1.2.2 City of Denton Materials Recovery Facility
Recycling in the City is delivered to the Pratt MRF located at the Denton Landfill owned and operated by
Pratt Industries (Pratt). Figure 4-9 shows the front entrance of the Pratt MRF.
Figure 4-9: Pratt Industries Material Recovery Facility
The Pratt MRF is approximately 40,000 square feet and processes about 20 tons per hour (TPH) of
Acceptable Recyclable Materials loaded into an in-feed conveyor to pre-sort material and to screen out
bags and other non-recyclable material or material that presents safety hazards (e.g., car bumper, lithium-
ion batteries, etc.). Material is conveyed over a star screen and through multiple trommel screens where it
then passes through quality control stations and drops into dedicated storage containers before it is baled
and sold on the secondary materials commodity market. Glass and fine materials (i.e., material that is less
than two inches in diameter) is collected and transported to local secondary glass processing facilities.
Source separated old corrugated cardboard (OCC) delivered by commercial entities is tipped directly on a
designated location on the MRF floor and baled without being fed through the processing system. Figure
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-13 Burns & McDonnell
4-10 provides an overview of the recycling process, specific to the Pratt MRF. Secondary material
commodity markets are described in more detail in Section 10.1.
Figure 4-10: City of Denton Recycling Process Flow Overview
The City entered into the Regional Recyclable Processing Agreement (Recycling Agreement) in 2007
with Pratt to build, own and operate a MRF at the Denton Landfill with an initial term of 20 years and the
option for two additional ten-year terms by mutual decision of both parties. The City is currently in the
initial 20-year term of the Recycling Agreement. At the conclusion of the Recycling Agreement, the City
will take ownership of the Pratt MRF building (excluding processing equipment).
The City provides utilities for the property (e.g., water, sanitary sewer, electric), delivers all recyclable
material collected from residential and commercial customers within the City limits to the Pratt MRF,
accepts residual materials at the Denton Landfill and is responsible for promoting recycling education.
Pratt pays the City $0.80 per ton of residential material delivered to the Pratt MRF to fund the City’s
effort market, promote and educate the community on recycling and waste diversion. Additionally, the
City receives a rebate ranging from $5.00 to $15.00 per ton for all Curbside Collected Single Stream
Recyclable Materials delivered by the City depending on the total tons delivered on a monthly basis. Pratt
pays a rebate for other material types delivered to the Pratt MRF (e.g., Clean Commercial Recyclable
Material, Unprocessed Commercial Recyclable Material) based on the tonnage and a percentage of index
prices and/or sales revenue.
Recyclable Material is defined as recyclable materials consisting of plastics #1 through #7, tin (steel
cans), aluminum cans, clear and colored glass bottles and jars, certain types of plastic film, newsprint,
magazines, corrugated cardboard, phone books, chipboard, white and colored paper, mail and office
paper, that are reasonably free of food residue. Unaccepted material and residue is not to exceed 15
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-14 Burns & McDonnell
percent by weight per load, and loads in excess of 15 percent may be rejected and disposed at the Denton
Landfill at no charge to Pratt.
Further discussion and evaluation of the Recycling Agreement is provided in the Recycling Processing
Evaluation (see Section 9.2).
4.1.3 Transfer Stations
Transfer stations are facilities that are used to consolidate MSW from multiple collection vehicles into
larger, high-volume transfer vehicles for economical shipment to distant disposal or processing facilities.
Transfer stations can be used for material destined for landfilling, recycling, or composting. With a
nationwide trend toward larger disposal and processing facilities, there has been an enhanced need for
transfer stations. When transport distances are longer, transfer stations allow collection vehicles to be
more productive by maximizing the amount of time spent collecting material rather than driving to a
distant facility.
Landfill trash, recycling, and yard trimmings collection vehicles may either haul material directly to one
of these facilities (referred to as “direct haul”) or utilize a transfer station, which aggregates material into
larger transfer trailers for more efficient transportation (referred to as “long haul”). There are presently
17 active transfer stations in the NCTCOG region, located among Collin, Dallas, Denton, Ellis, Johnson,
Navarro, Parker, and Tarrant Counties. Table 4-5 identifies the transfer stations currently in operation in
the region as reported by the TCEQ in 2020.41
Table 4-5: NCTCOG Transfer Stations and Tonnage Handled, FY 2020
Permit Permit Holder/Site Name Owner/Operator County 2020 Tons1
2045A Custer Solid Waste Transfer Station North Texas Municipal
Water District
Collin 315,048
53A Lookout Drive Transfer Station North Texas Municipal
Water District
Collin 178,639
1494 Parkway Transfer Station North Texas Municipal
Water District
Collin 109,414
40284 Town and Country Recycling Facility Champion Waste &
Recycling Services
Collin 48,110
2275 North Texas Recycling Complex
Transfer Station
Republic Services Tarrant 4,728
2306A WC Minnis Drive Transfer Station Waste Connections Tarrant 193,327
41 Texas Commission on Environmental Quality (TCEQ). September 2021. “Municipal Solid Waste in Texas: A
Year in Review; FY 2019 Data Summary and Analysis.” https://www.tceq.texas.gov/downloads/permitting/waste-
permits/waste-planning/docs/187-21.pdf
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-15 Burns & McDonnell
Permit Permit Holder/Site Name Owner/Operator County 2020 Tons1
40052 Southwest Paper Stock Transfer Station Southwest Paper Stock Tarrant 24,954
40186 Westside Transfer Station Waste Management of
Texas
Tarrant 215,181
1145 Bachman Transfer Station City of Dallas Dallas 160,177
60 Fair Oaks Transfer Station City of Dallas Dallas 84,100
1453 Southwest Transfer Station City of Dallas Dallas 75,804
12 Garland Transfer Station Facility City of Garland Dallas 117,078
1263 Mesquite Transfer Station Facility City of Mesquite Dallas 64,159
227 University Park Transfer Station City of University Park Dallas 13,059
40196 Community Waste Disposal Transfer
Station
Community Waste Disposal Dallas 119,120
40168 City of Cleburne Transfer Station
Facility
City of Cleburne Johnson 77,395
40181 Somervell County Transfer Station Somervell County Somervell 12,169
1. Tons represent all material processed at the facility on an annual basis and may include refuse, recycling,
and organic waste. Tons presented are based on TCEQ annual reporting data, except for the City of Dallas
transfer stations which are based on values provided to Burns & McDonnell directly by the City of Dallas
for FY 19-20.
The financial feasibility of a transfer station and whether material should be direct-hauled or long-hauled
is dependent on a number of factors, including:
Collection cost
Disposal cost
Distance/travel time to landfill
Fuel costs
Annual tonnage hauled
Payload of transfer trailers vs. collection vehicles
Assuming other factors are held constant, the further the landfill or processing facility is from the
collection point, the more financially feasible long-hauling with a transfer station is compared to direct
hauling. As described in Section 4.3, there is significant anticipated growth and development in the
southwest portion of the City. Tactics to develop infrastructure such as transfer station(s) to support
future growth and regional opportunity are evaluated in more detail as part of the Strategy to Plan for
Future Growth and Infrastructure (see Sections 8.0 and 11.4).
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-16 Burns & McDonnell
4.1.4 Organics Processing Facilities
This section provides an overview of organics processing facilities in the region and describes the City’s
organics processing facility.
TCEQ regulation and oversight of organics processing regulations vary depending on the types of
materials a facility accepts and therefore TCEQ does not actively regulate all organics processing
facilities. Burns & McDonnell has compiled an inventory of known active organics processing facilities,
although there may be additional organics processing operations in the region that are small scale or do
not generate a compost product that is marketed commercially.
Table 4-6 identifies major organics processing facilities within the Denton, Collins, and Tarrant County
areas that accept materials such as yard trimmings and food scraps.
Table 4-6: NCTCOG Organics Processing Facilities and Accepted Materials
Site Name County Accepted Materials1
Plano Pure Products Collin Vegetative materials only
Living Earth Collin Vegetative materials only
Sustainable Soil Solutions Collin Vegetative materials only
The Organic Recycler of Texas Collin Vegetative materials only
City of Denton Yard Waste Facility Denton Putrescible and vegetative materials
Living Earth Denton Putrescible and vegetative materials
Living Earth Dallas Putrescible and vegetative materials
Soil Building Systems Dallas Vegetative materials only
The Organic Recycler of Texas Dallas Putrescible and vegetative materials
City of Grand Prairie Landfill Dallas Vegetative materials only
Hunter Ferrell Landfill Dallas Vegetative materials only
Charles M. Hinton Jr Regional Landfill Dallas Vegetative materials only
City of Mesquite Municipal Compost Dallas Vegetative materials only
Alpine Materials LLC Tarrant Vegetative materials only
Living Earth Tarrant Putrescible and vegetative materials
Living Earth – Fort Worth SE Landfill Tarrant Putrescible and vegetative materials
Living Earth – City of Arlington Landfill Tarrant Putrescible and vegetative materials
Silver Creek Materials Recovery Facility Tarrant Vegetative materials only
The Organic Recycler of Texas Tarrant Putrescible and vegetative materials
Thelin Recycling Tarrant Vegetative materials only
1. Accepted materials are categorized as putrescible or vegetative. Putrescible materials have high moisture content and
include, but are not limited to, pre- and post-consumer food waste, biosolids, sludge, or liquid waste. Vegetative materials
are cellulosic with low moisture content and include, but are not limited to, tree branches and limbs, grass, shrubs, yard
waste, lumber, dry animal bedding, or floral trimmings.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-17 Burns & McDonnell
There is one major organics processing facility near the City, operated by Living. While there are
facilities with available capacity, private-sector processors have indicated there are challenges accepting
source-separated food waste or yard waste from municipalities directly at their existing facilities due to
high levels of contamination.
4.1.4.2 City of Denton Organics Processing Facility
The City owns and operates an organics processing facility which manages organic waste collected
through the residential and commercial collection program and biosolids from the Pecan Creek Water
Reclamation Plant. The Dyno Dirt Composting Facility (Composting Facility) is covered by a pole barn,
processes the material in open air windrows and houses various screening and material management
equipment. Figure 4-11 shows the composting facility and some of the equipment used on site.
Figure 4-11: City of Denton Dyno Dirt Composting Facility
Table 4-7 presents the annual tonnage processed at the Composting Facility from various sources.
Table 4-7: City of Denton Organics Management Tons by Source, 2016-2020
Source FY 15-16 FY 16-17 FY 17-18 FY 18-19 FY 19-20
Residential Yard Waste/Brush 6,909 7,249 6,219 7,166 5,606
City Facilities Yard Waste/Brush 153,094 19,785 17,250 16,917 19,701
Commercial Organics 487 427 371 343 335
Biosolids (Sludge) 3,713 4,343 4,312 4,934 4,957
TOTAL 164,203 31,804 28,152 29,360 30,599
Organic material that is ground and composted is sold and marketed as Dino Dirt products. Dino Dirt
products include compost, topdressing, potting mix, and mulch available to customers via pickup.
Although the City is able to manage the current amount of material that is delivered to the site, a
significant increase in tonnage or type of material may be challenging without infrastructure upgrades and
additional staffing (e.g., introduction of significant quantities of food waste).
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-18 Burns & McDonnell
4.1.4.3 Pecan Creek Wastewater Treatment Facility
The City’s Pecan Creek Wastewater Treatment Facility (WWTP) staff is responsible for the oversite,
operation, and maintenance of the Composting Facility. The WWTP TCEQ permit currently allows for
the processing of yard trimmings, biosolids, and pre-consumer food wastes at the Composting Facility.
Post-consumer food waste is not permitted at this time. The City has discussed amending the permit to
allow post-consumer food waste but elected not to at this time due to potential odor and vector issues.
The WWTP operation includes an anaerobic digester as a function of its treatment process. The digester
produces biogas which is used to produce energy for onsite electricity generation. The anaerobic digester
currently only processes biosolids but the City is analyzing the potential to accept food waste and the
capacity of food waste it could receive. The City recently received a grant from the NCTCOG to pilot a
commercial food waste composting program from the historic downtown area. The grant includes the
purchase of a piece of equipment called a macerator to prepare the food waste for acceptance in the
anaerobic digester at the WWTP. The project will require a collaborative approach to balancing the
volumes of food waste collected with the ability for the digesters to handle the additional waste stream.
Considerations must be made for additional staffing based on any additional workload demands from this
new process. Further discussion on organics processing are discussed in Section 6.0. Figure 4-12 shows
images of the Pecan Creek WWTP.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-19 Burns & McDonnell
Figure 4-12: City of Denton Pecan Creek WWTP
4.1.5 C&D Processing Facilities
This section provides an overview of regional construction and demolition (C&D) processing facilities in
the region including Type IV landfills, processing facilities, and an overview of the City’s C&D recovery
program.
4.1.5.1 Type IV Landfill Regional Overview
A Type IV landfill only accepts brush, construction or demolition waste, and other similar non-household
or non-putrescible waste (organic waste that decomposes without causing odors or attracting pests). There
are four Type IV Landfills in the NCTCOG region as indicated in Table 4-8.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-20 Burns & McDonnell
Table 4-8: NCTCOG Type IV Landfill Disposal and Remaining Site Lite, FY 2020
Permit Permit Holder/Site Name County 2020 Tons
Remaining
Site Life1
(years)
1749B Lewisville Landfill Denton 10 100
2278 Osttend C&D Waste Landfill/380 McKinney Collin 222,212 24
1983C Fort Worth C&D Landfill2 Tarrant 403,606 11
664 City of Stephenville Landfill Erath 16,290 27
1. Remaining years are calculated based on the annual airspace utilization factors reported to TCEQ for each landfill in
pounds per cubic yard.
2. Reflects landfill expansion approved by TCEQ during 2021.
4.1.5.2 Regional C&D Processing Facilities Overview
The only mixed C&D materials recovery facility in the region is Champion Waste & Recycling’s Town &
Country Recycling Facility in Celina, TX, which opened in 2015 as a single-stream construction MRF in
North Texas. The facility separates construction material using a combination of processing equipment
and sorting labor. Materials recycled throughout the process include cardboard, wood, concrete, metal,
plastics, wall board, paper, and aluminum. Figure 4-13 shows the type of equipment and labor required as
part of Champion’s operation.
Figure 4-13: Champion Construction MRF Materials Processing Line
Source: https://www.championwaste.com/
Champion staff assists contractors with generating waste diversion reports that qualify towards a project’s
Leadership in Energy and Environmental Design (LEED) certification. However, without a regulatory
obligation to provide recycled C&D tonnage or diversion metrics, Champion does not generate regular
reports regarding the diversion of material from projects in the City.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-21 Burns & McDonnell
In addition to Champion’s mixed C&D processing capability, there are a number of material-specific
processors throughout the region processing materials such as concrete/aggregate and scrap metal and
disposal facilities in the region may manually sort mixed C&D loads to divert high-value materials such
as scrap metal.
4.1.5.3 City of Denton Building Material Recovery
The City historically optimized C&D diversion efforts by diverting select loads from the landfill to be
sorted at the Building Material Recovery (BMR) location which was capable of diverting an average of
over 70 percent of the waste from each load. Figure 4-14 shows the BMR location at the Landfill Facility
where the grapple loader previously segregated materials for diversion. The City has discontinued the
BMR facility due to challenges with the cost-effectiveness of operation. With the discontinuation of the
City-operated C&D diversion facility, the City must currently look to the private sector for C&D
diversion services.
Figure 4-14: Manual Sorting of Building Materials for Recover
4.1.6 Home Chemical Collection and Other Special Wastes
Home chemical collection (HCC) programs can take many forms and may utilize one or more of the
program options shown in Table 4-9. Programs may use a number of strategies to increase material
recovery, such as adding door-to-door service to increase convenience and provide access to households
without reliable transportation. There is increasing interest to provide HCC services through regional
partnerships, which can expand access and benefit from economies of scale.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-22 Burns & McDonnell
Table 4-9: Common Home Chemical Collection (HCC) Program Options
HCC Program Option Operational Service Frequency
Permanent HCC Facility Six days per week
Door-to-Door Collection (regular or on-call) Once per month to unlimited
Trailer for Mobile Collection Multiple times per week
Collection Events One or more times per year
For NCTCOG programs that operate a permanent HCC facility, there is a trend to expand the materials
accepted as part of the drop-off program to include common hard-to-recycle materials such as plastic
film, expanded polystyrene (EPS) foam, electronics, textiles, paint, and batteries. Some of these programs
also expand service to neighboring communities through interlocal agreements. This form of partnership
is discussed in more detail in Section 10.6.3.
4.1.6.1 City of Denton Home Chemical Collection Services
The City provides safe disposal of household hazardous waste through their Home Chemical Collection
(HCC) Services. The HCC facility is located at the Denton Landfill and is available by appointment for
residents to drop off their materials. The City also offers a curbside collection by appointment. In
additional to the collection of household hazardous materials, the City also provide recycling of electronic
waste and the safe disposal of prescription and over the counter medications. Televisions, computers, and
all other small household electronics and kitchen appliances are accepted for recycling. Table 4-10
provides the annual tonnage of materials collected by material type.
Table 4-10: City of Denton Home Chemical Collection and Other Special Waste Tons, 2016-2020
Collection Material FY 15-16 FY 16-17 FY 17-18 FY 18-19 FY 19-20
Home Chemical Collection 46 60 60 53 57
Drug Kiosk Take Back 1.6 1.3 1.5 1.4 0.7
Electronics Recycling 112 114 113 92 71
4.2 Regional Partnerships
Appropriately planning for and developing MSW facilities and infrastructure operations, ownership, and
partnerships is critical for successful achievement of the priorities and strategies presented. Facilities,
infrastructure, and contractual service relationships allow the City to properly manage and process each
MSW material type.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-23 Burns & McDonnell
Based on the current system findings, the City will need to rely on a combination of facilities going
forward to meet needs of the community. The key to providing the most appropriate services in a cost-
effective manner is for the City to develop and maintain the most beneficial approach for each service
need (e.g., refuse disposal, recycling processing). There are a variety of approaches that the City can
consider to address operational needs, as shown in Error! Reference source not found..
Table 4-11: Examples of Public-Private Partnership Options for MSW Operations
Responsibility
City-Owned
and
Operated
City-Owned
with Private
Operations1
Privately
Owned and
Operated on
City Land1
Processing
Services
Agreement
Land Ownership City City City Private
Capital
Investment
City City Private Private
Operations City Private Private Private
1 True public-private partnership arrangement
Public-private partnerships. Public-private partnerships (PPP) can be an effective model to provide
needed infrastructure without the full financial risk falling on either the local government or the private
business. Effective public-private partnerships exist when both local governments and the private
industry collaborate to share resources, capital investment, risk, and revenue. The City’s current recycling
processing is through a public-private partnership, with Pratt constructing and operating the MRF on land
leased from the City.
Processing service agreements. An alternative approach is to secure material processing capacity
through a processing service agreement (PSA). Under a PSA, the City contracts with a private recycling
company that owns and operates a facility at a location owned or leased by the company. Local
governments that do not directly provide municipal collection may procure MRF processing services
though contracted hauler(s).
There are advantages and disadvantages to the different types of arrangements and which entity takes
ownership of the land, capital investment, and operations. While the processing services agreement is the
most common option in Texas, public-private partnerships such as the City’s agreement with Pratt are
gaining more appeal as a means to share risk given recent market volatility. Table 4-12 summarizes the
potential advantages and disadvantages for local governments of different ownership of the land, capital
investment, and operations.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 24 Burns & McDonnell
Table 4-12: Advantages and Disadvantages of Approaches to Finance and Operate Processing Facilities
Approach Advantages Disadvantages
Land
Ownership
Local
Government
as
Landowner
• Flexibility with public-private partnership structures.
• Local government may already own land.
• Potential to co-locate with existing
permitted facility with infrastructure (e.g., scale house).
• Can retain facility for long-term period.
• High control of facility and overall site (e.g. potential future
expansion).
• Increased level of effort.
• Higher risk to the local government.
Private as
Landowner
• Lower level of effort for local government.
• Lower risk to the local government.
• No local government involvement.
• Local government will not retain facility in the long term.
• Low control of facility and site.
Capital
Investment
Local
Government
MRF
Investment
• Municipal cost of capital is lower.
• Local government may not have to earn a return on capital
investment.
• Potentially longer depreciation period.
• High local control of facility and overall site.
• Large capital outlay for local government.
• Potentially longer project schedule.
• Higher risk to community.
• Potential for limited control over equipment maintenance and upkeep
depending on PPP arrangements.
Private MRF
Investment
• No capital outlay required by local government.
• Potential for some cost and/or schedule savings due to private-led
procurement processes.
• Lower risk to local government.
• Possible quicker adoption of new technology.
• Higher cost of capital.
• Compressed depreciation period to match contract term.
• Private company must earn a return on capital investment.
• Lower local control over facility and site.
Operations
Local
Government
as
Processor
• Local government receives 100% of revenue.
• Local control over operations.
• Local government may have limited recycling processing experience.
• Community would have sole responsibility for sourcing material.
• Local government may have limited in materials marketing capabilities &
experience.
• Hiring and other aspects of facility staffing may be constrained by public
hiring and Human Resources processes.
Private
Company
as
Processor
• Private company experience with recycling processing.
• Local government and private company work together to source
material.
• Potential to market a large volume of material from multiple facilities to
achieve economies of scale.
• Sophisticated materials marketing (e.g., hedging, derivatives).
• Local government must manage contractor and provide oversight.
• Local government likely to incur processing fee and must share revenue.
• Limited local control over operations.
1 Adapted from the 2020 Guide to Community MRF Contracts. More information is available at: https://recyclingpartnership.org/mrf-contracts/
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-25 Burns & McDonnell
In Texas, many cities provide MSW services either with City resources or through a single private hauler
contracted to provide those services. A small number of cities have an open market system in which
several private haulers are permitted to operate within the city; however, open market systems are much
more common for commercial, rather than residential, services. Generally, cities of smaller size in Texas
may choose to contract for MSW services, likely due to limited resources available for operation of a
municipal system. Among some smaller cities and many cities with higher populations, there is a split
between those that have municipally and privately provided services. This approach is consistent with
cities of comparable size in Texas. Table 4-13 shows Denton and the top 10 largest cities in Texas and
how solid waste collection, processing and disposal are managed.
Table 4-13: Comparison Matrix of Denton and Largest 10 Texas Cities Service Provision1
City Population
Residential Collection Recycling
Processing
Landfill Transfer Station
Refuse Recycling Brush &
Bulk Ownership Operations Ownership Operations
Denton 147,515 M M M PPP M M N/A N/A
Houston 2,310,000 M M M P P P M P
San
Antonio 1,508,000 M M M P P P M P
Dallas 1,331,000 M M M PPP M M M M
Austin 950,807 M M M P P P N/A N/A
Fort Worth 874,401 P P P P M P N/A N/A
El Paso 679,813 M M M P M M N/A N/A
Arlington 395,477 P P P P M P N/A N/A
Corpus
Christi 325,780 M M M P M P M M
Plano 287,064 M M M P M M M M
1. M = Municipalized, P = Private, PPP = Public-Private Partnership, N/A = Not Applicable
Other regional partnerships. In addition to the PPP options for the development of facilities, there are
opportunities for the City to partner with other municipalities in the region to expand material processing
capacity or expand services to underserved surrounding communities (e.g., regionalization of HCC
services). There are multiple ways in which local governments can successfully partner, including:
Special law districts. The Texas Legislature can establish special law districts with solid waste
management authority to handle all aspects of solid waste management within the district’s
boundaries (e.g., collection, processing, disposal, recycling, composting). Special law districts
can include multiple counties and municipalities, and do not need to be geographically
contiguous. An advantage of special law districts is that boundaries, structure, purpose, and
authority can all be specifically tailored legislatively. Disadvantages of special law districts
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-26 Burns & McDonnell
include the time and expense involved in establishing such districts, and the political risks. For
example, voter disapproval of a regional solid waste authority could substantially delay or derail
efforts to develop and implement a long-term solid waste strategy for the region.
The North Texas Municipal Water District (NTMWD) is a legislatively created special law
district responsible for solid waste management activities in the Cities of Allen, Frisco,
McKinney, Plano and Richardson, and Collin County. The NTMWD manages and operates three
transfer stations, four citizen convenience drop-off centers, and the 121 Regional Disposal
Facility landfill.
Interlocal cooperation agreements or joint-use ownership. Interlocal agreements are contracts
that can be used by local government entities to perform or provide government services
including to establish solid waste agencies or authorities. The creation of a solid waste agency
through interlocal agreement is more flexible than legislatively developed special law districts, as
details such as the structure and management of the agency are determined by the contract itself;
however, these agencies may lack powers typically associated with special law districts such as
the ability to issue bonds or levy taxes.
The Texoma Area Solid Waste Authority (TASWA) was created from a cooperative agreement
between Cities of Gainesville, Denison, and Sherman and Grayson and Cooke Counties to
provide a solid waste disposal facility (and a recycling facility until 2009). Interlocal agreements
are also commonly used to provide a specific solid waste service (e.g., an interlocal agreement to
allow county residents to participate in a city’s HCC program). For example, Dallas County
facilitates a regional HHW program for 16 member cities through its interlocal agreement, with
each member city paying a portion of the program’s disposal, operations, and capital costs.
4.3 Land Use and Growth
The City recently completed the Denton Plan 2030, which explored land use and planned growth options.
Through the stakeholder engagement process, the Denton community indicated a high-level of
community preference toward the Compact Growth Scenario (Figure 4-15), which reflects a shift toward
high-density multifamily and mixed-use growth in specific areas throughout the City.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-27 Burns & McDonnell
Figure 4-15: Compact Growth Scenario (Preferred Scenario from Denton Plan 2030)
Source: Denton Plan 2030 (Figure 1.6)
This desired growth pattern is consistent with shifts toward more multifamily and condensed development
among many cities in the North Central Texas region to reduce development sprawl and create more
environmentally and socially conscious housing. Increases in compact mixed-use development and multi-
family high density can cause challenges for solid waste collection activities. If zoning requirements and
design codes do not account for the needs of collection vehicles or equipment, it can create challenging
collection environments such as private drives, small alleyways, dead-ends, hammerhead turn-arounds,
and dangerous backing situations. Continued collaboration between the City’s Solid Waste & Recycling
and Development Services departments is important to anticipate and account for collection services.
4.3.1 Current and Projected Growth in the City of Denton
Figure 4-16 illustrates the location of the City’s disposal, recycling, organics, and HCC facilities in
relation to the City’s population. Currently, the City’s collection program landfill refuse, recycling, and
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-28 Burns & McDonnell
organics collection vehicles in the City haul material directly to one of these facilities (referred to as
“direct haul”).
Figure 4-17 shows the projected 2040 city population distribution based on projections developed by
NCTCOG. Based on these estimates, population growth through 2040 is anticipated in multiple areas of
the City with the largest increases currently projected in the south and southeast, with especially high
growth anticipated as a result of large master planned communities (MPC) in southwest Denton. The
current and anticipated areas of highest population within the City are shown in Figure 4-18, further
illustrating the significant anticipated growth in the southern Denton as well as adjacent areas just outside
the city limits.
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-29 Burns & McDonnell
Figure 4-16: Denton Population Distribution in Relation to City Solid Waste Facilities
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-30 Burns & McDonnell
Figure 4-17: Projected City of Denton 2040 Population in Relation to City Solid Waste Facilities
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-31 Burns & McDonnell
Figure 4-18: Population Areas Greater Than 6,000 Persons in City of Denton
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-32 Burns & McDonnell
Strategy to Plan for Future Growth and Infrastructure (see Sections 8.0 and 11.4).
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-33 Burns & McDonnell
Figure 4-19 communicates the planned residential growth in the City in relation to the City’s solid waste
facilities, developed based on known active and planned subdivisions. Planned residential growth
throughout the City includes:
Horizontal in-fill development along the north Loop 288 corridor. A majority of the
communities being developed are along 288 north of University Drive. The growth in this area
includes horizonal infill development, where remaining vacant or partially vacant areas within the
Loop 299 corridor are being developed into single family and/or multi-family residential
neighborhoods.
Large master-planned community (MPC) development in the rural southwest. While a
relatively smaller number of communities are being developed in the southwestern part of the
City, these communities represent the vast majority of planned new single family and multi-
family residential lots. Two MPCs (Hunter Ranch and Cole Ranch) are planned for undeveloped
ranchland, which will significantly increase the number of new solid waste (i.e., 15,717 single
family lots, 5,090 multifamily units, and 424 acres for commercial development) at full buildout
(2062).42
As the City continues to grow, it is important to consider whether direct haul of materials continues to be
the most efficient approach, or whether there is benefit to the City utilizing a transfer station to aggregate
material into larger transfer trailers for more efficient transportation (referred to as “long haul”). The
financial feasibility of a transfer station and whether material should be direct-hauled or long-hauled is
dependent on a number of factors, including distance/travel time to the landfill (or other facility). Based
on anticipated direct-haul routes for known developments, the furthest development along the north Loop
288 corridor is the Brentwood Place subdivision, with an estimated direct-haul route of 9.21 miles. For
the Hunter-Cole MPCs, the estimated direct-haul route along existing roadways (via I-35) is 12.42 miles.
Long term, however, the further direct-haul route for these solid waste customers will likely be along the
proposed portion of Loop 288, a 20.49 mile direct-haul route.
An evaluation of the appropriateness and feasibility of transfer stations as a part of the City’s long-term
waste management strategy is further evaluated as part of the Strategy to Plan for Future Growth and
Infrastructure (see Sections 8.0 and 11.4).
42 Based on “Hunter/Cole Ranch Development Projections” presented to Denton City Council (Dec 21, 2018).
Presentation available online at: https://lfpubweb.cityofdenton.com/PublicWeblink/4/edoc/15898/2018-
190%20Cole%20and%20Hunter%20Ranch%20Master-Planned%20Communities.pdf
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-34 Burns & McDonnell
Figure 4-19: New Residential Communities and Number of Platted Lots in Relation to City Solid Waste Facilities
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-35 Burns & McDonnell
4.3.2 Projected Growth in Surrounding Communities
As shown in Figure 4-20, in addition to population increases within the City limits, NCTCOG anticipates
significant growth in neighboring communities within Denton County. While these areas are not serviced
by the City’s solid waste collection program, materials from these communities are reflected in put-or-pay
contracts at the Denton Landfill and could potentially be diverted through other partnerships. Growth in
the surrounding communities and its potential impact on the City’s programs are considered in Sections
11.0 and 12.0 as part of the following:
Strategy to Efficiently Use Landfill Capacity
Strategy to Plan for Future Growth and Infrastructure
Strategy to Optimize Recycling Processing
Strategy to Support New Markets and Leverage Partnerships
Comprehensive Solid Waste Management Strategy Facilities and Infrastructure
City of Denton, Texas 4-36 Burns & McDonnell
Figure 4-20: Population Change Through 2040 for City of Denton and Surrounding Communities
4.4 Current System Findings
The following presents findings regarding key components of facilities in the City’s current solid waste
management system.
Landfills. With the recently approved landfill expansion, the City currently has sufficient capacity
through at least 2057 and potentially through 2077. As other landfills in the NCTCOG region reach
capacity and close, existing disposal capacity will become an increasingly valuable resource. Demand
will likely increase at the Denton Landfill from third-party haulers and other cities in the region,
providing the opportunity for the City to support surrounding communities with necessary disposal
capacity while incentivizing or partnering on recycling and diversion programs. For example, the put-or-
pay contract language and rate structure could reflect pricing based on whether the outside city or county
has diversion methods in place. Other landfill policies, such as material bans (e.g., yard waste) or
surcharges, could also be considered to further preserve airspace in the long-term and help drive regional
diversion effort so long as these policies account appropriately for existing competition and pricing.
Tactics to efficiently utilize landfill capacity for both financial and environmental benefit are evaluated in
more detail as part of the Strategy to Efficiently Use Landfill Capacity (see Sections 7.0 and 11.3).
Material recovery facilities. The current agreement with Pratt Industries has been sufficient to meet the
City’s recycling processing needs; however, there are opportunities the City can explore to increase the
effectiveness of recycling processing such as through improved MRF operational efficiencies. Given the
limited recycling processing capacity in Denton and Collin Counties and anticipated growth in the region,
it is important for the City to plan appropriately for any efforts to increase recycling to identify options for
new capacity and/or facilities. Options to consider for developing additional recycling processing capacity
include accepting responsibility for the processing of recycling materials either solely or through
partnerships with other cities in the area (e.g., McKinney, Plano). Tactics to address recycling processing
needs and regional opportunity are evaluated in more detail as part of the Strategy to Optimize Recycling
Processing (see Sections 9.0 and 11.5).
Transfer stations. Currently, material collected by the City is direct hauled to the Denton Landfill or
Pratt MRF. As the City and surrounding area continues to grow, there may be a need to develop one or
more transfer stations to efficiently manage waste and traffic. The locations of anticipated growth within
the City and surrounding Denton County in relationship to the Denton Landfill are discussed in Section
4.3. Tactics to develop infrastructure such as transfer station(s) to support future growth and regional
opportunity are evaluated in more detail as part of the Strategy to Plan for Future Growth and
Infrastructure (see Sections 8.0 and 11.4).
Organics processing facilities. The composting facility operated by the City is sufficient for the current
processing needs of the City. As the City looks to expand organics diversion, existing anerobic digestion
infrastructure at the Pecan Creek WWTP provides the potential opportunity to sustainably manage food
waste for the production of renewable energy. Tactics to increase organics diversion through established
and novel pathways are evaluated in more detail as part of Strategy to Implement Innovative Organics
Management (see Sections 6.0 and 11.2).
C&D processing facilities. With the discontinuation of the City-operated C&D diversion facility, the
City must currently look to the private sector for C&D diversion services. The proximity of the Champion
mixed C&D recycling facility provides opportunity to divert the potentially large quantities of C&D
material generated as a result of the City’s growth over the 2040 planning horizon. Since this processing
capacity exists, there is the opportunity for the City to drive recycling of this material through various
partnerships, incentives and/or policy mechanisms. Tactics to support and grow C&D recycling markets
and partnerships are evaluated in more detail as part of the Strategy to Support New Markets and
Leverage Partnerships (see Sections 10.0 and 11.6).
Home chemical collection. The City’s HCC program is well-established. There is an opportunity for
regionalization to provide access to surrounding communities for a user fee. Prior evaluation performed in
2018 documented a high level of interest and need in many of the surrounding communities. This could
be approached similar to other NCTCOG communities, where interlocal agreements are used to set the
terms and fees associated with residents outside the City of Denton accessing the HCC. Interlocal
agreements and other options for inter-governmental cooperation are discussed in Section 4.2. Tactics to
increase HCC material diversion through regional partnerships are evaluated in more detail as part of the
Strategy to Support New Markets and Leverage Partnerships (see Sections 10.0 and 11.6).
5.0 PUBLIC EDUCATION, OUTREACH AND COMPLIANCE
Providing effective public education and outreach to residential and commercial customers is critical for
the ongoing and future success of the City’s solid waste and recycling programs. Guidance and support
from the City can shape proper participation and positive program engagement experiences for customers,
which increases customer satisfaction and enables progress toward the City’s goals.
This section includes a description of the components of a successful education, outreach and compliance
program, an evaluation of the City’s programs among these components, case studies highlighting key
considerations, current system findings, and recommendations. Tactics to implement the Strategy to
Enhance Education, Outreach and Compliance were developed based on the evaluation, case studies, and
findings presented in this section as well as the outcomes of workshop discussions with City staff. Section
5.0 presents the Strategy to Enhance Education, Outreach and Compliance in more detail. Section 12.0
provides the implementation plan.
5.1 Education, Outreach and Compliance Evaluation
This section provides a detailed description of key components of a successful education, outreach and
compliance program then compares the City’s current efforts to those key components to evaluate the
programs and support further discussion about components of the program that should be kept, added, or
changed.
5.1.1 Components of a Successful Education, Outreach and Compliance
Program
Burns & McDonnell has developed the key components of a robust solid waste and recycling education,
outreach and compliance program as follows, with brief descriptions.
Establish program goals. This is a critical first step for any successful education, outreach and
compliance program that dictates how the program will be evaluated over time and the intended
outcomes of the program. Specific quantitative metrics, programmatic improvements, and
definitions of success should be determined to ensure that targeted action is taken to work toward
the established program goals.
Determine financial commitment. Determining the ability to support the program financially
will ultimately dictate the long-term success of any education, outreach and compliance program.
Target annual costs, dedicated staffing, and funding sources should be established before content
is generated and distributed to ensure that a sustained effort is possible.
Identify target audience(s). Depending on the program goals and financial commitment, the
next component of a successful education, outreach and compliance program is identifying the
target audiences. Audiences may include broader categories of customers including residential
customers, multi-family, and commercial customers or focus on more targeted audiences such as
specific housing types, collection routes, businesses, or home-owner associations.
Develop messaging content. Generally, there are two types of communication that are deployed
as part of education, outreach and compliance programs: specific program information (e.g., dates
of service, acceptable materials, set out instructions) and general environmental services
information (e.g., why recycling is beneficial, impacts of contamination). The messaging content
should be determined based on data-driven analysis and crafted with simple and easily
understood language and graphics to communicate information in a succinct and effective
manner.
Content distribution and public outreach. The distribution channels of content as part of any
successful education, outreach and compliance program should be based on the target audience
and the type of content. The most effective approach to reaching the target audience and
impacting behavior change is distribute the content where the audience already consumes
information. This may require many diverse forms of content distribution, including traditional
bill stuffers, traditional advertising (e.g., billboards, bus stops, radio advertising), in-person
meetings or events, social media platforms (e.g., Facebook, Instagram, NextDoor) or other
publications such as newsletters or other local print media.
Evaluate program effectiveness. This is a critical step to having a successful long-term program
that is able to maintain consistent messaging to the target audience over a sustained duration of
time, even as members of the selected target audience change. Evaluation of program
effectiveness may include activities such as tracking data (e.g., program costs over time,
engagement from target audience), establishing a meaningful feedback loop, and consistently
evaluating progress toward goals.
Deploy compliance. Holding material generators accountable is a component of having a
successful long-term education, outreach and compliance program. Compliance activities may
include cart tagging, skipping service or removing carts from consistently bad actors,
implementing service fees, and/or otherwise enforcing local regulations or ordinances.
Regional collaboration. Approaching solid waste and recycling from a regional perspective is
the final component of having a successful long-term education, outreach and compliance
program. Regional collaboration activities include coordinating with other municipalities on the
consistency of messaging, timing of content deployment and channel(s) of distribution. The North
Central Texas Council of Governments (NCTCOG) has developed and deployed a regional
education campaign intended to support regional collaboration among communities in North
Central Texas, and is described in further detail as part of Section 5.2.
5.1.2 Overview the City’s Education, Outreach and Compliance Efforts
The City uses a variety of programs and services to provide public education, outreach and compliance.
This section provides a detailed summary of activities as part of the City’s program organized by the
components of a successful education, outreach and compliance program as described in the previous
section.
Establish program goals
The City has anecdotal goals for its education, outreach and compliance program to increase the amount
of material diverted from the Landfill and reduce the amount of contamination in the recycling stream.
Determine financial commitment
The City has several funding sources that support its education, outreach and compliance program
including the Solid Waste Enterprise Fund, annual budget transfers for multi-departmental efforts, and a
public education fee of $0.80 per ton provided to the City by Pratt. The education, outreach and
compliance budget is approximately $308,000, including salaries.
The City’s staffing level include two coordinator positions with SWR and the Business Account
Coordinator that oversees two internship positions. Code compliance has six to seven FTEs that spend
about 10 percent of their time managing solid waste and recycling violations on an as-needed basis when
a set out is placed incorrectly, material is left in areas it should not be, increased volumes of litter or any
other code violation as it relates to solid waste and recycling.
Resources from the Public Affairs office also support solid waste and recycling by providing assistance
with large campaign efforts and communicating feedback from customers to inform the development of
education, outreach and compliance efforts.
Identify target audience(s)
The City focuses its education, outreach and compliance program on three target audiences: residents,
commercial establishments, and local institutions. The City’s education, outreach and compliance
coordinators and intern staff target residential customers along routes that have consistently high
contamination and engage with Homeowner Associations (HOAs) and multi-family tenants to encourage
recycling and minimizing contamination.
The City also engages with commercial establishments that are serviced by the City and local institutions
such as Denton Independent School District (DISD) and universities including University of North Texas
(UNT) and Texas Women’s University (TWU).
Develop messaging content
The City develops messaging content that includes both service information and general environmental
information. Service information includes alerts about holidays, potential service disruption, set out
requirements and other supporting information for customers. Figure 5-1 shows an example of messaging
content that communicates service information.
Figure 5-1: Example of Messaging Communicating Service Information
General environmental information includes facts about the benefits of recycling, tips to encourage source
reduction and other facts and figures that would encourage customers to participate in the recycling
program and otherwise support the City’s goals. Figure 5-2 shows an example of messaging content that
communicates general environmental information.
Figure 5-2: Example of Messaging Communicating General Environmental Information
Typical topics contained in the City’s messaging include, but are not limited to:
Set out requirements (e.g., when carts should be set out, distance between carts, set out limits)
Seasonal programs (e.g., leaf collection, pumpkin composting)
Minimizing recycling contamination (e.g., correct and incorrect materials)
Re-use opportunities (e.g., non-recyclable easter eggs)
HCC information
To develop the content there is multi-departmental coordination between the Public Affairs outreach
group and SWR. The two groups determine the content for the following month by discussing the top
contaminants that have been reported by Pratt, other relevant information based on customer engagement
with the Waste Wizard, and/or questions submitted to the City. Public Affairs also supports education,
outreach and compliance efforts by providing graphic design resources and formatting content to push
through the City’s general channels when key messaging is intended for a wider audience or demands a
higher level of attention such as milestone campaign efforts or service changes. Additionally, messaging
content is developed in both English and Spanish to meet the needs of residents.
Messaging distribution and public outreach
The City distributes messaging and engages with its target audience through a diverse set of channels and
communication mechanisms. The following lists the distribution channels, with brief descriptions:
Website. Provides program and service
information about solid waste and
recycling including the Waste Wizard
application. Users perform about 3,000
Waste Wizard searches per month, and
users can type in the name of a product or
packaging type to receive information
about how to recycle it (Figure 5-3). As
described above, the Waste Wizard is used
to provide information to customers as
well as inform the development of content
based on the type and frequency of
queries.
Social media. The City leverages several
social media platforms including NextDoor, Facebook, Instagram and Twitter. Each platform has
a different userbase and the content that is pushed out through each one is tailored to the type of
audience that engages with the content. For example, NextDoor is very useful for providing
service information to the residential community, Facebook can be used to host events and
engage businesses, and Instagram is more conducive to posting easily digestible facts and figures.
Messaging pushed out through social media platforms is geographically targeted (e.g., the City
pays for increased circulation of the content to users in designated locations) twice per week to
areas of the City with high recycling contamination.
In-person site visits, presentations and virtual events. The City’s education, outreach and
compliance coordinators provide tours of the City’s Solid Waste Facility to educate groups about
material management. Coordinators also visit schools, HOAs, and other environmental groups to
provide presentations about the City’s programs and initiatives and collaborate to improve the
City’s material management. When visiting with schools, the coordinators focus on working with
school administration and janitorial staff, as these are the key stakeholders who can implement
changes to improve the quality of recycling generated. Additionally, when in-person site visits or
presentation are not possible (e.g., due to COVID restrictions) the City has hosted Facebook Live
events to provide education and outreach virtually.
Figure 5-3: Waste Wizard
Direct outreach. As needed, the
City will provide direct
outreach to customers during
big campaign efforts or when
service changes are being
implemented. Direct outreach
includes making phone calls to
customers, including solid
waste and recycling information
in the City’s Citizen Connection
newsletter, developing and
sending direct mail to residents
(Figure 5-4), distributing annual
calendars, and generating flyers
that are included with monthly utility bills (e.g., bill stuffers).
Traditional media and advertising. The City distributes content through traditional media
including press releases, radio spots, airtime on Denton TV (DTV), and local print media (e.g.,
community impact).
Evaluate program effectiveness
The City evaluates program effectiveness by communicating with Pratt regarding levels of contamination,
analyzing data collected through social media platforms (e.g., engagements, impressions) and the Waste
Wizard application that indicated if the community is receiving information and through questions and
comments about solid waste and recycling that are provided by the community. The feedback from Waste
Wizard is used as both an internal and external feedback mechanism where the City can identify which
materials are causing most confusion based on the questions that are asked and can promote information
that is most impactful to communicate to the community.
Deploy compliance
The City has a “Lift the Lid” recycling set out program where interns go into the field utilizing tablets to
evaluate residential recycling set outs, targeting residential routes with high contamination (contamination
data provided by Pratt). If individual set outs are above 15 percent contamination, an “oops” tag is affixed
to the set out indicating what was wrong with the set out. These set outs are not serviced that week, and a
follow-up check is conducted the following week.
Figure 5-4: Brochure Mailer
When commercial set outs are contaminated, the City will dispose of the material and charge the
customer a $75.00 empty charge. Typically, recycling customers do not pay a processing fee. While the
City may conduct an intervention to ensure that contamination does not continue, there are not additional
fines associated with contaminated commercial containers.
Regional collaboration
The City integrates the NCTCOG’s “Know What to Throw” campaign content into its own messaging in
an effort to present a consistent message to audiences that may consume information in Denton but reside
or work elsewhere in the region. Figure 5-5 shows messaging from the City that incorporates the look and
feel of the “Know What to Throw” campaign, including the cart mascot.
Figure 5-5: Example of Regionally Collaborative Messaging
5.1.3 Evaluation of the City’s Education, Outreach and Compliance Efforts
This section evaluates the City’s current efforts against the components of a successful education,
outreach and compliance program. Table 5-1 provides an evaluation matrix indicating the strengths,
weaknesses, and opportunities associated with each of the program components of the City’s current
system.
Table 5-1: Evaluation Matrix of City’s Education, Outreach and Compliance Efforts
Program Component Strengths Weaknesses Opportunities
Establish program goals City has a clear high-level goal for the program to increase
diversion and decrease recycling contamination.
City does not report progress toward goals on recurring
interim basis. Success metrics are not clearly defined.
City can set quantitative goals and track ongoing progress
toward them including recycling/diversion rate, contamination
rate, capture rate, pounds per household disposal rate, and
community engagement with distributed content.
Determine Financial
Commitment
City’s current program is adequately funded and has the
capability to leverage multi-departmental coordination and
support.
City’s education and outreach financial assistance received
from Pratt (currently $0.80 per ton received at the MRF) may
not be sufficient to support future program needs.
Additionally, this per ton rate is lower than peer Cities in the
region. Further discussion of education and outreach financial
assistance is provided in Section 11.1.
City can establish program needs and financial commitment in
conjunction with more granular goals and target metrics.
Further discussion of anticipated programmatic needs for
education and outreach are provided in Section 11.1.
Identify target audience(s)
City identifies general target audiences and distributes
messaging designed for their consumption, including in both
English and Spanish.
City’s general target audiences are not segmented by groups
(e.g., age, gender, demographics) and no further specificity
has been established (e.g., specific business types, City
departments, types of residents).
City can identify where target audiences overlap to capture
synergies between them (e.g., middle-aged men that are both
residential customers and commercial customers)
Develop messaging content
City has multi-departmental collaboration and timely content
creation, using feedback from the community to influence
messaging content.
City struggles to determine which content is causing intended
behavior change, and if behavior changes are having the
intended impact on program performance.
City can incorporate best practices for developing content,
which include establishing messaging that supports the needs
of the City’s recycling processor, collection operation, and
residents, so all audiences consume messages that are
consistent, predictable, visually appealing and easy to
understand. Additional topics that could be considered include
information about MRF operations, labor demands, impacts of
City growth on recycling, minimizing litter or other
information that is not specific to individual recycling
materials but successfully engages audiences and educates
them to best support the City’s programs.
Messaging distribution and
public outreach
City has access to a diverse selection of distribution channels
including multi-departmental effort to push out content. City
leverages social media to reach a more target audience.
Service-related content increases engagement with
general/environmental content and vice versa.
Multiple City departments pushing out content may cause
confusion during program evaluation.
Multi-departmental efforts may overlap at times and it may be
worth considering the benefits of consolidating resources to
support education, outreach and compliance more
comprehensively as City continues to grow. However, there
are challenges associated with this approach further described
in Section 5.2.5.
Evaluate program effectiveness City tracks and leverages data from social media and Waste
Wizard to inform content development.
City has limited regular tracking of some key success metrics
including cost-effectiveness, waste reduction achieved, or
contamination reduction that may cause challenges gauging
program success.
City can track key performance metric data (e.g., program
costs over time, engagement from target audience, levels of
contamination) to establish a more impactful feedback loop
and more consistently evaluate progress toward interim
milestones/goals.
Deploy compliance
City has established the “Lift the Lid” program with in-field
technology (e.g. tablets) and is able to track which set outs
have been audited. City provides education at the point of
generation with “oops” tags. City also audits contaminated
commercial and multifamily containers and provides
intervention.
When the City follows up for second audit following an
“oops” tag, there is often no set out at that location. Also, there
is no penalty/incentive to minimize multi-family or
commercial recycling contamination.
City can scale up the “Lift the Lid” program to target
additional areas with high contamination. Also, removing the
recycling cart for repeat high contamination residential set
outs and implementing a penalty may result in positive
behavior change. Similarly, implementing financial penalties
for contaminated commercial set outs may result in positive
behavior change.
Regional Collaboration
City has generally reviewed regional campaign content and
uses it as one of several factors in developing messaging,
aligning its content to be consistent with the information
distributed on a regional basis.
City engages in limited regional collaboration to develop
messaging consistent with peer municipalities.
City can collaborate more closely with the NCTCOG regional
campaign to coordinate timing and content of messaging with
peer municipalities and drive further engagement in its
distributed material by amplifying unified messaging.
Comprehensive Solid Waste Management Strategy Public Education, Outreach and Compliance
City of Denton, Texas 5-10 Burns & McDonnell
5.2 Case Studies
This section provides overviews of practices that have been incorporated by municipalities in the region
for the City’s consideration and to inform the key findings and recommendations that follow. The case
studies are presented by topic and organized as follows:
Regional education and outreach campaign
Cart auditing programs
Compliance incentive policies
Commercial recycling support
Strategically allocate resources
5.2.1 Regional Education and Outreach Campaign
The NCTCOG regional “Know What to Throw” Campaign is highlighted to provide information and
context about how the City can continue to actively participate in the regional campaign and incorporate
its overall approach to campaign development as the City seeks to advance its education, outreach and
compliance programs.
The NCTCOG developed and deployed the “Know What to Throw” campaign in June 2019. NCTCOG
worked with Burns & McDonnell and The Recycling Partnership to host a series of surveys, focus groups
with stakeholders of the recycling value chain and data analysis to develop clear goals for the campaign
including increasing quantities of recycling generated in the region, reducing contamination in the
recycling stream and taking steps to proactively minimize the cost of recycling processing in the region.
The campaign’s target audience included residents that lived, worked and played in the North Central
Texas region and to increase collaboration among municipalities, streamline messaging and minimize
confusion for residents that may live in a different municipality than they work. Messaging content was
developed based on the results of a regional waste characterization, focus groups, and individual
interviews with the Material Recovery Facility (MRF) operators in the region including graphics, blogs,
pre-written social media posts, and videos that municipalities could easily download, edit, and incorporate
into their existing education and outreach programs. Based on the financial commitment established at the
start of the campaign development, NCTCOG determined that the most cost-effective use of resources
would be to distribute content through a blend of traditional advertising (e.g., billboard, radio spots),
social media (e.g., Facebook, Instagram, Youtube), and local publications (e.g., community impact).
Additionally, a quiz was developed to help drive engagement and teach residents in the region the most
valuable and detrimental recyclable materials based on waste characterization data analysis and feedback
from MRF operators.
Comprehensive Solid Waste Management Strategy Public Education, Outreach and Compliance
City of Denton, Texas 5-11 Burns & McDonnell
After the campaign was launched in 2019, NCTCOG staff have actively collected engagement data,
incorporated feedback from municipalities and residents, and hosted recycling roundtable events to
support further coordination and collaboration among municipalities in the region, amplify the collective
messaging being distributed, and discuss next steps to continue working to achieve the goals of the
campaign. During the initial development of the campaign, NCTCOG identified social media as the most
cost-effective medium to distribute content to the largest target audience (e.g. residential generators) in
the region. For this reason, social media is the primary distribution channel for the ongoing campaign that
is supplemented by traditional advertising and local publications.
5.2.2 Cart Auditing Programs
Cart auditing programs are intended to provide information about material set out for collection including
where carts are placed and the level of contamination in them. The Cities of Dallas and Fort Worth have
cart auditing programs in place. The approaches these cities have taken to cart auditing and challenges
they have encountered are provided for context as the City considers scaling its current cart auditing
program.
The City of Dallas’ “Take a Peek” program was established to better understand contamination levels,
where staff inspect recycling carts for contamination to identify areas and specific routes with high
contamination levels. With limited staff resources to inspect recycling carts, the goal was to “peek” into
the carts of 100 households per district each year (500 total). Given COVID-19 concerns, the program has
been suspended and will be re-established and eventually expand to a route-based approach, with a goal
to check every household along a specific route (about 1,500 total households) in four phases. However,
vacancies in staff positions and labor shortages have caused challenges in scaling the program to collect
more comprehensive and consistent route-based data.
The City of Fort Worth’s “Blue Crew” checks the contents of residential set outs each day and leaves tags
to inform the resident of any contamination that are found in recycling carts. The Blue Crew removes and
bags items/articles that are identified as contaminated and attach a tag to the bag or cart explaining the
situation to the customer. The Blue Crew staffing level of 6 to 7.5 full time employees (FTEs) allows Fort
Worth to effectively educate customers at the point of generation collaboratively with its contracted
recycling collection provider. Those who repeatedly are found to have put non-programmatic recyclable
goods in the recycling carts can be charged additional garbage fees, and have their recycling carts taken
away. Additionally, Fort Worth has found that by informing the community of the importance of
reduction contamination, there are few complaints about the auditing of set outs from residents.
Comprehensive Solid Waste Management Strategy Public Education, Outreach and Compliance
City of Denton, Texas 5-12 Burns & McDonnell
5.2.3 Compliance Incentive Policies
The Cities of San Antonio and Garland have policies that incentivize compliance with their solid waste
and recycling programs. These policy approaches have been summarized to provide context as the City
considers enhancing program compliance.
The City of San Antonio’s Solid Waste Management Department (SWMD) issues violations and collects
fees for cart contamination that are added to residents’ monthly utility bills from CPS Energy. SWMD
staff conducts cart audits and customers whose set outs are identified as contaminated are issued an initial
warning tag on the cart and a letter sent in the mail that informs residents of the problem. SWMD staff
members conducting the audit collect data including a picture of the cart, the serial number on the cart, a
picture of the home and pictures of the contaminated items to ensure that violations are sent to the correct
customer and information regarding the cart audit can be tracked. The second time that a cart is identified
as contaminated, SWMD staff leave a contamination fee tag to indicate that a fee will be placed on the
resident’s next utility bill.
Generally, contamination fees are $25 but increases to $50 for diaper contamination. Increased fees for
diaper contamination were added in 2018 because this specific contaminant represented a major problem
for San Antonio’s MRF. Another addition to the program has been the ability to wave a contamination
fee. If a resident is assessed a fee, they can have it removed from the upcoming monthly utility bill by
participating in an online educational activity within 10 days of the date of the fee notice letter. SWMD
allocates the revenue collected through contamination fees to fund the dispatch of a collection truck to
haul contaminated material for disposal rather than recycling.
City of Garland residents receive recycling service and are able to opt out of their program, meaning they
can ask the City not to provide recycling service. For this reason, only about 42,500 of the 63,000 total
refuse collection customers receive recycling collection service. Garland collection vehicle operators
identify and track customers that set out consistently contaminated carts by visually inspecting the carts
and recycling material as it is tipped into the collection vehicle from the cab.
Garland employs a “three-strike” rule to incentivize compliance with the recycling program. If the driver
encounters a contaminated recycling set out, the cart is tagged. If that same household has a second
unacceptable set out, the resident is sent a letter in the mail providing an official warning. Upon the third
unacceptable set out, the resident receives a call from the recycling outreach coordinator and their cart is
removed.
Although cart removal provides an incentive to remain in compliance with the program requirements for
minimizing contamination and proper set outs, if a resident’s cart is removed they are able to get it back
Comprehensive Solid Waste Management Strategy Public Education, Outreach and Compliance
City of Denton, Texas 5-13 Burns & McDonnell
upon request from the City and there are no further penalties, financial or otherwise, to further enforce
compliance.
5.2.4 Commercial Recycling Support
The Cities of Dallas and San Antonio provide support to commercial entities through business recognition
and technical assistance. The programs these cities have in place are described to provide context about
how the City may support increased diversion from commercial generators.
The City of Dallas Green Business Certification is a free service offered to recognize businesses that
prevent waste, incorporate recycling, and promote reuse, reduce, and composting in their operations. Any
business in Dallas that incorporates green practices and conserves resources can apply to become green
business certified including: multifamily properties, hotels, manufacturing companies, distribution
centers, warehouses, restaurants, bars, barbershops, office buildings, data centers, hospitals, and other
businesses.
Businesses applying for the Green Business Certification submit a complete scorecard to city staff that
identifies the types of programs that their business has implemented related to recycling, equipment
placement, zero waste policies, transportation, water conservation, and energy efficiency. The scorecard
also requires applicants to provide other data related to their solid waste management including their
contracted hauler and average monthly tonnage of garbage, recycling and organics generated. More
information related to the Green Business Certification program is available here:
https://dallascityhall.com/departments/sanitation/Pages/greenbusiness.aspx
The City of San Antonio has established a business certification and technical assistance program called
ReWorksSA to provide the local business community with consultancy, resources, materials, and training
at no cost. This program is a joint endeavor between the Solid Waste Management Department (SWMD)
and the Office of Sustainability (OS) that also serves as a promotion and recognition tool for
organizations that successfully complete the program and receive certification as a sustainable business.
ReWorksSA helps local businesses either start or improve recycling programs in the workplace and
supports the City of San Antonio’s climate initiatives by improving the environmental and economic
profile of the business community.
The certification process evaluates the number of programs and policies a business has in the areas of
recycling, energy conservation, water conservation, travel & transportation and a reduction in multiple
types of consumption. Points are awarded for both the number and the effectiveness of the best practices.
Comprehensive Solid Waste Management Strategy Public Education, Outreach and Compliance
City of Denton, Texas 5-14 Burns & McDonnell
Applicants can create an account on a dedicated web portal and review the best practices that are
available. City staff conduct an initial assessment with the business before they submit a formal
application for certification. After the application is reviewed, business are awarded bronze, silver, gold
or pinnacle status and certifications are valid for two years. More information related to ReWorksSA is
available here: https://www.reworkssa.org/
5.2.5 Strategically Allocate Resources
The Cities of Dallas and Frisco have adjusted their internal department roles and responsibilities related to
education, outreach and compliance. The changes these cities made to staffing, workflows, and overall
satisfaction with the resulting changes are highlighted to provide context about considerations that may
support the City to scale its public education, outreach and compliance program in the future.
The City of Dallas effectively develops, deploys and distributes messaging through multi-departmental
coordination. Responsibilities for public education and public outreach for solid waste and recycling
issues are shared between the City of Dallas’ Sanitation Department and the Office of Environmental
Quality and Sustainability (OEQS). When OEQS was established when the City reorganized its education
and outreach program by moving staff from multiple departments to OEQS. The purpose of the change
was to consolidate resources to develop a more comprehensive education and outreach program and to
more efficiently leverage staff resources (e.g., ability to develop messaging for multiple public education
and outreach topics using a single graphics designer).
Initially, OEQS took the role of providing all public education and outreach related to solid waste and
recycling; however, the Sanitation Department has since taken back the role of developing and deploying
content regarding collection scheduling, program compliance, and other service-related messaging. The
Sanitation Department and OEQS work closely together to coordinate content development and
messaging distribution to meet the objectives of its education, outreach and compliance program.
Although the City of Dallas has encountered challenges during COVID-19 with maintaining consistent
staffing levels to execute all programming (e.g., scaling cart audit program city-wide, increasing
community-based marketing efforts, etc.), the strategic allocation of resources between OEQS and the
Sanitation Department position Dallas to work more effectively to fully implement its education and
outreach program over time.
In 2019 the City of Frisco consolidated its education and outreach effort across multiple departments with
environment or sustainability-related messaging under the Parks Department to qualify for additional
grant funding to expand its programming. As such, staff that previously worked with the Environmental
Services Department have transitioned to the Parks Department under the newly established Natural
Comprehensive Solid Waste Management Strategy Public Education, Outreach and Compliance
City of Denton, Texas 5-15 Burns & McDonnell
Resources Division. Although the programs and content related to solid waste and recycling remained the
same, the communication and preparation required to develop and deploy the material under the new
consolidated organization structure required an adjustment in the Environmental Services Department
workflow.
There may be challenges associated with a consolidated organization given the increase in scope of
education and outreach content that would be deployed. For example, if a central group were developing
and deploying education and outreach content, there may be less information pushed out specific to solid
waste since the overall number of environmental topics that need to be covered would increase.
Additionally, there is potential for a more centralized approach to minimize the number of staff that have
a depth of knowledge of solid waste concepts. Any strategic allocation of resources must take into
account the knowledge, capabilities and capacity of resources that manage a consolidated program to
effectively receive feedback specific to solid waste programs and incorporate that information into the
content developed and deployed.
5.3 Key Findings and Recommendations
The following presents consolidated key findings and recommendations related to the City’s public
education, outreach and compliance efforts as a basis for the Strategy to Enhance Education, Outreach
and Compliance described and evaluated in Sections 11.1 and 12.0.
Current residential education and outreach efforts are extensive. The programs and services
provided to residents of the City are comprehensive and consistent. The City’s approach to
provide both specific resident information (i.e., time and day of collection) and also more general
environmental services (i.e., why recycling is worthwhile) effectively inform the community and
support ongoing program needs. Multi-departmental collaboration and communication to develop
and deploy messaging supports the current program needs and the education, outreach and
compliance services are consistent with other programs in the region and the City collaborates
closely with the MRF operator to identify key challenge materials to highlight in messaging.
Update and implement program metrics. The metrics for the City’s education, outreach and
compliance program do not provide a clear and measurable definition of success. Developing
program metrics that are driven by program goals and available funding (e.g., level of
engagement on social media platforms, number of compliance actions taken, participation rate,
material capture rate) would allow the City to better assess program effectiveness.
Advance data collection efforts that support future content development. The City should
consider approaches to scaling its cart auditing program and leveraging the hardware and
Comprehensive Solid Waste Management Strategy Public Education, Outreach and Compliance
City of Denton, Texas 5-16 Burns & McDonnell
software packages with Rubicon to actively collect and analyze data to assess key metrics and
evaluate program success over time. This data and analysis can become a valuable source of
insight in the development of future content, particularly managing changes to the program that
may be implemented based on the strategies developed and further detailed in Sections 11.1 and
12.0.
Identify future key target audiences. The City should identify sub-sets of its current high-level
target audiences to more effectively reach the milestones that are aligned with key metrics. More
focused target audiences may include specific types of businesses within the commercial sector
(e.g., grocery stores, fast-casual restaurants, vehicle maintenance shops, etc.), City departments to
ensure they lead by example on waste reduction and recycling efforts (e.g., collaboration with
Parks Department to incorporate best solid waste management practices in public space recycling,
minimizing litter, and illegal dumping), or residential customers that do not set out recycling cart
regularly and potentially contribute to a lower than ideal participation/set out rate.
Enhance compliance efforts. To successfully implement education and outreach efforts and
cause intended behavior change from target audiences, the City should consider enhancing its
compliance efforts by removing recycling carts from residents that are continually bad actors
similar to the City of Garland’s “three-strike” approach, or implement fees for excessive and/or
repeatedly contaminated set outs with the provision of a waiver if the resident engages in further
educational efforts (e.g., recycling quiz or mini-course).
Continue incorporating content provided by NCTCOG into education and outreach
materials. In an effort to support the regional recycling campaign, the City should continue to
incorporate the content of the regional campaign as it continues to advance to its own education
and outreach materials so residents are exposed to similar messaging regarding recycling
anywhere they are in the North Central Texas region. Additionally, as the education, outreach and
compliance program advances, consider developing dedicated campaigns using a similar
approach to NCTCOG’s regional campaign by collecting data, collaborating closely with
stakeholders, and setting goals with clearly defined definitions of success.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-1 Burns & McDonnell
6.0 ORGANICS MANAGEMENT
Organic materials include yard waste, food waste, biosolids, wood waste, and other waste as defined
below. Organic materials comprise a significant amount of the total waste stream generated from the
residential, commercial, and industrial sectors and present an opportunity for diversion. Effective organics
management can reduce the amount of waste that is sent to the landfill, generate renewable energy
through anaerobic digestion, create a valuable compost product, and return nutrients to the soil.
This section evaluates organic management strategies for the City and includes evaluation criteria, current
system findings, case studies highlighting key considerations, and recommended strategies. The Strategy
to Implement Innovative Organics Management was developed based on the findings presented in this
section as well as the outcomes of workshop discussions with City staff. Section 11.2 presents the
strategy in more detail. Section 12.0 provides the implementation plan.
Organics materials from residential, commercial, and industrial generators are defined as follows:
Yard waste. Materials such as leaves, grass clippings, brush, tree branches, stumps, and other
plant trimmings.
Food waste. Fruits and vegetables, meats, eggs and dairy, coffee grounds, and food-soiled
paper products such as napkins, pizza boxes and various types of cardboard and paper food
containers that are compostable. Food waste includes:
o Pre-consumer “kitchen waste” from food preparation including uncooked vegetative
waste such as peels, cores, tops, and loose coffee grounds.
o Post-consumer “plate waste” food discarded by consumers after the food has been sold or
served.
Biosolids. Solid, semi-solid, or liquid residue generated during the treatment of domestic
sewage in treatment works (sewage sludge that has been treated or processed to meet Class
A, Class AB, or Class B pathogen standards for beneficial use).
Wood waste. Non-C&D items such as pallets.
Other. Items such as natural textiles, material pumped from septic tanks (septage), water
treatment plant residuals, fats, oils, and greases (FOG), dead animals, and manure.
6.1 Evaluation Criteria
This section provides an overview of evaluation criteria for analyzing options for management of organic
material including an overview of the U. S. EPA Food Waste Hierarchy as a guiding tool for evaluating
the options (Figure 6-2) and discussion of pre- and post-consumer food waste management.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-2 Burns & McDonnell
6.1.1 Food Waste Recovery Hierarchy
Food waste is an issue throughout the entire country, in every sector including residential, multifamily,
commercial, and industrial. In the United States, an estimated 30 percent of food goes from farm to table
to landfill43. This presents not only an issue downstream to manage this food waste, but also economic
and environmental impacts along every step of the production, distribution, and consumption chain.
The U. S. EPA Food Recovery Hierarchy prioritizes actions organizations can take to prevent and divert
wasted food. Each tier of the Food Recovery
Hierarchy focuses on different management
strategies for wasted food. The top levels of the
hierarchy are the most preferred methods to prevent
and divert wasted food because they create the
greatest benefit for the environment, society, and the
economy. This hierarchy is used as a tool in
implementing an approach to food waste
management.
The City is well positioned with the infrastructure
for both composting and anaerobic digestion of food
waste. The more preferred strategy, based on the
Food Recovery Hierarchy, is anaerobic digestion (industrial uses) over composting; however, both
strategies are preferred over landfill disposal. Other strategies that rise higher on the food recovery
hierarchy, such as source reduction (e.g., smart purchasing), feeding hungry people (e.g., food donation)
and feeding animals, are higher priority.
Diverted food waste is most commonly processed at composting facilities. High-quality compost is a
valuable product that enriches soil, helps retain soil moisture, and suppresses plant diseases and pests.
Using compost can reduce the need for chemical fertilizers.
Anaerobic digestion, another means of processing food waste and other organics, creates biogas and a
digestate material that can be used as a soil amendment. Captured biogas can be used to generate
electricity, as fuel for boilers or furnaces, or create pipeline quality gas or compressed natural gas that can
43 US Department of Agriculture, The Estimated Amount, Value, and Calories of Postharvest Food Losses at the
Retail and Consumer Levels in the United States. 2010 Economic Research Service.
Figure 7-1: U.S. EPA’s Food Recovery Hierarchy
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-3 Burns & McDonnell
be sold as a vehicle fuel or sold on the open market. Most commonly it is used to generate electricity and
provide combined heat and power.
6.1.2 Pre-consumer versus Post-consumer Food Waste
Pre-consumer food waste. Pre-consumer food waste is only a portion of the food waste pie but there are
many benefits to diverting this material. Pre-consumer food waste is considered “back of house” waste or
“kitchen waste” that comes from food preparation. Collection of this material is controlled by staff who
can be trained; workstations can be designed to efficiently collect the material; and contamination is
typically low. The City’s Compost Facility is accepting pre-consumer food waste for composting and the
City has the collection infrastructure to grow this program.
Post-consumer food waste. Post-consumer food waste programs would capture a larger quantity of food
waste, but it comes with challenges including collection, contamination, and processing. Post-consumer
food waste collection includes food waste that is generated after the food is prepared and served. Two
challenges are prominent in post-consumer food-waste programs: food & beverage packaging and
consumer responsibility for food-waste disposal. There are many solutions to overcome these challenges,
but it takes intention and commitment on behalf of the generators to have a successful program. The
City’s Compost Facility is hesitant to accept post-consumer food waste due to the potential attraction of
vectors. The City’s Pecan Creek WWTP has anaerobic digesters which have ability to accept all food
waste (see discussion in Section 6.3).
6.2 Generation and Diversion Summary
The City has progressive programs to address organics management and divert material for beneficial use.
The City diverts 19 percent of its total generated MSW (residential and commercial combined) through
their composting efforts. However, organics still comprise over 40 percent of the waste generated for
landfill disposal from the residential and commercial sectors. Section 3.3 details the solid waste
generation, recycling, and disposal for the City by sector and data from that section is referenced
throughout this section.
The City’s efforts to capture organic waste for composting is successful, especially in the categories of
yard waste and biosolids. Figure 6-2 shows the tonnage of organic material managed by the City at the
Compost Facility and Landfill in 2020. This figure does not include organic material diverted or handled
by private haulers or other activities. Based on this tonnage information, the largest opportunity to
increase organics diversion is commercial sector food waste, followed by residential food waste. The
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-4 Burns & McDonnell
majority of residential and commercial yard waste is being captured through collection programs.
Biosolids are effectively managed through composting.
Figure 6-2: Organic Material Managed by the City in 2020 (Tons)
6.3 Organics Management Infrastructure
City of Denton Compost Facility. The Compost Facility is managed by the City’s Pecan Creek WWTP
staff. The Compost Facility currently accepts yard trimmings, biosolids, and relatively small quantities of
pre-consumer food wastes co-collected with residential yard trimmings for processing. Post-consumer
food waste is not accepted at this time. The City has considered allowing post-consumer food waste but
elected not to at this time due to concerns related to potential odor and vectors (primarily feral hogs).
The Compost Facility is permitted and currently operated by the Pecan Creek WWTP through their
biosolids permit. The MSW disposal permit for the Denton Landfill also allows for on-site composting at
the Landfill, which could potentially be pursued to address future growth of the program. The specific
type of permitting or notification required by the TCEQ varies depending on the types of materials
accepted for composting. The specific permitting considerations would need to be further explored to
fully understand the options available.
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
Residential Yard
Waste
Residential
Food Waste
Commercial
Yard Waste
Commercial
Food Waste
Biosolids
Compost Facility Tons Landfill Tons
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-5 Burns & McDonnell
The Compost Facility has room for growth at its current location, specifically for additional windrows.
The grinding operation, however, is space constrained and the City is considering options for moving this
operation to another area on the landfill.
Pecan Creek WWTP. The WWTP operation includes an anaerobic digester as a function of its treatment
process. The digester produces biogas which is used to produce energy for onsite electricity generation.
The anaerobic digester currently only processes biosolids but the City is analyzing the system’s capacity
to accept food waste for co-digestion with biosolids and the quantity it can receive. The City recently
received a grant from NCTCOG (further discussed in Section 6.5) which includes the purchase of a piece
of equipment called a macerator, used to process food waste and prepare it for introduction into the
anaerobic digester. With the anticipated increase of food waste material collected for processing from the
commercial pilot program (further discussed in Section 6.6.1), additional staff and equipment may be
required. The financial impacts would need to be addressed between the WWTP and SWR.
6.4 Yard Waste – Residential and Commercial
The City’s current residential and commercial organics collection programs are focused primarily on the
collection of yard waste materials. These materials can be ground for mulch and/or composted at the
City’s Compost Facility at the Pecan Creek WWTP. Currently, approximately 90 percent of the yard
waste generated by residential customers is diverted through the curbside collection program. Additional
yard waste and brush is diverted when clean loads of yard waste are received at the Denton Landfill
scalehouse. This material is sent to the Compost Facility for composting rather than landfill disposal.
This section describes various options for managing residential or commercial yard waste including those
currently used by the City, followed by a summary of the strengths, weaknesses, and opportunities
associated with the City’s current yard waste program (Table 6-1).
6.4.1 Yard Waste Options
Residential source reduction and backyard composting. Promoting source reduction of yard waste
includes mulch-mowing of grass clippings and leaves and backyard composting. Backyard composting is
an effective way that residents can manage their yard waste at home, creating a usable, beneficial lawn
and garden product. The City is not currently promoting backyard composting to residents through web
resources or classes. Given that it is challenging to track, it is unknown how prevalent backyard
composting is among residents. There are no City regulations precluding single family homes from
backyard composting.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-6 Burns & McDonnell
Residential yard waste collection. The City’s residential curbside collection program includes weekly
collection of yard waste and brush as part of the basic service. In 2020, 5,606 tons of material was
collected through the residential curbside program, and waste characterization results, described in
Section 3.4, indicate that very little yard waste is sent to the landfill. While significant growth is
anticipated from the Hunter-Cole development, trends such as zero lot line development will result in less
yard waste generation from these neighborhoods.
Commercial yard waste collection. Yard waste generated by the commercial sector is generally handled
by landscaping companies. Due to this, it is unknown how much yard waste is generated by the
commercial sector. The City provides brush collection service to a small number of commercial
customers and material is processed at the City Compost Facility. Most commercial yard waste customers
request intermittent service to handle material generated due to weather related events. In 2020, the City
collected approximately 27 tons of organic material from the commercial sector. Despite the City’s
commercial collection program for yard waste, there is still yard waste being disposed in the landfill. In
2020, there were an estimated 6,500 tons of yard waste disposed of in the landfill (based on waste
characterization results presented in Section 3.4).
Yard waste diversion program at the Denton Landfill. The largest waste stream processed at the
City’s Compost Facility is vegetative waste sourced from clean loads brought to the Denton Landfill by
residential and commercial customers from within Denton or surrounding communities. In 2020, landfill
customers delivered 19,700 tons of material to the Compost Facility for processing. The Compost Facility
does not track the source of these drop off customers, but tonnage from this program has been assumed to
be from the commercial sector.
Table 6-1 provides an evaluation matrix indicating the strengths, weaknesses, and opportunities
associated with each of the program components of the City’s current system. Overall, yard waste
diversion is high and the capture rate from the residential and commercial sectors is high. The City’s
collection programs are working and should continue to be provided and promoted.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-7 Burns & McDonnell
Table 6-1: Evaluation Matrix of the City’s Yard Waste Programs
Program Strengths Weaknesses Opportunities
Residential yard
waste
City-provided weekly
collection service in the
base rate for all single-
family residences.
Minimal promotion of
source reduction and
backyard composting.
Promote activities such
as backyard composting,
mulch mowing grass.
Partner with County
Extension Service to
deliver compost
education and materials.
Encourage xeriscaping.
Commercial yard
waste
City offers service to the
commercial sector to
manage yard waste.
Yard waste is still
ending up in the landfill
from the commercial
sector.
Promote commercial
collection and drop off
programs. Consider
landfill restrictions on
yard waste (discussed in
Section 7.2).
6.5 Residential Food Waste
Food waste represents 32 percent of the residential refuse sent to landfill and a significant opportunity for
diversion. This section describes various options for managing residential food waste including those
currently used by the City, followed by a summary of the strengths, weaknesses, and opportunities
associated with the City’s current residential food waste programs (Table 6-2).
6.5.1 Residential Food Waste Options
Promote source reduction. Awareness and understanding of the issues surrounding food waste can
promote behavior change. Education and outreach campaigns that promote awareness around the topic of
food waste can inspire residents to make more efficient choices in food purchases, meal planning, and
serving size to ultimately reduce waste. The City does not currently promote source reduction through
web resources or classes.
Promote backyard composting. Backyard composting is an effective way that residents can manage
their pre-consumer food waste at home, creating a usable, beneficial lawn and garden product. The City is
not currently promoting backyard composting to residents through web resources or classes. It is
unknown how prevalent backyard composting is to residents of Denton. There are no City regulations
precluding single family homes from managing food waste through a backyard compost bin. Promotion
of backyard composting allows the City the opportunity to enforce any provisions, such as setback
distances, vector prevention, or container requirements.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-8 Burns & McDonnell
There are organizations promoting backyard composting that would serve as resources. The State of
Texas Alliance for Recycling (STAR) serves as the statewide administrator for the Texas-based Master
Composter programs and can provide resources and technical assistance to communities hosting Master
Composter training events44. Texas A&M AgriLife Extension provides research-based information and
educational materials as well as classes on backyard composting45.
City curbside collection of pre-consumer food waste. In addition to the City’s yard waste collection
service, single-family residents can place pre-consumer food waste in their carts or paper bags. Weekly
curbside collection of organics is part of the base service for all single-family residents. Quantities of food
waste diverted is unknown due to the comingling of food waste with yard waste. This program is
promoted as part of ongoing education and outreach efforts, with typically seasonally based content (e.g.,
pumpkins, food waste, holidays). There is an opportunity to further educate the community about
diverting pre-consumer food waste with their yard waste, if technically and economically feasible.
The benefit of comingling yard trimmings and food waste into one bin for curbside pickup is that there is
no addition level of effort to collect the material; the infrastructure is already in place including bins,
routes, trucks, and disposal. If residents do not purchase a yard waste cart or place yard trimmings in
paper bags, then they do not have a sanctioned method for setting out food waste. The primary level of
effort for the City is education of residents about the program and contamination. Promoting the program
will increase awareness and participation; promoting the correct way to participate will keep
contamination low.
Pre-consumer food waste is only a portion of the total food waste that is generated and limiting a program
to pre-consumer food waste limits the quantities of materials that can be diverted. The City’s Compost
Facility does not permit post-consumer food waste at their facility.
Private sector-provided residential organics collection program. There are private companies (e.g.,
Turn Compost, Compost Carpool) offering subscription-based food waste collection and composting
services in the North Central Texas region including Denton County. By law, no private or third-party
provider may collect materials curbside in the City of Denton for disposal, recycling, or diversion from
residential customers, as SWR is the exclusive provider of residential solid waste services. City residents
may still participate in these subscription-based third-party programs through drop-off collection, which
is offered by in Denton by at least two private companies for pre-consumer vegetative food waste.
44 https://www.recyclingstar.org/Master-Composter-Program
45 https://agrilifeextension.tamu.edu/library/gardening/composting/
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-9 Burns & McDonnell
Table 6-2 provides an evaluation matrix indicating the strengths, weaknesses, and opportunities
associated with each of the program components of the City’s current system. The City is already
engaged in the promoting source reduction, backyard composting, and curbside collection of pre-
consumer food waste; however, there are options to enhance these efforts to improve the overall
effectiveness.
Table 6-2: Evaluation Matrix of the City’s Residential Food Waste Programs
Program Strengths Weaknesses Opportunities
Promote residential
source reduction
As described in Section
5.0, the City has an
established and
comprehensive approach
to residential education
and outreach.
Source reduction is most
preferred on the food
waste hierarchy and
aligns with Sustainable
Denton messaging.
Limited promotion of
food waste source
reduction.
Partnership with Save
the Food (NRDC).
Promote backyard
composting
There are no City
regulations preventing
backyard composting.
Limited promotion of
backyard composting.
Partnership with County
Extension Service
and/or STAR Master
Composter program.
Curbside organics
program
There is a program and
infrastructure in place to
collect organic material
curbside, including
comingled pre-consumer
vegetative food waste,
for composting.
The City owns and
operates the composting
facility, providing
control over facility and
program materials.
Limited promotion of
the program limits
participation.
If residents don’t have a
cart and don’t set out
any yard waste in a
paper bag, then they do
not have a recognizable
container to set out food
waste.
The program is limited
to pre-consumer food
waste.
The City provides bins
that could be labeled
with stickers that inform
what materials are
accepted through the
organics program.
The City can collect
significantly more
material from residents
if operations were
modified to allow all
food waste (pre-and
post-consumer) at the
Compost Facility.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-10 Burns & McDonnell
6.5.2 Residential Food Waste Case Studies
Source reduction: Save the Food PSA. The Natural Resources Defense
Council (NRDC) developed a campaign to raise awareness about the
economic and environmental impacts of wasted food and encourage
Americans to take easy and actionable steps to reduce food waste in their
homes. The Save the Food campaign provides all materials for free on their
website to partnering organizations. Materials available for distribution
consists of a series of public service ads (PSAs), a website serving as a
resource for tips and tools to help consumers take action, and a host of
materials like posters and graphics to educate consumers on the issue of
food waste. The PSAs drive to SaveTheFood.com, where visitors can learn
how to better plan, store, and cook their food.
Backyard composting: Johnson County, Kansas. Since 2010, Johnson County, KS has supported a
backyard composting program for residents. For the first three years, the program included selling heavily
discounted compost bins. The program also includes hosting educational classes and attending
community events. The County partners with their local Extension office through Kansas State University
to develop backyard composting guidance and provide education and outreach to the community. The
backyard composting program won an award from the local regional planning agency for the significant
number of individual participants it has reached with its message through classes, events, and compost bin
sales.
Curbside collection of organics: San Antonio, Texas. San Antonio has a comprehensive curbside
collection organics program. Residents are provided a green cart (96- or 48-gallon) for items that can be
composted into nutrient-rich material that is made available back to the community. The San Antonio
organics program accepts all food waste (pre- and post-consumer), non-recyclable paper, and yard waste
in their collection cart for composting. Materials may be either loose or placed in paper bags in the cart.
When unaccepted items (contamination) are in the green cart, it cannot go to the compost facility and
must go to the landfill. Customers incur a fee when their cart is contaminated, and fees are collected
through the resident’s utility bill. Most violation fees are $25-50. In 2020, participation in this program
helped divert 70,000 tons of material from the landfill.
6.6 Commercial Food Waste
As shown in Figure 6-2, food waste generated by the commercial sector represents the most significant
opportunity for organics diversion in the City. This section describes various options for managing
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-11 Burns & McDonnell
commercial food waste including those used by the City, followed by a summary of the strengths,
weaknesses, and opportunities associated with the City’s current food waste programs (Table 6-3).
6.6.1 Commercial Food Waste Options
Promote source reduction, feed hungry people and animals. The City is not currently engaged in
promoting source reduction or feeding people and animals, the more preferred methods of food waste
management. There are several resources available in the region including the following:
The U. S. EPA has several great resources available to share with businesses including a food
waste audit tool, safety regulations and guidance for food donations, and a legal guide for feeding
animals leftover food46.
FoodSource DFW is a nonprofit organization that strives to reduce waste and distribute food and
resources to people and families in need47.
Melissa Feeders is a family-owned company specializing in all areas of the beef and dairy beef
industries that uses food waste for animal feed48.
Partnerships to potentially divert edible food to feed hungry people are discussed in more detail in the
Partnerships section (Section 10.0).
City-provided commercial organics collection program. The City offers collection service of pre-
consumer food waste to commercial customers. There are currently only a handful of participating
customers, which are big-box stores. In 2020, this program diverted 308 tons of pre-consumer food waste
for composting. Material is composted at the City’s Compost Facility. There is opportunity to expand this
program to more customers.
Commercial Food Waste Diversion – Pilot Program. The City recently received a grant from the
NCTCOG to fund a pilot program for food waste diversion from the historic downtown area. There are 50
bars and restaurants that would be offered the opportunity to join the pilot program. Each participating
business will be provided a kitchen bin to collect food waste and a 35-gallon locking cart for collection.
Food waste will be collected by the City and delivered to the City’s Pecan Creek WWTP. The material
will be macerated and processed in the anaerobic digester prior to being composted. Because the material
collected will be processed in the anaerobic digesters, the program is able to collect all food waste (pre-
46 https://www.epa.gov/sustainable-management-food/tools-preventing-and-diverting-wasted-food
47 https://www.foodsourcedfw.org/
48 http://www.melissafeeders.com/environmentalstewardship/valueaddedfeeds.html
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-12 Burns & McDonnell
and post-consumer). This pilot program will be a huge benefit to the City, providing a significant learning
opportunity on how to implement a successful program.
Private sector-provided commercial organics collection program. There are private companies (e.g.,
Turn Compost, Compost Carpool) providing food waste collection and composting services in the North
Central Texas region. It is unknown if they are providing services to any commercial entities the City of
Denton, and if so how many customers they service. Material collected by the private sector is typically
diverted for composting.
Table 6-3 provides an evaluation matrix indicating the strengths, weaknesses, and opportunities
associated with each of the program components of the City’s current commercial system. The City
currently offers collection of pre-consumer food waste to certain commercial customers and is exploring
expansion opportunities supported by regional grant funding. As with the residential sector, promoting
source reduction and feeding hungry people and animals are the most preferred methods of reducing food
waste and there are opportunities for the City to expand activities in these areas.
Table 6-3: Evaluation Matrix of the City’s Commercial Food Waste Programs
Program Strengths Weaknesses Opportunities
Promote
commercial source
reduction
The City’s education
and outreach program
includes targeted
outreach to commercial
generators.
Source reduction is most
preferred on the food
waste hierarchy and
aligns with Sustainable
Denton messaging.
Limited to no promotion
of food waste source
reduction.
Distribute U. S. EPA
and other available
resources to commercial
sector.
City provided food
waste collection
The City offers
collection of pre-
consumer food waste to
certain commercial
customers. The Compost
Facility has room to
expand.
There is limited
participation in the
program. Collection is
limited to pre-consumer
food waste. There may
be additional equipment
and staffing necessary
with increased material.
Increase participation in
the program through
promotion. Pilot
collection of post-
consumer food waste for
processing at the
WWTP anaerobic
digesters.
Commercial Food
Waste Pilot
Program
NCTCOG grant funding
has been awarded to
support this program.
The City provides a
valet service to the
The WWTP does not
currently have
experience processing
food waste. It is
unknown how much
material the AD and gas
Track data to learn from
this pilot program.
Expand the program
across the City.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-13 Burns & McDonnell
Program Strengths Weaknesses Opportunities
historic downtown
businesses and has
control over the
program.
There is existing
infrastructure and
experience with biogas
(landfill gas) upgrading.
storage system can
handle.
There may be staffing
and equipment needs
beyond what is currently
available to pilot or
scale-up food waste co-
digestion at the WWTP.
The U. S. EPA conducted a national survey to develop an “Excess Food Opportunities Map” to support
diversion of excess food from landfills49. Figure 6-3 shows that the restaurants and food services and food
wholesale and retail sectors make up the majority of potential sources of excess food in terms of number
of establishments. This information can be used to inform waste management and food recovery at the
local level.
Figure 6-3: Non-Residential Excess Food Generating Sectors
6.6.2 Commercial Food Waste Case Studies
Anaerobic digestion of food waste: East Bay Municipal Utility District. In 2006, the U. S. EPA
provided a grant to the East Bay Municipal Utility District (EBMUD) in Oakland, California to
49 https://www.epa.gov/sites/default/files/2020-04/documents/efom_v2.1_technical_methodology-clean_v2.pdf
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-14 Burns & McDonnell
investigate anaerobic digestion of food waste. The purpose of the study was to identify design and
operating criteria for anaerobic digestion of food waste, and to compare food waste digestion to that of
municipal wastewater solids digestion. The pilot showed that 100 tons of food waste anaerobically
digested per day produces enough energy to power up to 1,400 homes. A complete report of the technical
findings is available through the U. S. EPA archive50 and is summarized as follows:
The digester feedstock was comprised of pre- and post-consumer food waste pretreated by the
EBMUD food waste process to produce a pulp. The food waste evaluated during this study is
representative of food wastes available from restaurants, produce markets, fish markets and
wherever else food is prepared throughout California and around the country.
Anaerobic digestion of food waste provides approximately three to three and a half times more
methane production per volume of digester than does municipal wastewater solids.
Anaerobically digesting 100 tons of food waste per day, five days a week, provides sufficient
power for an estimated 800 to 1,400 homes for one year.
Food waste digestion results in half the residual produced after digestion, compared to residual
biosolids from municipal wastewater treatment sludge digestion. This residual was then
composted for further use.
Food waste contains more biodegradable solids, based on a higher volatile solids percentage (86
to 90 percent), than does municipal wastewater treatment solids (70 to 80 percent).
Because food waste is more readily biodegradable than municipal wastewater solids, a shorter
anaerobic digestion solids residence time is needed.
The shorter residence time means that food waste can be recycled in smaller digesters than
municipal solids, resulting in lower capital costs for new digesters.
An anaerobic digester can accept much more food waste at one time than municipal wastewater
solids without adverse process impacts.
Commercial food material disposal ban: Massachusetts. In 2014, the state of Massachusetts passed a
state-wide ban to reduce the disposal of commercial organic waste. The law requires any business or
institution which disposes of one ton or more of food waste per week to divert it through donations,
feeding animals, composting, or anaerobic digestion. 1,700 businesses and institutions were impacted by
the ban. Two years after the implementation of the law, the total reported diversion of food waste was
260,000 tons. In 2017 MassDEP released an economic impact analysis on the commercial food waste ban
which found that in two years the commercial food waste ban created more than 900 new jobs, and $175
50 https://archive.epa.gov/region9/organics/web/pdf/ebmudfactsheet.pdf
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-15 Burns & McDonnell
million in economic activity resulting from more composting facilities, food rescue organizations, and
waste haulers to keep up with demand51. Based on the success of the law, the state is lowering the
threshold of the ban so that it applies to businesses and institutions generating one-half ton or more food
waste per week, effective November 1, 2022.
Despite the success of the law, there have also been some unintended consequences through increased
nutrient pollution from composting facilities. Some facilities are discharging nutrient rich leachate into
local waterways, causing water quality impairments in local communities. Leachate samples collected
from one composting facility showed very high total nitrogen concentrations52. This highlights the need
for clear standards and oversight on composting facilities to protect water quality and conservation
efforts.
6.7 Biosolids
Biosolids generated by the City’s WWTP operations are composted at the Compost Facility. The Pecan
Creek WWTP generated 4,957 tons of biosolids in 2020 which was composted, sold, and marketed as
Dyno Dirt products. Composting biosolids is a common practice to beneficially use this byproduct of
wastewater treatment, with land application being another practice to recycle biosolids in Texas.
Biosolids composting requires the use of a bulking agent to improve the structure of the compost product.
Yard waste diverted through SWR programs serves as the bulking agent at Pecan Creek WWTP, avoiding
the need for the facility to purchase or procure a bulking agent (e.g., wood chips, shredded paper, animal
bedding) from an outside source.
6.8 Wood Waste and Other Organic Wastes
Wood waste. Wood waste represents less than one percent of landfilled material from both the residential
and commercial sectors. The Waste Characterization calculated the quantities at 0.5 percent from
residential and 0.1 percent from commercial. Wood waste from these sources may be acceptable in
compost programs.
Fats, oils, grease. Fats, oils, and grease (FOG) are not included in MSW calculations. There are no
reporting requirements therefore little is known about the quantity generated or the disposal destination.
FOG is generally collected from commercial and industrial generators by commercial collectors. FOG
51 https://www.mass.gov/files/documents/2016/11/vz/icfrep.pdf
52 https://www.epa.gov/snep/composting-food-waste-keeping-good-thing-going
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-16 Burns & McDonnell
may be processed at anaerobic digestion facilities, de-watered and land applied (where allowed),
composted, or landfilled.
Other. The majority of “other” organics represent waste streams that are not currently readily able to be
recovered for diversion such as textiles, leather, shoes, diapers, natural fibers, and rubber products.
Construction and demolition debris. Organic debris from construction and demolition (C&D) projects
present an opportunity for diversion. Source separated material of wood waste could be captured for
mulching and/or composting.
6.9 Key Findings and Recommendations
The following presents consolidated key findings and recommendations related to the City’s organics
management program for both residential and commercial generators, as a basis for the Strategy to
Implement Innovative Organics Management described and evaluated in Sections 11.2 and 12.0.
The City has a successful model for diversion of yard waste and biosolids with the infrastructure in place
to manage the material generated by the residential and commercial sectors. Food waste diversion is the
next frontier with the highest tonnages available for capture. The existing infrastructure including
collection and the Composting Facility at the WWTP is adequate for managing yard waste and biosolids;
however, as increased food waste is diverted, additional resources may need to be put towards handing of
the additional material. The financial impacts would need to be addressed between the WWTP and SWR
programs.
6.9.1 Residential Organics Recommendations
Promote source reduction. Consider leading the effort to promote source reduction to residents
through implementation of the key components of a robust education, outreach and compliance
program as described in Section 6.1.1. The City may consider utilizing the Save the Food
campaign materials or developing their own unique campaign materials.
Promote backyard composting. Consider promoting backyard composting to residents through
implementation of the key components of a robust education, outreach and compliance program
as described in Section 6.1.1. Consider partnering with the County Extension Service to provide
research-based information and educational materials as well as classes. Share information with
residents about the STAR Master Composter program.
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-17 Burns & McDonnell
Increase awareness of the City curbside collection of food waste program. Consider
promoting the curbside collection of pre-consumer food waste to residents through
implementation of the key components of a robust education, outreach and compliance program
as described in Section 6.1.1.
6.9.2 Commercial Organics Recommendations
Promote source reduction, feed hungry people and animals. Consider promoting actions
higher on the food waste hierarchy to the commercial community. There are many resources
available to support outreach efforts as outlined in Section 6.5, and opportunities to leverage
partnerships for increased diversion are discussed in more detail in Section 10.0.
Implement the Commercial Food Waste Pilot Program. Consider implementing the pilot
program for food waste diversion from the historic downtown area. This will be a valuable
opportunity to pilot a commercial food waste program in a controlled setting and gain insights
from participating generators, collection service providers (valet staff), and processing
facility(ies). Gathering feedback from participants and tracking metrics will provide useful
information to developing a successful full-scale organics collection program across the City.
Suggested activities associated with data gathering are as follows:
o Track the quantity, type, size, and type of businesses which sign up to participate as well
as the dropout rate/duration of participation.
o Survey participating businesses to gain insights into what elements of the program are
beneficial, need attention, and suggestions for improvement.
o Survey the valet service staff to understand their challenges and suggestions for
improvement.
o Track quantities across each business and categorize quantities by type of establishment
(bar/café/restaurant/etc.).
o Check in frequently with the WWTP staff to ensure that they can handle the incoming
volumes for maceration/pre-processing, that the quality of incoming material is
acceptable, that the new material streams are not adversely affecting the digester (e.g.,
microbial health), and if there is sufficient digester and biogas capacity handle the
amount of material received.
Expand commercial food waste collection. Following the pilot program period, consider
expanding the commercial food waste collection program throughout the City. It will require
Comprehensive Solid Waste Management Strategy Organics Management
City of Denton, Texas 6-18 Burns & McDonnell
working closely in partnership with the Compost Facility and WWTP to ensure that both facilities
have capacity, infrastructure, and staffing required to expand.
Conduct a master study of organics management. Consider a collaborative approach between
SWR and Water Utilities to evaluate the long-term infrastructure needs for the City for increasing
management of organic materials. As the City continues to grow, the capabilities of SWR and
Water Utilities will need to expand, including currently planned system expansions to provide
sufficient WWTP capacity for the Hunter-Cole development. As part of the long-term planning
processes, there are benefits from collaboration and awareness between departments regarding
any infrastructure upgrades (e.g., increased excess digester capacity), new programs or policies
(e.g., expanded food waste diversion programs), and future staffing needs for joint efforts (e.g.,
expansion of the commercial food waste pilot).
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-1 Burns & McDonnell
7.0 LANDFILL DISPOSAL
Landfills will play a necessary role in materials management through the 2040 planning horizon, even
with increasing rates of recycling, waste reduction efforts, and technological advancement. The City owns
and operates the Denton Landfill, placing it in a position of self-determination regarding refuse disposal
and capacity planning.
As described in Section 4.0, the Denton Landfill consists of a total permit boundary of 404.4 acres and a
waste disposal footprint of 258.0 acres with a total in situ waste disposal capacity of 51.88 million cubic
yards. This includes recent approval of a vertical and lateral expansion, which added 40 million cubic
yards in situ disposal capacity. Prior to the expansion, the site had an estimated 7.27 million cubic yards
remaining in 2020 (11.5 years of capacity). Based on current disposal rates, the recently approved vertical
and lateral expansion increases the expected capacity of the Denton Landfill to 72 years (see Table 4-1 in
Section 4.0 for details). However, population and economic growth are forecasted to result in increased
City-hauled landfill disposal tonnages. Further, growth in surrounding communities coupled with other
NCTCOG landfills reaching capacity and closing will increase disposal demand at the Denton Landfill.
The remaining landfill life of the Denton Landfill is dependent on the City’s approach to pricing and
policy to efficiently utilize airspace.
This section summarizes the City’s current approach to landfill pricing and contracts and describes
opportunities and approaches for the City to manage incoming quantities and leverage the Denton
Landfill as a resource to incentivize diversion activity while meeting financial responsibility and needs of
residents and SWR.
Tactics to implement the Strategy to Efficiently Use Landfill Capacity were developed based on the
evaluation, case studies, key findings and recommendations presented in this section as well as the
outcomes of workshop discussions with City staff. Section 11.3 presents the Strategy to Efficiently Use
Landfill Capacity in more detail. Section 12.0 provides the implementation plan.
7.1 Landfill Pricing Strategies
This section describes the City’s pricing strategy and presents case study examples of approaches used in
other communities.
7.1.1 Gate Rates
The City’s 2022 landfill rates (Ordinance 21-1967) are shown in Table 4-2. A customer’s gate rate is
depending on the type of customer (e.g., Denton resident, commercial customer) and the type of material
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-2 Burns & McDonnell
(e.g., MSW, sludge, clean brush or green waste). The City’s landfill pricing strategy is designed to
maintain a favorable gate rate for Denton residents while also bringing in outside tonnage to generate
needed revenue to pay down long-term debt. Rates are generally adjusted annually based on factors such
as inflation.
Table 7-1: Disposal Rates at the Denton Landfill (2022)
Customer/Material Rate per Ton
Gate Rate (City Residents/Businesses) $44.00
Gate Rate (Non-Denton Residents/Businesses) $48.00
City Hauled Commercial Open Top and Compactors $40.00
City of Denton Departments $24.50
Sludge, Dewatered $60.00
Clean Concrete, Asphalt, Brick or Dirt (if needed) $22.00
Whole Tree Stumps $50.00
Unbagged Grass, Leaves, and Brush (Denton Resident) $25.00
Unbagged Grass, Leaves, and Brush (Non-Denton Resident) $35.00
Large Brush $30.00
Special Waste (must be approved by City of Denton) Varies
There are many landfills within the Dallas-Fort Worth Metroplex and greater North Central Texas region
(more detail presented in Section 4.0). Figure 7-1 shows the average rate charged at landfills in the
NCTCOG region based on information reported to the TCEQ, which ranged from $24-53 per ton. This is
facility-reported information, and it’s possible that facilities may interpret and estimate the average rate
charged in potentially disparate ways (e.g., exclusive of some fees, exclusive of wholesale customers).
While the rate reported to TCEQ by the City ($44 per ton) appears higher than the reported average rate
charged in the surrounding counties, this rate represents the gate rate for Denton residents/businesses
($44; Table 4-2). Burns & McDonnell estimates that the average rate charged in 2020 at the Denton
Landfill was $34 per ton.
As communicated in Table 7-3, the City has also established a set of material-specific gate rates.
Charging different rates for specific materials can be an effective approach to incentivizing or
disincentivizing specific materials being brought to the Denton Landfill. For example, the material-
specific gate rate of $25-35 per ton for unbagged grass, leaves, and brush incentivizes customers to
deliver clean loads of this material to receive the reduced rate. The City can then divert these loads to be
composted at the WWTP composting facility. As discussed in Section 6.0, these clean loads comprise a
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-3 Burns & McDonnell
significant portion of the yard trimmings composted through the City’s program, provide useful bulking
material for biosolids composting, and preserve landfill space through diversion.
As landfills in the NCTCOG region reach capacity and close, existing disposal capacity will become an
increasingly valuable resource. Facilities in the region may adjust gate rates and discounts based on
facility capacity, regional disposal markets, nearby facility pricing, and other factors (e.g., consumer price
index (CPI)) to meet specific facility goals related to facility financials, landfill life, or material needs
(e.g., securing incoming waste that is suitable as alternative daily cover or as a bulking agent for the
disposal of high-moisture wastes).
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-4 Burns & McDonnell
Figure 7-1: Average Gate Rates Charged in the NCTCOG Region (2020)1
1Average gate rate charged for the City ($34 per ton) estimated based on data provided by the City. All others are as reported to the TCEQ as part of 2020 annual MSW reports.
$24 $25 $26
$34 $35 $38
$29 $30 $33
$29 $30 $30
$40
$25
$32
$37
$45
$53
$60
$44
0
10
20
30
40
50
60
70
Camelot LandfillDFW Recycling And Disposal FacilityLewisville LandfillCity Of Denton LandfillOsttend Landfill121 Regional Disposal FacilityFort Worth Southeast LandfillCity Of Arlington LandfillFort Worth C & D LandfillCity Of Dallas McCommas Bluff LandfillCharles M Hinton Jr Regional LandfillCity Of Grand Prairie LandfillHunter Ferrell LandfillWM Skyline LandfillTurkey Creek LandfillEllis County LandfillRepublic Maloy LandfillWeatherford LandfillCity Of Stephenville LandfillDENTON COLLIN TARRANT DALLAS OTHER
Dark Grey = Type I Light Grey = Type IV
Ж indicates the rate reported by the City
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-5 Burns & McDonnell
7.1.2 Guaranteed Tonnage Contracts
Wholesale or discount gate rate agreements are a common practice used to guarantee tonnage and revenue
and provide some budget predictability, especially in competitive disposal markets. The majority of
outside tonnage received at the Denton Landfill is through put-or-pay contracts tons that guarantee
revenue for the City. The City’s current put-or-pay contracts are summarized in Table 7-2.
Table 7-2: City Put-or-Pay Contract Terms
Denton Landfill Regional Perspective
Contract Length 3 years
Some cities in NCTCOG (e.g., Garland) have historically
renegotiated contracts every year, rather than utilizing multi-
year contract. Multi-year contracts provide some predictability
in budgets for both the city and the customer.
Cities may use a discount matrix with greater discount for
longer contracts (see Dallas case study and Table 7-4).
Guaranteed
Tons per Year
Ranges from
approximately
2,000-90,000
tons per year per
contract
Known discount contracts in the region are typically for higher
tonnages than some of those executed with the City’s
customers. Recently, the City of Dallas added a tier to their
discount matrix to include discount levels smaller contracts
(5,000 to 9,999 tons per year).
Average
Discounted Rate $28 per ton
The City’s discounted rates are within the range of other
discounts in the region, which are generally in the mid-$20 per
ton range up to possibly $50 per ton depending on location in
the Dallas-Fort Worth Metroplex. Lowest price is not the only
factor in rate competitiveness; haulers also report that
considerations such as distance, use of toll roads, travel time
and turnaround time affect disposal contract decision-making.
The City’s put-or-pay contracts are negotiated on a case-by-case basis with each customer, and the
potential discount rate or structure is not formally set. While some communities opt to negotiate discount
rates and a case-by-case basis, others utilize a set discount structure or matrix to determine the percentage
discount a customer receives. The percentage discount may apply to the posted gate rate for the material
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-6 Burns & McDonnell
or to an established base contract rate. A benefit of set discount structures formalized through ordinance is
that they provide transparency; however, formalized structures introduce the potential to lose customers
who are on the upper threshold of a pricing tier and cannot receive or negotiate a better rate. Additionally,
unless expressly included in the ordinance, formalized rate structures can limit the ability to negotiate
one-time discount contracts for desired large loads.
The typical discount approach is that the more tonnage a customer guarantees the greater the discount.
While this approach provides near-term financial benefits, it does not reflect the economic reality of
increasing future disposal costs. As the Denton Landfill reaches capacity, eventually the City will need to
look to alternatives which will be increasingly expensive compared to the current disposal costs and may
result in limited cost control if the City must send material to a third-party landfill. While the City can
work to minimize the amount of waste generated within Denton that is landfilled, the City’s programs
cannot incentivize diversion in the neighboring communities for which the Denton Landfill is one of
limited disposal options. To incentivize diversion programs in these communities, the City could shift the
discount structure to provide more favorable pricing based on a documented level of diversion. This shift
would align the financial incentives of the discount structure with the anticipated future costs of disposal
in the region. Burns & McDonnell is not currently aware of any communities with a landfill discount
structured in this manner, and believes it represents a novel approach to pricing contracts.
Case Study: City of Dallas McCommas Bluff Landfill. The City of Dallas began raising prices for
disposal to be more in line with other facilities in the region in 2018. Table 7-3 shows this historical gate
rate for the landfill between 2015 and 2022.
Table 7-3: Historical McCommas Bluff Landfill Gate Rate (Dallas)
Fiscal
Year
Gate
Rate
Dollar
Change
Percent
Change
2015 $21.50 $0.00 0.0%
2016 $21.50 $0.00 0.0%
2017 $25.00 $3.50 16.3%
2018 $25.00 $0.00 0.0%
2019 $26.25 $1.25 5.0%
2020 $28.50 $2.25 8.6%
2021 $34.20 $5.70 20.0%
2022 $34.88 $0.68 2.0%
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-7 Burns & McDonnell
The City of Dallas allows higher volume customers to receive a discount relative to the gate rate based on
the guaranteed annual tons and the length of commitment. Once the discounted rate is established, it
increases each year of the contract based on a Consumer Price Index (CPI) adjustment. Table 7-4 presents
the landfill discount matrix. While the discount matrix previously included tiers for 10,000 or more
guaranteed annual tons per year, the city added a gate rate discount tier for 5,000 to 9,999 tons when the
new discount matrix was implemented in October 2020.
Table 7-4: Landfill Discount Matrix
Guaranteed Annual Tons Discount from Gate Rate
From To 1 or 2 Year
Contract Term
3 or 4 Year
Contract Term
5 Year
Contract Term
5,000 9,999 12.28% 13.60% 14.88%
10,000 49,999 17.81% 19.72% 21.58%
50,000 74,999 20.65% 23.55% 29.23%
75,000 99,999 21.58% 25.46% 33.06%
100,000 124,999 22.62% 27.32% 36.83%
125,000 149,999 22.85% 27.78% 37.87%
150,000 199,999 22.97% 28.13% 38.45%
200,000 No maximum 23.20% 28.65% 39.38%
Based on the current published gate rate ($34.88 per ton), the discount structure in Table 7-4 is equivalent
to a rate of approximately $21-31 per ton depending on the guaranteed tonnage tier and length of contract.
7.1.3 Landfill Disposal Surcharges
Disposal surcharges (e.g., landfill environmental fees, impact fees) are an element of landfill pricing that
raise the cost of disposal above the gate rate. Disposal surcharges can encourage diversion and help
recycling to be more cost competitive as well as generating funding to support local recycling programs.
Disposal surcharges may be enacted at the state and/or local level. Currently, the per-ton disposal fee in
Texas is $0.94 per ton, which is below the national average. Local governments, such as the City of Fort
Worth, may charge additional local solid waste disposal fees.
Case Study: City of Fort Worth. The City of Fort Worth’s “Non-City Landfill Environmental Fee”
(Ordinance 24533-11-2020) was adopted November 17, 2020 and became effective January 1, 2021. The
fee adds $5 per ton of landfill environmental fee collected with the tipping fee at the City’s Southeast
Landfill. Prior to fee enactment, residents and permitted haulers contributed financially to the costs of the
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-8 Burns & McDonnell
city’s solid waste disposal program through residential rates or permit fees; however, haulers disposing of
non-city material did not contribute in a similar manner. Objectives of the Fort Worth’s environmental fee
include to preserve remaining capacity for City-generated materials and to equalize the financial burden
of responsible solid waste management among all users of the landfill.
7.2 Other Approaches to Increase Diversion and Extend Landfill Life
This section provides an overview of approaches that can be implemented at landfills to increase
diversion.
7.2.1 Landfill Bans for Certain Materials
Communities in the U.S. have moved forward with banning C&D and/or yard trimmings/brush materials
from landfills primarily in order to extend landfill life, to prevent odor violations53, and due to
community-wide diversion goals. The following are examples from communities that have enacted a
landfill ban:
Johnson County, Kansas. Beginning in 2012, the county banned disposal or transfer for
disposal of yard waste, which had been previously identified as one of the top four most disposed
materials at the Johnson County Landfill.54 The county developed a phased process that included
establishment of a Solid Waste Management Committee with staff, resident, and industry
representatives to develop the ban ordinance.
Wake County, North Carolina. Commercial C&D is not accepted at any county-operated
landfill and is only accepted at eight private facilities in Wake County. In 2000, the Wake
County Solid Waste Management Division enacted the ban following a waste characterization
study that indicated 22.5 percent of material in the North Wake MSW Landfill was C&D. The
County has found success in the decade following the ban—in FY 2011, nearly 100 percent of
C&D material generated in Wake County was either disposed in private facilities or recycled.55
As a part of Wake County’s ban, MSW loads brought to county landfills containing 10 percent or
more C&D material are assessed at two times the tipping fee.56
53 Decomposition of gypsum in landfills releases hydrogen sulfide, creating a strong odor. Landfills in
Massachusetts and New Hampshire have encouraged gypsum recycling and best management practices to reduce
odor. https://www.waste360.com/mag/waste_passing_smell_test
54Johnson County Solid Waste Management Plan, 2007 Edition, page 11.
https://www.jocogov.org/sites/default/files/documents/DHE/ENV/swSWMP2007Plan.pdf
55 Wake County Solid Waste Management Plan, page 3-2.
http://www.wakegov.com/recycling/division/reports/Documents/2012WCSWMP.pdf
56 Best Practice: Wake County C&D Disposal Surcharge.
http://www.p2pays.org/bmp/main/studies/Wake%20County%20C&D%20Surcharge.pdf
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-9 Burns & McDonnell
State of Massachusetts. The State of Massachusetts banned asphalt pavement, concrete, metal,
and wood from landfills under 201 CMR 19.017 in 2006 and clean gypsum in 2011.57
Implementation of the ban including the materials considered was developed in collaboration
between the state’s Department of Environmental Protection (MassDEP) and a C&D Debris
Subcommittee comprised of architects, building owners, consultants, contractors, haulers, landfill
owners, municipalities, processors, and other key stakeholders. The state’s ban identifies loads
that are more than 20 percent banned material by volume to be non-compliant, and penalties for
non-compliance vary by case.9, 58
City of Seattle, Washington. The City of Seattle began an expansive stakeholder input process
from 2009 to 2012 to determine the implementation process of a C&D recycling requirement and
landfill ban in the city.59 Aspects of the ban related to diversion plans, material types, and
reporting where determined by stakeholder groups including representatives from construction
trades, facilities, and haulers. In 2012, the city began a phased approach to its C&D landfill ban
on a material-by-material basis with a year of education prior to the beginning of enforcement.
The city has delayed phasing in a ban of plastic film wrap, carpet, and tear-off asphalt shingles
disposal due to uncertainties of recycling capacity and end-user markets in the region. Section
21.36.089 of Seattle’s ordinance notes that presence of banned materials in very small qualities
are exempt from penalties, which are assessed on an actual cost basis of City inspection and
increase following violation.60
Similar to landfill bans, local governments can enact ordinances specific to the collection of material. For
example, some local governments enact prohibitions on yard trimmings comingled with refuse. If
separate collection service is not provided through a program or contract, then it would be left up to
customers to manage yard trimmings. Options for management of yard trimmings includes contracting
individually with a private hauler, self-hauling to a drop off facility, or managing the material on site
through mulch mowing and/or backyard composting. The benefit of this option is that only customers
who use a collection service pay for the service; however, it can lead to increases in illegal dumping of
yard trimmings.
57 https://www.mass.gov/doc/frequently-asked-questions-construction-demolition-materials-waste-ban/download
58 https://www.mass.gov/doc/310-cmr-19000-solid-waste-management-facility-regulations/download
59 https://wsra.xyz/wp-content/uploads/2019/12/impact_of_bans_-_wsra_confer.pdf
60https://library.municode.com/wa/seattle/codes/municipal_code?nodeId=TIT21UT_SUBTITLE_IIISOWA_CH21.3
6SOWACO_SUBCHAPTER_IISOWACO_21.36.089CODEWARERE
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-10 Burns & McDonnell
7.2.2 Other Incentives and Disincentives
While surcharges and disposal ban policies are commonly used to enhance diversion, there are other
policies and ordinance options related to landfill diversion from both a generator and material type focus.
Table 7-5 provides options for policies and ordinances specific to commercial generators, organics and
food waste, and C&D materials, which communities may use in additional to or instead of a landfill ban.
Many of these options are discussed in detail as part of the Strategy to Support New Markets and
Leverage Partnerships (see Sections 10.0, 11.6, and 12.0).
Table 7-5: Alternatives to Landfill Bans
Commercial Organics & Food Waste C&D
Awards and recognition
Hauler minimum service
standards
Mandatory diversion for
generators
Building design requirements
specifying adequate space
for containers
Donation of unused food
Food to agriculture programs
Voluntary collection
programs
Hauler minimum service
standards
Mandatory recovery program
for specified generators
Target diversion rate
Processing capacity and end
markets
Education and outreach for
reuse and recycling
Incentivize materials
recovery and deconstruction
through building permit fees
Green building and LEED
ordinances
Mandatory recovery program
for specified generators
Processing capacity and end
markets
7.3 Key Findings and Recommendations
The following presents consolidated key findings and recommendations related to the City’s landfill
capacity and pricing, as a basis for the Strategy to Efficiently Use Landfill Capacity described and
evaluated in Sections 11.3 and 12.0.
The recent landfill expansion provides long term capacity for the City. If diversion rates do
not improve, the City currently has sufficient capacity through at least 2057 and potentially
through 2077. The City’s landfill space will only increase in value over time as the area continues
to grow and more landfills reach capacity. As a City-owned and operated landfill, the City
maintains control over its disposal needs and should consider the Denton Landfill a valuable
resource. The City should anticipate increased interest from third-party haulers and private waste
management companies to operate or acquire the facility; however, the City should seek to
maintain its status as owner-operator.
Comprehensive Solid Waste Management Strategy Landfill Disposal
City of Denton, Texas 7-11 Burns & McDonnell
The regional market price for disposal is driven by many factors and facility pricing
dynamics are ever changing. The City’s current gate rates and discount contracts appear to be
generally in line with other facilities in the region; however, as facilities change their respective
pricing and discount strategies the market will shift. Given the number of factors, including price,
that influence the flow of refuse throughout the region, the City should conduct routine market
studies to track disposal capacity market price and set rates accordingly to balance short- and
long-term capacity and revenue needs.
Put-or-pay contracts have been used successfully to pay down long-term debt. After 2023, it
is anticipated that the put-or-pay contracts will not be needed to pay down long-term debt, and
instead can generate net revenue for SWR. Implementing a sustainable materials management
plan will require expanded and new programs to further increase the City’s diversion efforts. In
turn, programs will require funding support that could include revenue generated through put-or-
pay contracts. The City should explore the creation of a special fund so that future disposal
contract revenues could be directed to stabilize residential rates and fund diversion programs. The
creation of a special fund may become increasingly important as the value of put-or-pay contracts
increases due to regional capacity constraints.
Put-or-pay contract structure could be leveraged to support the City’s costs of services
while also encouraging diversion in surrounding communities. The Denton Landfill is an
important disposal resource not just for the City but also for north and west areas of the region
where disposal alternatives and diversion programs are limited (e.g., Wise County). While the
City provides essential sanitary service to these communities through the safe disposal of non-
recyclable wastes, there is an opportunity to divert material from these communities as well. The
City can leverage put-or-pay discount structures to incentivize third-party communities to divert
by contracting directly with communities (rather than their contracted hauler) and implementing a
discount structure that provides an increase discount rate based on documented diversion
tonnages. This put-or-pay approach could be used to attract increased volumes of recycling
material to the Pratt MRF (or future expanded regional MRF) as well as the potential
regionalization of other City programs (e.g., HCC) for increased diversion and improved
economies of scale. Discount levels should be carefully set based on the recommended landfill
market studies.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-1 Burns & McDonnell
8.0 PLANNING FOR FUTURE GROWTH & INFRASTRUCTURE
This section includes an evaluation of the programs and opportunities for effectively managing waste and
recycling as the City continues to grow at a significant rate. The section discusses both infrastructure and
considerations for future policies and approaches to manage these materials in an effective way.
Tactics to implement the Strategy to Plan for Future Growth and Infrastructure were developed based on
the evaluation, case studies, key findings and recommendations presented in this section as well as the
outcomes of workshop discussions with City staff. The Strategy to Plan for Future Growth and
Infrastructure is presented in more detail in Section 11.4. Section 12.0 provides the implementation plan.
8.1 Future Transfer Station Evaluation
As described in Section 4.0, transfer stations may be used to improve the efficiency and/or costs
associated with hauling materials. Given the significant growth planned within the Hunter Ranch and
Cole Ranch master planned communities (MPCs) and the anticipated 20-mile distance from these routes
to the Denton Landfill and Pratt MRF (see land use and growth analysis in Section 4.3), a transfer station
may be appropriate to efficiently manage material from these routes. This section provides an evaluation
of the operational appropriateness, financial feasibility, and long-term planning considerations for a
transfer station.
8.1.1 Operational Appropriateness Evaluation
Benefits associated with transfer station use can include:
Quicker turn-around times for collection route service. Collection vehicles can often save
time and return to service their remaining/second route sooner by tipping at a transfer station
rather than a landfill that is further away and/or has significantly more scalehouse and working
face traffic.
Reduced fuel use and air emissions. Consolidation of waste for transportation to the landfill
increases efficiency, and thereby reduces the overall fuel use and air emissions of collection
activities. As alternative fuel vehicles gain popularity, they can be tailored to the specific use or
service duty for best performance (i.e., low-speed frequent stops of collection routes vs. long-haul
transport from transfer station to landfill).
Increased lifespan of collection fleet. Due to reduced travel time and consolidated
transportation, the lifespan of the City’s collection fleet could be extended.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-2 Burns & McDonnell
Co-located services such as community drop-off. A transfer station can improve convenience
for residents, further reduce small vehicle traffic at the landfill, and improve safety by directing
self-haul residents to transfer station drop-off rather than the landfill working face.
Currently, the Denton Landfill experiences periods of long wait times and unloading times due to
increased growth in the area and traffic volumes. Scalehouse wait times of 10-15 minutes are typical at
the landfill but can be up to 30 minutes depending on conditions and the need to control traffic and
tonnage at the working face. If conditions are challenging (e.g., wet weather), the total turn-around time at
the working face can be up to 90-120 minutes at peak times resulting in significant waits before returning
to service a second route.
As discussed in Section 4.0, the planned Hunter Ranch and Cole Ranch developments have an anticipated
20-mile travel distance each way between collection routes and the Denton Landfill via the proposed
Loop 288 (refer to Figure 4-19). At this distance, there are potential time savings for these routes to be
diverted to a transfer station located in a yet to be determined location in west/southwest Denton,
especially if Denton Landfill turn-around times remain high. However, the Public Disposal Facility at the
Denton Landfill (expected in early to mid-2022), can provide some benefits similar to a transfer station by
alleviating some traffic at the working face, improving wait times at the landfill, and providing a safer and
more convenient option for self-haul customers.
8.1.2 Financial Feasibility Evaluation
The financial feasibility of a transfer station is dependent on many factors, including:
Collection cost
Disposal cost
Distance/travel time to landfill
Fuel costs
Annual tonnage hauled
Payload of transfer trailers vs. collection vehicles
Assuming other factors are held constant, the further the landfill or processing facility is from the
collection point, the more financially feasible long hauling with a transfer station is compared to direct
hauling from the point of collection.
Based on the growth patterns of the City and location of other facilities in the region, a location in the
southwest of the City could potentially minimize the impacts of the concentrated growth of the Hunter
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-3 Burns & McDonnell
Ranch and Cole Ranch MPCs. The cost of developing a transfer station is dependent on several site-
specific factors, including location, size, type of operation and number of material streams. Burns &
McDonnell evaluated options to manage the waste and recycling generated by single-family residential
customers in Hunter Ranch and Cole Ranch MPCs and surrounding areas in the year 2040.
Table 8-1 presents a planning-level estimate of typical direct capital, operating and hauling costs for a
transfer station managing 25,000 tons per year and with additional design capacity to accommodate
growth or third-party tonnage. The size of the transfer station will vary based on site-specific conditions,
usage of the facility and the location of disposal and/or processing facilities.
The costs shown are only direct costs, where other costs that may be incurred during the development and
operation of a transfer station are not included such as land purchase, potential utility relocations,
potential environmental mitigation (e.g., wetlands, threatened and endangered species), access road
development (i.e., roads leading to the site), profit margin and income taxes (for public-private
partnership), fund transfers (for public-sector operations), and other indirect/overhead costs. Therefore,
the values shown in Table 8-1 do not represent the total costs for owning and operating a transfer station.
Table 8-1: Transfer Station Direct Costs1
Annual Cost
Site/Building Capital2 $184,800
Equipment Capital $99,286
On-Site Operations $691,520
Hauling $413,932
Total $1,389,538
Cost/ton $55.58
1. These items only include direct costs and do not include items that may be
incurred during the development and operation of a transfer station
including utility relocation, wetlands mitigation, land purchase, access
road development (i.e., roads leading to the site), fund transfers and/or
shared overhead costs.
2. Base estimated site/building capital costs, overall site engineering, scales,
scalehouse, and other environmental management infrastructure totaling
$5.3 million and annualized over 20 years using a four percent cost of
debt.
The following descriptions provide further detail of each cost category shown in Table 8-1:
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-4 Burns & McDonnell
Site/Building Capital. This cost category includes one-time costs required to start transfer
station operations such as engineering design, permitting and legal fees, building and site
development, equipment mobilization, site improvements, installation of scale house and scales.
Total site/building capital costs estimated at approximately $5.3 million and are shown in Table
8-1 amortized over 20 years.
Equipment Capital Costs. This cost category includes annual capital costs requirements that
support the purchase of equipment.
On-Site Operating Costs. This cost category includes annual costs required to operate a transfer
station facility including personnel salaries and benefits, equipment operating and maintenance,
building maintenance and utilities.
Hauling Costs. This cost category represents the cost of hauling material to disposal at a
distance of 20 miles. Hauling represents significant cost to the operation and is largely dependent
on the distance to disposal. For example, increasing the distance of disposal from 20 to 90 miles
for a transfer station that processes 25,000 tons per year would increase the cost of hauling from
approximately $414,000 to $765,000.
Based on cost of service data provided by the City, constructing and operating a transfer station to
manage material generated in southwest Denton would increase waste and recycling costs by nearly
$546,000 per year compared to direct hauling (as shown in
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-5 Burns & McDonnell
Table 8-2). Use of a transfer station would provide an estimated $990,000 savings from increased
collection efficiency; however, the costs associated with the transfer station facility (including capital,
equipment, operations, and maintenance) and hauling are greater at $1,536,000 than the financial benefits
that could be realized from increased transportation efficiency.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-6 Burns & McDonnell
Table 8-2: Estimated Financial Feasibility of a Transfer Station Compared to Direct Haul
Annual Savings1
Collection Operations
Refuse Collection2 $660,000
Recycling Collection2 $330,000
Transfer Station
Hauling3 ($414,000)
Transfer Station Facility4 ($1,122,000)
Total Savings ($546,000)
1. Annualized based on 25-year facility life and 7-year life for equipment.
Negative values indicate an increase in direct costs.
2. Based on cost of service information provided by the City.
3. Hauling from transfer station to Denton Landfill (refuse) and Pratt MRF
(recycling).
4. Includes site/building capital, equipment capital, and on-site operations
as defined in Table 9-1.
While the anticipated growth in the City represents a significant increase, the estimated single-family
residential tonnages from the Hunter Ranch and Cole Ranch MPCs and surrounding communities is of
relatively small scale for a multi-material transfer station (approximately 25,000 tons per year refuse and
recycling). As a result, the financial feasibility of a transfer station to manage only this waste is limited.
One option to improve feasibility from a financial perspective is to allow third-party tonnages to benefit
from economies of scale. Based on the analysis performed by Burns & McDonnell, the transfer station
approaches financial feasibility if at least 35,000 tons per year of third-party material is also managed
through the transfer station. This would require that the facility more than double the amount of material
from only the City in order to become financially feasible.
8.1.3 Long-Term Considerations for a Transfer Station
While this evaluation indicates that a transfer station designed to manage Hunter Ranch and Cole Ranch
and surrounding routes is not financially feasible at estimated 2040 tonnages, the City should continue to
consider a transfer station as part of long-term infrastructure planning. There are approaches that could be
used to increase the financial feasibility or operational benefits to a point where transfer station
construction would be favorable. In addition to the acceptance of third-party tonnage, the City could
consider public-private partnership as well as the expansion of services at the site. As needs arise due to
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-7 Burns & McDonnell
growth in the southwestern portion of the City (e.g., need for fleet yard, municipal service building,
recycling drop-off, etc.) and the regional disposal market shifts due to facility closures, a transfer station
may become more financially feasible in the future.
Should the City decide to pursue a transfer station in the future, the City is likely well-positioned to obtain
an approved registration from the TCEQ for the construction and operation of the site. The permitting
requirements under 30 TAC §330.9(e) allow for a registration process (rather than full permitting) for
transfer stations that can demonstrate the following:
Ten percent or greater (by weight) of incoming waste streams is recovered for reuse or recycling;
or already reduced through programs such as curbside recycling.
The non-recyclable and non-reusable incoming materials are transferred to a permitted MSW
landfill located within 50 miles of the transfer station.
Given the City’s established recycling programs and the location of the Denton Landfill with respect to
potential transfer station locations, the City would likely be able to pursue this registration approach. This
can help to reduce costs and expedite the permitting process.
8.2 Development Code and Community Planning
This section discusses current development trends and the City’s approach to determining if proposed
new development can be safely serviced by waste and recycling fleets.
8.2.1 New Urbanism and Development Trends
A shift toward more multifamily and condensed development is a current or planned trend among many
cities in the North Central Texas region to reduce development sprawl and create more environmentally
and socially conscious housing. As described in Section 4.3.1, currently planned residential growth
throughout the City includes both in-fill development as well as large master planned communities
(MPCs). New MPCs increasingly include elements of New Urbanism (i.e., development that creates
walkable, mixed-use neighborhoods) and may be designed in accordance with SmartCode to
accommodate environmental techniques such as reduced usage of impervious cover (e.g., pavement,
asphalt, cement), increased usage of green spaces (e.g., parks, fields, gardens), and more walkable or
multi-modal transit (e.g., bicycle lanes, trolley tracks).
Compact mixed-use and high-density development can create challenges for solid waste collection
activities. If zoning requirements and design codes do not account for the needs of collection vehicles or
equipment, it can create challenging collection environments such as:
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-8 Burns & McDonnell
Inaccessible alleys. Service location in narrow or obstructed alleys, alley subsurface under-
engineered to support the weight of collection infrastructure, ingress and egress not protected thus
hindering access by heavy municipal equipment.
Private drives with limited maneuverability. Service locations only accessible by private
drives.
Cul-de-sacs with inaccessible set outs. Service locations on Cul-de-sacs that are too small or
contain obstructions.
Hammerhead or dead ends. Service locations on hammerhead (i.e., dead-end streets that end in
a “Y” shape) or dead-end streets with undersized turn radii.
Boulevards. Service locations on arterial roads that contain obstacles for collection due to multi-
modal transportation lanes.
The City’s current approach to reviewing new development reflects collaboration between the SWR and
Development Services departments to review plans and discuss the serviceability of designs. The City is
currently modifying the development criteria to address potential issues such as alleys and enclosures, and
the process has proactively included SWR staff. Continued collaboration becomes more critical as
development trends continue to evolve and the number of residential developments that are inaccessible
by standard collection vehicles potentially increases. The City should continue to be proactive in
identifying and addressing potential challenges and collaborating on modifications to criteria.
8.2.1.1 Case Studies: Considerations for SmartCode and Permit Review
Multiple cities across Texas are experiencing collection challenges associated with the implementation of
SmartCode development, including Austin, Fort Worth, and San Antonio. Each of these cities have
indicated that applications for new developments are provided to its solid waste and recycling collection
group for initial review. It is clear, however, that even though this initial review process may be sufficient
for the needs of fire truck equipment, the needs of solid waste and recycling collection vehicles require
additional attention regarding interim applications or amendments. This is because solid waste and
recycling collection vehicles will visit these locations more frequently than emergency fire vehicles.
Additionally:
Fort Worth noted that even after reviewing initial permits, developments were still being installed
that did not meet the needs of solid waste and recycling collection equipment.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-9 Burns & McDonnell
Fort Worth indicated that it is challenging to devote resources to interim reviews. San Antonio
shares this challenge and suggested that a potential solution could be to form a dedicated team be
to manage interim reviews.
Austin indicated that it has a strategic development team that is dedicated to tracking policy
development and reviewing inconsistencies in code that would impact solid waste and recycling
collection vehicle accessibility. This team works closely with Austin’s Planning and Zoning
Department.
San Antonio has developed a committee that seeks to ensure the safest and most efficient solid
waste and recycling collection equipment is able to remain in operation. This committee is tasked
to create an informational bulletin that would serve as the policy to determine criteria for
SmartCode policy implementation. Recommendations may include variable fee structures,
minimums for ASL service and emergency fire equipment, cart set out placement, parking
restrictions, and protocols for private haulers.
8.3 Recycling Program and Policy Options to Address Growth
As the City’s population continues to grow substantially over the next 20 years, there is a corresponding
anticipated increase in the amount of waste and recycling generated in the residential and commercial
sectors. With new development to support this growth, additional quantities of C&D debris will also be
generated. This section discusses program and policy options to recover more of the recyclable material in
the single-family residential, multifamily, commercial, and C&D sectors, including examples that have
been implemented in other cities. More information on these options, including model ordinance language
and considerations, can be found in the NCTCOG’s Recycling Ordinances and Building Design
Guidelines report.61
8.3.1 Residential Recycling Options
Currently, the City provides cart-based recycling service to single-family residences and curbside
collection of yard wastes with the option to use carts or kraft bags. As described in Section 5.0, the City
conducts extensive education and outreach efforts to provide both specific program information (i.e., time
and day of collection) and general environmental awareness (i.e., why recycling is worthwhile).
The following programs and policies present options for the City to enhance participation and improve
performance of the residential program.
61 Available online at: https://www.nctcog.org/nctcg/media/Environment-and-
Development/Documents/Materials%20Management/Final_Report-Ordinances_Guidelines_August_2009.pdf
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-10 Burns & McDonnell
Scaling the cart auditing program. The City has implemented a “Lift the Lid” cart auditing program
with cart tagging. This program could be expanded to other areas with high contamination (refer to
Section 5.2.2 for more details).
Compliance incentive programs. Options include cart removal for repeatedly contaminated carts (e.g.,
a “three-strike” approach) or additional fees for excessive and/or repeated contamination, with the
provision of a waiver if the resident engages in further educational efforts (refer to Section 5.2.3 for more
details).
Material collection ordinances/bans. Materials could be banned from the landfill to encourage
recycling. Similarly, local governments can enact ordinances specific to the collection of material. For
example, some local governments enact prohibitions on yard trimmings comingled with refuse. These
options are described in more detail in Section 7.2.
Adjusted Pay-As-You-Throw (PAYT) pricing tiers. A common strategy used by cities to drive
increases in recycling percentages and to meet recycling goals is to implement a PAYT rate structure.
Generally, the larger the price differential between large (e.g., 95 gallon) and small (e.g., 65 or 32 gallon)
refuse carts, the lower the demand for large carts. The trend toward small trash cart sizes incentivizes
recycling and/or waste reduction by residential customers. The City’s price differential between 95-gallon
and 65-gallon carts ($4.53 in 2021) is lower than those of Fort Worth, San Antonio, and Austin. Prior to
implementing any PAYT adjustment, the City’s recycling contamination must be addressed. Otherwise,
contamination rates in recycling carts may increase if residents move to a smaller cart to cut cost and then
place additional refuse in the recycling cart.
8.3.2 Multifamily Recycling Options
An estimated 30.4 percent of the housing units in the City of Denton are multifamily housing units (Table
3-2), and housing development trends suggest this percentage is increasing. The City is the exclusive
provider of multifamily refuse collection and disposal services. The City provides residential curbside
recycling services to some multifamily units (four or fewer units) through the residential curbside
recycling program and to some larger multifamily buildings through the commercial recycling collection
program. For the majority of multifamily units that do not receive residential curbside recycling services
from the City, the multifamily properties will contract with a private hauler should the property elect to
offer residents recycling services.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-11 Burns & McDonnell
Approaches to increasing multifamily recycling can include programs provided by the City, private
hauler, and/or multifamily property managers. The following programs and policies describe options for
the City to enhance participation and improve performance of the multifamily recycling program.
Expanded drop-off service. One challenge for implementing mandatory multifamily (or commercial
sector) recycling is lack of space for a recycling dumpster at some properties. Expanding drop-off options
within the City can increase recycling access to all users, especially multifamily residents without
recycling service. The City currently operates two unstaffed drop-off locations. The City could expand
drop-off service through the creation of additional unstaffed location(s); however, due to contamination
concerns unstaffed locations are best suited for the collection of a more limited set of materials (e.g.,
cardboard and single-stream recycling containers). Staffed drop-off stations represent a notable increase
in labor costs but would allow the City to collect other materials (e.g., staffed densifier to collect clean
expanded polystyrene, metals, textiles, etc.).
Mandatory multifamily recycling. Mandatory recycling ordinances require property owners and/or
managers to establish recycling program for residents of multifamily dwellings. Typically, these
ordinances do not require that residents use the service, only that a specific recycling service level is made
available. By defining a service level (e.g., materials, frequency, capacity per unit), cities are able to
provide a more uniform or standardized program to residents independent of which hauler services a
multifamily program. The requirements of City of Dallas’ multifamily recycling ordinance went into
effect in 2020, and require multifamily properties with eight or more units to have a defined level of
recycling service. Dallas’ Multifamily Recycling Ordinance is described in more detail in Section 8.3.2.1.
The City of Austin’s Universal Recycling Ordinance, described in more detail as a commercial recycling
case study (Section 8.3.3.1), also applies to multifamily properties with five or more units.
Mandatory hauler-provided recycling services. Local governments can require haulers, via ordinance,
to provide recycling services to certain customers (e.g., type, size) including multifamily. This type of
ordinance places the burden of compliance on haulers rather than individual businesses. Hauler-provided
recycling requirements are structured such that commercial haulers operating in the city to perform
actions such as providing recycling carts, providing a specific collection frequency, including specific
designated materials in the recycling program, and performing education and outreach to affected
customers. Placing the requirement on haulers is much less common than placing the requirement on the
businesses. The State of Connecticut’s mandatory hauler-provided recycling requirement is described in
more detail in Section 8.3.2.1.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-12 Burns & McDonnell
8.3.2.1 Case Studies: Multifamily Recycling Options
The following case studies provide examples of the multifamily recycling options presented in Section
8.3.2
Multifamily recycling ordinance: City of Dallas, Texas. In 2018, the City of Dallas approved a
multifamily recycling ordinance requiring property owners/managers to offer access to either valet, dual
stream, or single stream recycling service at multifamily buildings (defined as eight or more units). Some
multifamily buildings are eligible for recycling collection service from the city’s commercial recycling
service. For others, property owners/managers must contract recycling service through a hauler that has
received a City of Dallas recycling hauler permit. Materials collected in the multifamily program must be
consistent with the city’s single-family residential program (i.e., paper, cartons, cardboard, and containers
made of glass, metal, or plastics #1-7). Collection frequency must be at least weekly and provided to
residents in a similar method to refuse collection (i.e., if refuse collection is valet, then recycling should
also be valet). The ordinance outlines specific education and outreach requirements for both the property
owners/mangers (e.g., training staff, providing education to residents) as well as haulers (e.g., bin
signage), annual registration and reporting requirements for both property owners/managers and haulers,
and multifamily inspections for compliance. The ordinance requirements went into effect January 1, 2020.
Mandatory hauler-provided recycling service: State of Connecticut. As of 2012, all refuse collection
contracts between haulers and customers in the State of Connecticut must also include recycling
collection for a designated set of recyclable materials. The requirement applies to all commercial and
residential customers unless they already have a recycling collection contract in place with another hauler.
The designated set of recyclable materials are:
Plastic containers (PET, HDPE)
Paper and paperboard (cardboard, boxboard, magazines, office paper, newspapers, etc.)
Glass food and beverage containers
Metal food and beverage containers
Scrap metal
Waste oil
Leaves and grass clippings
Batteries (lead-acid, Ni-Cd rechargeable)
Residential electronics
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-13 Burns & McDonnell
8.3.3 Commercial Recycling Options
The City is the exclusive provider of commercial refuse collection and disposal services in the City.
Commercial entities can contract with the City for recycling services, including typical recyclables and
brush/yard waste. The City provides valet service to commercial entities in a specific area of downtown,
which includes a planned food waste diversion pilot program (refer to Section 6.6 for more details).
Approaches to increasing commercial recycling can include programs provided by the City, private
hauler, and/or property managers. The following programs and policies describe options for the City to
enhance participation and improve performance of the commercial recycling program.
Expansion of commercial food waste program. As discussed in Section 6.6, the City currently
provides food waste service to a limited number of a large-quantity generators (big-box stores) and has
planned a food waste diversion pilot as part of the valet service in the historic downtown area. Depending
on the success and lessons learned from the pilot program, food waste diversion services could be
expanded to be a subscription service option Citywide.
Recycling rewards and recognition programs. Awards and recognition programs for commercial
establishments can provide incentive for businesses to recycle. Awards and recognition programs
typically provide public recognition for commercial businesses that have developed exceptional or
innovative recycling programs. Awards and recognition programs can be accounted for in a community’s
recycling ordinances. However, it is also possible to create an awards and recognition program that is not
mentioned within a city’s ordinances. This option is probably the easiest for the City to implement, as it
could be part of the existing green business program, but also will likely result in the least amount of
diversion.
Mandatory commercial recycling programs. The City may enact an ordinance that requires
commercial establishments to develop recycling programs. Many cities that have implemented this type
of ordinance have done so in stages, starting with larger businesses and gradually phasing in requirements
for smaller businesses. Austin’s URO, which applies to both multifamily and commercial properties, is
described in more detail in Section 8.3.3.1.
Mandatory hauler-provided recycling services. Local governments can require haulers, via ordinance,
to provide recycling services to commercial customers. This type of ordinance places the burden of
compliance on haulers rather than individual businesses. Placing the requirement on haulers is much less
common than placing the requirement on the businesses. The State of Connecticut’s mandatory hauler-
provided recycling requirement is described in more detail in Section 8.3.2.1.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-14 Burns & McDonnell
Material disposal bans. Disposal ban ordinances prohibit commercial establishments from disposing
designated materials. In addition, these ordinances can prohibit disposal facilities in the community, such
as landfills and transfer stations, from accepting the prohibited materials for disposal. These ordinances
go one step beyond requiring recycling by banning specific materials from being disposed. Disposal ban
ordinances are commonly enacted in conjunction with a mandatory recycling ordinance. Prior to
implementing a disposal ban, the City would need to ensure the processing capacity was available to
handle the increase in material before enacting the ban.
8.3.3.1 Case Studies: Commercial Recycling Options
The following case studies provide examples of the commercial recycling options presented in Section
8.3.3.
Mandatory Recycling Ordinance: Austin, Texas. The City of Austin implemented a Universal
Recycling Ordinance (URO) that requires commercial, multifamily (defined as five or more units), and
food-permitted properties (i.e., those with a food permit) to provide access to diversion services for their
employees and/or tenants. The ordinance requires access to recycling of single-stream materials (i.e.,
paper, plastic, metals, glass) and, if the property is food-permitted, diversion of organics. Property owners
may choose the method by which materials are collected and diverted, including:
Contracting with a city-licensed hauler for recycling and/or organics collection services
Self-hauling materials to a materials recovery facility (MRF) or composting facility
Alternative food diversion methods such as donation to food banks, farms, or community gardens
The URO was adopted by the city council in 2010. Implementation began in 2012 and was tiered and
based on size (square footage) of a business, with larger businesses becoming subject earlier. Currently,
approximately 15,000 entities within the city are subject to URO requirements.
For recycling, commercial entities may comply with the ordinance by meeting a 50 percent diversion
capacity by volume (measured by service capacity ratios; most entities choose this option) or by meeting
an 85 percent diversion rate by weight. Multifamily properties comply with the URO if they provide a
minimum capacity of single-stream recycling per unit per week. For organics, food-permitted entities
comply by providing one or more organics diversion options (including waste reduction) to employees.
URO organics diversion requirements do not address businesses that generate organic materials (e.g.,
from landscaping activities) but are not food-permitted businesses.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-15 Burns & McDonnell
Each URO-subject property must submit an Annual Diversion Plan for recyclables and food-permitted
properties must also submit an Organics Diversion Plan. Plans are submitted online through the Re-
TRAC Connect platform. Annual Diversion Plans and Organics Diversion Plans allow the city to compile
data regarding compliance with the URO service requirements. Generally, business do not report data on
material quantities, so the city relies on semi-annual reports for material tonnage data. Haulers are
required to provide the city with semi-annual tonnage reports to maintain a hauling license with the city.
8.3.4 C&D Recycling Options
As the City continues to grow, construction and renovation activity will lead to increased generation of
C&D debris. Historically, the City optimized C&D diversion efforts by diverting select loads from the
landfill to be sorted at its Building Material Recovery (BMR) location; however, this program has been
discontinued due to challenges with the cost-effectiveness of operation and the ability to actually divert
materials from the landfill (refer to Section 4.1.5).
The following programs and policies describe options for the City to increase the diversion of C&D
materials from landfills. Since nearby C&D processing capacity exists for materials that cannot be reused,
there is the opportunity for the City to drive recycling of this material through various partnerships,
incentives and/or policy mechanisms.
Establishing a building material reuse facility. A large portion of C&D materials can be in reusable
condition, such as cabinets, doors, fixtures and equipment, flooring material, windows, and raw materials
(e.g., lumber, pipe, sheetrock). Cities programs can facilitate C&D reuse by establishing reuse
warehouses, where a defined set of generators (e.g., contractors, residents) and end users (e.g., residents,
non-profits) are eligible to drop off or pick up materials. C&D reuse facilities can play a symbiotic role
with existing or future green building and deconstruction programs, by receiving materials from
deconstruction projects that can then be used to meet green building requirements for other projects. The
City should consider using available space at SWR’s warehouse “Building 651” also located on S.
Mayfield Road to establish a reuse warehouse for C&D items. If the City were to establish a C&D reuse
facility, favorable pricing could be set at the nearby Denton Landfill for clean loads (similar to how brush
is handled for composing). The City of Houston’s C&D reuse program is described as a case study in
Section 8.3.3.1.
Municipal green building programs. Municipal green building programs are used to encourage or
require sustainable building practices, typically for City-owned buildings. Once established, a municipal
green building program may be expanded to the private sector as well. In green building programs, the
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-16 Burns & McDonnell
entity responsible for the project is required to address specific elements of sustainability (e.g., water
conservation, energy efficiency, indoor air quality, waste minimization) by implementing specific actions
and/or being eligible for a specific certification (e.g., Leadership in Energy and Environmental Design
(LEED) Silver, Green Built Texas). As part of these programs, projects typically must develop and
implement a construction waste management plan that identifies the materials to be diverted from
disposal and whether the materials will be sorted on-site or commingled. Green building programs in the
cities of Austin, Texas (a voluntary City-developed rating system), Frisco, Texas (a mandatory program
for single-family construction) and Dallas, Texas (a LEED-based requirement for public works) are
described as case studies in Section 8.3.3.1.
C&D permit fees or deposits. During the permitting process, cities may incorporate an additional green
building fee or deposit. For developers that provide the proper documentation for reusing or recycling a
certain percentage of the material from a project site, the C&D permit fee would be waived, or the deposit
refunded. The City of Plano’s C&D Recycling Deposit Program is described as a case study in Section
8.3.3.1.
Buy-recycled procurement programs. Procurement programs for recycled-content products can apply
to C&D debris by mandating that local government agencies buy recycled-content products as their first
choice in purchasing supplies. Recycled C&D materials typically must meet all existing building codes,
standards, and specifications. The major advantage of a buy-recycled program is its ability to increase the
market for recycled C&D material. Environmental procurement programs (EPP) are discussed in more
detail in Section 10.6.1.
Landfill disposal surcharges. As described in Section 7.1, landfill pricing (or surcharges) can be used to
encourage the recycling of specific materials. With a C&D disposal surcharge ordinance, the City could
require C&D haulers to pay a surcharge for the disposal of C&D debris at the Denton Landfill. However,
it is important to set the fee at the appropriate level to encourage haulers to recycle this material (such as
at the Champion C&D MRF) rather than disposing at a nearby landfill accepting C&D waste at a lower
gate rate. If the City were to implement C&D surcharges, pricing should be set and updated based on
routine landfill market studies.
Mandatory C&D debris recycling. A mandatory C&D debris recycling ordinance typically requires
developers to recycle or reuse C&D debris generated from projects. The ordinance typically will include
a list of the materials that are designated as recyclable and reusable. The City of Austin’s C&D
Recycling Ordinance is described as a case study in Section 8.3.3.1.
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-17 Burns & McDonnell
8.3.4.1 Case Studies: C&D Recycling Options
The following case studies provide examples of the multifamily recycling options presented in Section
8.3.4.
City-operated C&D reuse facility: Houston, Texas. The City of Houston has operated a building
materials Reuse Warehouse since 2009. The site accepts donated construction materials from most
entities, including individuals, contractors, suppliers, builders and remodelers. Materials can be picked up
for free by any non-profit organization. In turn, non-profits may use these materials directly or make
materials available to individuals.
City-developed green building rating system: Austin, Texas. The City of Austin developed the first
green building rating system in the early 1990s. The Austin Energy Green Building (AEGB) program
assigns a five-level certification (i.e., star rating) for buildings based on a detailed checklist. While the
program is voluntary for most properties, AEGB ratings are required for buildings in certain development
districts and for some affordable housing incentive programs. Builders have the option to decide which
waste minimization actions to incorporate, including using at least one 50 percent recycled-content
material, recycling all lumber over two feet in length, and reuse or recycling of specific C&D materials
(e.g., stone, metal, OCC).
Public works green building program: Dallas, Texas. As a component of its 2003 Bond Program for
capital improvements, the City of Dallas included a requirement that all C&D projects over 10,000 square
feet must be LEED Silver Certified. In 2006, the Green Building Program policy was updated, increasing
the requirement for new public works facilities under the 2006 bond program to achieve LEED Gold
Certification.
Commercial green building program: Frisco, Texas. The City of Frisco developed a Commercial
Green Building Program. The program addresses multiple sustainability topics (e.g., energy efficiency,
water conservation) and includes the requirement that no waste concrete or metal from C&D projects may
be landfilled.
C&D deposits or rebates: Plano, Texas. The City of Plano has implemented a C&D Recycling Deposit
Program as an incentive to encourage Plano construction contractors to recycle on-site debris and divert it
from local landfills. The amount of the deposit required by Plano is based on project type and square
footage and is refundable in full or in part based on the project’s documented diversion rate. Plano’s
program began in 2009 and was reinvigorated when Toyota located its Manufacturing Product Innovation
Center campus to Plano in 2014 due to the significant increase in construction materials generated. The
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-18 Burns & McDonnell
program was intended to cause behavior change and increased diversion from new construction projects
exceeding 10,000 square feet and demolition or renovation projects exceeding 5,000 feet. Revenue
generated from unclaimed deposits is used to support sustainability initiatives that benefit the community.
C&D recycling ordinance: Austin, Texas. The City of Austin has a Construction and Demolition
Recycling Ordinance intended to increase recycling and reuse of C&D materials. The ordinance sets
minimum diversion requirements for building projects (single-family, multifamily and commercial) that
exceed 5,000 square feet as well as all multifamily and commercial demolition projects. The ordinance
went into effect on October 1, 2016. Contractors demonstrate compliance by achieving a minimum
diversion rate of 50 percent or disposing of less than 2.5 pounds of material per square foot.
Affected projects are required to submit a form through the Re-TRAC Connect platform for the city to
collect and analyze relevant data. Projects affected by the ordinance between 2016 and 2019 reported
diverting 70 - 85 percent of material generated. However, the city has indicated that project reporting has
steadily declined since the ordinance was first implemented and therefore the high diversion reported
under the C&D Ordinance could be a result of only higher-diversion projects reporting results. The city is
currently developing an enforcement program to increase the number of projects that report results.
8.4 Data Needs for Licensed Hauler Reporting
Recycling data is an essential component of developing, implementing, and assessing the impact of any
policies or ordinances the City may enact to enhance recycling participation. Multiple permitted haulers
operate within the City to provide for the collection, transportation, and processing of multifamily and
commercial recyclables; and because of this, quantities of recyclables collected in these sectors are not
fully known. The City has developed enhancements to Chapter 24 of the Code of Ordinances to obtain
data from waste manifests and other diversion activities (e.g., metals facilities, donation boxes).
The City’s focus on improving reporting from permitted haulers is consistent with trends to focus on
reporting from haulers, rather than generators or processors, to improve data collection, as demonstrated
in the case studies presented in Section 8.4.1.
8.4.1 Case Studies: Hauler Reporting
Dallas, Texas. Collection services for commercial and multifamily entities in the City of Dallas are
primarily provided by private haulers that are granted non-exclusive franchises, or the right to operate and
conduct business within the City. Over 200 haulers hold franchise agreements with the City. The City
adopted an ordinance, effective January 2020, to address the need to obtain consistent and complete
recycling data for multifamily customers, that establishes requirements for haulers of multifamily
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-19 Burns & McDonnell
recyclables within the City. Multifamily recyclables haulers must apply for and be granted a permit to
operate by the City. Permitted haulers are required to submit an annual report to the City detailing
tonnage of recyclable material collected from multifamily sites within the City, the average number of
multifamily units served, and total weekly collection capacity provided, recyclables processing facilities
utilized, and residue and rejected load information, among other reporting requirements62. The City of
Dallas also requires, by ordinance, apartment complex owners and/or managers to submit an annual
recycling plan and affidavit of compliance to obtain or renew its multi-tenant permit on an annual basis.
Apartment complexes are required to use a permitted recycling collector, provide weekly collection
service, and educate tenants about program and recycling requirements. The City of Dallas Office of
Environmental Quality & Sustainability works closely with the Code Compliance department to enforce
the multifamily recycling ordinance requirements as part of the approval and issuance of multi-tenant
permits. The City of Dallas consulted with multiple other Texas and national cities, including Austin,
regarding their challenges and successes in obtaining quality data from the multifamily and commercial
sectors, to inform development of the newly adopted ordinance.
Minneapolis, Minnesota. Collection services for commercial and multifamily entities in the City of
Minneapolis are primarily provided by private haulers that obtain a hauling license from the City and does
not require private haulers and the City to enter into franchise agreements. The City of Minneapolis has
ordinances in place requiring both commercial properties (implemented 2011) and multifamily properties
(implemented 1991) to provide recycling opportunities onsite for tenants and residents. Further, the State
of Minnesota mandated commercial recycling in 2014.63 Private haulers servicing commercial and/or
multifamily customers within the City of Minneapolis are required to obtain a hauling license from the
City. The City has a long-standing ordinance (implemented 1995) requiring commercial recycling
haulers, including those servicing multifamily properties, to provide semi-annual reports to the City.
Reporting requirements include the address of each commercial and multifamily recycling customer
serviced, total tonnage of commercial and multifamily recyclables collected within the City, and the
processing facility or end-markets utilized.
Seattle, Washington. Trash collection services for commercial and multifamily entities in the City of
Seattle are provided through a zoned franchise system with a limited number of additional haulers
providing recycling and organics collection in the City. The City of Seattle has ordinances first
implemented in 2003 requiring residential, multifamily, and commercial customers to separate recycling
and organics from trash. Commercial recycling and organics haulers and processors submit annual
62 https://dallascityhall.com/departments/sanitation/Pages/commercialrecycling.aspx
63 http://www.ci.minneapolis.mn.us/solid-waste/recycling/commercial-recycling
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-20 Burns & McDonnell
reports to the City to maintain their City of Seattle Recyclers Business License.64 Reporting requirements
include tons recycled or composted, by material, and disposition of processed material. Once reports are
received, the City analyzes the reports to ensure tons reported by haulers and processors are not double
counted. If a hauler does not report, the City estimates amounts hauled based on historic reporting (if
available). Commercial recycling haulers that fail to submit annual reports have received fines. 65
Los Angeles, California. Collection services for commercial and multifamily entities in the City of Los
Angeles are provided through a zoned franchise system. The State of California adopted an ordinance in
2014 that requires businesses and large multifamily properties (five units or more) that generate four or
more cubic yards of solid waste per week to arrange for recycling services. In 2017, The City of Los
Angeles launched recycLA, a public-private partnership that offers universal recycling services to all
commercial and industrial businesses, institutions, and large multifamily buildings. The program divides
the city into 11 zones serviced by seven franchised service providers, and all commercial and multifamily
buildings in each zone are serviced by a single franchise service provider. The City of Los Angeles
provides oversight to each service provider to ensure they comply with the City’s reporting requirements
and provide public education to enhance recycling opportunities.66 Franchise contracts require haulers to
report a wide variety of detailed information including but not limited to:67
Customer account, contact, billing, and service inquiry data
Customer service level data associated with each account and location by collection stream
Diversion reports and tonnages of materials delivered to certified facilities by collection stream
Documentation of outreach and education efforts
Data about field operations, staffing levels, fleets, safety trainings and meetings, and injury and
illness prevention
8.5 Key Findings and Recommendations
The following presents consolidated key findings and recommendations related to planning for the City’s
anticipated growth, as a basis for the Strategy to Plan for Future Growth and Infrastructure described and
evaluated in Sections 11.4 and 12.0.
64 https://www.seattle.gov/Documents/Departments/SPU/Documents/Plans/SW_Plan_015204.pdf
65 Specific information regarding level of fees and penalties for non-compliance with reporting requirements was not
available.
66 https://www.lacitysan.org/san/faces/home/portal/s-lsh-wwd/s-lsh-wwd-s/s-lsh-wwd-s-zwlaf?_adf.ctrl-
state=ci5f16vqu_5&_afrLoop=4891411484568428#!
67 Refer to Table 10-1 in the exclusive franchise contract:
https://www.lacitysan.org/cs/groups/public/documents/document/y250/mde0/~edisp/cnt014118.pdf
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-21 Burns & McDonnell
The City can consider a transfer station in municipal facility planning, but financial
feasibility would not be realized in the near term. While operational benefits could be obtained
from a transfer station, the facility would not be financially viable through the 2040 planning
horizon if only managing the projected tonnages from the Hunter Ranch and Cole Ranch MPCs
and nearby service areas. The facility financials improve if outside tonnage of at least 35,000 tons
of third-party material is also managed through the facility (and subsequently managed at the
Denton Landfill or Pratt MRF). Adding additional services or programs at the site may also
improve feasibility.
The City has taken a proactive approach to address development trends that present
collection challenges or create unserviceable areas. Continued collaboration between SWR and
Development Services becomes more critical as development trends continue to evolve and the
number of residential developments inaccessible by standard collection vehicles potentially
increases. As construction in large MPC developments increases and continues in future years,
the City should continue to be proactive in identifying and addressing potential challenges and
collaborating on modifications to criteria.
A lack of data related to multifamily, commercial, and C&D recycling presents a challenge
for the City to assess the success of any future recycling incentive programs. The City’s
efforts to increase access to recycling data through hauler manifests and other recycling activities
(e.g., drop-off boxes, metal recyclers) will provide valuable information to inform future
decision-making on any policies and programs to enact for multifamily and/or commercial
recycling.
Most approaches to increasing recycling, especially in multifamily and commercial sectors,
focus on increasing (or mandating) access to programs; however, if recycling contamination
is not addressed, increased recycling access will be detrimental rather than beneficial to the
recycling system. Mandated recycling programs, such as through a universal recycling
ordinance, increase recycling participation through improved access to programs. However, the
City currently faces contamination challenges especially from multifamily and commercial
generators. When contamination rates are too high for the material to be processed effectively at
the MRF, these loads are taken to the Denton Landfill for disposal. It is of crucial importance to
reduce contamination prior to implementing policies such as recycling mandates in the
multifamily or commercial sectors, so that these programs yield clean recyclable material. A
phased approach of customized diversion incentives & strategies for residential, multifamily, and
Comprehensive Solid Waste Management Strategy Planning For Future Growth & Infrastructure
City of Denton, Texas 8-22 Burns & McDonnell
commercial sectors should be established with long-term options to expand (as warranted). For
example:
o Reduce recycling contamination. Options and recommendations are outlined in the
Strategy to Enhance Education, Outreach and Compliance. Sector-specific options
include cart removal for single-family residential and an ordinance allowing the City to
establish contamination requirements and reclassify highly contaminated commercial
recycling loads as refuse (for which the City is the exclusive service provider).
o Expand or adjust City programs and partnerships to incentivize recycling, as
appropriate. Options such as expanding drop-off programs, adjusting landfill pricing
based on market studies, and leveraging partnerships (as described in Section 10.6) can
be used to incentivize recycling activity.
o Enact recycling ordinances to expand requirements (when needed). Consider options
such as residential PAYT pricing changes and mandatory commercial and multifamily
recycling on a longer timeline to allow the City to first address contamination and collect
necessary data from the commercial sector to determine the most appropriate approach.
The City is well-positioned to directly support C&D reuse and take steps to incentivize the
use of existing C&D recycling capacity in the region. From a sustainability perspective,
material reuse is preferred to recycling. The City should consider establishing a City-operated
C&D Reuse Warehouse at Building 651, to provide a local option to divert reusable C&D
material from the Denton Landfill and be a source of building materials for local entities. A reuse
warehouse can also support future C&D policies that encourage or require C&D diversion and/or
use of recycled materials. Nearby C&D processing capacity exists (e.g., Champion C&D MRF),
and the City should consider a variety of options to encourage recycling potentially through a
combination of landfill pricing and ordinance rather than establishing a City-operated C&D
recycling facility.
Comprehensive Solid Waste Management Strategy Recycling Processing
9.0 RECYCLING PROCESSING
Effective recycling programs can provide environmental, diversion, and financial benefits, especially as
residents and commercial entities increasingly value sustainability. Recycling services in Denton are
provided through multiple City programs and partnerships, including the Lease and Regional Recyclable
Processing Agreement (Recycling Agreement) with Pratt Industries for the operation of the Pratt MRF.
One of the largest challenges currently facing the City’s recycling program is contamination (garbage and
non-programmatic recyclable material).
This section includes an evaluation of the programs and opportunities to minimize contamination and
other challenging materials in the recycling stream, an overview of recycling processing agreement best
management practices, an evaluation of the City’s current agreement with Pratt, and considerations for
future recycling procurement. These evaluations are meant to support the City in answering three
questions:
1. What options exist to increase the diversion of challenging materials before they reach the MRF?
2. How should the City prepare if Pratt opens the rebate provision for renegotiation in prior to the
commencement of the five-year period beginning October 2, 2023?
3. What are the considerations for future recycling processing when the current contract expires?
Tactics to implement the Strategy to Optimize Recycling Processing were developed based on the
evaluation, case studies, key findings and recommendations presented in this section as well as the
outcomes of workshop discussions with City staff. Section 11.5 presents the Strategy to Optimize
Recycling Processing in more detail. Section 12.0 provides the implementation plan.
9.1 Minimizing Challenging Materials in the Recycling Stream
Contamination is a challenge in many recycling programs, and MRFs may receive many materials that are
not suitable for processing at the facility or could be managed through alternatives. These include:
Specific contaminants of concern as determined and communicated by Pratt
Materials such as batteries and needles/sharps that present a safety hazard when received at a
MRF
Materials such as textiles or shredded paper that are recyclable but cannot be processed/sorted at
a MRF and must be diverted through other programs or facilities
Comprehensive Solid Waste Management Strategy Recycling Processing
Materials such as glass that are recyclable but may not be included in all recycling programs.
Currently, these materials are not well-captured at the Pratt MRF
The materials described herein are not suitable for processing at the Pratt MRF or not currently well-
captured (in the case of glass) because the equipment types and configuration are not designed to
segregate and capture these materials. Table 9-1 presents the current system and available
alternatives/approaches to managing these materials. Following the table, the current system and
recommendation option(s) for each material are described in more detail.
Comprehensive Solid Waste Management Strategy Recycling Processing
Table 9-1: Current and Available Management Strategies for Challenging Materials at MRFs1
Material Challenge or Concern
Drop-Off
Facility
Retail
Drop-Off
Separate
Curbside
Collection
Reuse or
Donation
Education
&
Outreach
Collection
Events
Film/bags
Contaminants of concern for
Pratt
o ● -2 ●
Styrofoam (EPS) o o ●
Food ●3 o ●
Glass Not well-captured at Pratt MRF ● o o ●
Sharps
Presents a safety hazard for
recycling collection or MRF
workers
o o ● o
Batteries o ● ● ●
Tanglers ●
Explosives ●
Home chemical waste ● ● ● ●
Shredded paper
Recyclable but not suitable for
MRF processing
●4 ● o
Textiles o ● ●
Furniture/bulky items ● ● ● o
1. A closed circle “●” indicates a strategy that is currently implemented in Denton. An open circle “o” indicates an alternative management option or strategy.
2. While a limited number of programs in Texas include film in their single-stream program (e.g., “bag the bag”), this approach is not recommended compared to
opportunities to divert this material from the MRF-bound recycling stream. Therefore, it is not shown as an alternative management option or strategy.
3. Material is currently accepted from residential customers comingled in the curbside yard waste collection program.
4. Material is currently accepted from residential customers comingled in the curbside yard waste collection program or in the recycling cart if bagged in a clear plastic
bag.
Comprehensive Solid Waste Management Strategy Recycling Processing
9.1.2 Plastic Film and Bags
Plastic film and bags are flexible packaging materials such as Linear Low-Density Polyethylene (LLDPE)
and other composite plastics. The low density of this material makes it challenging to capture at the MRF
when included as an accepted material, as it acts like paper in among the sorting equipment and mixes
with the MRF’s paper stream. Rather than being separately recovered at the MRF, plastic film and bags
typically contaminate the paper stream or become process residue. This material can enter a MRF either
as “wish-cycled” materials that residents believe will be recycled at the MRF or when residents bag their
recyclable materials prior to placing them in the curbside cart.
Current System. The primary way that recyclable plastic film (e.g., grocery bags) is recovered is through
retail drop-off. Many grocery stores and some other retailers offer bins for customers to drop off
recyclable film plastics for recycling. This type of outlet can effectively recycle the plastic film and bags
because they are not mixed with other recyclables.
Opportunities. With the prevalence of retail drop-off in Denton, the primary opportunity for the City
related to film plastics recycling is to raise awareness through education and outreach. The City can
leverage existing resources (e.g., NCTCOG’s “Know What to Throw”) to raise community awareness of
the importance of keeping film plastics out of the recycling cart and the existing opportunities to drop off
suitable plastics to retail establishments for recycling.
9.1.3 Styrofoam
Expanded polystyrene (EPS, “Styrofoam”) foam is a common form of plastic buffer typically found as
protection in packaging for consumer goods or in other forms such as packing peanuts. EPS typically
enters a MRF as a “wish-cycled” material. While there are processes to recycle clean and dry EPS into
new materials, it cannot be recovered through a MRF because is it very lightweight and low-density and
will break into tiny pieces, blow off conveyors and contaminate other lines/materials.
Current System. Currently there is not an organized system for EPS recycling in Denton. The City’s
Waste Wizard directs residents who wish to recycle this material to transport it to the drop-off programs
in Fort Worth or Frisco.
Opportunities. The City could offer an EPS recycling pilot program to residents, co-located with a
manned drop-off such as the HCC. Important considerations for starting an EPS drop-off program include
capital costs of necessary equipment (i.e., densifier), having a convenient and sufficiently sized location
for drop-off, securing a consistently available end market, and effective education and outreach to raise
awareness of the program. There are currently multiple cities in Texas with successful with city-operated
Comprehensive Solid Waste Management Strategy Recycling Processing
EPS drop-off programs, including the Cities of Austin, Fort Worth, and Frisco (which is described in
more detail in the following case study).
Case Study: City of Frisco EPS Foam Recycling Program. The City of Frisco provides handling and
processing services for this material so it can be recycled cost effectively. The City of Frisco densifies
EPS using a screw press to create briquettes that can be stored and sold in bulk, as shown in Figure 9-1.
The City works with Avangard Innovative for the collection of hard-to-recycle plastics including EPS
foam, low-density polyethylene (LDPE) and high-density polyethylene (HDPE). As of August 2019, the
City sells this material at about 0.13 cents per pound, which includes shipping. The City of Frisco reports
that despite strong interest in the program, material throughput (and revenues) can be limited due to space
constraints for storage.
Figure 9-1: Densified Briquettes of EPS Foam
The City of Frisco’s EPS drop-off program is located with its home chemical collection and other hard-to-
recycle material drop-off programs at the City’s Environmental Collections Center (ECC). As a result, the
program convenient for residents who may wish to drop off multiple material types. Similarly, education
and outreach efforts to raise awareness of all ECC programs can include the EPS drop-off program,
raising awareness efficiently. The City of Frisco has also seen strong awareness growth from word-of-
Comprehensive Solid Waste Management Strategy Recycling Processing
mouth, as residents and commercial entities have a strong interest in recycling EPS. Currently, the City of
Frisco program is available only to residents, but they receive many requests from commercial entities
looking for an opportunity to recycle EPS materials.
9.1.4 Food
Food waste, including both pre- and post-consumer materials, can enter recycling systems as
contamination when containers are not properly rinsed and dried before recycling. Further description of
pre- and post- consumer food waste is provided in Section 6.0.
Current System. The City does not operate a dedicated food waste collection program; however,
residents may include pre-consumer vegetative waste in their curbside yard waste container or kraft bags.
A detailed summary and evaluation of the City’s organics management programs is provided in Section
6.0.
Opportunities. The City has an established and comprehensive education and outreach program;
however, additional resources are available to City staff to promote proper food waste management,
including the NCTCOG’s “Know What to Throw” campaign content on keeping food out of the recycling
bin. In addition to promoting proper disposal of food (i.e., not in the recycling bin, certain materials
suitable for yard waste program), the NRDC’s Save the Food campaign (described in more detail in
Section 7.6.2) provides information to reduce the amount of food waste generated. These resources are
available to the City to supplement education and outreach content related to food waste. Edible food can
also be recovered for donation to in-need populations. These partnerships are discussed in more detail as
part of the Strategy to Support New Markets and Leverage Partnerships (see Sections 10.6, 11.6 and
12.0).
9.1.5 Glass
Clean glass bottles (including clear, amber, and green glass) are part of the typical recyclable stream of
curbside recycling programs in many communities across the country. Glass from single-stream
collection programs can be a challenging material to process efficiently in older MRFs, or those designed
for fiber/dual-stream programs. Processed glass can be challenging financially due to low commodity
values and increased wear on MRF equipment.
Current System. Glass is collected as part of the single-stream recycling program in the City, including
curbside collection and drop-off locations. However, not all Pratt MRF customers include glass as a
program material.
Comprehensive Solid Waste Management Strategy Recycling Processing
The Dallas-Fort Worth Metroplex area is home to key infrastructure and recycled glass end users to
support healthy recycled glass markets, specifically secondary glass processing/beneficiation facilities to
further clean and sort glass and produce clean cullet and end users such as bottle and fiberglass
manufacturers.
Secondary Processors:
Strategic Materials (Midlothian)
Dlubak Glass (Waxahachie)
End Users:
Owens Corning (Waxahachie), manufacturer of fiberglass;
Johns Manville (Cleburne), manufacturer of fiberglass;
Potters Industries (Brownwood), Manufacturer of industrial glass beads; and
SWARCO Reflex (Mexia), manufacturer of industrial glass beads.
Although Denton is located on the northern edge of the Dallas-Fort Worth Metroplex and further away
from the region’s glass recycling infrastructure, which is primarily south of I-20, the City still has
competitive access to infrastructure to support glass recycling markets. Clean material is key to
maximizing the economic viability and environmental benefits of processing and recycling glass, as
environmental benefit is high for end uses such as bottle-to-bottle glass recycling and low or negative for
other beneficial uses such as sandblasting or landfill cover.
Opportunities. Opportunities to improve glass recycling often focus on contamination, as glass often
faces salability challenges due to high levels of contamination.
MRF-focused approaches to improve glass recycling include equipment upgrades that improve
the ability to sort and capture glass, and incentives such as MRF standards (e.g., performance or
outbound quality standards) or certification (e.g., Glass Recycling Coalition (GRC)’s MRF Glass
Certification) to encourage efficient glass recovery.
Supplemental “glass on the side” collection programs can be used to increase quantities of
source-separated, clean glass. For example, a supplemental curbside glass-only collection
program could be implemented in targeted downtown areas in and often conjunction with an
incentive or mandatory recycling requirement for specific commercial generators (e.g., bars,
restaurants). Glass on the side programs can also be operated as drop-off only (such as in the
Comprehensive Solid Waste Management Strategy Recycling Processing
Kansas City metro area), or a combination of curbside and drop-off (such as in Orange County,
NC). Details on these programs are shared as case studies, below. Many drop-off programs
partner across multiple cities or counties, thereby benefitting from economies of scale.
The City can continue to work with Pratt on opportunities to address contamination and work towards
better recovery, including overdue facility upgrades that Pratt has expressed an intention to undertake in
the near term. Once upgrades are completed, the Pratt MRF may be able to obtain GRC MRF Glass
Certification which can help to highlight the MRF to cullet buyers within and beyond the immediate
metroplex area.
The City’s current commercial valet program provides diversion services to commercial generators in the
downtown area. With the recent NCTCOG grant, diversion opportunities for entities in the valet area will
expand to include food waste diversion at approximately 140 businesses including bars and restaurants. A
curbside glass on the side program could be similarly implemented to target clean glass generated in
relatively large quantities from bars/restaurants, and gauge the feasibility, costs, and interest of
commercial generators to expand the program.
The City could also consider including a glass-only drop-off option at existing locations. While
contamination is typically a concern in unmanned drop-off stations (e.g., North Lakes Recycling Center),
unmanned glass drop-off programs can be successful, and may be a suitable progression of a glass on the
side program in Denton once single stream contamination levels are further addressed through options
such as those presented in the Strategy to Enhance Education, Outreach, and Compliance (see Sections
5.0, 11.1, and 12.0).
Case Study: Glass on the side. Orange County, NC recently implemented a supplemental “glass on the
side” program for glass bottles and jars. The program serves commercial collection routes as well as
unstaffed drop-off locations throughout the county for residential program access. The program is a
regional effort with two neighboring counties, and was supported in part from state agency grant funding
and the GRC. The commercial access program complements the state’s law that mandates glass recycling
at bars and restaurants. Based on information from October 2020, the county receives $20 per ton for the
clean glass from a local glass processor that produces glass bottles, fiberglass, sand blasting material, and
reflective paint beads. Glass is also accepted in the counties’ curbside recycling single stream programs.
9.1.6 Sharps
Medical household sharps, such as needles and syringes, are routinely observed at MRFs across the
country, and put workers picking material from conveyor belts at risk of needlestick injuries. The amount
Comprehensive Solid Waste Management Strategy Recycling Processing
of household sharps is increasing nationally due to an aging population, increase use of injection
medication (e.g., insulin), confusion on proper disposal practices, and limited access to safe disposal and
take-back programs.
Current System. In Texas, residents are instructed to place sharps in a strong plastic container to dispose
of in their household trash. While some household hazardous waste (HHW) programs accept medical
sharps, the City’s current HCC program does not.
Opportunities. Education and outreach is important so that residents know how to properly dispose of
any medical household sharps they generate, as sharps at MRFs present an elevated risk due to the nature
of picking-line work. The City could expand safe disposal opportunities through the HCC program or
through partnerships with other entities (e.g., City of Denton Police Department or Fire Department, retail
pharmacies).
9.1.7 Batteries
Batteries generally enter MRFs as a result of “wish-cycling.” Batteries, specifically lithium and lithium-
ion batteries, have become a contaminant of concern at many MRFs due to the potential to combust if
compressed or punctured during collection or processing.
Current System. While many types of batteries are recyclable they cannot be recycled through the Pratt
MRF. Currently, residents can recycle batteries through the City’s HCC programs (at the HCC facility,
door-to-door, or mobile BOPA events) and at some retailers (i.e., Home Depot, Lowes).
Opportunities. With the existence of drop-off options in Denton, the primary opportunity for the City
related to battery recycling is to raise awareness through education and outreach. The City can leverage
existing resources (e.g., NCTCOG’s “Know What to Throw”) to raise community awareness of the
importance of keeping waste and recycling workers safe by recycling batteries at the HCC or retail drop
off locations. The City plans to expand the HCC mobile events specifically targeting batteries.
9.1.8 Tanglers and Explosives
Recycling contaminants that present a risk to worker safety and may cause equipment damage include
tanglers (e.g., cords, string lights), explosives (e.g., ammunition), and compressed gas tanks. While some
of these materials have recyclable materials/components (e.g., electronics, metals), they cannot be
recycled safely through MRFs. Items such as hoses, cords, and string lights can become tangled in
equipment, causing downtime and the potential for worker injuries. Items such as propane tanks and
Comprehensive Solid Waste Management Strategy Recycling Processing
ammunition present a significant safety risk to recycling workers, since the process of collecting and
processing recyclables often includes compacting materials.
Current System. Ammunition and other hazardous materials should be safely and responsibly disposed
of. Some police stations or gun ranges accept ammunition for safe disposal. Undamaged propane tanks
can be refilled or exchanged at retail locations, and other materials (e.g., string lights) can be donated if in
working condition. While the City’s HCC does accept aerosol cans, it does not accept propane and butane
cylinders.
Opportunities. The City can leverage existing resources (e.g., NCTCOG’s “Know What to Throw”) to
raise community awareness of the importance of keeping these items out of the recycling cart. The
NCTCOG campaign included content specific to these categories of materials.
9.1.9 Home Chemical Waste
Home chemical waste includes items such as household cleaners, pool chemicals, lawn and garden
pesticides, paint, varnishes. These items can be a safety risk at MRFs, including chemical exposure and
fire hazards. Pool chemicals, for example, are a common cause of “hot loads,” that is materials collected
for disposal or recycling that smolder or burn. Home chemical waste requires separate, safe disposal or
recycling.
Current System. The City’s HCC program includes many service offerings. The permanent HCC facility
offers in-person disposal of specified home chemical waste and other items requiring special disposal
(e.g., batteries, lightbulbs), as well as reuse of HCC items in good condition through the free ReUse Store.
Demand for this service is high, including from residents of surrounding communities without HCC
programs. The City’s program also includes door-to-door collection, which provides a high level of
convenience for those with mobility or transportation challenges or are not located near the HCC.
Additionally, the City hosts mobile HCC events in targeted areas of the City (e.g., Robeson Ranch) and
plans to expand this service.
Opportunities. The City can leverage existing resources (e.g., NCTCOG’s “Know What to Throw”) to
raise community awareness of the importance of keeping these items out of the recycling cart, in addition
to existing outreach informing residents to divert these materials through the many HCC program
offerings for proper disposal (or reuse, if in usable condition). Given the demand for HCC from residents
of surrounding communities, the City could expand program access through partnerships with these
communities. These regional programs have been successful in other parts of the NCTCOG and in other
Comprehensive Solid Waste Management Strategy Recycling Processing
parts of the state. An approach to HCC regionalization is discussed in more detail as part of the Strategy
to Support New Markets and Leverage Partnerships (see Sections 10.0, 11.6 and 12.0).
Case Study: Regional HHW Programs in the NCTCOG. The City of Fort Worth owns and operates a
permanent facility providing HHW and hard-to-recycle material drop-off to residents of Fort Worth and
50 neighboring cities. Additionally, the program includes facilitating mobile collection events in partner
cities and the option for partner cities to perform their own door-to-door collection or mobile collection
and subsequently drop off materials at the City of Fort Worth’s permanent facility (ECC) for disposal.
This structure provides a regional “hub-and-spoke” structure with the ECC serving as a central material
processing and disposal site with collection opportunities throughout the 50 neighboring cities. Partner
cities compensate Fort Worth on a per-household basis for use the ECC or mobile collection events
within the partner cities.
Dallas County facilitates a regional HHW program for 16 member cities through its interlocal agreement,
with each member city paying a portion of the program’s disposal, operations, and capital costs. Member
cities contribute to disposal proportionally based on the number residents who use the program and
contribute to operations and capital costs proportionally based on the number of single-family households
in the service area. Additionally, non-member residents can use the program for $95 per visit.
9.1.10 Shredded Paper
Shredded paper typically enters recycling systems as a “wish-cycled” material, since non-shredded papers
(e.g., office paper, mail) is recyclable in curbside recycling programs. Some programs allow residents to
put shredded paper in the recycling cart if it is in a clear plastic bag, so that it can be separated from single
stream materials at the tipping floor to be later baled with other paper. Because of the small size,
unbagged loose shredded paper cannot be recovered through MRFs and becomes contamination.
Current System. The City’s Waste Wise tool instructs residents to place shredded paper in the recycling
cart in a clear plastic bag. Shredded paper could also be disposed of in the yard waste program for
composting.
Opportunities. The City can further leverage its education and outreach to ensure residents understand
the requirements to bag shredded paper if placed in the blue bin, and to make residents aware that this
material can also be diverted for composting through the yard waste program. Many cities have success
hosting or partnering for shredding events, where residents can bring documents for shredding and secure
destruction (via recycling).
Comprehensive Solid Waste Management Strategy Recycling Processing
9.1.11 Textiles
While many textiles are recyclable, they cannot be recycled through MRFs, and if textiles such as
clothing or towels enter a MRF they can act as tanglers (discussed in Section 9.1.8).
Current System. There are many thrift and other reuse-oriented businesses in Denton that accept textiles
for reuse or recycling, including at drop-off boxes located throughout the City.
Opportunities. The City has an established and comprehensive education and outreach program, which
can be leveraged to raise awareness of existing reuse and recycling options for textiles. As the City begins
to collect recycling data from third-party entities, the effectiveness of current textile recycling can be
evaluated. Other cities have seen mixed success with third-party private sector curbside collection
programs (e.g., Simple Recycling), these options exist.
9.1.12 Furniture and Other Bulky Items
Large items such as furniture or scrap metal cannot be recycled through MRFs, and because of their size
cause challenges if collected with typical recyclables. Many discarded furniture and bulky items can be
donated for reuse or upcycling, but if sent to a MRF these items are likely to damage processing
equipment (e.g., ripping conveyor belts), injure workers, and ultimately get disposed in landfill with other
contaminants and problem materials.
Current System. Furniture, mattresses, televisions, and refrigerators are popular search items in the
City’s Waste Wizard. There are many thrift and other reuse-oriented entities in Denton that accept
furniture and similar bulky items for reuse. Some bulky items that are not in usable condition can be
recycled through City programs (e.g., televisions at the HCC, refrigerators and other white goods at the
landfill).
Opportunities. The City has an established and comprehensive education and outreach program, which
can be leveraged to raise awareness of existing reuse, recycling, and safe disposal options for furniture
and other bulky items. The Denton community presents multiple partnership opportunities for the City to
increase the reuse of furniture and other home goods. Denton is home to multiple universities (i.e.,
University of North Texas and Texas Woman’s University), which presents an opportunity for the City to
partner with university housing for move-out events. Typically during move out, a significant quantity of
reusable furniture and other household goods are discarded to landfill. Many universities have seen
success with “zero waste” move-out and similar events to collect usable furniture and other household
goods. Collected materials could be used to meet community needs through non-profits providing
furniture for in-need populations (e.g., homelessness, crisis, disaster). Partnership options are discussed in
Comprehensive Solid Waste Management Strategy Recycling Processing
more detail as part of the Strategy to Support New Markets and Leverage Partnerships (see Sections 10.0,
11.6 and 12.0).
9.2 Recycling Processing Agreement Overview
This section provides a detailed description of best management practices and procurement considerations
to support the evaluation of the City’s existing Recycling Agreement and identify components that should
be kept, added, or adjusted as part of the Strategy. An overview of the types of recycling processing
agreements and public-private partnerships, include advantages and disadvantage, is provided in Section
4.2. Appropriately planning, developing and maintaining partnerships is critical to properly manage and
recycle materials and pursue the key findings and recommendations presented in Section 9.4 and further
evaluated in Section 11.5. The key to maximizing the value of the existing and future recycling
processing agreements is to leverage public-private partnerships (PPP) that support the City’s long-term
needs.
9.2.1 Recycling Processing Agreement Best Management Practices
Burns & McDonnell has compiled the best management practices related to key components and
provisions of a recycling processing agreement as follows, with brief descriptions.
Identify processing fees. The charge assessed on a per ton basis should be based on the operating
cost of the MRF and may include base level profit requirements for sustainable business
operations. Processing fees are a standard elements of recycling processing agreements and in
some cases are critical to MRF business viability.
Establish revenue sharing. The allocation of money received from the sale of materials should
be established to allow both parties to realize benefits from favorable market conditions and
minimize risk in depressed markets. Revenue sharing arrangements should be based on the
composition and value of the inbound material and needs to be calculated in a transparent way.
The basis for revenue sharing should be based on actual commodity sales or on the composition
of inbound material. Revenue sharing calculated using material composition can make
agreements more equitable in both strong and weak commodity markets and can incentivize
actions from both parties to reduce inbound contamination or increase capture of high value
materials. Although revenue sharing provides key benefits as part of recycling agreements,
market challenges and fluctuations should be expected revenue sharing should not be sole source
of revenue that supports recycling program operational costs.
Determine material value. Published or otherwise available sources of secondary commodity
material pricing should be identified as part of a recycling processing agreement and should be
Comprehensive Solid Waste Management Strategy Recycling Processing
explicit on how material values are determined. Material values should be based on the higher or
actual sales price or published index prices to incentivize MRF operators to seek the highest
pricing for materials. If one or more published indices are not used, it is possible for MRF
operators to share the value of materials based on actual material sales; however, periodic third-
party verification should be implemented to ensure transparency and accuracy of reported data.
At a minimum, a recycling processing agreement should detail how often MRF material sale
values are reported and how they are used as part of revenue sharing calculations on a monthly or
quarterly basis.
Determine acceptable materials. The materials the MRF is obligated to accept, process and
market and procedures or conditions under which the mix of materials may change should be
established explicitly as part of a recycling processing agreement (e.g., allowing adjustments to
acceptable materials without requiring contract amendments. The accepted materials should be
determined taking into account diversion goals, collection procedures (e.g., single-stream or
source separated), markets (including emerging markets) and the current and future capability of
the MRF to process and market each type of materials. The general trend has been for recycling
processing agreements to include an expansive range of materials in hopes of reaching higher
diversion targets and has created challenges for MRFs to effectively operate their facilities and
sell materials that meet increasingly rising quality standards.
Conduct material audits. Recycling processing agreement should explicitly establish the
frequency, protocols, and intended uses of material audits. Such audits can be particularly useful
when trying to measure the effect of specific actions in the collection program, such as the
initiation of a cart-tagging program intended to reduce contamination. Understanding both the
composition of the incoming recyclable material stream and outgoing residue is important to
increase the effectiveness of efforts to decrease contamination and increase the capture of
acceptable materials. Additionally, conducting material audits can provide a basis for revenue
sharing agreements. Two main methods can be used to conduct a material audit: inbound material
sampling or full system audit. Inbound material sampling is a desktop sorting of select materials
before they are processed through the MRF equipment and full system audits are a more
comprehensive evaluation of the amount and type of material captured by the MRF equipment.
Maintain material quality and minimize contamination. Specific conditions related to levels
and types of contamination expressed as a percentage of the inbound material should be
established in a recycling processing agreement to ensure that inbound material quality is
consistently high. The acceptable amount of contamination should be based on a combination of
historical contamination amounts and reflect the efforts or practices in place to decrease
Comprehensive Solid Waste Management Strategy Recycling Processing
contamination. High levels of contamination can cause the cost to double because trash that
generates zero revenue must be processed and the separated contamination must be transported
and disposed. An innovative approach to maintaining material quality and minimizing
contamination is to adjust the processing fee relative to the level of contamination (e.g., if base
processing fee is $80.00 per ton based on a 20 percent contamination threshold, the processing
fee would rise to $85.00 per ton if the contamination increases to 25 percent or fall to $75.00 per
ton with a 15 percent contamination level). To implement this approach, clear and transparent
data collection and analysis would need to be carried to gauge how much residue had been cause
by contaminants in inbound loads specific to the City.
Establish minimum performance criteria. Recycling processing agreements should establish
the minimum expectations regarding operating performance including meeting the equipment
manufacturer’s designated recovery rating. Typically, recycling processing equipment
manufacturers design their systems to recover 95 percent or more of the intended recyclable
material. A full system audit of outgoing MRF residue compared with the quantities of sold
commodities allow this type of mass balance equation to be calculated to measure the MRF’s
operating performance.
Address rejected loads and residue disposal. Recycling processing agreements should provide
clear parameters on what constitutes unacceptable loads, how they are handled, and how MRF
residue and/or contamination is managed and explicitly assign costs and responsibilities to each
parties. For example, when an incoming load is rejected due to excessive contamination, there
may be a per ton disposal fee for transporting and disposing of the rejected load. In all cases, it is
important to the transparency and fairness of the contractual relationship for there to be timely
reporting and documentation associated with load rejection, including ideally the taking of
photos. Additionally, recycling processing agreements should clearly define residue and
contamination, indicating that residue is acceptable materials that are not captured by equipment
and contamination are unacceptable materials or materials that the MRF processor is unable to
sell due to adverse market conditions.
Provide education and outreach support. The level and nature of education and outreach
provided to the community through a recycling processing agreement including the
responsibilities for both parties and the ways that the agreement provides specific resources for
conducting effective outreach. Municipalities have more direct contract with residents, and
therefore should have the lead responsibility for education and outreach while the MRF operator
may financially support the educational efforts with dedicated payments or in-kind services.
Municipalities and MRF operators should coordinate to review results from material audits to
Comprehensive Solid Waste Management Strategy Recycling Processing
better understand what residents are setting out for collection, and how the education information
may need to be updated.
Determine contractual contingencies. Establishing clear guidance on the procedures in the
event of service disruptions from unforeseeable events (e.g., accidents, inclement weather, natural
disasters, equipment failure, business failure, etc.) should be included in recycling processing
agreements. MRF operations have the potential to be seriously impacted by a range of negative
conditions and every contract should contain provisions that address these issues, as unlikely as
they may seem when the agreement is initially development. Contingency provisions protect both
parties from the unexpected by providing direction, guidance, and assignment of responsibilities
in emergencies and other negative situations.
Establish reporting and communication protocols. Regular and productive sharing of
information between contracting parties is essential for the long-term viability of a recycling
processing agreement. Communications between a municipality and its MRF should include a
combination of written reports, with the specific type and frequency of reporting outlined in the
contract including inbound tonnage, operational reports including staffing, financial reports, audit
results, and unacceptable loads rejected.
9.2.2 Evaluation of Lease and Recycling Processing Agreement
This section evaluates the City’s current Lease and Recycling Agreement against the best practices
described in Section 9.2.1. Table 9-2 provides an evaluation matrix that compares key components the
Recycling Agreement in an approach consistent with evaluations of submissions as part of an RFP
process; strengths, weaknesses and opportunities are provided for each of these key components. This
evaluation provides the basis, in part, for the key findings and recommendations presented in Section 9.4
and further evaluation related to the Strategy to Optimize Recycling Processing provided in Section 11.5.
Comprehensive Solid Waste Management Strategy Recycling Processing
Table 9-2: Evaluation Matrix of City’s Current Lease and Recycling Processing Agreement
Processing
Agreement
Component Strengths Weaknesses Opportunities
Lease
The MRF building size is adequate to handle the current volume of
Accepted Recyclable Materials delivered to the facility. The City receives
revenue from Pratt to lease the land and will receive the MRF building at
and of the agreement at no cost to the City (if the agreement reaches the
end of the initial term).
The current footprint of the MRF may not be sufficient to handle the future
increased volume of materials, especially if the City established a regional
program to process materials generated in neighboring municipalities.
Additionally, at the end of the lease, the City does not receive ownership of the
processing equipment.
Evaluate Pratt’s interest and ability to expand the footprint and/or capacity of
the MRF leading up to the completion of the initial term of the Recycling
Agreement.
Processing Fees
There is no processing fee as part of the current Lease and Recycling
Processing Agreement minimizing the cost to the City for recycling
processing.
Other recycling processing agreements in the region include a processing fee
providing Pratt a basis to request a processing fee be introduced into the agreement
going forward.
Maintain the current structure of the Lease and Recycling Processing
Agreement to minimize the future cost of recycling processing.
Revenue
Sharing
The City receives a monthly rebate on the total tons of material delivered to
the MRF for multiple types of material including Curbside Collected Single
Stream Recyclable Material, Clean Commercial Recyclable Material, and
Non-City Recyclable Material. The rebate on Curbside Single Stream
increases incrementally as the tonnage of total material delivered to the
MRF rises, incentivizing the City to maximize diversion from landfill. The
rebate received from Pratt is not the sole revenue stream supporting the
City’s recycling program.
The material types and indices that serve as the basis for the rebates are outdated,
including certain material classifications that are no longer recognized or are based
on tonnages that are not aligned with the generators producing that material (e.g.,
per Section 1.09(a) the monthly rebate for Curbside Collected Single Stream
Recyclable Material is based on total tonnage delivered to the MRF rather than
only the curbside collected material).
Pratt has the opportunity to renegotiate the rebate prior to the commencement
of the five-year period beginning October 2, 2023 per Section 1.09(e) of the
Recycling Agreement. In the case Pratt causes the parties to renegotiate, the
City can develop potentially more favorable rebate values of certain materials,
update indices and take advantage of the recent increase in the secondary
commodity material markets. Additionally, the City may implement provisions
for utilizing a material audit to determine the rebate percentages.
Material Value
Determination
The base rebates set forth in Section 1.09(a) of the Recycling Agreement
were based on the value and cost of recovering Plastics #1 and #2, Steel,
Aluminum, old newspaper (ONP), OCC and Glass at the time the
agreement was initially developed. The value and cost of recovering these
materials has changed substantially since the agreement was initially
developed.
The materials used to derive the rebates include some materials that have
decreased in volume since the Recycling Agreement was initially developed (e.g.,
#6 and #8 ONP) and do not include other materials that are a recyclable in today’s
markets (e.g., #5 plastic).
Given the changes to recycling markets, material specifications and the volume
of certain materials generated have changed since the Recycling Agreement
was initially developed. If Pratt causes the parties to renegotiate per Section
1.09(e), City has the opportunity to update the specifications and values of
certain materials and take advantage of the recent increase in the secondary
commodity material markets. Additionally, the City may adjust the basis for
values be the higher of selected indices or actual sales price to incentivize Pratt
to seek the highest pricing for material.
Acceptable
Materials Mix
Section 1.06(a) of the Recycling Agreement lists the Acceptable
Recyclable Materials. The number and type of Acceptable Recyclable
Materials is robust, includes materials that could potentially be recycled in
the future (e.g., certain types of film plastics) and may be changed if
mutually agreed to by the City and Pratt without a formal contract
amendment.
Pratt is unable to segregate and recycle the complete list of Acceptable Recyclable
Materials due to equipment limitations operational constraints. Additionally,
certain materials are included as Acceptable Recyclable Materials and
Unacceptable Materials per Section 1.06(o) (e.g., certain types of film plastic is
listed as an Acceptable Recyclable Material and plastic items that are not rigid
containers is listed as an Unacceptable Material).
Pratt has expressed the intention to complete needed facility upgrades in the
near term, which provides the opportunity to transition equipment and
operations consistent with a modern single-stream MRF. The City and Pratt can
collaborate to clarify the list of Unacceptable Materials and the needs and
ability to recover all Acceptable Recyclable Materials at a high rate. In the case
of glass, facility upgrades may provide the opportunity to pursue GRC MRF
Glass Certification for improved marketing of glass cullet to end users in the
region.
Material Audit
Pratt currently conducts material audits of inbound material and provides
information to the City to support its recycling program.
The Recycling Agreement does not specify a material audit procedure, frequency
or any Standard Operating Procedure1 requirements to conduct material audits.
Although Pratt does conduct sorting of inbound material and provides this
information to the City, they are under no contractual obligation to do so.
If all or part of the Recycling Agreement is renegotiated, develop and
implement provisions that establish an audit procedure and frequency to
evaluate the inbound and outbound material and allows the right City to
participate in the process. The audit should provide key performance and
operational data such as capture rate, contamination rate, and residue rate that
the City and Pratt can use to collaboratively improve the performance of the
MRF.
Comprehensive Solid Waste Management Strategy Recycling Processing
Processing
Agreement
Component Strengths Weaknesses Opportunities
Material Quality
Section 1.07 of the Recycling Agreement allows Pratt discretion to visually
inspect and reject all or portions of inbound loads if they exceed 15 percent
Unacceptable Material and Residue, by weight. Pratt has been a good
partner to work proactively with the City to minimize rejected loads and
identify generators that habitually deliver loads exceeding the contractual
percentage threshold. Pratt conducts assessments of contamination levels
by sorting inbound material on an as-needed basis and communicates items
to support education and outreach efforts. Section 1.05(g) states that Pratt
owns the Recyclable Material upon delivery to the MRF and is responsible
for marketing the processed commodities, minimizing the requirements of
the City to divert material from disposal.
Per section 1.06(b) of the Recycling Agreement Clean Commercial Recyclable
Material refers to material that does not require removal of Unacceptable Materials
to meet the Institute of Scrap Recycling Industries (ISRI) specifications. Several
specifications published by ISRI related to mixed paper were updated in 2018
when international end-markets were disrupted due to increased contamination
standards implemented at Chinese ports2. Outdated material specifications may
lead to confusion or miscalculation of rebates based on Curbside Collected Single
Stream Recyclable Material, Clean Commercial Recyclable Material, or Non-City
Recyclable Material.
If all or part of the Recycling Agreement is renegotiated, revisit the basis for
determining for the contractual percentage threshold to incorporate historical
contamination figures from the past five years. Historical data should be based
on a consistent and mutually agreed on methodology consistent with the best
management practices described in Section 9.2.1. Additionally, determine if the
basis of the contractual percentage threshold is best represented by weight (as it
is in the current Recycling Agreement) or volume3.
Facility
Performance
Per Section 1.05(b) of the Recycling Agreement, the MRF contains
equipment that can process inbound material at a rate of 20 Tons per Hour
(TPH) and can accept between 32,000 and 50,000 Tons per Year (TPY).
This is sufficient capacity for the current needs of the City.
Although Section 1.05(h) of the Recycling Agreement requires Pratt to use
commercially reasonable efforts to recover all Recyclable Materials, this does not
allow the City to hold Pratt accountable to recover material at the equipment
manufacturer’s efficiency rating, typically 95 percent.
When the City considers which audit procedure to implement (either inbound
material sampling or full system audit as described in Section 9.2.2) ensure that
the contractual protocols or Standard Operating Procedures collects outgoing
MRF residue data in comparison with the quantities of sold commodities to
allow the City to calculate a mass balance equation to confirm an equipment
efficiency requirement of 95 percent or percentage consistent with the
equipment manufacturers rating.
Rejected Loads
and Residue
Disposal
Although Section 1.07 of the Recycling Agreement does not indicate that
rejected loads must be at mutual consent between Pratt and the City, it does
indicate that Pratt will deliver the material that is rejected for disposal.
Section 1.06(j) defines Residue as an Unacceptable Material or other contaminant
but does not provide a definition for Acceptable Recyclable Material that is
processed but not captured and erroneously considered Residue (as it is currently
defined by the Recycling Agreement).
If all or part of the Recycling Agreement is renegotiated, the City should work
with Pratt to develop and implement contractual protocols or Standard
Operating Procedures related to the inspection of inbound loads, including
mandatory communication protocols between Pratt and the City before a load is
rejected.
Education and
Outreach
The City publicizes the list of Acceptable Recycling Materials and
disseminates the list as it changes pursuant to mutual agreement between
Pratt and City. Further discussion of education, outreach and compliance
efforts by the City is provided in Section 5.0. Pratt provides $0.80 per ton
of Curbside Collected Single Stream Recyclable Material on a quarterly
basis per Section 1.04(e) of the Recycling Agreement. Pratt provides an
education and viewing room. Pratt conducts assessments of contamination
levels by sorting inbound material on an as-needed basis and communicates
items to support education and outreach efforts.
The financial support provided by Pratt is less than other peer Cities in the region
which range from $1.00 to $2.004 . Additionally, per Section 1.04(e) the funds
provided by Pratt must be used exclusively to fund the marketing, promotion and
education of the community. This language may limit the City to develop
innovative approaches to education and outreach that may fall outside marketing,
promotion or education (e.g., development of innovation grants, etc.).
If all or part of the Recycling Agreement is renegotiated, the City should revisit
the per ton value of financial support provided by Pratt to ensure that it will
support the City’s future need, given anticipated growth. Additionally, the City
should evaluate the current restriction on the uses of these funds to provide the
flexibility to use this funding to support ongoing or future programs that both
parties agree supports education and outreach (e.g., funding additional data
collection and analysis services using Rubicon equipment/services).
Contingencies
Per Section 1.05(d) of the Recycling Agreement, if downtime at the MRF
exceeds capacity to store unprocessed Recyclable Material, Pratt will be
responsible for finding a facility to store or process material and it shall not
be disposed in a landfill.
Per Section 1.04(h) of the Recycling Agreement, if the Landfill closes the City
shall accept Unacceptable Materials and Residue at successor landfill and City
shall provide transportation to replacement landfill at no cost to Pratt. Depending
on where the successor Landfill is located, this may become a significant expense
for the City over time.
If all or part of the Recycling Agreement is renegotiated, the City should revisit
Article IV Force Majeure to update the terms in light of recent challenges with
pandemic, labor shortage, and other market forces that may impact the patterns
of generation or collection of solid waste and recycling.
Reporting and
Communication
Pratt has been a good partner to provide reporting for various aspects of the
operation at the City’s request including confirming scale certification,
tonnage reports, rejected loads and supporting data for rebate calculation.
The Recycling Agreement does not specify reporting and communication
requirements related to rebates, volume and type of material accepted, or other
operational and financial considerations. Although Pratt provides this information
upon request, there is no contractual obligation for them to do so. This limits the
ability for the City to hold Pratt accountable to the terms of the Recycling
Agreement and requires additional effort from City staff to determine the accuracy
of rebate calculations.
If all or part of the Recycling Agreement is renegotiated, the City should
implement language defining specific reports generated by Pratt and provided
to the City including the format, data included, and frequency (e.g., monthly,
quarterly) related to rejected loads, rebates, education and outreach payments,
facility performance (including staffing), planned or unplanned downtime, and
planned capital improvements.
Comprehensive Solid Waste Management Strategy Recycling Processing
Processing
Agreement
Component Strengths Weaknesses Opportunities
1. Standard Operating Procedure refers to a series of technical procedure to satisfy provisions of the agreement
2. In 2018, the Chinese government implemented policies to increase minimum contamination requirements from imported material under Operation National Sword. As a result, shifting international end-markets for processed recyclables and increased quality standards led to lower
pricing of materials in the secondary commodity markets.
3. A contractual percentage threshold with a weight basis should be determined using a methodology to confirm if the weight of Unacceptable Materials/Residue in a given load exceeds the threshold. There are limitations on the capability of visual inspections (as it is in the current
Recycling Agreement) to consistently and accurately determine percentage by weight. Visual inspections are better suited to indicate the percentage of Unacceptable Materials/Residue by volume.
4. As of 2019 the City of Dallas received $1.04 per ton, City of Fort Worth received $2.00 per ton, and City of San Antonio received $1.00 per ton in financial support from their MRF operators to provide education and outreach to residential generators.
Comprehensive Solid Waste Management Strategy Recycling Processing
City of Denton, Texas 9-20 Burns & McDonnell
9.3 Recycling Agreement Procurement Considerations
Local governments usually require a competitive procurement process to enter into a contract with a
private recycling company. Considering that a MRF processing contract can be for multiple years and
involve millions of dollars, completing a procurement process requires careful planning and multiple
steps.
Local programs have multiple possible options for procuring MRF processing services, including Request
for Information (RFI), Request for Qualifications (RFQ), Requests for Bids (RFB) and Requests for
Proposals (RFP). Each has its own advantages and disadvantages. For example, an RFQ can help
establish minimum qualifications and can be used as a step in the RFB and RFP process. An RFB is a
straightforward method of receiving price proposals when all essential parameters are known. An RFP
method is generally recommended as it allows local governments to consider a combination of factors in
the decision-making process. Also known as a “best value” approach, an RFP is a more versatile in
allowing a wider exploration of varying service parameters from different companies and is not just based
on price alone. Figure 9-2 shows the RFP process from the initial development of the strategy through
contract award and transition.
Figure 9-2: RFP Process Description
A key factor in determining how much time is needed for the procurement process depends on the
competitiveness of the local recycling processing market and processing capacity in that region. For
example, if there are multiple MRFs in a region with extra processing capacity, the procurement process
will require between three and nine months to fully implement a new service provider since a range of
possible suitable MRFs are already in place. On the other hand, if there is a need to build a new MRF
based on the outcome of the procurement process, much more time would be required to allow the
recycler to design, build, and start operating a new facility, or potentially build a transfer station to
transport the material to a MRF and will require 18 to 32 months to fully implement a new service
provider. Longer MRF contracts may also be appropriate when a community is trying to attract a new
facility.
Comprehensive Solid Waste Management Strategy Recycling Processing
City of Denton, Texas 9-21 Burns & McDonnell
Contract length is a critical issue related to procuring a recycling contractor and can have a significant
effect on how competitive proposers are able to make their submissions. Several factors determine the
optimal recycling processing contract length, but perhaps the most important factors are the type of
contractual arrangement and whether a private company is building a new facility. A Processing Service
Agreement, or PSA, is strictly based on the processing of a MRF Facility where a PPP allows for the
parties to share more ownership and/or risk related to the contract. New, state-of-the-art MRFs built to
serve large geographic areas can cost $20 million or more, depending on local development costs and the
level of processing automation. If a private company is building a new MRF for either a PPP or PSA, the
company will ideally seek to recover its capital costs over the life of the contract. Consequently, aligning
contract length to the useful life of capital assets can help local governments and the private recycling
processor achieve a lower cost. Table 9-3 shows the recommended schedule for recycling procurements.
Table 9-3: Recommended Schedules for Recycling Processing Procurements
Agreement
Type
New or
Existing MRF Initial Term Renewal
PSA Existing Five to seven years One or more renewals for a total of up
to three to five more years.
PSA New 10-15 years One or more renewals for a total of up
to 10 more years.
PPP Existing
Depends upon the level of investment from private company. If there is
a need for substantial investment, a longer term of 10-20 years may be
needed. Without high investment levels, 10 years may be sufficient.
PPP New 10-20 years One or more renewals for a total of up
to 10 more years.
There are a number of conditions and circumstances that may require the City to conduct a new MRF
services procurement process, including changing material values, concerns about contract fairness or
MRF performance, merger and acquisition activities affecting their vendor, or just a general need or
desire to test the competitiveness of the market. Local programs should consider this issue as they create
bid or proposal documents and subsequent contracts, making sure to spell out the conditions that would
allow or lead to a new procurement process. Transparency is critical so that private MRF companies
know exactly what to expect as they develop proposals and enter into contracts.
As local programs plan their procurement process, they also need to think about the content of their RFP
documents and the eventual contract. This is where paying close attention to the best practices described
in Section 9.2.1 come into play, allowing communities and recycling processing service providers to
establish comprehensive fairness in a mutually-beneficial and long-term contractual relationship.
Comprehensive Solid Waste Management Strategy Recycling Processing
City of Denton, Texas 9-22 Burns & McDonnell
Case Study: The City of Dallas, recognizing the recycling industry’s broader financial challenges,
pursued an innovative public-private partnership approach to increase financial returns and recycling
quantities for residents and businesses in Dallas and surrounding communities. In 2013, the City released
an RFP intended to provide companies with the option to propose an existing facility or to build a new
MRF located at the City’s landfill. The City planned for a three-year procurement schedule (36 months)
in case the City decided to contract with a company for a new MRF. Ultimately, the City partnered with a
private company in November 2015 to design, build, and operate a new MRF to process recyclable
materials from the city and other surrounding communities. The facility began accepting recyclables on
January 1, 2017. While the private company funded the building and equipment, ownership of the
building will transfer to the City at the end of the 15-year agreement.
9.4 Key Findings and Recommendations
This section describes strategic tactics for the City to consider based on the information and evaluation
presented previously in this section related to challenging materials in the recycling stream, types and best
management practices of recycling processing agreements, evaluation of the Recycling Agreement, and
procurement considerations. The following sub-sections present information that describes each strategic
tactic including why it is included, the implementation timeline, responsible party, and logistical
information that support the evaluation presented as part of Section 11.5.
The City has programs that divert many challenging materials in the MRF recycling
stream, but there are opportunities to expand recovery. The City’s HCC, curbside yard waste,
and bulky collection programs provide for the proper collection of materials that would become
contamination at the Pratt MRF. The City should leverage its education and outreach program to
further increase the awareness of how to divert these materials, including the use of existing
resources (e.g., NCTCOG “Know What to Throw” and NRDC food waste source reduction).
New programs or services that the City should consider in the near- or long-term to increase
diversion of challenging materials include MRF facility upgrades for improved processing
capabilities, drop-off recycling for EPS, partnerships with other entities for safe sharps disposal
and reusable furniture/household items, and hosting paper shredding events to capture this
material for recycling.
The current Recycling Agreement does not require the City to pay a processing fee.
Recycling processing agreements with other municipalities in the region include a processing fee.
It is advantageous to the City under the current agreement to maximize revenues generates as part
of the Recycling Agreement, but since this is atypical of contracts in the region it provides Pratt a
Comprehensive Solid Waste Management Strategy Recycling Processing
City of Denton, Texas 9-23 Burns & McDonnell
basis to request that a processing fee be introduced into the Recycling Agreement in the future. If
the City enters negotiations with Pratt, they should seek to maintain the current pricing structure.
Prepare to renegotiate rebate provision of Recycling Agreement. Pratt has the option to cause
the parties renegotiate the rebate provision per Section 1.09(e) of the Recycling Agreement. In the
case Pratt causes the parties to renegotiate before the five-year period beginning October 2, 2023,
the City should leverage the recycling best management practices including updating the rebate
structure to be based on material composition, updating material specifications and percentages to
be more reflective of the current secondary commodities market, adjust the basis for values be the
higher of selected indices or actual sales price to incentivize Pratt to seek the highest pricing for
material and take advantage of the recent increase in the commodity prices to minimize long term
risk to the City (e.g., establishing a price floor for some or all commodities).
Prepare to renegotiate other provisions of the Recycling Agreement. In the case Pratt causes
the parties to renegotiate in prior to the five-year period beginning October 2, 2023 and is open
to renegotiating other provisions of the Recycling Agreement, the City should leverage the
recycling best management practices to adjust key terms including (a) develop and implement
provisions that establish an audit procedure and frequency to evaluate the inbound and outbound
material and allows the right City to participate in the process; (b) revisit the basis for the
contractual contamination percentage threshold to incorporate historical contamination figures
from the past five years; (c) revisit the basis for the education and outreach funding; (d)
implement contractual protocols or Standard Operating Procedures related to the inspection of
inbound loads; (e) revisit Article IV Force Majeure to update the terms in light of recent
challenges with pandemic, labor shortage, and other market forces that may impact the patterns of
generation or collection of solid waste and recycling; and, (f) define specific required reports
including the format, data, and frequency (e.g., monthly, quarterly) related to rejected loads,
rebates, education and outreach payments, facility performance (including staffing), planned or
unplanned downtime, and planned capital improvements.
Explore options to extend Recycling Agreement with Pratt and feasible alternatives. The
City should work with Pratt to identify if they are interested to continue the existing relationship
upon the expiration of the initial term of the Recycling Agreement. If so, further identify if Pratt
is interested or able to expand operations to provide the City the opportunity to attract tonnage
from other areas among, Denton County and other areas in the northern part of the NCTCOG
region (e.g., City of Frisco, City of McKinney). Developing a larger facility may allow the City to
prepare for anticipated growth in volume of recycling and position the parties to collaboratively
Comprehensive Solid Waste Management Strategy Recycling Processing
City of Denton, Texas 9-24 Burns & McDonnell
realize technical and economic benefits associated with increased economies of scale. There is at
least one other recycling processor looking to build MRF processing capacity in the Denton-
McKinney-Frisco corridor, which would provide needed capacity in the region. While the City
should look to work with Pratt to maintain the processing relationship, it is also important to
continue to explore and compare developing opportunities prior to the expiration of the current
contract in October 2027. While the Recycling Agreement indicates that the negotiations to
determine if the parties will exercise any available extensions will begin approximately one year
before the initial 20-year term expires, the City may need to prepare to release a solicitation up to
36 months prior to the expiration of the initial term as described in Section 9.3.
Evaluate expanded facility requirements. If the City pursues an increased facility in footprint
or operating capacity, confirm that the current building and footprint are able to be expanded and
if not, identify strategic locations (e.g., close proximity to the City’s current recycling collection
routes) that would provide sufficient acreage, utility connections, and to develop a regional
facility. The size requirements would be based on the anticipated tonnage that could be attracted
to the facility from the City and other areas of the norther part of the NCTCOG region.
Leverage Wholesale Disposal Agreements (put or pay contracts) to attract increased
volumes of recycling material to a regional MRF. The City should evaluate the feasibility of
incentivizing users of the landfill to increase recycling tonnage delivered by requiring they have
diversion programs in place to dispose material or provide discounted disposal rates for out of
county haulers that also deliver recyclables to the MRF. Section 6.05 of the Recycling Agreement
requires that Pratt is provided the opportunity to review and comment on any ordinances that may
result in increased tonnage flowing to the facility.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-1 Burns & McDonnell
10.0 MATERIAL END MARKETS & PARTERNSHIP OPPORTUNITIES
Previous financial struggles in recycling markets have placed significant pressure on recycling programs.
Additionally, the State of Texas has recently published a plan to support recycling market development
that identifies barriers and opportunities to increasing recycling statewide.68 This section provides an
overview of current markets for recovered and recyclable materials, including information on pricing,
material supply and end users; and describes the potential roles and partnerships the City can leverage to
support recycling markets and address community needs.
The Strategy to Support New Markets and Leverage Partnerships was developed based on the findings
presented in this section as well as the outcomes of workshop discussions with City staff. Section 11.6
presents the strategy in more detail. Section 12.0 provides the implementation plan.
10.1 Current Markets for Typical Recyclables
As described in Section 9.2.1, trends and best practices in recycling processing agreements point to
revenue sharing based on a percentage of the recovered material market pricing. As a result, markets can
drive increased capture and recovery rates for recyclable commodities, such as when prices are high in an
effort to maximize revenue from a material. Contamination is also a concern, especially when markets are
more challenged, as high contamination increases processing and disposal costs and can reduce
marketability and price of recovered commodities.
The average value of single stream materials varies based on the composition of the materials (i.e.,
quantity of paper, plastics, metal, and glass) and the quality of the materials. The average blended market
value of processed recyclable materials collected single stream (paper, plastics, metal, and glass) from
municipal collection programs in Texas over the five-year period from 2016-2021 was $98 per ton.
Figure 10-1 illustrates the changes in the average value of single stream materials in Texas over this
period based on regional commodity data and single stream material composition.
Due to factors such as pandemic market forces and supply chain challenges, recent 2021 pricing has
doubled compared to the five-year average (Figure 10-1). While it is important to emphasize that
recyclables are commodities and their values are subject to change, there are some key trends impacting
commodity pricing. First, one of the key reasons for the decrease in material value in preceding years was
due to China restricting the import of recyclable materials. In response to this issue, the United States is in
68 TCEQ. August 2021. “Recycling Market Development Plan.” Available online:
https://www.tceq.texas.gov/assets/public/assistance/P2Recycle/Recyclable-
Materials/2021%20Recycling%20Market%20Development%20Plan.pdf
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-2 Burns & McDonnell
the process of enhancing its recycling end markets for materials like paper and plastic. Second, there is a
trend for manufacturing and packaging companies to increase their use of recycled content material in
their products, which increases the demand for recycled materials. While it is likely that there will be
fluctuations in future commodity pricing, these additional factors may provide enhanced stability in the
future.
Figure 10-1: Single Stream Material Revenue (per Ton)
Pricing varies notably by material, and materials as subject to differing market factors (e.g., supply-
demand relationship).
$35
$55
$75
$95
$115
$135
$155
$175
$195
$215
$ per tonSingle Stream
5-year Average
Five-year Average = $98
September 2021 Average = $196
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-3 Burns & McDonnell
Table 10-1 communicates the market prices for individual recyclable material types, including the current
and five-year average regional commodity prices (as determined from recyclingmarkets.net, a
subscription-based, recycling data provider).
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-4 Burns & McDonnell
Table 10-1: Current and Five-year Average Commodity Prices
Material
Composition of
Single-Family
Recycling (%)1
Commodity Price ($ per ton)
Five-year Average September 2021
Plastics
PET #1 5.64% $261 $545
HDPE #2 (natural) 1.71% $868 $2,250
HDPE #2 (pigmented) 1.73% $279 $1,250
Plastics #3-7 0.91% $21 $20
Paper
Sorted Residential 15.24% $47 $118
Cardboard 21.70% $93 $190
Aluminum 2.61% $1,197 $1,567
Steel 1.08% $125 $260
Glass 10.88% $0 $0
Residual 35.34% $0 $0
Weighted Average2 $98.64 $195.92
1 Based on sample-and-sort waste composition study of residential recycling bins, conducted in 2020.
2 Average pricing based on the single-family recycling composition based on the waste characterization studies described in
Section 3.4.
10.1.1 Paper Markets
Recovered paper can be recycled into a variety of products and packing, including recycled printing and
office papers, toilet paper, towels, napkins, newsprint, paperboard, cellulose insulation, roofing felt,
cushioning material for packaging and molded pulp products (e.g., egg cartons, nursery pots). Recovered
paper may be processed and separated into grade by a paper stock dealer (which typically handle mostly
or exclusively commercial sources) or a materials recovery facility (MRF, which typically handle mainly
residential as well as selected commercial and institutional sources). Some paper manufacturing
companies, such as Pratt Industries, are vertically integrated into recycling processing as a means to
secure feedstock of recovered paper feedstocks. This is the case for the Denton MRF where, in addition to
processing commingled recyclables, the facility receives source separated paper (e.g., cardboard,
commercial sorted office paper) to be baled and shipped to Pratt mills.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-5 Burns & McDonnell
There are multiple end users of recycled paper in Texas including recovered paper mills, a cellulose
insulation plant, and a molded pulp plant in the North Central Texas region and surrounding areas.
Recovered Paper Mills:
Smurfit Kappa (Forney)
WestRock (Dallas)
International Paper (Queen City)
Cellulose Insulation Plants:
U.S. Green Fiber LLC (Waco)
Molded Pulp Plants:
Western Pulp Products Company (Jacksonville)
In response to changes in the global recovered fiber marketplace, multiple mill expansions and new mills
have been announced in the U.S. and Mexico that will markedly expand domestic fiber demand over the
next two years. However, contamination affecting material quality is a significant concern, particularly
with respect to residential fiber. Consequently, MRFs are working to improve their ability to generate
cleaner fiber supply to meet domestic mill and fiber product manufacturer feedstock requirements. Many
MRFs are installing equipment such as optical sorters and robots to enable further sorting and cleaning;
however, doing so means the cost of processed recovered fiber is increasing.
10.1.2 Metals Markets
Most ferrous and non-ferrous metals are recycled into durable products, with a portion of steel and
aluminum also recycled into product packaging (i.e., steel cans, aluminum beverage containers, foil
wraps). A significant portion of metals recycling occurs within the scrap industry, comprised of scrap
yards, auto shredders, mills, and foundries. There are over 600 scrap mills in the state, and the North
Central Texas region has sufficient capacity to recycle additional ferrous and non-ferrous scrap.
Due to the value of recycled metals, as well as the environmental benefits of recycling these materials,
metals markets can be larger geographically with longer transport distances while still maintaining
financial and environmental benefits compared to landfilling. A significant amount of steel is shipped to
consumers in other states or countries. For example, there are four steel mills in Mexico near the Texas
border that likely source from Texas, as well as Gulf Coast ports for shipping processed steel to recyclers
in other countries. Texas-generated non-ferrous recyclable scrap metal end markets vary by material.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-6 Burns & McDonnell
Baled aluminum cans are sent to Alabama, Georgia, or Tennessee. The national recycling infrastructure
can recycle more cans from Texas and other states than are currently collected.
10.1.3 Plastics Markets
Plastic containers and packaging can be made from various resins, including polyethylene terephthalate
(PET), high density polyethylene (HDPE), polyvinyl chloride (PVC), low density polyethylene (LDPE),
linear low-density polyethylene (LLDPE), polypropylene (PP), and polystyrene (PS). Plastics can be
recycled into a variety of products and packaging, depending on the resin type.
There are multiple plastics reclaimers and end users in Texas, including:69
Two PET reclaimers, one suppling PET to bottle manufacturers and one focused on chemical
recycling of hard-to-recycle items
Two HDPE bottle reclaimers
Two end users for recycling HDPE crates, bins, and pallets
Six companies recycling clean post-consumer commercial film plastic to produce garbage bags,
single-use retail plastic bags, and other commercial-use bags
One recycler for laser toner cartridges, which receives material from across the U.S.
PET reclamation capacity exceeds available supply, and PET is currently imported from other states.
Increased PET recovery in Texas could be managed by in-state reclaimers. In-state reclaimers also need
more supply of natural HDPE and clean post-commercial film to meet demand. Other plastic types (i.e.,
PET thermoforms, pigmented HDPE, contaminated film, and mixed plastics) face challenging recycling
markets in Texas due to a number of factors including lack of demand for specific resins, contamination,
and lack of sorting for plastics #3-7.
10.1.4 Glass Markets
Clean recovered glass can be recycled into a variety of end products including into new glass containers,
plate glass, glass beads; or beneficially reused in applications such as alternative landfill cover, aggregate,
filter material, and road base. The strength of glass recycling markets is often dependent on the
infrastructure at the local level, as glass is heavy and can be costly to transport.
As described in 10.1.4, the North Central Texas region and nearby counites are home to key infrastructure
and recycled glass end users to support healthy recycled glass markets, specifically secondary glass
69 Specific company names and locations are not shared for plastics recycling facilities due to confidentiality
associated with the Recycling Market Development Plan.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-7 Burns & McDonnell
processing/beneficiation facilities to further clean and sort glass and produce clean cullet and end users
such as bottle and fiberglass manufacturers. The City has access to infrastructure to support glass
recycling markets, which is primarily south of I-20 in the region. Clean material is key to maximizing the
economic viability and environmental benefits of processing and recycling glass, as environmental benefit
is high for end uses such as bottle-to-bottle glass recycling and low or negative for other beneficial uses
such as sandblasting or landfill cover. MRF glass often faces challenges due to high levels of
contamination.
10.2 Current Markets for Organics
In addition to the City’s composting facility, described in Section 6.0, there are also private organics
processing facilities in the region producing finished compost and mulch products for market. Most
private compost facilities indicate they could use more feedstock.
Current end markets for the City’s compost and mulch products include Denton-area residents and
professional landscapers, as well as a purchase agreement with the Texas Department of Transportation
(TxDOT). Demand is high, and sales of the City’s products have increased significantly in the last few
years.
Compost markets in the region can face challenges from contamination (primarily in the food waste
stream) as well as limited demand for some compost products. As the City implements the commercial
food waste pilot into its organics diversion program, it will be important to address contamination and
work with participants to identify tools and strategies (e.g., signage) to prevent contamination in the
future. A lack of end product demand can result from a lack of awareness of the benefits of using compost
as well as concerns over the quality and safety of compost products (typically for non-certified compost
products). The City is using current best practices required to maintain the US Composting Council’s Seal
of Testing Assurance (STA) Certification of Dyno Dirt, which includes sampling and testing standards for
the Class-A compost product. Education and outreach on the benefits of using compost (e.g., water
conservation, soil health) and the safety of the City’s compost products can help maintain demand for the
City’s compost product. As research continues regarding the best practices for managing new materials
and compounds that may be found in organic waste streams (e.g., compostable packaging, PFAS), the
City should stay informed of new research findings.
10.3 Current Markets for C&D Debris
Based on data provided by the City and TCEQ, C&D debris comprises four percent of the material
disposed at the City of Denton landfill (approximately 15,000 tons in 2020). As growth continues and
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-8 Burns & McDonnell
accelerates throughout the local area, development (and therefore C&D debris generation) will also
increase. C&D debris includes materials from new construction, renovation, and demolition projects such
as:
Concrete/masonry
Ferrous and non-ferrous metals
Wood
Cardboard
Other materials, including soil, asphalt, drywall, roofing, carpet, ceiling tiles, and insulation.
The best practice for handling C&D debris generated on the construction and/or demolition project sites is
to separate C&D debris into separate roll-off containers for individual recyclable materials. Most job
sites that separate and recycle material have two types of containers, one for commingled recyclable C&D
material and one for disposal. Commingled recyclable C&D must then be processed at a mixed C&D
processing facility (or C&D MRF). A limited portion of C&D recycling facilities across the state are
known to process mixed C&D. One large and well-equipped mixed C&D processing facility is located in
North Texas (Champion Waste & Recycling Services), providing valuable local C&D processing
capabilities to support end-market demand for uncontaminated concrete/aggregate, cardboard, plastic and
metals. Additional material-specific C&D recycling facilities/end users also exist in the region, supporting
strong markets for materials such as concrete and asphalt. There is also an asphalt shingle recycling
company with locations in the Dallas-Fort Worth Metroplex (Sustainable Pavement Technologies, LLC
(Dallas, Fort Worth)).
Local markets are available for key C&D materials including concrete/aggregate, metals, cardboard,
plastic, lumber, and gypsum. Concrete/aggregate, metals, cardboard, and plastic have established end-
markets that are strong and consistent. Demand of recycled asphalt shingles (RAS) has waned in recent
years, with TxDOT and private contractors reducing its use in new pavement application; and some C&D
recycling facilities have stopped accepting this material. Facilities with stockpiles of shingles are working
to sell them as they are able. Other materials may have more limited or intermittent local markets. There
are limited end-markets for gypsum other than processing the material on-site as part of composting
operations and wood is often ground on processors’ sites and used as part of disposal operations,
composted, or otherwise re-purposed.
As the City continues to develop and grow, C&D processing will continue to be critical infrastructure and
an important opportunity for materials diversion through recycling. Given the City’s proximity to C&D
recycling facilities, including mixed C&D processing capabilities at Champion Waste & Recycling
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-9 Burns & McDonnell
Services, there is significant opportunity to increase C&D recycling. One key challenge to C&D recycling
is that project sites that are not required to recycle by local ordinance or company policy will only
separate high-value materials like scrap metal.
10.4 Value of Additional Recycling Opportunities
An estimated $8.63 million worth of recyclable materials are disposed by City customers annually, based
on current commodity values (
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-10 Burns & McDonnell
Table 10-1) and the landfill disposal and composition information presented in Section 3.0 for single
family, multi-family and commercial customers.
Nearly half of the value of disposed materials is plastics (48 percent), followed by food and yard waste
(24 percent) and aluminum cans and paper (12 percent each).
Table 10-2: Estimated Value of Recyclables in the City’s Landfilled Waste Stream
Recyclable Material Category
Total
Tonnage
Disposed1
Value Disposed
(rounded)
Glass2 1,936 $ -
Metals – Ferrous2 1,177 $ 310,000
Metals – Non-Ferrous2 618 $ 1,010,000
Paper2 7,833 $ 1,040,000
Plastics2 5,390 $ 4,170,000
Food and Yard Waste3 46,393 $ 2,100,000
Total 63,347 $ 8,630,000
1. Total estimates based on refuse composition information collected during the waste
composition study conducted in 2020. Due to the limited number of samples sorted from
multifamily and commercial generators, total composition and material-specific tonnages
should be treated as an approximation.
2. Values of these material categories are based on September 2021 market data for the Houston
(Southcentral USA) region, as shown in
Table 10-1. 3. Value based on industry value of compost at mulch per cubic yard (CY),
assuming $30 per CY for compost and $15 per CY for mulch and 1.51 tons of compost
produced per ton of organics.
As described in Section 10.1, there is market demand for increased quantities of many of these recycled
materials, provided these materials can meet standards related to quality/contamination. In addition to
commodity value, increased recycling also provides benefits to the local and statewide economy. Based
on recent statewide IMPLAN modeling performed for the State of Texas70, recycling activity provides the
following economic benefits (including local benefits of material collection and processing):
Employment per 10,000 tons diverted:
o Single-stream recycling: 38 full-time person-years
o Organics composting: 17 full-time person-years
70 IMPLAN is a commonly employed tool for input-output analysis, used by governments, consultants, and
academics.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-11 Burns & McDonnell
o C&D recycling: 5 full-time person-years
Economic benefit71 per ton diverted:
o Single-stream recycling: $790 per ton72
o Organics composting: $350 per ton
o C&D recycling: $110 per ton72
10.5 Role of Local Government in Recycling Market Development
The TCEQ’s recently published Recycling Market Development Plan highlights the following tools that
can be used by local governments to support recycled material markets.
Education and Outreach. An important component of supporting recycling markets is education
and outreach to residents and businesses so that the community is aware of material recycling
opportunities. As described in Section 5.0, the City has an extensive residential education and
outreach program, and includes outreach to the commercial sector in audience targeting.
Partnerships. Local governments may partner with a variety of entities to provide recycling
services in a cost effective and sustainable way, including internal collaboration between
departments, with local entities such as non-profits and universities, and with other local
governments. Partnerships can help to collect sufficient material to meet market or community
needs (e.g., donation) and achieve economies of scale and overcome potential cost barriers to
recycling. Partnership opportunities for the City and are discussed in Section 10.6. Additionally,
when contracting for material processing through a public-private partnership, it’s important to
structure contracts to limit contamination and strengthen material marketability (as discussed in
Section 9.2).
Preferential Procurement. Public purchasing policies can be used by local government to
support demand for recycled material feedstocks, through incentivized or required use of
recycled-content paper, compost, or C&D aggregates. Environmentally preferred purchasing
(EPP) is discussed in more detail in Section 10.6.1.3.
Pay-as-you-Throw (PAYT) User Fee System. PAYT is an approach to treat recycling and waste
management service provision like a utility (charging in accordance with the amount of waste
disposed). These variable fee programs can result in higher recycling rates due to the financial
71 Economic benefit is defined as the sum of labor income, value added, and tax revenue.
72 Excludes additional economic benefits of manufacturing using recycling material feedstock.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-12 Burns & McDonnell
incentive of minimizing waste disposed and increasing recycling. The City’s variable rate
structure charges residential customers based on the refuse cart size (either 65 or 95 gallons) as
well as an additional fee for an extra 95-gallon cart. PAYT systems are effective in many cities,
though recycling contamination can be a significant challenge. The City should focus on
addressing contamination before considering significant changes to its pricing approach. Another
approach to treating recycling and waste service as a utility can be the incorporation of impact
fees, though these would need to be reviewed by the City attorney before being enacted.
Service Provision Mandates. Mandated service provisions are ordinances enacted by local
government to require specific sectors (e.g., multifamily, C&D) to contract for recycling services.
These policies can be effective in supporting recycling markets for materials in areas with low
participation/access to recycling programs. Policies can include mandatory recycling of certain
materials (e.g., Austin’s Commercial Organics Diversion Requirements) and universal recycling
ordinances (e.g., Dallas’s Multifamily Recycling Ordinance). The use of service provision
mandates is discussed in more detail in Section 8.3 related to growth in the single family,
multifamily, and C&D sectors.
Business Incentives. Cities may offer recycling-related businesses certain incentives to
encourage the enhanced use of recovered materials from local, regional, or statewide sources.
Example incentives include a reduced rate for waste disposal, reduced taxes/tax exemptions, and
reduced utility rates. One approach local governments might consider is establishing recycling
market development zones (RMDZs), which is particularly appropriate where local governments
wish to concentrate such industry in one or more geographic areas.
10.6 Partnerships Options for Increased Diversion
This section summarizes current and potential partnership opportunities identified throughout the
development of the CSWMS. As program and community needs change, it will be important to
periodically reexamine partnership opportunities. These include partnerships with other City departments
and programs (described in Section 10.6.1), local entities (described in Section 10.6.2) and neighboring
communities (described in Section 10.6.3).
10.6.1 Partnerships with City Departments
Within the City’s current waste and recycling services, there are opportunities to partner with other
departments to expand or improve services. There are also several tools and mechanisms that local
government can implement to support recycling markets and increase diversion. Implementation of some
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-13 Burns & McDonnell
of these opportunities will require coordination among multiple departments, including SWR. This
section describes each of these opportunities, the current status, and future opportunities.
10.6.1.1 Public Space Recycling
The City of Denton Parks & Recreation department is responsible for refuse and recycling in the City’s
parks, trails, and public spaces. Currently, the program is passive with limited to no education and
outreach from Parks & Recreation related to recycling and limited availability of recycling bins in public
spaces. There is an opportunity to phase in recycling through paired bins (i.e., recycling bins co-located
with existing refuse bins) and provide education and outreach through the City’s recreation leagues on
topics such as bringing reusable water bottles or recycling single-use water bottles during league
activities. Longer term, the City could explore establishing a small impact fee for leagues to support the
investment and costs associated with the provision of recycling services.
10.6.1.2 Innovative Food Waste Diversion
As described in Section 6.6, the City recently received a grant from the NCTCOG to fund a food waste
diversion pilot program in the historic downtown area. Diverted organics are currently composted at the
City’s Pecan Creek WWTP, which is located adjacent to the Denton Landfill. There are plans to macerate
recovered food waste to be co-digested at the WWTP for the production of biogas (and potential upgrade
for pipeline injection). There is an opportunity for the City to divert increased quantities and types of food
waste for co-digestion, based on the successes and lessons learned from this pilot program. SWR should
continue to collaborate with the City’s wastewater treatment staff throughout the pilot program to
evaluate success and coordinate on needs and opportunities to expand the program.
10.6.1.3 Environmentally Preferred Purchasing (EPP)
Environmental preferred purchasing (EPP) strategies, such as recycled-content requirements are one
method to incorporate environmental considerations into public purchasing. As part of the recent
Governmental Entity Recycling Program (30 TAC §328 Subchapter K), counties, municipalities, school
districts, and certain other public entities not previously subject to the state’s procurement policies
(described in more detail below) must give purchasing preference to “products made of recycled materials
if the products meet applicable specifications as to quantity and quality and the average price of the
product is not more than 10 percent greater than the price of comparable nonrecycled products.”73
73 30 TAC §328.203. TCEQ’s resources for implementation are available online:
https://www.tceq.texas.gov/p2/recycle/governmental-entity-recycling-program
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-14 Burns & McDonnell
The City’s Procurement Policy allows the City to establish environmentally preferred purchasing (EPP)
policies, including and in addition to those in 30 TAC §328.203, to incorporate environmental
considerations into public purchasing to the extent that it is available, practical, and reasonably permitted
by law.74 The City’s Procurement and Compliance Department has hired staff to work on EPP. There is
an opportunity for the City to further support recycling markets through the purchase and use of recycled-
content products, which can be encouraged or required through EPP policy developed in partnership with
the Procurement and Compliance Department and SWR. EPP programs may apply to typical recyclables
(e.g., recycled-content paper or plastic products) to support existing markets or other materials (e.g.,
construction debris) to increase local markets for these materials. Buy-recycled programs are typically
implemented by local governments as a policy or program rather than as an ordinance.
State of Texas Procurement Policies. State agencies are required to give preference to the following
specific type of products:
1. Certain recycled, re-manufactured, or environmentally sensitive products. These products are
known as “first choice purchasing options.” First Choice products have a 10 percent price
preferential (meaning they should be preferred even if they cost up to 10 percent more than
products that do not contain recycled content) and must suit the needs of the purchaser. These
product types include:
o Re-refined oils and lubricants (to be 25 percent recycled content, if quality similar);
o Certain paper products, including paper towels, toilet paper, toilet seat covers, printing,
computer and copier paper, and business envelopes (a state agency is to procure the
highest recycled content that meets their needs and is offered by the Comptroller);
o Certain plastic products including trash bags, binders, and recycling containers; and
o Steel products.
2. Electronics manufactured by “a manufacturer that has a program to recycle the computer
equipment of other manufacturers, including collection events and manufacturer initiatives to
accept computer equipment labeled with another manufacturer’s brand” (Texas Health and Safety
Code §361.965(d)).
Additionally, the Comptroller may give priority to rubberized asphalt paving (RAP) material made from
scrap tires by a facility in this state if the cost, as determined by life-cycle cost-benefit analysis, does not
74 Resolutions R2007-032, R2008-42, and R2014-008 in Denton Procurement Policy, June 2020. Section 17.1.
Available online: https://www.cityofdenton.com/DocumentCenter/View/615/Procurement-Policy-PDF
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-15 Burns & McDonnell
exceed the bid cost of alternative paving materials by more than 15 percent. (Texas Government Code
§2155.443).
10.6.2 Partnerships with Other Community Entities
The City has had success with current partnerships, including with the Denton Independent School
District (DISD). The DISD program is popular to help raise awareness, interest, and engagement with K-
12 students on topics related to materials management, recycling and sustainability. While the
coronavirus pandemic interrupted in-person elements of the DISD partnership, it has provided the
opportunity for City staff to refresh and retool the program content. While previous years had focused on
the quantity of materials that were recycled, the program will now focus on recycling correctly to address
issues like contamination.
In addition to continuing the DISD program, there are additional community partnerships the City could
establish and/or leverage to address community needs and support innovation and reuse. These are
described in the following sections.
10.6.2.1 Partnerships to Address Community Needs
There are opportunities for the City to partner with others in the community to increase the diversion of
materials.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-16 Burns & McDonnell
Table 10-3 communicates example partnership-based collection and end use opportunities currently
identified to divert useable materials to meet community needs. Following the table, university move out
and food donation examples are described in more detail.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-17 Burns & McDonnell
Table 10-3: Example Community Collection and End Use Opportunities
Material Category Collection Opportunities
Reuse and End Use
Opportunities
Furniture/Bulk University Move Out Shelters, Homeless and at-risk
programs
Edible Food Restaurants Food banks, Shelters
Bikes University and City
Abandoned/Surplus
Shelters, Homeless and at-risk
programs
Textiles
University Move Out Shelters, Homeless and at-risk
programs, University design
programs
University Move Out. There are multiple colleges within Denton. Student move out events can
create significant amount of waste, including large quantities of furniture and other home goods
still in usable condition. While these items could be donated, time constraints and convenience
often result in them being landfilled. The City services refuse dumpsters from the universities,
and this material is transported to the Denton Landfill. There is an opportunity for the City to
partner or assist local universities to recover material from move out events to be donated to local
non-profits that provide furniture and other items to those experiencing or at-risk of homelessness
or experience other crisis, including the City’s Loop 288 Building partnership with Our Daily
Bread.75 The City can coordinate with university student life and sustainability offices and non-
profits to operate drop-off based move out program. The City of Austin has experienced success
with its MoveOutATX program, which diverts significant quantities of material to local non-
profits during move-out. The program is a partnership between the City’s Office of Resource
Recovery, the University of Texas at Austin, and multiple reuse organizations throughout the city.
As part of its program, MoveOutATX also provides donation and cardboard recycling drop-off
during move-in.
Food Donation. Food insecurity is a challenge in communities across the state and country.
While many businesses with surplus food may already donate to shelters, there is an opportunity
to the City to encourage donation of edible surplus food to local food banks though existing
programs such as the Green Business Program. This practice can increase sustainability by
avoiding food waste generation.
75 https://www.cityofdenton.com/429/Current-Initiatives
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-18 Burns & McDonnell
Community partnerships can be supported, and in some cases co-located, through an established facility
for community drop-off. This is the approach used for the Center for Hard to Recycle Materials (CHaRM)
and ReSource Reuse facility in Boulder, Colorado. The city operates these facilities in partnership with
local non-profits to support community needs and collect material (e.g., textiles) that can be upcycled by
local companies.
Case study: City of Boulder, Colorado. The City of Boulder operates the Center for Hard to Recycle
Materials (CHaRM) in partnership with local non-profit Eco-Cycle. The CHaRM facility is located along
“Recycling Row,” a one-mile section of 63rd St. that also includes the City’s recycling center, a stand-
alone HHW facility, a yard-waste drop-off center, and the ReSource Reuse facility (a non-profit
conservation hub that includes zero waste programs such as deconstruction assessments and a tool lending
library). Through the CHaRM facility, the City collects a variety of materials for recycling or reuse,
including rigid HDPE, plastic bags/film, bubble wrap, bike tires and tubes, print cartridges, electronics,
textiles, yoga mats, and cooking oil. Some of these programs are facilitated through community
partnerships and coordination, such as:
Electronics and plastic appliances are recycled on-site through a partnership that employs people
with autism and other disability who are trained as recycling technicians. Since electronics are
disassembled on-site, CHaRM provides guaranteed chain-of-custody and data security.
Bike tires and tubes are recycled into packs and bags by a local company (Green Guru Gear)
Yoga mats are used as a recycled textile to make bags and other gear by local companies
10.6.2.2 Partnerships to Support Innovation and Creative Reuse
Educational institutions can serve as engines of innovation for sustainability. Due to the complex
inter-disciplinary nature of sustainability and zero waste research (i.e., benefiting from research in
chemistry, psychology, business, economics, and other disciplines), there are various vantage
points from which recycling can be explored, including:
Researching novel end uses for incorporating recycled materials into new products
Advancing processing technologies
Conducting product life-cycle assessments (LCA)
Studying behavioral science related to diversion and contamination
Research topics may be spurred by discussions among faculty, City staff, the business and non-profit
communities, and other government institutions; and could be targeted to materials of specific challenge
or concern to the city (e.g., glass recycling, contamination).
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-19 Burns & McDonnell
Universities can also demonstrate creative reuse through visual art, textiles, design, and other creative
fields. For example, UNT’s College of Visual Arts and Design (CVAD) may be a potential partner for
demonstration projects or other creative reuse.
10.6.3 Partnerships with Neighboring Communities
There are multiple related opportunities for the City to partner with neighboring communities to increase
diversion and support recycling markets. As described in Section 8.3, the Denton Landfill is an important
disposal resource not just for the City but also for north and west areas of the region where disposal
alternatives and diversion programs are more limited (e.g., Wise County). Because of this, the City can
leverage its put-or-pay discount structures to incentivize neighboring communities to divert material from
landfill. This approach will be most feasible if the City executes these discount contracts directly with the
communities (rather than with the private haulers, as is currently the case). The communities can
subsequently tailor their hauler contracts to include additional diversion programs (e.g., curbside
recycling, if not already available) as desired to meet the discount contract terms and/or operate their own
diversion collection programs. Timing will be a consideration when implementing this approach with
individual communities, as each transition would need to occur when the contract between the respective
community and hauler(s) expire or are up for renegotiation. Additionally, it may be challenging for some
smaller communities to transition to this approach in the near-term, but it may become a viable
opportunity in the long term based on future growth in these communities. The discount approach could
attract increased volumes of recycling material to the Pratt MRF (or future expanded regional MRF) or to
other City programs (such as a regional HCC approach, as described in this section).
Regional HCC approach. As noted in Section 10.1.9, there is demand and opportunity to expand the
City’s HCC program through partnership with surrounding communities to provide safe home chemical
management to residents without a current program. This approach has been successful in other parts of
the North Central Texas region, including Dallas County and the cities of Fort Worth and Frisco.
Currently, the City’s HCC drive through program must turn away residents from surrounding
communities (estimated at 5-10 people per week). These customers and others could be accommodated
through a regionalized program, with drive through service potentially doubling if opened to surrounding
communities.
Major elements to expanding the HCC to be a regional program include:
Understanding regional market and interest from neighboring communities. Planning for an
expanded program first requires identifying potential participants. Burns & McDonnell
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-20 Burns & McDonnell
completed regional market evaluation for the City as part of the 2017 Regional HCC Study and
multiple entities expressed a high level of interest in partnering with the City to participate in the
HCC program.
Set program pricing. Pricing is the most important factor in determining whether a city will
participate in a regional program. The City must set an appropriate non-resident price to account
for additional material management costs and increased staffing needs. Cities with regional HCC
program are consistently able to fully recover costs by using billing structures that charge
participating cities for actual program participation and costs, such as through a voucher program
(as is the case in Fort Worth).
Execute interlocal agreements. Interlocal agreements for regional HCC services outline key
items such as the participation options, costs and responsibilities (e.g., staffing, capital costs)
pricing structure (e.g., use of vouchers), and reporting/auditing procedures. The 2017 Regional
HCC Study includes a draft interlocal agreement created for the potential HCC expansion at that
time, and contract language could be revised as necessary to facilitate HCC regionalization.
Raise awareness within communities. Education and outreach are necessary to raise awareness
and participation in the regional HCC service. Brochures and other material can be provided to
participating communities, which can be created from existing program resources (including the
HCC brochure produced for the City by Burns & McDonnell as part of the 2017 study, shown in
Figure 10-2). Outreach efforts can be most successful if performed by the individual
participating communities, as they have established methods to reach residents regarding solid
waste services. Based on the experience in Dallas and Fort Worth, it can take 5-7 years for a
regional program to become firmly established.
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-21 Burns & McDonnell
Figure 10-2: Regional HCC Brochure1
1Developed previously by Burns & McDonnell for the City’s 2017 Regional HCC Study
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-22 Burns & McDonnell
Depending on the success of an expanded HCC drive through program, the city and participating
communities could consider other options such as mobile events in partner cities. To accommodate new
programs and the associated capital costs, the interlocal agreements could be updated to specify how
additional capital and operating costs incurred by the City would be factored into program pricing.
10.7 Key Findings and Recommendations
The following presents consolidated key findings and recommendations related to the opportunities for
the City to increase diversion and reuse to address community and market needs, as a basis for the
Strategy to Support New Markets and Leverage Partnerships evaluated in Sections 11.6 and 12.0.
Contamination is a barrier of concern for end markets for many recyclable materials.
Market demand exists to support increased recovery of many typical recyclables; however, high
contamination reduces bale quality and marketability of recovered commodities. The City’s
efforts to reduce contamination through enhanced education, outreach, and compliance and
optimized recycling processing will improve the quality and value of the City’s recyclables,
especially for materials such as glass, paper, plastics. Efforts to increase recycling will provide
more, clean material to Pratt for recycling.
While markets for compost products face challenges in Texas, the City’s program is well-
positioned to be competitive. While the Recycling Market Development Plan identified key
challenges of contamination, lack of education and outreach, and concern over product quality,
the City currently addresses these challenges through program design, a robust education and
outreach program, and STA certification for Dyno Dirt compost. The City should be mindful of
the contamination potential in the commercial food waste pilot and any future expansion, and
track research developments on compost quality and safety to continue to be proactive regarding
compost product quality, testing, and marketability.
There are multiple tools and mechanisms available to local governments to support
recycling market development efforts. These include education and outreach, leveraging
partnerships, preferential procurement, treating waste and recycling as a utility, service
requirements and ordinances, and business incentives. These tools and mechanism options have
been summarized and evaluated throughout the development of this CSWMS, so that the City’s
efforts can align with future implementation of TCEQ’s Recycling Market Development Plan.
There are coordination opportunities for SWR with other City departments to increase
diversion through sustainability initiatives, programs, and services. As the service provider,
Comprehensive Solid Waste Management Strategy Material End Markets & Parternship Opportunities
City of Denton, Texas 10-23 Burns & McDonnell
SWR may be department most associated with waste and recycling; however, other departments
can plan important roles in enacting initiatives and policies to advance sustainable materials
management. These include collaboration with:
o Parks & Recreation to address opportunities to increase public space recycling
o Pecan Creek WWTP to advance a long-term strategy related to organics diversion
o Procurement & Compliance to develop EPP programs to support recycling markets
There are community needs that could be met through coordination opportunities with
local entities to recover specific materials. By directly partnering or supporting and facilitating
programs established by local universities or non-profits, the City can help divert materials that
would otherwise be collected and landfilled through City-provided disposal service. Potential
examples include:
o Reuse and donation drop-off at college move out to support shelters and homelessness
services, including the Loop 288 Building/Our Daily Bread initiative.
o Food waste diversion efforts to support food banks and soup kitchens.
University research, innovation and demonstration initiatives to find new markets and raise
awareness of creative reuse and recycling. With multiple universities located nearby, the City
can benefit from partnerships to support research and innovation related to materials management
and demonstrate creative reuse through design and other visual arts programs. The City has also
benefited from having student interns participate with SWR.
Partner for regional HCC services to support key diversion activities in neighboring
communities. Currently, residents of neighboring communities attempt to use the HCC drive
through service and must be turned away. The City should explore the creation of regional HCC
program. Regionalization can provide economy of scale benefits for the City’s current program
and allow for home chemical materials and other household hazardous wastes to be safely and
properly managed in neighboring communities that may otherwise be sending these materials to
the Denton Landfill. Regional expansion can be executed through interlocal agreements and
billed using a voucher system (or similar per-participant reimbursement) to recover additional
costs associated with the expanded program.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-1 Burns & McDonnell
11.0 STRATEGY DEVELOPMENT AND ANALYSIS
This section presents an evaluation of the strategy options identified based on the current system analysis,
industry trends and best practices, and community engagement, for the City of Denton CSWMS. The
identified strategies for the City’s consideration and implementation are to:
Enhance Education, Outreach and Compliance
Implement Innovative Organics Management
Efficiently Use Landfill Capacity
Plan for Future Growth
Optimize Recycling Processing
Support New Markets and Leverage Partnerships
The evaluation of each of these strategies is presented below, and includes the following:
Strategy objectives. Describes the overall objective of the strategy, and related key performance
indicators or metrics of success.
Tactics for strategy implementation. Lists the recommended tactics or actions for the City to
achieve the strategy objectives.
Financial impact. Describes the financial impacts of implementing the option and if it would
increase operational/capital costs to the City or customers a low, medium or high basis. Planning-
level cost estimates are also provided for some potential new programs, as applicable.
Environmental impact. Indicates if the option would increase emissions or result in other
environmental consequences on a low, medium or high basis.
11.1 Enhance Education, Outreach and Compliance
The City currently provides a robust education and outreach program, complemented by cart tagging and
contamination tracking assisted by Rubicon. Efforts to improve program performance (i.e., contamination
rate, participation rate, diversion rate) can be enhanced through additional education, outreach, and
compliance strategies.
11.1.1 Tactics and Recommendations
Tactics to enhance education, outreach, and compliance are focused on efforts to address challenges (e.g.,
contamination) and increase diversion through education and outreach content and scaled up compliance
efforts. Specifically, to implement this strategy, the City should:
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-2 Burns & McDonnell
Track and report material capture rates, recycling contamination, and waste reduction.
Continue data-driven content and audience targeting.
Incorporate incentives into compliance program.
Track and report material capture rates, recycling contamination, and waste reduction. The
metrics for the City’s current education, outreach and compliance program do not provide a clear and
measurable definition of success For the City, material capture rate, recycling contamination rate, and
waste reduction rate can serve as valuable metrics to understand how well education and outreach
program content impacts residents and others in the City to participate in recycling programs (through
material capture rate), recycle the right materials (through contamination rate), and engage in other
sustainable behavior for waste reduction (through waste reduction rate). With these metrics, it is essential
to have quality data to benchmark and track the progress of education, outreach and compliance efforts
and goals (described in Section 1.0). The City currently tracks data related to its waste and recycling
programs from a variety sources, including the quantities of material collected through its curbside
programs (primarily residential data), information on collection activity from on-board technology, and
estimates of recycling contamination from the Pratt MRF. The City has also participated in NCTCOG
waste composition studies, which provide insight into the composition of its waste and recycling streams
and resulting capture rates of recyclable materials. Key implementation steps identified for tracking and
reporting capture rate, recycling contamination, and waste reduction are:
Develop a Data Collection and Analysis Plan and negotiate components of the recycling
processing agreement (if necessary) to obtain reliable recycling and contamination data.
Perform routine tracking and reporting of material capture rates, recycling contamination, and
waste reduction consistent with Data Collection and Analysis Plan.
Continue data-driven content and audience targeting. The City has demonstrated success with
reaching broad target audiences and developing data-driven content (e.g., based on common Waste
Wizard searches). Key implementation steps identified to build on current success with data-driven
content and audience targeting are:
Continue to track and leverage technology developments (e.g., Waste Wizard, Rubicon hardware
and software packages) for future content development and audience targeting.
Segment target audiences such as specific types of businesses, City departments, or customers
with low participation, to target messaging to specific milestones or challenges (e.g.,
contamination, participation).
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-3 Burns & McDonnell
Consider developing dedicated campaigns implemented with the approach of collecting data,
collaborating closely with stakeholders, and setting goals with clearly defined success metrics.
Incorporate incentives into compliance program. The City’s current cart audit and “oops” tag cart-
tagging programs have been successful in decreasing contamination in highly contaminated routes.
Incorporating compliance incentives into the existing program can help further deter contamination and
improve recycling behavior. The range of options including case studies are presented in Section 5.2. Key
implementation steps identified to incorporate incentives into the compliance program are:
Scale up cart audit and "oops” tag program to additional routes/areas of the City.
Determine desired additional compliance actions to deter contamination (e.g., fee, "three-strikes"
bin removal), and education and outreach opportunities for fee waiver (e.g., training and quiz) as
appropriate.
Develop program, ordinance and phasing plan for additional compliance actions to deter
contamination.
11.1.2 Financial Impacts
The financial impacts of the tactics to implement enhancements to the education and outreach program
are generally low, and these recommendations build from current activities. There are additional direct
costs are associated with scaling the City’s use on-board camera technology for contamination tracking to
support the “oops” tag program, which is currently in a pilot stage. Current costs are approximately
$4,000 per trucks for on-board equipment and annual maintenance costs around $1,500. As the program
scales as part of data collection and data-driven audience targeting, these direct costs are expected to
scale. To manage costs associated with expanded data collection, the City can strategically deploy newly
outfitted trucks methodically across routes to observe contamination rates. The City can also take an
approach to determine the level of invested as trucks are replaced, rather than retrofitting the full existing
fleet in a single budget year.
11.1.3 Environmental Impacts
This strategy focuses on improving system performance, specifically reducing recycling contamination
and increasing diversion rates. Based on the composition of the City’s residential single-stream recycling
program, for every additional ton of program material captured through increased residential recycling
participation, greenhouse gas (GHG) emissions would be reduced by approximately 2.5 MTCO2e. If the
City were to increase recycling capture rates to 80 percent for each material category by 2040, an
additional 9,100 tons of recycling would be diverted from landfill in 2040, reducing the City’s carbon
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-4 Burns & McDonnell
footprint by as much as 23,000 MTCO2e per year. 76 Reducing contamination is also important from a
GHG perspective, as contamination reduces MRF efficiency (resulting in emissions such as additional
energy use at the MRF), can cause lower-grade bales (resulting in reduced carbon off-sets if bales are not
suitable for the highest and best uses), and results in rejected loads that are landfilled rather than recycled
(resulting in no environmental benefit as recyclable materials are disposed).
Other benefits associated with increasing diversion and reducing contamination include:
Energy Use and Conservation. One of the largest environmental benefits of recycling is the
resulting energy savings when manufacturers use recycled (rather than virgin) feedstocks in the
manufacturing of products. These savings result from avoiding energy-intensive processes such
as mining, refining, and processing raw materials. Energy savings from recycling vary by
material and end use of the recycled feedstock but are generally greatest for paper grades
followed by plastics, aluminum, glass and ferrous metals. Reducing contamination avoids wasted
energy used to sort and process materials not suitable for recycling.
Land Use. On a local scale, recycling presents significant landfill diversion potential,
contributing to airspace preservation and extending the life of the Denton Landfill.
Transportation. Reducing contamination can result in more efficient recycling collection routes.
Although net transportation will increase as more single-stream material is diverted and tonnage
increases on recycling routes, the energy savings (including fossil energy) associated with using
recycled material feedstock will greatly offset these local increases.
Watershed Protection and Open/Natural Space Utilization. Globally, recycling materials for
remanufacturing reduces or prevents the need for raw material extraction (e.g., mining, forestry),
which provides environmental benefits associated with reduced run-off and preservation of
open/natural space in these areas.
11.2 Implement Innovative Organics Management
The Strategy to Implement Innovative Organics Management is focused on expanding the City’s waste
reduction and diversion efforts associated with organic wastes, especially food waste. Food waste is a
significant portion of both the generated and landfilled materials. As described in Section 2.0, there is
growing national focus on food waste reduction.
76 Estimate is based on diverting an additional 9,120 tons of residential single-stream recycling (compared to
maintaining current rates as the City’s population grows), with net GHG emissions reduction of 2.5 MTCO2e/ton
mixed single-stream recycling. Reductions vary based on material from 9.15 MTCO2e/ton for aluminum cans to
0.30 MTCO2e/ton for glass bottles. Impact factors based on U.S. EPA Waste Reduction Model (WARM) v15
documentation (https://www.epa.gov/warm).
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-5 Burns & McDonnell
11.2.1 Tactics and Recommendations
Tactics to implement innovative organics management are focused on two-pronged approach: to increase
the diversion of food waste recovery from commercial generators where clean food waste materials can
be collected and processed efficiently, and to increase awareness and technical assistance City-wide of
reduction and diversion strategies. Specifically, to implement this strategy, the City should:
Pilot commercial organics composting or co-digestion program at Pecan Creek WWTP.
Increase education and outreach and technical assistance for source reduction and diversion of
food waste.
Pilot commercial organics composting or co-digestion program at Pecan Creek WWTP. The
commercial sector presents the greatest food waste diversion potential for the City with over 30,000 tons
of commercial food waste generated in the City and subsequently disposed in landfill in 2020. The City
has existing anaerobic digestion infrastructure and biogas upgrading experience, providing the potential to
convert clean source-separated commercial organics to energy in partnership with the Pecan Creek
WWTP. Key implementation steps identified for source-separated commercial organics diversion are:
Implement source-separated organics collection program in the downtown areas for customers
served by the valet service, including purchase of new macerator technology for feedstock
processing.
Track performance of commercial food waste pilot program through KPIs, survey of participating
businesses and valet service staff, and coordination with WWTP.
Target additional large commercial food waste generators (e.g., DISD and UNT cafeterias) for
expansion of the food waste diversion program to become city-wide.
Increase education and outreach and technical assistance for source reduction and diversion of food
waste. The City’s education and outreach program includes information on the importance of source
reduction, and there is opportunity to expand content to further encourage or incentivize activities such as
waste reduction, backyard composting and food donation. Key implementation steps identified for
increasing education and outreach and technical assistance are:
Increase source reduction education and awareness content, through unique content and/or
available Save the Food campaign.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-6 Burns & McDonnell
Promote backyard composting to single family residents through education and outreach, and
explore options such as partnership with County Extension Service and a home composting
rebate program, or a compost bin discount or giveaway.
Promote source reduction and donation to commercial entities through education and outreach,
partnerships with food banks, and/or as part of the green business program. The United States
Department of Agriculture (USDA) provides resources regarding liability protection afforded by
the Bill Emerson Good Samaritan Food Donation Act and other frequently asked questions for
commercial entities seeking to donate excess food.77
11.2.2 Financial Impacts
The City recently submitted a successful NCTCOG regional solid waste management grant application to
pilot a commercial organics program in the valet service area, and was awarded $60,723 in grant funding.
Recent global supply chain challenges have resulted in an increase in estimated program costs
(communicated in Table 11-1). Estimated costs are $100,224 to purchase and install necessary equipment
(i.e., food waste macerator) supplies for participating entities (i.e., food waste carts, bins) and program
educational materials. Accounting for the $60,723 in grant funding to the City, this leaves approximately
$39,500 remaining to be funded.
Table 11-1: Planning-Level Cost Estimate for Commercial Organics Pilot
Item Quantity Unit Cost Total Cost1
Macerator 1 $65,000 $65,000
Construction 1 $15,000 $15,000
Food Waste Cart 112 $49 $5,440
Gravity Lock 112 $7 $784
Freight 1 $2,000 $2,000
Food Waste Kitchen Bin 100 $20 $2,000
Educational Materials 1 $10,000 $10,000
Total Pilot Costs $100,224
1Initial cost estimates submitted as part of the grant application were $67,724; however, estimated costs of the
macerator have doubled from approximately $32,500 to $65,000 due to global supply chain challenges.
77 https://www.usda.gov/sites/default/files/documents/usda-good-samaritan-faqs.pdf
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-7 Burns & McDonnell
Estimated costs for increased education and outreach for source reduction and diversion of food waste are
minimal as quality free resources such as the NRDC’s Save the Food campaign available to support these
efforts. Implementing new incentive programs, such a home composting rebate programs or compost bin
discount, would require additional funding to support the incentives and associated staff time. Direct costs
are estimated to be approximately $6,000 per year, based on a typical rebate cost of $75 per participating
household and annual participation of 80 households per year (based on participation rates of single-
family homes in other compost rebate programs of approximately 0.25 percent). Some home composting
programs, such as in the City of Austin, require participation in a City-hosted composting education event
(or webinar). The City could partner with entities such as Keep Denton Beautiful or the Denton County
Master Gardner Association to implement a similar training requirement, if desired.
11.2.3 Environmental Impacts
This strategy focuses on food waste reduction and diversion from landfill, both of which have GHG
benefits. Commercial organics represent the largest portion of potential food waste diversion. If the City
were to capture 20 percent of commercial organics by 2040, this would represent an estimated 21,000
tons of food waste diverted from landfill. The resulting reduction in landfill emissions and carbon benefits
of managing this material at Pecan Creek WWTP through either anaerobic digestion or composting would
reduce the City’s carbon footprint by as much as 11,300 MTCO2e per year in 2040.78
Other benefits associated with diversion of food waste organics include:
Energy Use and Conservation. Food waste diverted through anaerobic digestion at the Pecan
Creek WWTP provides biogas-derived energy. Capture of biogas from food waste is more
efficient than in a landfill gas system, as food waste materials degrade more rapidly than other
organics and a notable portion of methane generation occurs prior to the installation of landfill
gas collection system. On a broader scale, food waste source reduction tactics such as smart
purchasing and donation reduce the waste of imbedded energy resources in the food products.
Land Use and Open/Natural Space Utilization. On a local scale, commercial food waste
presents significant landfill diversion potential, contributing to airspace preservation and
extending the life of the Denton Landfill. On a broader scale, significant land is used to produce
food that is later wasted. Food waste source reduction tactics such as smart purchasing and
donation help mitigate these impacts.
78 Estimate is based on diverting 20,961 tons of commercial food waste (20 percent of estimated commercial food
waste generation in 2040), with net GHG emissions reduction of 0.54 MTCO2e/ton when diverted via composting
and 0.42 MTCO2e/ton when diverted via anaerobic digestion. Exact values will vary based on exact composting and
anaerobic digestion technology utilized. Impact factors based on U.S. EPA WARM v15 documentation
(https://www.epa.gov/warm).
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-8 Burns & McDonnell
Watershed Protection. Compost soil amendments (produced from composting food waste or the
solids resulting from anaerobic digestion) provide multiple benefits including reducing run-off
through improved soil porosity and decreased need to apply fertilizers.
11.3 Efficiently Use Landfill Capacity
Landfills will play a necessary role in materials management through the 2040 planning horizon, even
with increasing rates of recycling, waste reduction efforts, and technological advancement. The City owns
and operates the Denton Landfill, placing it in a position of self-determination regarding refuse disposal
and capacity planning.
11.3.1 Tactics and Recommendations
Tactics to efficiently use landfill capacity are focused on efforts to balance the need to preserve airspace
while meeting short- and long-term revenue needs. Specifically, to implement this strategy, the City
should:
Track landfill market pricing to set and revise rates accordingly.
Stabilize residential disposal rates and adequately fund diversion programs.
Use disposal contract rates to preserve airspace by incentivizing diversion in surrounding
communities.
Track landfill market pricing to set and revise rates accordingly. The City’s current gate rates and
discount contracts appear to be generally in line with other facilities in the region; however, as facilities
change their respective pricing and discount strategies the market will shift. Given the number of factors,
including price, that influence the flow of refuse throughout the region, the City should conduct routine
market studies to track disposal capacity market price and set rates accordingly to balance short- and
long-term capacity and revenue needs.
Stabilize residential disposal rates and adequately fund diversion programs. After 2023, it is
anticipated that the put-or-pay contracts will not be needed to pay down long-term debt, and instead can
generate net revenue for SWR. Implementing a sustainable materials management plan will require
expanded and new programs to further increase the City’s diversion efforts. In turn, programs will require
funding support that could include revenue generated through put-or-pay contracts. The City should
explore the creation of a special fund so that future disposal contract revenues could be directed to
stabilize residential rates and fund diversion programs. The creation of a special fund may become
increasingly important as the value of put-or-pay contracts increases due to regional capacity constraints.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-9 Burns & McDonnell
Use disposal contract rates to preserve airspace by incentivizing diversion in surrounding
communities. The Denton Landfill is an important disposal resource for north and west areas of the
region where disposal alternatives and diversion programs are more limited (e.g., Wise County). While
the City provides essential sanitary service to these communities through the safe disposal of non-
recyclable wastes, there is an opportunity to divert material from these communities as well. The City can
leverage put-or-pay discount structures to incentivize third-party communities to divert by contracting
directly with communities (rather than their contracted hauler) and implementing a discount structure that
provides an increase discount rate based on documented diversion tonnages. This shift in the put-or-pay
approach could be used to attract increased volumes of recycling material to the Pratt MRF (or future
expanded regional MRF) as well as the potential regionalization of other City programs (e.g., HCC) for
increased diversion and improved economies of scale. Key implementation steps identified for tracking
and reporting capture rate, recycling contamination, and waste reduction are:
Develop rate structure, ordinance, and implementation plan for revised discount contract
approach that considers diversion level of the generating community.
Implement updated disposal contract rate structure by executing contracts with communities.
11.3.2 Financial Impacts
The primary direct costs associated with the Strategy to Efficiently Use Landfill Capacity are to conduct
routine studies to track regional disposal capacity market price and capacity, which could require
significant staff time and/or outside services to complete. These studies would inform the City’s decisions
when setting disposal pricing at the Denton Landfill for non-resident customers. At current gate rate
pricing, each ton of airspace saved through recycling or waste reduction is valued at $48; however that
saved capacity will become increasing valuable as the regions’ landfills reach capacity in the coming
years. As the City explores options to revise the put-or-pay contract structure and incentivize diversion in
neighboring communities, contract pricing and discount structure should be balanced with near-term
financial needs to not drive tonnage away to the extent that revenues become insufficient to fund
operational needs.
11.3.3 Environmental Impacts
This strategy focuses on the efficient use of the City’s landfill capacity. The environmental impacts of
landfilling, including GHG emissions, vary depending on the materials being landfilled as well as the
landfill gas management approach. Organic materials (e.g., food waste, yard trimmings, paper) undergo
decomposition in a landfill, producing GHGs such as methane which must be managed. Operations at the
landfill such as using diesel-powered equipment also result in GHG emissions. Currently, the Denton
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-10 Burns & McDonnell
Landfill collects landfill gas for beneficial use which helps to offset a portion of the carbon footprint of
the landfill’s disposal activities through the production of renewable energy from landfill biogas. Efforts
to preserve landfill airspace through diversion and waste reduction (i.e., avoiding the creation of wastes
that must be managed) reduce the City’s carbon footprint through both the avoided landfill emissions and
the associated benefits of diversion or avoided initial manufacturing of the material. While the exact
environmental benefits vary significantly by material and whether it is diverted or avoided through waste
reduction, the portion associated with avoided landfill emissions would be approximately 0.08 MTCO2e
per ton diverted or reduced.79
Other benefits associated with landfill airspace preservation include:
Energy Use and Conservation. The City operates a landfill gas to energy system at the landfill,
which converts biogas to renewable energy. Efforts to reduce the amount of organics entering the
landfill (e.g., food waste) can result in a decrease in gas production for energy. However, there
are also benefits associated with reduced landfilling including a decrease in emissions from
diesel-powered landfill equipment.
Land Use and Open/Natural Space Utilization. Landfill airspace preservation extends the life
of the Denton Landfill, resulting in prolonged and efficient use of the land already developed
and/or permitting for disposal activities.
Transportation. Landfill pricing efforts to increase diversion and preserve airspace can result in
reduced transportation emissions as more distant communities may be incentivized based on price
to use a closer landfill and/or haul less material to the Denton Landfill due to incentives to
implement diversion and waste reduction practices in their communities.
Watershed Protection. Landfills require careful stormwater and leachate management to protect
watersheds and efforts to preserve landfill airspace, especially through organics diversion, will
help to preserve local watersheds.
11.4 Planning for Future Growth and Infrastructure
The City is experiencing rapid growth, including concentrated growth in the Hunter Ranch and Cole
Ranch MPCs. The Strategy to Plan for Future Growth and Infrastructure is focused on the operational
considerations for servicing this area and the resulting increase in material generation from residential,
commercial, and C&D sources.
79 Impact factors based on U.S. EPA WARM v15 documentation (https://www.epa.gov/warm).
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-11 Burns & McDonnell
11.4.1 Tactics and Recommendations
Tactics to plan for future growth are focused on actions the City can take to continue to safely and
efficiently manage the materials generated in the City and to increase diversion as more materials are
generated from increasing population and associated construction and development. Specifically, to
implement this strategy the City should:
Continue to proactively review and update development policies to address route serviceability.
Continue consideration of a transfer station in municipal facility planning .
Encourage decreased contamination, increased recycling participation and diversion, and
standardized services in the multifamily and commercial sectors.
Continue to proactively review and update development policies to address route serviceability. The
City has provided proactive input and coordinated with Development Services on issues related to
serviceability of new development. It is important that the City continue coordination with Development
Services to monitor development trends, address situations inaccessible to standard collection vehicles,
and modify code and criteria as warranted.
Continue consideration of a transfer station in municipal facility planning. With significant growth
planned for southwest Denton including the Hunter Ranch and Cole Ranch MPCs, a transfer station
would not be financially viable through the 2040 planning horizon if only managing these materials but
would provide operational benefits. The City should continue to include consideration of a transfer station
in long-term municipal facility planning and potential land acquisitions for municipal
facilities/infrastructure to serve the growth in southwest Denton.
Encourage decreased contamination, increased recycling participation and diversion, and
standardized services in the multifamily and commercial sectors. As residential and commercial
activity increases in the City as a result of growth, it is important for the City to develop sector-specific
plans to address key challenges or needs. Key implementation steps are:
Address contamination through education and outreach and additional ordinance(s) such as
contamination limits and reclassification of highly contaminated commercial or multifamily
recycling loads and refuse.
Develop a multifamily recycling implementation plan, including expanded opportunities (e.g.,
drop-off programs) and ordinances (as desired) to expand multifamily recycling access and
requirement as warranted by program performance.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-12 Burns & McDonnell
Develop a commercial recycling implementation plan, including expanded opportunities (e.g.,
partnerships) and ordinances (as desired) to expand commercial recycling access and requirement
as warranted by program performance.
Support C&D recycling and reuse in the region. As residential and commercial activity increases in
the City as a result of growth, it is important for the City to develop sector-specific plans to address key
challenges or needs. Key implementation steps are:
Establish a City-operated C&D Reuse Warehouse at Building 651, to provide an opportunity for
the diversion of re-use quality C&D materials.
Develop a C&D recycling implementation plan, and desired ordinance(s) to incentivize C&D
recycling through existing regional capacity and reuse through the City-operated facility.
11.4.2 Financial Impacts
Minimal financial impact is anticipated for continued coordination with Development Services, as this
activity is currently ongoing with current staffing levels. Similarly, including a future transfer station in
municipal facility planning has minimal financial impact and may be financially advantageous as the cost
of land in southwest Denton will likely increase over time.
The financial impacts of sector-specific options to address key challenges and needs (such as decrease
contamination, increase participation and diversion) vary depending on the opportunities chosen for each
sector.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-13 Burns & McDonnell
Table 11-2 communicates anticipated financial and operational impacts of recycling opportunities
identified in Section 8.3 and the associated potential impact on diversion rate.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-14 Burns & McDonnell
Table 11-2: Anticipated Impacts of Sector-Specific Options
Option Sector
Financial and Operational Impact
to:
Diversion
Impact
City Residents or
Businesses
Pay-As-You-Throw (PAYT) Residential Low Medium High
Mandatory Recycling Ordinance Multifamily Low High High
Mandatory Hauler Recycling Services Multifamily Medium1 Low High
Recycling Rewards and Recognition
Programs
Commercial Low Low Low
Mandatory Recycling Ordinance Commercial Low High High
Mandatory Hauler Recycling Service Commercial Medium1 High Medium
Expanded Drop Off Multifamily and
Commercial
Medium Low Medium
Material Disposal Bans All Medium High High
1 Financial and operational impact would be higher in cases where the City is the hauler and lower in cases where the customer is
serviced by a third-party permitted recyclable material hauler.
Financial and operational impacts for the City to build and operate are high due to staffing and equipment
needs. Table 12-4 presents estimated annualized costs for the program, which total $266,730 per year.
Table 11-3: Planning-Level Cost Estimate for C&D Warehouse Program
Item Quantity Unit Cost Annualized Cost1
Staffing2 1 $236,400 $236,400
Forklift or Similar Equipment 1 $50,000 $8,330
Equipment O&M 1 $20,000 $20,000
Pallet Racks or Similar Storage 20 $1,000 $2,000
Total Annual Cost $266,730
1 Annualized costs based on a useful life of 7 years for forklift equipment and 10 years for pallet racks
2 Site staffing is based on a similar service participation level to the HCC program and includes benefits.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-15 Burns & McDonnell
11.4.3 Environmental Impacts
This strategy includes multiple operational and programmatic efforts related to planning for the
anticipated high levels of growth in the City. As population grows, more materials are generated from
increasing population and associated construction and development. Increasing multifamily and
commercial diversion results in GHG benefits associated with both recycling (as described in Section
11.1.3) and organics diversion (as described in Section 11.2.3). C&D reuse and recycling also provides
GHG benefits, with diversion via reuse providing approximately 2.3 times the benefits of recycling. The
City could reduce overall carbon footprint by an estimated 0.4 MTCO2e per ton of C&D diverted through
a C&D reuse warehouse.80
Other benefits associated with efficiently managing growth and increasing diversion include:
Energy Use and Conservation. The diversion of additional material from multifamily,
commercial, and C&D sources result in energy savings. Efforts to reuse materials (such as
through a C&D reuse warehouse) and reduce total waste generation are even more impactful on
energy conservation as they result in avoided manufacturing of products.
Transportation. Efforts to increase diversion from the commercial, multifamily, and C&D
sectors can result in increased transportation associated with recycling routes or transportation by
the generator to drop-off sites. A transfer station would provide transportation efficiency when
servicing the Hunter Ranch and Cole Ranch MPCs are surrounding areas. This efficiency reduces
total miles traveled as well as the associated emissions.
11.5 Optimize Recycling Processing
Many MRFs, including the Pratt MRF, receive materials that are not suitable for processing at the facility
or could be managed through alternatives. The City has programs to divert many of these challenging
materials, however there are opportunities to expand diversion.
11.5.1 Tactics and Recommendations
Tactics to optimize recycling processing are focused on considerations to improve MRF processing by
diverting challenging or hard-to-recycle materials before they reach the MRF as well as securing
sufficient recycling processing capabilities. Specifically, to implement this strategy, the City should:
80 Estimate is based on available data of recyclable C&D in the Texas and impact factors from U.S. EPA WARM
v15 documentation (https://www.epa.gov/warm). Diverting an average C&D stream from landfill to recycling
results in GHG savings of 0.17 MTCO2e per ton, while diverting via reuse rather than landfilling results in GHG
savings of 0.4 MTCO2e per ton.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-16 Burns & McDonnell
Target key challenging materials in the MRF recycling stream to decrease contamination and
increase diversion.
Prepare to negotiate the rebate provision of the Recycling Agreement, if requested by Pratt.
Explore contract options that include a regional recycling approach for 2028 and beyond.
Target key challenging materials in the MRF recycling stream to decrease contamination and
increase diversion. Challenging and/or hard-to-recycle materials enter MRFs as contamination where
they are not suitable to be recovered and may cause other challenges for facility operations; however,
there are opportunities to expand diversion. Key implementation steps identified for expanding diversion
of challenging materials are:
Continue discussion with Pratt related to MRF equipment upgrades and to gather real-time
understanding of common inbound contaminants of concern.
Explore development of a City-operated expanded polystyrene drop-off recycling option
Explore development of a City-operated paper shredding (and recycling) events.
Coordinate efforts with local entities (e.g., police department, retail pharmacies) to facilitate
and/or promote safe sharps disposal.
Coordinate efforts with local entities (e.g., non-profits, shelters, UNT) to facilitate and/or promote
furniture and bulky item donation.
Prepare to negotiate the rebate provision of the Recycling Agreement, if requested by Pratt. Pratt
has the option to cause the parties renegotiate the rebate provision per Section 1.09(e) of the Recycling
Agreement. In the case Pratt causes the parties to renegotiate before the five-year period beginning
October 2, 2023, the City should leverage the recycling best management practices including updating the
rebate structure to be based on material composition, updating material specifications and percentages to
be more reflective of the current secondary commodities market, adjust the basis for values be the higher
of selected indices or actual sales price to incentivize Pratt to seek the highest pricing for material and
take advantage of the recent increase in the commodity prices to minimize long term risk to the City (e.g.,
establishing a price floor for some or all commodities).
Explore contract options that include a regional recycling approach for 2028 and beyond. Given the
limited recycling processing capacity in Denton and Collin Counties and anticipated growth in the region,
it is important for the City to plan appropriately for any efforts to increase recycling to identify options for
new capacity and/or facilities. Options to consider for developing additional recycling processing capacity
include explore expanded recycling at the Pratt MRF and alternatives such as accepting responsibility for
the processing of recycling materials either solely or through partnerships with other cities in the area
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-17 Burns & McDonnell
(e.g., McKinney, Plano). Key implementation steps identified to explore a regional recycling processing
approach for 2028 and beyond are:
Explore recycling processing options with Pratt at the expiration of the initial term of the
Recycling Agreement, including interest or ability to expand operations to meet recycling needs
in the northern part of the NCTCOG.
Explore alternative recycling processing options, including through public-private partnership or
processing agreement, to meet the growing needs of Denton and surrounding communities.
11.5.2 Financial Impacts
Many of the tactics to implement the Strategy to Optimize Recycling Processing related to continued
discussion, negotiation, and planning for recycling processing services. These initial steps generally have
a low financial impact but are valuable for the City to identify options and make informed decisions on
future recycling processing contracts and pricing terms.
Table 11-4 communicates the estimated planning-level costs associated with developing new City-
operated diversion programs to target challenging materials in the MRF recycling stream.
Table 11-4: Planning-Level Cost Estimate for EPS Densifier Program
Item Quantity Unit Cost Annualized Cost1
Staffing2 0.5 $118,200 $59,100
Densifier System 1 $20,000 $3,332
Total Annual Costs
$62,432
1Annualized cost based on a useful life of 7 years. Does not include revenues of 0.13 cents per pound of EPS
2Staffing based on a 25 percent increase in HCC staffing to accommodate demand for ESP drop-off service.
11.5.3 Environmental Impacts
This strategy includes efforts to recover challenging materials such as EPS and furniture for recycling or
reuse. The City can reuse its carbon footprint through the recovery of these materials for recycling and
reuse. The level of benefit varies based on the specific material and end use, however reuse generally
provides a higher level of benefit than recycling. The strategy also includes efforts to optimizing recycling
processing at the MRF to attain high performance such as recovering 95 percent of incoming program
materials. Successfully processing and sorting materials is key to producing clean saleable bales and
realizing the GHG and other benefits associated with using recycled material feedstocks in
manufacturing. On average, each ton of single-stream recycling provides a GHG benefit of 2.5-2.87
MTCO2e/ton, however this ranges from 9.15 MTCO2e/ton for aluminum cans to 0.30 MTCO2e/ton for
glass bottles.
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-18 Burns & McDonnell
Other benefits of increasing recycling and reuse of challenging materials include:
Energy Use and Conservation. In addition to the benefits of diversion discussed in Section
11.1.3, recycling of EPS can provide some additional energy use benefits when remanufactured
into products such as insulation providing additional energy savings for residential or commercial
heating and cooling.
Land Use. Efforts to divert additional recyclable or reusable materials, reduce contamination, and
improve material recovery at the MRF contribute to airspace preservation and extending the life
of the Denton Landfill.
Transportation. Similar to transportation impacts discussed in Section 11.3.3, implementation of
drop-off programs such as for EPS can result in increased transportation for residents to
participate. Reuse efforts provide transportation benefits, however, as materials are reused locally
rather than the long-haul transport of new products through manufacturing and distribution.
11.6 Support New Markets and Leverage Partnerships
Many valuable materials (e.g., furniture) can be diverted for reuse prior to entering the solid waste
management system. The Strategy to Support New Markets and Leverage Partnerships is focused on
actions the City can take to support the recycling and reuse of these materials.
11.6.1 Tactics and Recommendations
Tactics to support new markets and leverage partnerships are focused on actions the City can take to
increase the supply and demand of reusable items and recycled products through partnerships and other
methods outside of the City’s solid waste program. Specifically, to implement this strategy the City
should:
Continue coordination with other City departments to increase diversion.
Coordinate with local entities to meet community needs through diversion.
Continue and expand partnerships with local universities to raise awareness of reuse and
recycling.
Expand HCC services to neighboring communities through regionalization.
Continue coordination with other City departments to increase diversion. There are multiple cross-
departmental efforts that support increased diversion in the City. Key implementation steps identified for
coordination are:
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-19 Burns & McDonnell
Coordinate efforts with Parks & Recreation to address opportunities to increase public space
recycling, including consideration for impact fee for sports leagues.
Coordinate efforts with Procurement & Compliance to develop and support environmentally
preferred purchasing programs to support recycling markets.
Coordinate with local entities to meet community needs through diversion. By directly partnering or
supporting and facilitating programs established by local universities or non-profits, the City can help
divert materials that would otherwise be collected and landfilled through City-provided disposal service.
Key implementation opportunities identified are:
Explore a pilot donation program during college move out to support shelters and homelessness
services, including the Loop 288 Building/Our Daily Bread initiative.
Develop targeted outreach and support coordination for food waste diversion to support food
banks and soup kitchens.
Continue and expand partnerships with local universities to raise awareness of reuse and recycling.
With multiple universities located nearby, the City can benefit from partnerships to support research and
innovation related to materials management and demonstrate creative reuse through design and other
visual arts programs. The City has also benefited from having student interns participate with SWR. Key
implementation opportunities identified are:
Consider opportunities to expand involvement of student interns in solid waste recycling
activities, including expanded cart audit program.
Explore opportunities to partner with or support university departments in research, innovation, or
demonstration initiatives for new markets or end uses of challenging materials (e.g., glass and
plastic film).
Explore opportunities to partner with or support university departments in creative reuse and
other visual arts programs that raise awareness of waste generation and sustainability.
Expand HCC services to neighboring communities through regionalization. Currently, residents of
neighboring communities attempt to use the HCC drive through service and must be turned away.
Regionalization can provide economy of scale benefits for the City’s current program and allow for home
chemical materials and other household hazardous wastes to be safely and properly managed in
neighboring communities that may otherwise be sending these materials to the Denton Landfill. Key
implementation steps identified for exploring and implementing regionalization of HCC services are:
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-20 Burns & McDonnell
Conduct outreach with neighboring communities to evaluate potential volumes and staffing
needs.
Develop rate structure and update previously developed interlocal agreements, current HCC
recycling contracts, and education/outreach materials as needed to operate expanded regional
program.
11.6.2 Financial Impacts
The financial impacts of the tactics to support new markets through partnerships are generally low, and
include continued cross-departmental coordination. Costs associated with supporting community
partnerships to meet local needs may include some coordination, raising awareness of events, and in some
cases potentially providing roll-off service for one-time events (e.g., college move-out).
There are additional direct costs associated with the regionalization of the City’s HCC program. City staff
estimate that a regional program could result in a doubling of HCC demand based on the number of non-
resident customers turned away at the City’s facility. Table 11-5 communicates planning-level cost
estimates for a regionalized HCC program based on 2020 SWR financials. A regionalized HCC program
managing twice as much material would cost an estimated $460,000 per year, based on increased staffing
requirements and material handling and supplies. This is approximately $227,000 more that the current
HCC program. While direct costs would increase, the estimated financial impact to the City is limited as a
regional program would be structured as a cost-neutral expansion such that participating neighboring
communities would pay for their proportional share of the costs. Prior to program expansion, interlocal
agreements would be signed with participating communities detailing the program costs and structure for
participation (such as a voucher system).
Table 11-5: Planning-Level Cost Estimates for Regionalized HCC Program
Item Annual Costs1
Staffing $317,000
Materials and Supplies $24,000
Insurance $5,000
Operations $114,000
Total Annual Costs $460,000
1 Estimated based on a regional program managing twice as much material as the City’s current HCC.
11.6.3 Environmental Impacts
This strategy includes efforts to support markets for recycled materials. As described in Section 11.1.3,
GHG benefits from recycling are derived primarily from the use of recycled material feedstocks in
Comprehensive Solid Waste Management Strategy Strategy Development and Analysis
City of Denton, Texas 11-21 Burns & McDonnell
manufacturing. Realizing these benefits is therefore dependent on the level of market demand and types
of end users able to incorporate recycled material feedstock into their manufacturing processes. While
many of the tactics in the Strategy to Support New Markets and Leverage Partnerships do not have easily
definable levels of emissions reductions (e.g., inclusion of college interns in SWR activities), efforts such
as developing environmentally preferred purchasing programs will support markets for materials and
allow the potential environmental benefits of increased diversion to be realized.
Benefits of the initiatives and partnerships discussed in this strategy include:
Energy Use and Conservation. Recycled-content products are associated with energy savings
during manufacturing. Food waste donation reduces the waste of imbedded energy resources in
the food products.
Land Use. Food waste donation help to mitigate significant land is used to produce food that is
later wasted. Food waste source reduction tactics such as smart purchasing and donation help
mitigate these impacts.
Transportation. Reuse of materials to meet local needs helps to reduce transportation impacts
associated with long-haul for disposal or recycling as well as transportation of manufacturing and
distributing new products in the community.
Watershed Protection and Open/Natural Space Utilization. Partnering with Parks &
Recreation to increase diversion in public spaces can provide watershed protection and natural
space preservation through reduced littering and beautification.
Comprehensive Solid Waste Management Strategy Implementation Plan
12.0 IMPLEMENTATION PLAN
The implementation plan presents the following information for each of the six components of the
CSWMS:
Strategy Recommendations and Tactics. The six strategies were developed to align with the
Guiding Principles. Each strategy has between two and four recommendations for implementing
the strategy. Further, tactics are presented for each of these recommendations, defining the
identified program components, department actions, or policy steps to implement the
recommendation. The City can further evaluate which specific tactics, activities, and actions to
implement each strategy.
Priority. Each tactic has been assigned a high, medium, or low implementation priority in the
CSWMS, reflecting that each has differing potential for progress toward the City’s future
integrated management system. The City will first implement critically important activities (high
priority) and then implement activities assigned medium and low implementation priority as
resources are available.
Increased diversion potential. Each tactic has been assigned a high, medium, or low increased
diversion potential based on the relative impact that each tactic could have on the citywide
diversion rate based on waste composition and programmatic information for the City.
Financial impact. Each tactic has been assigned a high, medium, or low financial impact based
on the level of capital and/or operational costs required to fund the implementation of the tactic.
Potential funding sources. For tactics with a medium or high anticipated financial impact,
potential funding sources are identified to support the implementation of the tactic, including
SWR budget and user fees and/or alternative funding opportunities.
Implementation timing. Timing gives a general indication of when the City proposes to
implement each strategy. Timing designations were determined by considering multiple factors,
including resources required, current market conditions (whether current infrastructure and
customer/consumer behaviors would support it), and the length of time required for
implementation.
APPENDIX A - GOAL AND SWOT ANALYSIS
During the November 2020 kick-off meeting, Burns & McDonnell facilitated discussion to prioritize
goals and conduct a SWOT (Strengths, Weaknesses, Opportunities and Threats) analysis to gain further
perspective on key issues that needed to be evaluated in the development of the Comprehensive Solid
Waste Management Strategy. All information from the goals prioritization and SWOT analysis will be
used as background information to guide the Strategy development. Tables 1 through 3 communicate the
specific points identified during the facilitated discussion.
Table 1: Initial Goals to Address in the Comprehensive Solid Waste Management Strategy
Initial Goals
• HHW innovation
• Innovative technology and program implementation
• Food waste diversion
• Keep cost down
• Maximize airspace
• Tracking data to make informed interventions
• Sustainable
• Eliminate outside waste
• Future direction for solid waste
• Maximize landfill life
• Cost effective
• Reduce waste per capita
• Safe airspace
• Diversion to save air space, recycling contamination, illegal dumping, assisting our large
industrial warehouses
• Value and efficiency
• Addressing contamination
• Contamination
• Landfill space preservation
• Increased diversion
• Minimize disposal
• Maximize diversion
Table 2: Three Most Important Goals for the Comprehensive Solid Waste Management Strategy
First Most Important Goal
• Increase Diversion
• Diversion
• Diversion
• Diversion
• Landfill space preservation
• Increase diversion
• Airspace
• Diversion
• Landfill airspace
• Diversion
Second Most Important Goal
• Innovation balancing community needs and desires
• Cost
• Community needs
• Cost analysis
• Cost effectiveness
• Cost
• Cost-effective
• Facilities upgrade
• Properly manage resources
• Cost-benefit
• Innovation
• Innovation and technology
• Cost effectiveness
Third Most Important Goal
• Recycling contamination
• Community needs
• Benchmarking
• Contamination
• Streamlined process.
• Recycling is expensive, is it worth the cost?
• New programs...food waste diversion, others
• Regional accommodation
• Level set expectations
• Easily implemented
Table 3: Strengths, Weaknesses, Opportunities and Threats Summary
Strengths
• Innovative mindset
• Open to new ideas flexible
• Community support
• Financially responsible
• We have collections, recycling and landfill operations, one stop shop
• Experience
• Willingness to be flexible as a team
• Great professional staff
• The City owns the solid waste & recycling and landfill operations
• Teamwork and customer service
• Employee dedication and commitment
• Customer service and vision.
• Working together to get the job done
• The City's solid waste workforce
• Financially stable
• Excellent customer service
• Customer service
Weaknesses
• Pricing of services
• Misinformation
• Misinformation
• Community fear of the landfill site
• Various educational resources - competing messages
• Recycling market
• Managing customer expectations with higher volumes
• Growth around the landfill location
• Ensure to have the proper staff in place, don't overload
• Providers
• Location of facility
• Documenting accomplishments
• Contamination
• Public opinions
• Controlling illegal dumping and contamination
• Competing interests and priorities (e.g., food waste diversion, LF expansion)
• Financial constraints
• Ability to reduce contamination
• Community apathy
• Lack of full City Council support
• Competing community interests
Opportunities
• Developing educational programs in local colleges
• Restart and implement diversion
• Regional HHW
• Reducing recycling waste contamination
• Opportunity to educate the community while they are paying attention
• Potential to modify 3rd party waste contracts to incentivize or require diversion improvements
in other, smaller communities sending waste here
• Community growth
• Community interest
• City development
• Lack of regional airspace
• Broader opportunity to divert materials
• Closure of DFW-area landfills
• Large unused land footprint
• Other landfills closing or coming to end of life
• New landfill permit
• Diversity of the community
Threats
• Program executions
• Lack of end users for recycling commodities
• Non-owners occupied housing
• City growth outpacing infrastructure
• Widespread misinformation campaigns
• Lazy recyclers, don't comply with program, increase contamination
• Cost of fuel
• Privatization/misinformation about the landfill in the community
• Privatization
• Reluctance to participate in programs appropriately
• Myopic interests and visioning
• Development sprawl
• Economic downturn or slow growth
• Increased environmental requirements
• Special interest groups, especially from outside the area
• COVID and the economy
• Community misinformation
APPENDIX B - VISION FOR DENTON THINK-TANK REPORT
COMPREHENSIVE SOLD WASTE MANAGEMENT STRATEGY
VISION FOR DENTON THINK-TANK REPORT
Denton, Texas
May 2021
Create Future Intelligence®
COMPREHENSIVE SOLID WASTE
MANAGEMENT STRATEGY
VISION FOR DENTON THINK-TANK REPORT
DENTON, TEXAS
MAY 2021
This visioning report has been produced as part of Denton’s Comprehensive Solid Waste
Management Strategy Project and represents a summary of Task 1.
Report Prepared by:
Think-Tank Hosted by:
Create Future Intelligence®
TABLE OF CONTENTS
1.0 Introduction ...................................................................................................................1
2.0 Forces Shaping the Future .......................................................................................................2
3.0 Survey Results – Key Stakeholder Input ........................................................................3
3.1 Profile Information ..........................................................................................................................................3
3.2 Importance of a Shared Vision .......................................................................................................................4
3.3 Key Drivers Analysis ........................................................................................................................................5
3.3.1 Key drivers – importance and performance ............................................................................................................5
3.3.2 Impact of age on respondent perception ................................................................................................................6
3.4 Ranking of key factors impacting solid waste management ......................................................................6
3.5 Views of the Future – Threats Facing Solid Waste Management in Denton ..............................................8
3.6 Views of the Future – Opportunities Facing Solid Waste Management in Denton ....................................9
4.0 Scenario-Based Think-Tank ..........................................................................................10
5.0 Creating the Scenario Framework .................................................................................11
5.1 Scenario A: Greed Without Guilt ...................................................................................................................12
5.2 Scenario B: Change the Future Now! ............................................................................................................14
5.3 Scenario C: Low Tech Recycling Community ................................................................................................16
5.4 Scenario D: Trash Trouble ...............................................................................................................................18
6.0 Expected and Preferred Futures .................................................................................20
7.1 Urgency to Implement the Vision .................................................................................................................21
7.2 Appetite for Change ......................................................................................................................................22
8.0 Consulting Team – Task One ........................................................................................23
9.0 Acknowledgements .....................................................................................................24
10.0 For More Information ...................................................................................................24
1Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
1.0 INTRODUCTION
This report represents the culmination and summary of Task 1 of the seven-task Denton Solid
Waste Management Strategy project. The overall project aims to produce an executable
strategy, which will guide Denton’s solid waste and recycling priorities for the next twenty
years. Task 1 was designed to gather significant and relevant data, leading to the discovery
of expected and preferred futures for the future of solid waste management and recycling in
Denton. Each step of Task 1 built upon the preceding steps. The project kicked-off on November
16, 2020, with Task 1 wrapping-up on May 27, 2021.
The following provides descriptions of each deliverable completed in Task One:
• Virtual Project Launch – Burns & McDonnell and Future IQ collaborated to provide an online overview of
the scope and timeline of the project.
• Denton Solid Waste Management Community Survey – A collaboratively developed survey was distributed as
broadly as possible in the community. The survey was made available via an online project portal and was live from
January 25 through March 1, 2021. 883 individuals participated in the survey.
• Think-Tank Module 1: Future Trends – This two-hour module provided participants with an overview of macro and
local trends impacting solid waste management. Trends were examined with an eye to current processes, as
well as the impact of these trends looking out to 2040. This workshop took place virtually on Thursday,
April 8, 2021.
• Think-Tank Module 2: Key Drivers – This two-hour module explored key drivers of solid waste
management and recycling and introduced participants to the main themes used to create
the scenario matrix for Module 3 of the Think-Tank. The Key Driver Workshop took place on
Thursday, April 15, 2021.
• Think-Tank Module 3: Think-Tank – The two-hour scenario-based planning Think-Tank
module on April 29, 2021, provided an important opportunity to engage community
stakeholders and city staff in a critical dialogue about the future and to discuss the impacts
of changing dynamics solid waste management and recycling looking out to 2040.
• Denton Solid Waste Management Vision Survey – Participants of the Think-Tank modules were
asked to participate in the Vision Survey. Results produced heatmaps that illustrate expected and
preferred futures for solid waste management in Denton looking out to 2040.
• Future Summit – This one-hour summit provided community stakeholders with a summary of survey
and Think-Tank findings in the project’s Think-Tank report and allowed for questions and answers. The Future
Summit was held on May 27, 2021.
Task 1 of Denton’s Solid
Waste Management
Strategy Project has allowed
community stakeholders
to take a ‘deep-dive’ into
strategic visioning and
future-thinking through a
scenario-planning process.
2Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
2.0 FORCES SHAPING THE FUTURE
The three Think-Tank modules provided a forum for participants to explore the forces of change
shaping the future of solid waste management and recycling in the City of Denton. Participants
at the Think-Tank modules explored emerging macro trends, key drivers, and possible future
scenarios. Perceptions around the nature of impact of these forces, both in terms of size and
timing of impact, were explored to gauge how important participants consider these forces
of change. Participants discussed the emerging trends on global, regional, and local scales, and
related them directly to solid waste management and recycling in terms of how well prepared they
considered the City of Denton.
Specifically, the trend areas were:
• Consumption patterns and waste types
• Policy setting and application of technology
• Waste management systems being utilized
Of relevance to the discussion on trends, is the speed and scale of change that is occurring. Newly developed innovations
in solid waste management are being implemented globally and locally at all scales, thereby changing the face of
industries and society in a rapid and profound way. Advanced technologies are at the forefront of this transformation.
At the same time, societal values are shifting, and there is an increased awareness of environmental factors and
sustainable resource use.
The Increasing Capability of Digital Technologies
Digital Transformation Initiative Mining and Metals Industry, White Paper, World Economic Forum / Accenture analysis, January 2017
In the face of accelerating
speed of change, the key
to resiliency is the ability
to anticipate change and
remain agile. To be successful,
Denton’s new comprehensive
solid waste management
strategy will require the
active involvement of all
community stakeholders.
1950 1960 1970 1980 1990 2000 2010 2020
Mainframe
Client-serverand PCs
Web 1.0 eCommerce
Web 2.0, cloud, mobile
Big Data, analytics, visualization
IoT and smartmachine
Artificialintelligence
CUMULATIVE CAPABILITYTIME
“Denton has the
chance to set a great
example for the rest
of the area and State.
Denton is on the
progressive side and
we could make a huge
dent in the general
mentality regarding
Waste Management in
this state.”
- Denton Community
Survey Respondent
3Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
3.0 SURVEY RESULTS – KEY STAKEHOLDER INPUT
Prior to the Think-Tank modules, a community survey was conducted, and 883 community
stakeholders responded to the survey. Respondents were asked about their views on having a
shared vision for the future of solid waste management and recycling in Denton. Below are the
compiled results of the community survey.
3.1 PROFILE INFORMATION
In terms of survey respondent demographics, most respondents were aged 40 or over, with 33%
between the ages of 18-39. Respondents were asked about their organizational affiliation.
Survey respondent self-identified organizational affiliation
DATA INSIGHTS:
• Survey respondents overwhelmingly self-identified as private residents.
• Survey respondents were well distributed across the age ranges from 18 years to 80 years of age; with most age-
decade groups (i.e., 30-39 years old) having 15-20% of responses. Survey responses were dominated by women,
with nearly 60% of response self- identifying as female.
• In addition, respondents reported a wide range of periods of living in Denton, with good sized cohorts from 0-5
years, right through to 41 years or more.
The community survey has
achieved a strong response
rate from private residents.
This suggests the survey
reflects the desires of the
broader community.
VISUALISE
COMPLEXITY
DataInsight
City of Denton Board, Commission
or Committee Member
City of Denton Staff
Composting Industry
Environmental / Civic Organization
Large Business
Local Government
Private Resident
Recycling Industry
Small Business
Solid Waste Industry
State Government
Other
14.38%
84.03%
1.25%
0.23%
1.36%
0.79%
5.66%
0.79%
4.08%
1.36%
1.13%
1.59%
ORGANIZATIONAL AFFILIATION
Please select your organizational affiliation.
Answer
City of Denton Board, Commission or Committee Member
City of Denton Staff
Composting Industry
Environmental / Civic Organization
Large Business
Local Government
Private Resident
Recycling Industry
Small Business
Solid Waste Industry
State Government
Other
“I appreciate Denton’s environmentally progressive thinking and programs
available through solid waste and other city departments. I encourage you
to keep up the good work; it’s so important right now to do these things
to combat climate change and keep our environment clean.”
- Denton Community Survey Respondent
4Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
3.2 IMPORTANCE OF A SHARED VISION
Survey respondents were asked two questions about the importance of having a shared vision
for the future of solid waste management in Denton. The questions were:
• How important it is to have a long-term vision for solid waste management in the city?
• How important is long-term vision for making decisions in your home, business,
or organization?
The scale was: 1 = Not at all important; 10 = Critically important
Below is an illustration of the combined responses in a pivot chart (n=625). This chart seeks to
understand the importance of vision, and how much having a city vision will influence individual choices
and decision making.
Importance of Vision
DATA INSIGHTS:
• Most survey responses are in the extreme upper right quadrant of the matrix indicates the critically
important nature of having a shared vision for solid waste management in Denton.
• It is notable that having a shared vision is perceived as being similarly important and impactful at a city level, as
well as individual level. This suggests strong support for action as a city will strongly influence and shape individual
household and business behavior.
A long-term vision for solid
waste management was
identified as important not
only for Denton, but also
for survey respondents’
decision making at a level
of their home, business,
or organization.
1 2 3 4 5 6 7 8 9 10
Importance of Vision
1
2
3
4
5
6
7
8
9
10
Importance for YouPivot Chart - Importance of VISION X Importance for YOU - All Data
X axis is Importance of VISION - Scale: 1= Not at all important; 10 = critically important.
Y axis is Importance for YOU - Scale: 1= Not at all important; 10 = critically important.
Color
Blue
Green
LightBlue
Size
1
50
100
150
181
VISUALISE
COMPLEXITY
DataInsight
5Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
3.3 KEY DRIVERS ANALYSIS
To analyze the perceived drivers and influences on solid waste management and recycling in Denton, survey participants
were asked about the importance of changes to some topic areas over time, as well as Denton’s performance in
addressing these drivers of change.
3.3.1 KEY DRIVERS – IMPORTANCE AND PERFORMANCE
Survey respondents were asked about the importance of 18 key drivers of change as they relate to solid waste management
in Denton. Respondents were also asked to rate the city’s current performance in addressing each of these drivers.
DATA INSIGHTS:
• This data represents the results for all drivers. It shows that a very high level of importance attributed across the
set of 18 drivers. This is reflected in the responses being concentrated to the right-hand side of the chart. Sorting by
individual drivers shows no real difference between each of the 18 drivers.
• There is a much wider spread in perception of how well the city is currently performing for the drivers – with a very
large spread from ‘Not very well’ to ‘Very well’ on the Y-axis.
• A significant number of respondents recorded ‘Don’t know’ on the question of ‘How well is the city currently address
each driver’.
1 2 3 4 5 6 7 8 9 10
Importance of Drivers
1
2
3
4
5
6
7
8
9
10
How Well Currently Addressing DriversPivot Chart - Importance of Drivers X How Well Currently Addressing
Drivers - All Data
X axis is Importance of Drivers - Scale: 1= Not at all important; 10 = critically important.
Y axis is How Well Currently Addressing Drivers - Scale: 1= Not very well; 10 = Very Well.
Size
1
100
200
318
Key Drivers
• Alignment of Federal and State Regulations with Local State
Solid Waste Reduction goals
• Changing solid waste management regulations
• Climate change and sustainability efforts
• Collaboration with other cities and private companies
• Denton citizens’ desire for sustainable solid waste management
• Efforts to increase food waste diversion
• Enhanced efforts to decrease contamination in the recycling stream
• Focus on waste reduction and reuse
• Implementation of cost effective solutions
• Importance of cost effective solutions
• Importance of education focused on behavior change
• Increase producer’s/manufacturer’s responsibility for materials
reuse and recycling
• Markets and pricing for recyclable materials
• More efficient distribution and transportation systems
• New Materials recovery (recycling) technologies
• Preservation of the useful life of the City’s landfill
• Product packaging design changes
• Solid waste conversion technologies (e.g. energy from waste)
• Waste diversion and recycling goals
VISUALISE
COMPLEXITY
DataInsight
6Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
3.3.2 IMPACT OF AGE ON RESPONDENT PERCEPTION
The data on the importance and performance questions was also sorted by age cohorts. The
results for responses to all drivers was group by the 10-year age cohorts. This analysis allows
a better understanding of the perspectives of various groups within the community. The data
shows an incredibly interesting distribution. In terms of a perception of how well the city is
currently addressing these drivers, the continuum goes from young people saying, ‘Not very
well’ to more senior cohorts saying, ‘Very well’. This reflects broader societal attitudes and
reflects the heightened awareness and sensitivity to these issues with emerging age groups.
DATA INSIGHTS:
• This data is the results for all drivers. It shows that a very high level of importance attributed across the set
of 18 drivers. This is reflected in the responses being concentrated to the right-hand side of the chart.
• Younger and older cohorts are outliers in the perception of how well the city is currently addressing these drivers.
Emerging generations
exhibit much greater
awareness and sensitivity to
environmental impacts. This
is important when shaping
a 10- to 20-year strategy, as
these emerging values will
likely be the predominate
societal views in the future.
1 2 3 4 5 6 7 8 9 10
Importance of Drivers
1
2
3
4
5
6
7
8
9
10
How Well Currently Addressing DriversPivot Chart - Importance of Drivers X How Well Currently Addressing
Drivers - Cohort by Age
X axis is Importance of Drivers - Scale: 1= Not at all important; 10 = critically important.
Y axis is How Well Currently Addressing Drivers - Scale: 1= Not very well; 10 = Very Well.
Age
10-18 years
18-29 years
30-39 years
40-49 years
50-59 years
60-69 years
70-79 years
80 years and over
Size
17
200
400
600
800
913
VISUALISE
COMPLEXITY
DataInsight
7Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
3.4 RANKING OF KEY FACTORS IMPACTING SOLID WASTE MANAGEMENT
To gauge the relative importance of certain factors and their impact on the future of solid waste management in
Denton, survey respondents were asked to rank seven factors. These had been identified by the City of Denton team as
important to the future of solid waste management.
DATA INSIGHTS:
• Recycling education, population growth and increased waste materials, and landfill capacity were identified by
survey respondents as the three most important factors.
• Changes in citizen sensitivity to environmental responsibility will be important elements in gaining support for
Denton’s new comprehensive solid waste management strategy.
Drivers 1 2 3 4 5 6 7
Citizen sensitivity to
environmental
responsibility
Costs of services
provided
Increasing regulations
Landfill capacity
Policies to incentivize
or require changes
Population growth and
increased waste
materials
Recycling education
RANKING OF FACTOR
In terms of their impact on the future of solid waste management in Denton, please rank the relative importance of the following factors
SCALE: 1 = Most important; 7 = Least important
Answer
1
2
3
4
5
6
7
Size
21
50
100
166
VISUALISE
COMPLEXITY
DataInsight
8Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
3.5 VIEWS OF THE FUTURE – THREATS FACING SOLID WASTE
MANAGEMENT IN DENTON
As a measure of where community stakeholders considered the City of Denton unprepared or
threatened by future impacts, survey respondents were asked to cite in narrative form what
they believe are the biggest threats facing solid waste management in Denton looking out
to 2040. Initial results show considerable concern over lack of landfill space, population and
commercial growth, collection of waste from other cities and lack of stakeholder education as
primary concerns.
What do you think are the biggest threats facing solid waste management in Denton in the future?
(n=453)
DATA INSIGHTS:
• Addressing perceived threats to waste management will take significant and sensitive leadership in order to achieve
the desired effects of a post-pandemic comprehensive solid waste management strategy in Denton.
• The reliance on recycling markets for discarded recycling products directly impacts Denton’s ability to achieve
effective solid waste management and recycling goals for the city.
An effective
comprehensive waste
management strategy
will require increased
community education
about the benefits of
sustainable strategies
and to deal with issues
of apathy, ignorance,
and indifference
towards the issue.
VISUALISE
COMPLEXITY
DataInsight
9Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
3.6 VIEWS OF THE FUTURE – OPPORTUNITIES FACING SOLID
WASTE MANAGEMENT IN DENTON
In order to ascertain where the City of Denton should focus its efforts on leveraging resources,
survey respondents were asked to describe in narrative form what they believed were the
greatest opportunities for future solid waste management in the city looking out to 2040.
Increased recycling options were overwhelmingly identified as the greatest opportunity,
followed by instituting a community composting program, increasing community education and
consumer awareness about waste management options, and advanced technologies.
What do you think are the biggest opportunities facing solid waste management in Denton in the
future? (n=436)
DATA INSIGHTS:
• Survey respondents revealed an out-sized appetite for increased recycling options in Denton. This provides the city a
mandate to address recycling options.
• Given the considerable number of respondents who indicated they didn’t know any opportunities or threats facing
solid waste management in Denton in the future calls for an increase in community education on the topic.
The messaging
surrounding the
opportunities facing solid
waste management in
Denton in the future will
be key in gaining public
support for necessary
policy changes.
VISUALISE
COMPLEXITY
DataInsight
10Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
4.0 SCENARIO-BASED THINK-TANK
Denton’s scenario-based Think-Tank modules were conducted virtually over the course of three
two-hour workshops in April 2021. Approximately 20-25 people attended these workshops that
included city staff, community members, industry, and agency representatives. The Think-Tank
modules were intended to build coherency around a vision for initial future planning for solid
waste management and recycling in Denton that will guide community stakeholders over the
next twenty years.
The scenario planning process provides a method to explore plausible futures and consider the
implications of various future scenarios. The Think-Tank workshops aimed to:
• Deepen the understanding and examination of how external events and local conditions could shape
decision-making
• Identify and understand the key influences, trends, and dynamics that will shape the solid waste management and
recycling looking out to 2040
• Create and describe four plausible long-term scenarios for the City of Denton
• Explore alignment around a shared future vision
• Examine the strengths and weaknesses of the current solid waste management strategy in Denton as
perceived by community stakeholders
The scenarios developed during the scenario planning process and outlined in this report are important
to provide a framework to discuss future possible outcomes and implications for sustainable solid
waste management and recycling in Denton. In addition, the Think-Tank deliberations can assist in
identifying key actions for the city and in exploring how various groups might collaborate to best
contribute to future policy-making.
Think-Tank participants were guided through a scenario planning process to develop four plausible
scenarios for the future of solid waste management in the City of Denton. The process involved
exploration of local trends and forces of change; development of a scenario matrix defining four
plausible scenario spaces for the future; and, the development of descriptive narratives of each
scenario. The event concluded with discussion of the scenarios, selection of a preferred scenario, and
consequences of inaction.
The scenario planning
process allowed Denton
community stakeholders to
examine the implications
of choices about future
direction for solid waste
management and recycling.
11Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
5.0 CREATING THE SCENARIO FRAMEWORK
Based on the community survey responses and key input from city staff, themes were
identified to become the basis for two axes on the scenario matrix. The two axes identified
were Changing Societal Attitudes and Behavior and Impacts of Technology and Policy.
Think-Tank participants were presented with the scenario matrix, defined by the two major axes
of ‘Changing Societal Attitudes and Behavior’ and ‘Impacts of Technology and Policy’ (see diagram).
Brief descriptions were also attached to the end points of each driver axes. Participants were divided into
four groups to develop a narrative for each scenario. Each group was asked to describe the characteristics of solid waste
management in 2040 under the conditions of the scenario quadrant that they had been given. After the characteristics
were established, Think-Tank participants were asked to devise major events or headlines of how the scenario occurred
using the years 2025, 2030, and 2040, and to give their scenario a descriptive name. Narratives and descriptions of each
scenario as developed by the workshop participants are included in the following sections.FUTURE-SPLITTING QUESTIO N S ™
The scenario-planning
process provides a way to
tease out plausible future
scenarios and examine them
from a speculative standpoint.
They represent different
possibilities for the future.
Macro and local policy supports the application of new technology and
innovation in waste management. New local economic activity is driven by the
next generation of materials recovery technologies.
Hands-off policy position leads the system to local management and low-cost
solutions, including continued landll disposal. There are low levels of
technology application, and a reliance on traditional approaches.
Focus of society remains
consumption based.
Internet-based retailing increases
overall consumption and more
packaging waste. Priority is on
delivering individual consumer
choice and cost competiveness.
Stronger local and societal focus
on reduce, reuse, and recycling
principles. There is a culture of
collective responsibility and shared
solutions. There is a focus on
approaches such as integrated
local waste to energy systems.
A B
D C
D
A B
A B
C
Technology Driven Solutions
Low-cost / Low-tech Policy Options Reduce, Reuse, RecycleConsumption CultureImpacts of technology and policyChanging societal attitudes & behavior
TRASH
TROUBLE
GREED
WITHOUT GUILT
CHANGE THE
FUTURE NOW!
LOW-TECH
RECYLING
COMMUNITY
A B
D C
A
D
B
C
Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
5.1 SCENARIO A: GREED WITHOUT GUILT
This scenario forecasts a future where societal attitudes and
behaviors continue to espouse a culture that is consumption
oriented, and no efforts are made to reduce materials use
or waste production. Online retail continues to increase, and
priority is given to accommodating individual consumer choice
above all else. Increasing amounts of waste spur technological
innovation to deal with the ramifications of excess and new
types of packaging that rely on plant-based solutions are
created. The City of Denton no longer allows residents to sort
their own trash and the city utilizes cutting edge technologies
to sort and mine its waste. At first new technologies allow
consumption culture to continue uninhibited, and mined
waste is sold to support the expense of new technologies.
Use of anaerobic digestion increases, and new public-private
partnerships are formed to come up with new solutions for
dealing with waste. However over time, the City is ultimately
unable to keep up with resource use and waste production.D C
D
A B
A B
C
Technology Driven Solutions
Low-cost / Low-tech Policy Options Reduce, Reuse, RecycleConsumption CultureImpacts of technology and policyChanging societal attitudes & behavior
TRASH
TROUBLE
GREED
WITHOUT GUILT
CHANGE THE
FUTURE NOW!
LOW-TECH
RECYLING
COMMUNITY
The ‘Greed without Guilt’
scenario paints a future
where a growing consumption
culture necessitates the
use of technology driven
solutions in solid waste
management. These solutions
cannot mitigate the impacts
of unlimited resource and
waste production over time.
1212Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
13Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
SCENARIO A CHARACTERISTICS: GREED WITHOUT GUILT – 2040
To deal with the effects of a culture oriented to consumption, the characteristics of this scenario
paint a future where the City of Denton adopts policy settings that lean heavily towards innovative
technological solutions for solid waste management. New generation technologies in packaging, sorting,
and mining all help to stave off the effects of unlimited consumption, but over time municipalities are unable to
keep up with waste production and the associated costs.
2025 HEADLINE NEWS:
“Denton puts your trash to work”
2030 HEADLINE NEWS:
“Your trash is our treasure”
2040 HEADLINE NEWS:
“No such thing as waste”
Consumption Patterns
and Waste Types
Waste stream increases dramatically,
and packaging types vary more.
• Technology provides more varied and robust
packaging including plant based.
• Organics become the next food as intensive
agriculture increases.
• Denton sorts all trash for residents;
residents no longer need to sort.
Waste Management
Systems Being Utilized
Waste management is localized,
and a variety of systems are utilized
to deal with increased waste.
• New public-private partnerships are formed
with companies to sort waste.
• More metals are reclaimed from electronics
as new recovery technologies are adopted.
• Denton begins to sell its sorted waste as
landfill fills up.
Policy Setting and
Application of
Technology
Policies are driven towards technological
solutions as waste stream increases.
• Policy makers turn to industrial
infrastructure to sort, process, and handle
waste.
• Mining waste streams becomes critical for
energy production.
• As cost of processes decrease, new
technologies are adopted.
In the ‘Greed without
Guilt’ scenario, the world’s
finite resources are slowly
depleted. Technology
driven waste management
solutions mask the effects
of unmitigated consumption
until the world runs out of
those natural elements that
cannot be reproduced.
Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
5.2 SCENARIO B: CHANGE THE FUTURE NOW!
This scenario forecasts a future where Denton community
stakeholders understand their critical role in the waste
management process and fully support reduce, reuse, recycle
principles. Stakeholders are environmentally conscious
and are willing to make investments in innovative next
generation technologies necessary to achieve zero-waste
goals. By 2040, these technologies including sensors and
robots can sort, identify, and capture any type of material
and make use of it. Contamination is easily detected by
monitoring systems and anaerobic digesters are used to
produce energy for city vehicles. The ideal of a complete
closed-loop system is sought and policy settings follow suit.
Solid waste management expands from the local level to a
systems-wide approach within the State of Texas.
D C
D
A B
A B
C
Technology Driven Solutions
Low-cost / Low-tech Policy Options Reduce, Reuse, RecycleConsumption CultureImpacts of technology and policyChanging societal attitudes & behavior
TRASH
TROUBLE
GREED
WITHOUT GUILT
CHANGE THE
FUTURE NOW!
LOW-TECH
RECYLING
COMMUNITY
The ‘Change the Future
Now!’ scenario paints
a future where society
maintains a culture of
collective responsibility
and shared solutions for
solid waste management.
Advanced technologies move
solid waste management
towards total capture and
closed loop systems.
14Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
15Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
2025 HEADLINE NEWS:
“In the ‘Change the Future Now!’
scenario, continuous investment
in consumer”
2030 HEADLINE NEWS:
“Denton County leads Dallas
County in recycling numbers”
2040 HEADLINE NEWS:
“Organics provide all power for the
City of Denton”
SCENARIO B CHARACTERISTICS: CHANGE THE FUTURE NOW! – 2040
The characteristics of this scenario paint a future where community consumption patterns
reflect attitudes and behaviors that are fully supportive of reduce, reuse, recycle principals and
accept collective responsibility for sustainable waste management policies. Advanced technologies are
embraced to sort, identify, and capture all waste types and new markets expand for Denton’s waste products.
Consumption Patterns
and Waste Types
There is continuous investment
in consumer education with a
focus on collective responsibility
and shared solutions.
• Community stakeholders are fully supportive
of ‘reduce, reuse, recycle’ principles.
• Community stakeholders understand
their role in waste management and are
incentivized to change behaviors.
• All types of waste are collected and fully
utilized.
Waste Management
Systems Being Utilized
Solid waste management expands
from the local level to a systems-wide
approach within the State of Texas.
• Route monitoring occurs to identify with
precision where contamination occurs.
• Capture and conversion of CO2 and methane
to energy is a normalized process in waste
management.
• Landfill mining occurs to empty the landfill.
Policy Setting and
Application of
Technology
Advanced technologies make use
of all waste and policy settings are
graduated to ensure that there will be
no need for landfill use after 2040.
• Technologies can sort, identify, and capture
any type of material and make use of it.
• Increased use of sensors and robots make
sorting 100% efficient and creates markets
for waste use.
• Policies only allow use of recyclable materials
for all packaging and construction.
In the ‘Change the Future
Now!’ scenario, continuous
investment in consumer
education about waste
management pays off and
produces policy settings
that set the community
on a path to achieve its
zero-waste goals.
Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
5.3 SCENARIO C: LOW TECH RECYCLING COMMUNITY
This scenario forecasts a future where community
stakeholders have a high-level understanding of the impacts
of waste on the environment, but there is no political will to
pursue high-cost technical solutions at the governmental
level. The focus remains on localized, low-tech solutions
such as the landfill, combined with low-cost reduce, reuse,
recycle remedies. Creative low-tech solutions such as drop-
offs, reusable containers, gamifying recycling, interest in
reuse ‘garbage to gold’, and incentives for participation are
popular waste management initiatives. As new technologies
age and become less expensive over time, they are added
to Denton’s waste management strategies. This low-cost,
low-tech approach is problematic in the long run, as the city
is unable to keep up with consumer and producer waste
production and the landfill reaches capacity.
D C
D
A B
A B
C
Technology Driven Solutions
Low-cost / Low-tech Policy Options Reduce, Reuse, RecycleConsumption CultureImpacts of technology and policyChanging societal attitudes & behavior
TRASH
TROUBLE
GREED
WITHOUT GUILT
CHANGE THE
FUTURE NOW!
LOW-TECH
RECYLING
COMMUNITY
The ‘Low Tech Recycling
Community’ scenario paints a
future where the desire to keep
costs low impedes Denton’s
ability to be a leader in waste
management initiatives, and
the City is unable to keep
up with waste production.
1616Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
17Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
2025 HEADLINE NEWS:
“Residential recycling outpaces
residential waste across Denton”
2030 HEADLINE NEWS:
“Pop up reuse stores a growing
sector for Denton businesses”
2040 HEADLINE NEWS:
“No more confusion over what can
go in the bin”
SCENARIO C CHARACTERISTICS: Low Tech Recycling Community – 2040
The characteristics of this scenario paint a future where Denton community stakeholders are highly
aware of the benefits of environmentally sustainable waste management strategies, only there is
no political will to pay for them. Policy settings are set at low-tech, low-cost levels with an emphasis on
recycling and landfill solutions. Denton is a follower, not a leader in waste management technologies.
Consumption Patterns
and Waste Types
Consumers have a high-level
understanding of environmental
impact and financial implications.
• Society has a high desire to reduce, reuse
and recycle, and practices conscientious
consumerism.
• Manufacturers adopt recyclable packaging
with extended lifecycles.
• Waste shed area is micro-local with
neighborhood focus.
Waste Management
Systems Being Utilized
Waste management systems
continue to be local with focus
on recyclables and reuse.
• Recycling is required and incentives are
provided for participation.
• City expands reuse options and accepts more
items at the reuse shed.
• Denton is a follower, not a leader in waste
management technologies.
Policy Setting and
Application of
Technology
Policies do not provide funding
for next generation waste
management technologies and
low-cost solutions continue.
• Denton continues to use the landfill while
at the same time promoting ‘reduce, reuse,
recycle’ principles.
• Taxing is based on consumption and there
are repercussions for contamination.
• With no appetite for technology
investments, the focus is on education.
In the ‘Low Tech Recycling
Community’ scenario,
the savvy community
stakeholder pushes for
low-tech, low-cost options
while promoting ‘reduce,
reuse, recycle’ principles.
Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
5.4 SCENARIO D: TRASH TROUBLE
This scenario forecasts a future where the effects of excessive
consumerism without regard for the environment slowly
overwhelms the City of Denton’s solid waste management
system. A low-cost, low-tech policy orientation adds to the
city’s burden of dealing with waste and the landfill remains
the go-to solution. With no funding or political support to
pursue newer materials recovery technologies, costs rise as
the landfill reaches capacity and forces the city to search for
other lower-cost solutions such as incineration. Consumers
don’t help the situation with low recycling participation rates
and increased litter and illegal dumping to avoid high waste
collection costs. Food and recycling waste fills up the landfill
at an exponential rate. Sanitation issues arise with illegal
dumping and this creates a breeding ground for viruses such
as the Zika virus.
D C
D
A B
A B
C
Technology Driven Solutions
Low-cost / Low-tech Policy Options Reduce, Reuse, RecycleConsumption CultureImpacts of technology and policyChanging societal attitudes & behavior
TRASH
TROUBLE
GREED
WITHOUT GUILT
CHANGE THE
FUTURE NOW!
LOW-TECH
RECYLING
COMMUNITY
The ‘Trash Trouble’ scenario
paints a future that portrays
the worst-case scenario
for the City of Denton. The
combined effects of reliance
on traditional approaches
to waste management and
climate change would have
severe negative consequences
on quality of life for animals
and humans in Denton.
1818Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
19Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
2025 HEADLINE NEWS:
“Landfill reaches new ‘heights’.”
2030 HEADLINE NEWS:
“Illegal dumping accumulates
with no sign of collection.”
2040 HEADLINE NEWS:
“Doomsday comes to Denton”
SCENARIO D CHARACTERISTICS: TRASH TROUBLE – 2040
The characteristics of this scenario paint a future where Denton is gradually overtaken by waste
and pollution, and disease spreads among animals and humans. The impacts of a low-cost, low-tech
approach to solid waste management and recycling cannot keep up with a consumption-focused society
and resources are slowly depleted.
Consumption Patterns
and Waste Types
Consumers have no regard for
environmental sustainability and make
no effort to reduce, reuse, or recycle.
• Low participation rates in recycling programs
exponentially decreases landfill capacity.
• Limited recycling services restrict recycled
items to only most valuable commodities.
• Landfill reaches capacity and increased illegal
dumping occurs.
Waste Management
Systems Being Utilized
Reliance on traditional approaches to
waste management increases illegal
dumping, pollution, and tipping fees.
• Consumption-based consumer focus
increases waste quantities headed to the
landfill.
• Costs rise as the landfill reaches capacity and
the City searches for other low-cost solutions.
• Sanitation issues arise with illegal dumping
and creates breeding grounds for viruses.
Policy Setting and
Application of
Technology
Lack of progressive policies restricts
investment in new technologies as the
City seeks low-cost, low-tech options.
• With no concern for carbon mitigation, the
most polluting collection vehicle technologies
are used.
• Individual homeowners and businesses
pay for all waste management services
disincentivizing participation.
• Costs increase for customers as consumption
and waste production increase.
In the ‘Trash Trouble’
scenario, irreparable
harm occurs to the living
environment of Denton.
Severe losses occur in
the areas of water, air,
resources, and land.
20Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
6.0 EXPECTED AND PREFERRED FUTURES
Think-Tank participants discussed the ramifications and implications of failing to achieve the
preferred future. There was strong alignment among participants that Scenario B, ‘Change the Future
Now!’ represented the preferred scenario for Denton. To get to the preferred future, there was recognition
among Think-Tank participants that in addition to community behavior adjustments, policies must become more
supportive of new technologies, expanded recycling options and a systems-wide approach to solid waste management.
Getting from Expected to Preferred Future
FUTURE INSIGHTS:
• A definite preference for the ‘Change the future now!’ scenario indicates a clear mandate for the City of Denton to take
actions that support that vision for the future.
• There is an expectation that with generational change, there will be a more holistic, systems-wide approach to solid
waste management. The issue is how long this will take and whether humans will be able to mitigate the damage
done to the planet.
Because of the
long-term nature of
the Scenario Planning
methodology, stakeholders
often see the ‘distant future
vision (2040)’ as unattainable
and unrealistic. However, this
underestimates the progress
that can be made during the
intervening years, and the
cumulative positive
impacts of change.
21Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
7.1 URGENCY TO IMPLEMENT THE VISION
The survey conducted during the Think Tank at the end of Module 3, explored the perceived
sense of urgency to implement the preferred future. The results indicate a strong desire to move
with urgency. This reflects a sentiment seen in the community survey results.
Sense of Urgency
Question: How quickly do you think the City of Denton needs to adopt and pursue strategies to achieve the
preferred future? Scale: 1 = Not urgent right now; 10 = Critically urgent right now
“You are doing a great job - keep up the good work - people might moan and
groan about changes for the better but they did that when seatbelt laws were
enacted too and now most folks wear them.... Change takes time - just hope we
have enough time to turn around the mess we have made on planet Earth.”
- Denton Community Survey Respondent
FUTURE INSIGHTS:
• Think tank participants who took the survey, rated the urgency of adopting and pursuing the vision in the 7-10
scoring range (Urgent to Critically Urgent).
• This data reflects a strong desire to move quickly. This was also reflected in Think-Tank modules 1 and 2, as well as the
initial community survey.
The sense of urgency
reflected by survey
respondents gives the
City of Denton a clear
mandate to institute
change quickly as the
community seeks to achieve
their preferred future.
22Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
7.2 APPETITE FOR CHANGE
To gauge appetite for change to Denton’s solid waste management strategy, Think-Tank Module
1 participants were asked a series of rapid polling questions. The first question asked what kind
of waste management leadership role the city should take relative to similar Texas cities. The
second question asked how active city should be in advocating for change. The third question asked
how much respondents would be willing to pay for improved comprehensive solid waste management
services in Denton.
“I think if handled correctly, Denton could easily lead the way in Texas on waste
management. It would be great to see a big effort towards reducing waste of all kinds
through better recycling programs, composting programs, and public education.”
- Denton Community Survey Respondent
FUTURE INSIGHTS:
• Module #1 participants expressed a desire to see Denton be very active in advocating at the State of local level for
change in solid waste and recycling and doing so in collaboration with other municipalities.
• There was a willingness to pay more for improved comprehensive solid waste management services in Denton.
With support from the
community, the City of Denton
can strive to be a leading
role-model community for
solid waste management
in the State of Texas.
1
Module #1
Rapid Polling
23Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
8.0 CONSULTING TEAM – TASK ONE
The Task One consulting team was led by Burns & McDonnell, with survey and visioning components delivered by Future iQ.
Future iQ specializes in applying innovative tools and
approaches to assist municipalities, organizations,
regions, and industries shape their economic and
community futures. With nearly two decades of
experience, the company has a global clientele spanning
three continents.
To learn more visit
www.future-iq.com
Burns & McDonnell is a full-service engineering,
architecture, construction, environmental and consulting
solutions firm, based in Kansas City, Missouri. Our Solid
Waste and Resource Recovery group assists public and
private clients throughout North America.
To learn more visit
https://www.burnsmcd.com
The Task One Consulting Team included:
David Beurle
CEO, Future iQ
Heather Branigin
VP, Foresight Research
Future iQ
Scott Pasternak
Senior Project Manager
Burns & McDonnell
Debra L. Kantner
Solid Waste & Waste Minimization
Strategic Planner
Burns & McDonnell
Create Future Intelligence®
24Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
9.0 ACKNOWLEDGEMENTS
Future iQ and Burns & McDonnell team members would like to thank Denton community stakeholders for their dedication and
time committed to this project. Their presence at the virtual Think-Tank modules and participation in the community survey were
critical elements in the success of the visioning process. We would also like to thank Brian Boerner and the staff at the City of
Denton for the many hours of meetings and material support.
10.0 FOR MORE INFORMATION
For more information about Denton’s Solid Waste Management Strategy Project, please contact:
Brian Boerner, Director of Solid Waste
City of Denton
Phone: (940) 349-8001
Email: Brian.Boerner@cityofdenton.com
2424Comprehensive Solid Waste Management Strategy – Vision for Denton - Think-Tank Report – May 2021
Create Future Intelligence®
APPENDIX C - WASTE CHARACTERIZATION MEMO
MEMORANDUM
8911 Capital of Texas Highway \ Building 4, Suite 4260 \ Austin, TX 78759
O 512-872-7130 \ F 512-872-7127 \ burnsmcd.com
To: Brian Boerner - City of Denton
From: Scott Pasternak - Burns & McDonnell
Debra Kantner - Burns & McDonnell
Eric Weiss - Burns & McDonnell
Subject: Waste Characterization Event Results
Date: March 11, 2021
Burns & McDonnell is pleased to provide the composition results from garbage and recycling samples
provided by the City of Denton (City) during the sorting event held the week of November 5 - 8, 2020.
This memo presents results from 2020 sorting event for the City’s review including the garbage and
recycling composition from single-family residential, multi-family residential, and commercial samples
collected by City vehicles and delivered to the sorting site. The results presented in this memo are meant
to describe the results of the waste characterization, and will be used to support and inform the
development of the Comprehensive Solid Waste Strategy which will include further evaluation and
analysis of the results presented here.
Methodology
The methodology of the sorting event included coordinating with the City to identify, collect and deliver
material to the sorting site located at the ECO W.E.R.C.S. for handling and sortation as shown in Figure
1.
Figure 1: Sorting Site Collection Methodology
top left – sorting table; bottom left – weighing sorted material; top right – tipping commercial sample; bottom right – staged single-family samples
Page 2
Table 1 shows the number of samples collected and sorted from each generator type.
Table 1: Number of Samples by Generator Type
Generator
Refuse
Samples
Recycling
Samples
Single-Family Residential1 8 8
Multi-Family Residential 3 3
Commercial 8 8
Total Samples 19 19
1. The results shown in this memo include four additional refuse and recycling sample data gathered as part of the North Central Texas Council of Governments (NCTCOG) sorting event held October 26 – November 1, 2020. This is intended to show results with an increased level of
confidence as a result of sorting more material.
Each single-family garbage sample was collected from eight to 10 households and the recycling samples were collected from the same households from the four quadrants of the City. The City selected three multi-family complexes, including a small, medium and large complex to provide a representative
sampling. The City selected various commercial establishment among grocery stores, universities, retail stores, restaurants and automotive shops to provide a representative sampling.
When material was delivered to the sorting site, the sort crew received and managed the material, staging
it for sorting. The sort crew hand separated the material from each sample individually into designated buckets and then weighed and tracked the amount of each material type. The data collected in the field was compiled and analyzed to evaluate the composition profile of each generator type. The detailed results of this evaluation for each generator type are provided attached. The data was not extrapolated to evaluate the City-wide garbage and recycling composition due to limited sample size.
2020 Garbage and Recycling Composition
This section presents the material composition profiles and the contamination levels from each generator type. There are several key items to consider while reviewing the results, described as follows:
• Changes in material categories. Certain materials like rigid plastics and Construction & Demolition (C&D) metals were considered residue based on how they would be managed and processed by the City’s contract Material Processing Facility (MRF). These materials can
represent 1 - 3 percent of the material stream.
• Liquids. There may be loss of liquids when material is transported from a household and
processed at the MRF. During the sorting event, all of this liquid was counted as residue and no material was compacted during transportation. When setouts with liquids are collected by a refuse or recycling vehicle, some may leak out when the material is compacted and other material
may evaporate upon arrival at the MRF. At MRFs, it is common to see “shrinkage” of 1 - 3 percent of the incoming to processed material.
• Sampling methodology. The small number of samples for each generator type may cause an irregular load to skew the average composition profile to show an inflated residue rate that is not reflective of the composition of material over time.
Page 3
Table 2 shows the high-level composition profile by each generator type. Detailed composition profiles of
each generator type are provided attached.
Table 2: Composition Profiles by Generator Type
Material
Single-Family1 Multi-Family Commercial
Garbage Recycling Garbage Recycling Garbage Recycling
Newsprint 0.2% 1.0% 0.8% 2.3% 0.1% 0.0%
Recyclable OCC 0.7% 14.1% 3.4% 26.5% 1.0% 69.3%
Recyclable E-Commerce OCC 0.1% 7.4% 0.5% 7.7% 0.0% 1.5%
Pizza Boxes 0.1% 0.2% 0.6% 0.1% 0.0% 0.0%
Non-Recyclable OCC 0.7% 4.6% 1.0% 1.0% 3.1% 4.3%
Kraft Paper/paperboard 2.0% 9.7% 2.0% 8.4% 1.0% 1.5%
High Grade Office Paper 0.5% 0.6% 0.4% 0.8% 2.8% 1.7%
Magazines/ Glossy 0.2% 0.7% 0.2% 2.1% 0.1% 0.7%
Polycoated/ Aseptic Containers 0.2% 0.4% 0.3% 0.6% 0.2% 0.1%
Mixed (Other Recyclable) 1.4% 2.6% 1.6% 2.2% 1.0% 1.1%
Other (Non-Recyclable) 12.5% 5.7% 8.9% 4.6% 13.9% 7.2%
Paper Subtotal 18.5% 47.1% 19.7% 56.4% 23.3% 87.5%
PET Containers 2.4% 5.6% 2.6% 4.1% 1.1% 0.4%
HDPE Containers - Natural 0.3% 1.7% 0.3% 0.7% 0.4% 0.2%
HDPE Containers - Colored 0.5% 1.7% 0.6% 0.4% 1.8% 1.1%
#3 - #7 Containers 0.3% 0.9% 0.4% 0.2% 0.8% 0.0%
Polypropylene 0.8% 1.4% 1.0% 0.5% 0.2% 0.1%
Non Recyclable Plastic 11.0% 9.5% 7.7% 6.9% 16.3% 3.1%
Plastic Subtotal 15.2% 20.8% 12.7% 12.7% 20.6% 4.9%
Aluminum Used Beverage Containers 1.1% 2.6% 0.9% 1.2% 0.2% 0.1%
Ferrous Metal Food Containers 2.0% 1.1% 0.7% 1.4% 0.6% 0.1%
Other Ferrous Metal 1.0% 1.4% 1.2% 0.1% 7.8% 0.4%
Other Non-Ferrous Metal 0.7% 0.4% 0.3% 0.1% 0.3% 0.1%
Metals Subtotal 4.7% 5.5% 3.1% 2.8% 9.0% 0.7%
Recyclable Glass 2.7% 10.9% 5.3% 15.5% 0.6% 0.2%
Non-Recyclable Glass 1.6% 1.0% 0.5% 1.8% 1.0% 0.3%
Glass Subtotal 4.3% 11.9% 5.8% 17.3% 1.7% 0.5%
Yard Waste 2.0% 0.5% 0.1% 0.0% 7.0% 1.0%
Wood (non-C&D) 0.5% 0.1% 0.0% 0.0% 0.1% 0.0%
Food Waste 32.0% 6.8% 29.6% 4.7% 32.4% 1.4%
Page 4
Material
Single-Family1 Multi-Family Commercial
Garbage Recycling Garbage Recycling Garbage Recycling
Other Organics 12.0% 5.1% 10.5% 0.3% 2.0% 0.5%
Organics Subtotal 46.6% 12.4% 40.2% 5.0% 41.4% 2.9%
Recyclable C&D 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%
Other C&D 0.7% 0.0% 0.0% 1.4% 0.3% 0.7%
C&D Subtotal 0.7% 0.0% 0.0% 1.4% 0.3% 0.7%
Electronics 0.9% 0.5% 1.5% 4.1% 0.0% 0.2%
HHW 0.4% 0.0% 0.0% 0.0% 1.5% 2.2%
Bulky Waste 1.8% 0.9% 8.9% 0.0% 0.0% 0.0%
Problem Material Subtotal 3.0% 1.4% 10.4% 4.1% 1.5% 2.4%
Other Inorganics 3.8% 0.7% 4.6% 0.0% 0.0% 0.0%
Fines 3.4% 0.4% 3.4% 0.2% 2.3% 0.4%
Other Subtotal 7.2% 1.0% 8.0% 0.2% 2.3% 0.4%
Total2 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%
1. The composition of single-family garbage and recycling shown is reflective of the combined results (a total of 12 samples of garbage and recycling) from the samples provided both during the City’s sorting event and the NCTCOG sorting event held October 26 – November 1, 2020 to show results with an increased level of confidence.
2. Total may not sum exactly due to rounding.
Table 3 shows the recycling contamination present in the aggregated samples from each generator type. Contamination categories include non-recyclable Old Corrugated Cardboard (OCC), other non-recyclable paper, non-recyclable plastic, non-recyclable glass, organics, other C&D, problem material and other
material.
Table 3: Recycling Contamination by Generator Type
Single-Family1 Multi-Family Commercial
Contamination 35.5% 25.0% 21.4%
1. Contamination in the single-family recycling shown is reflective of the combined results (a total of 12 samples of garbage and recycling) from the samples provided both during the City’s sorting event and the NCTCOG sorting event intended to show results with an increased level of confidence.
Page 5
Capture Rate
This section provides the capture rate of the material provided from each generator type. Capture rate is calculated using the following formula: 𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑃𝑃𝑜𝑜 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 𝑀𝑀𝑅𝑅𝑀𝑀𝑅𝑅𝑀𝑀𝑀𝑀𝑅𝑅𝑅𝑅𝑃𝑃 𝑀𝑀𝑃𝑃 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑀𝑀𝑃𝑃𝑅𝑅(𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑃𝑃𝑜𝑜 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 𝑀𝑀𝑅𝑅𝑀𝑀𝑅𝑅𝑀𝑀𝑀𝑀𝑅𝑅𝑅𝑅 𝑀𝑀𝑃𝑃 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑀𝑀𝑃𝑃𝑅𝑅+𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃𝑃 𝑃𝑃𝑜𝑜 𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 𝑀𝑀𝑅𝑅𝑀𝑀𝑅𝑅𝑀𝑀𝑀𝑀𝑅𝑅𝑅𝑅 𝑀𝑀𝑃𝑃 𝐺𝐺𝑅𝑅𝑀𝑀𝑅𝑅𝑅𝑅𝑅𝑅𝑅𝑅 )
Table 4 shows the capture rate from the materials delivered to the sort site, by generator type.
Table 4: Capture Rate by Generator Type
Recyclable Material
Single-
Family1 Multi-Family Commercial
Recyclable OCC 84.2% 70.8% 97.8%
Mixed Paper 46.9% 48.6% 50.2%
PET Containers 37.0% 32.4% 18.4%
HDPE Containers - Natural 55.3% 42.6% 24.8%
HDPE Containers - Colored 44.0% 13.2% 27.7%
#3-#7 Containers 35.8% 9.9% 10.4%
Aluminum Used Beverage
Containers 37.1% 27.2% 31.5%
Ferrous Metal Food Containers 11.0% 38.2% 7.3%
Recyclable Glass 50.4% 48.5% 19.7%
Weighted Average 49.2% 51.9% 84.3%
1. Capture rate from single-family material is reflective of the combined results (a total of 12 samples of garbage and recycling) from the samples provided both during the City’s sorting event and the NCTCOG sorting event intended to show results with an increased level of confidence.
Please see the results on the attached pages and thank you again for your support to carry out this regional effort. If you have any questions please do not hesitate to reach out to Eric Weiss at ebweiss@burnsmcd.com or (737) 242-7830 and Scott Pasternak at spasternak@burnsmcd.com or (512) 872-7141.
City of DentonSingle‐Family Garbage and Recycling Composition ‐ November 2020Results in blue indicate samples were from the North Central Texas Council of Governments sorting eventheld October 26 ‐ November 1, 2020Overall Sample No.1‐G 2‐G 7‐G 8‐G 12‐G 13‐G 18‐G 19‐G47‐G48‐G49‐G50‐G1‐R 2‐R 7‐R 8‐R 12‐R 13‐R 18‐R 19‐R47‐R 48‐R 49‐R 50‐RGeneratorSingle‐FamilyMaterial Group MaterialAverageAverageTotal Refuse Samples Sorted12Newsprint 0.4% 0.6% 0.3% 0.0% 0.1% 0.0% 0.2% 0.1%0.3% 0.5% 0.0% 0.0%0.2% 0.0% 0.7% 0.0% 2.4% 0.0% 0.6% 2.2% 0.0%3.2% 1.8% 0.9% 0.5%1.0%Total Recycling Samples Sorted12Recyclable OCC 0.6% 1.1% 0.1% 0.4% 0.8% 1.0% 0.3% 0.3%0.1% 0.7% 1.2% 1.4%0.7% 30.5% 9.0% 11.3% 3.9% 8.2% 1.9% 20.1% 31.5%7.6% 14.8% 3.7% 26.6%14.1%Recyclable E‐Commerce OCC 0.4% 0.0% 0.1% 0.0% 0.0% 0.1% 0.0% 0.2%0.0% 0.7% 0.3% 0.0%0.1% 10.4% 8.1% 1.4% 10.4% 3.0% 1.8% 6.5% 4.9%20.9% 8.9% 5.7% 7.3%7.4%Pizza Boxes 0.0% 0.0% 0.5% 0.0% 0.0% 0.1% 0.1% 0.0%0.0% 0.0% 0.0% 0.0%0.1% 0.0% 1.5% 0.0% 0.0% 0.7% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.2%Recyclable Material in Refuse15.3%Non‐Recyclable OCC 0.1% 1.3% 1.3% 0.6% 0.4% 0.1% 1.1% 0.3%0.7% 1.0% 0.8% 0.6%0.7% 0.0% 11.9% 0.6% 0.4% 2.3% 14.3% 10.6% 4.0%1.4% 2.4% 5.1% 2.6%4.6%Residue in Recycling Samples35.5%Kraft Paper/paperboard 2.7% 2.5% 1.6% 1.6% 1.1% 1.0% 2.4% 1.5%2.8% 2.2% 2.0% 2.7%2.0% 13.4% 19.7% 5.4% 6.7% 7.4% 5.7% 6.0% 12.3%8.5% 15.3% 7.7% 8.6%9.7%High Grade Office Paper 1.7% 0.6% 0.4% 0.5% 0.3% 0.2% 0.4% 0.0%0.8% 0.4% 0.2% 0.5%0.5% 0.0% 0.3% 2.1% 3.4% 0.3% 0.1% 0.4% 0.1%0.2% 0.3% 0.4% 0.1%0.6%Magazines/ Glossy 0.3% 0.3% 0.9% 0.0% 0.0% 0.2% 0.0% 0.0%0.2% 0.1% 0.0% 0.0%0.2% 0.4% 0.0% 0.4% 1.8% 0.0% 0.7% 0.0% 0.0%4.5% 0.0% 0.0% 0.0%0.7%Polycoated/ Aseptic Containers 0.1% 0.1% 0.2% 0.3% 0.1% 0.0% 0.0% 0.1%0.3% 0.1% 0.5% 0.1%0.2% 0.0% 0.6% 0.3% 0.5% 1.7% 0.8% 0.0% 0.2%0.0% 0.0% 0.1% 0.3%0.4%Mixed (Other Recyclable) 6.0% 1.2% 2.6% 0.6% 0.6% 0.5% 1.2% 0.2%0.9% 0.4% 0.3% 1.9%1.4% 0.9% 3.1% 3.0% 10.8% 0.6% 1.2% 0.8% 0.4%3.5% 5.1% 0.6% 1.9%2.6%Other (Non‐Recyclable) 6.5% 14.2% 14.5% 8.9% 10.1% 10.2% 8.9% 9.3%21.4% 14.3% 21.5% 10.1%12.5% 0.4% 0.8% 8.8% 0.0% 7.6% 6.4% 3.4% 3.6%16.5% 8.3% 10.9% 1.1%5.7%Paper Subtotal18.8% 22.0% 22.5% 12.9% 13.6% 13.4% 14.6% 11.9%27.6% 20.5% 26.9% 17.5%18.5% 55.9% 55.7% 33.2% 40.2% 32.0% 33.5% 49.9% 57.1%66.4% 56.9% 35.0% 48.9%47.1%PET Containers 2.5% 3.0% 2.2% 1.1% 1.5% 1.7% 3.2% 1.9%2.2% 1.9% 5.4% 2.5%2.4% 2.4% 4.9% 1.8% 3.6% 3.9% 11.2% 5.3% 5.4%8.0% 5.5% 10.3% 5.4%5.6%HDPE Containers ‐ Natural 0.5% 0.1% 0.1% 0.2% 0.3% 0.2% 0.0% 0.3%0.2% 0.6% 0.4% 0.2%0.3% 3.7% 0.3% 0.6% 0.7% 2.4% 2.2% 1.7% 1.8%0.6% 3.1% 2.5% 1.0%1.7%HDPE Containers ‐ Colored 0.4% 0.3% 0.4% 0.4% 0.1% 0.1% 1.1% 0.8%0.4% 0.4% 0.6% 0.9%0.5% 4.8% 0.0% 3.0% 0.4% 3.0% 3.8% 1.8% 0.0%1.3% 1.0% 1.3% 0.4%1.7%#3 ‐ #7 Containers 0.3% 0.4% 0.2% 0.4% 0.1% 0.2% 0.2% 0.4%0.1% 0.5% 0.3% 0.1%0.3% 0.0% 0.0% 5.9% 2.0% 0.7% 1.2% 0.3% 0.0%0.5% 0.3% 0.1% 0.0%0.9%Polypropylene 0.3% 0.0% 1.0% 0.4% 0.4% 0.4% 1.6% 0.8%0.9% 1.1% 1.6% 0.5%0.8% 0.0% 7.5% 0.2% 1.4% 0.5% 2.5% 0.9% 0.5%1.1% 0.7% 0.6% 0.6%1.4%Non Recyclable Plastic 10.8% 6.7% 11.3% 8.7% 10.2% 11.5% 10.2% 10.1%12.5%12.8% 16.7% 10.2%11.0% 4.1% 3.2% 23.3% 6.9% 8.8% 10.2% 9.7% 5.2%11.7% 10.5% 14.3% 5.5%9.5%Plastic Subtotal14.9% 10.6% 15.1% 11.2% 12.4% 14.1% 16.4% 14.3%16.4% 17.2% 25.0% 14.4%15.2% 14.9% 15.8% 34.8% 15.0% 19.4% 31.1% 19.7% 12.9%23.1% 21.1% 29.0% 12.9%20.8%Aluminum Used Beverage Containers 2.0% 3.1% 0.0% 0.5% 0.0% 0.6% 2.3% 1.0%0.5% 1.2% 0.6% 0.9%1.1% 0.0% 5.0% 0.3% 1.5% 0.6% 1.5% 6.0% 6.3%0.6% 5.8% 0.7% 3.0%2.6%Ferrous Metal Food Containers 0.7% 4.3% 0.6% 1.3% 0.6% 2.0% 1.3% 8.7%0.3% 1.3% 1.5% 1.2%2.0% 0.0% 1.4% 0.3% 2.1% 2.1% 1.4% 0.0% 0.9%2.8% 0.5% 0.3% 1.1%1.1%Other Ferrous Metal 3.8% 0.2% 0.2% 0.5% 0.8% 2.1% 0.2% 0.5%2.6% 0.6% 0.1% 0.2%1.0% 0.0% 0.0% 0.4% 2.0% 0.0% 7.2% 3.1% 0.0%0.0% 1.1% 2.8% 0.0%1.4%Other Non‐Ferrous Metal 1.7% 0.2% 0.4% 0.3% 0.8% 1.1% 0.7% 0.4%0.8% 0.6% 0.4% 0.6%0.7% 0.0% 0.3% 0.2% 1.3% 0.7% 0.0% 0.4% 0.1%0.2% 0.7% 0.4% 0.3%0.4%Metals Subtotal8.1% 7.8% 1.2% 2.5% 2.2% 5.7% 4.5% 10.5%4.3% 3.6% 2.6% 3.0%4.7% 0.0% 6.7% 1.2% 6.9% 3.5% 10.1% 9.5% 7.3%3.6% 8.1% 4.2% 4.4%5.5%Recyclable Glass 7.0% 11.9% 1.6% 2.0% 0.4% 3.1% 2.4% 0.7%0.2% 0.8% 0.8% 1.8%2.7% 17.1% 19.0% 2.1% 14.5% 3.4% 24.6% 13.6% 10.2%2.9% 9.3% 3.5% 10.4%10.9%Non‐Recyclable Glass 0.0% 0.1% 10.9% 0.3% 0.8% 0.0% 4.8% 0.0%0.7% 0.7% 0.4% 0.0%1.6% 0.0% 0.0% 2.0% 0.2% 0.0% 0.0% 0.0% 5.9%2.8% 0.0% 0.7% 0.2%1.0%Glass Subtotal7.0% 12.0% 12.5% 2.3% 1.2% 3.1% 7.2% 0.7%0.9% 1.5% 1.2% 1.8%4.3% 17.1% 19.0% 4.0% 14.7% 3.4% 24.6% 13.6% 16.0%5.7% 9.3% 4.2% 10.6%11.9%Yard Waste 0.1% 0.0% 3.5% 1.6% 8.0% 0.2% 0.0% 4.6%0.0% 3.4% 0.3% 2.3%2.0% 0.0% 0.0% 0.0% 0.0% 5.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.6% 0.0%0.5%Wood (non‐C&D) 0.2% 0.3% 1.4% 0.2% 0.3% 1.0% 0.0% 0.0%0.2% 0.3% 2.4% 0.0%0.5% 0.9% 0.0% 0.1% 0.1% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.1%Food Waste 15.6% 31.8% 38.3% 44.5% 20.8% 36.7% 22.0% 31.3%31.2% 28.2% 37.1% 47.2%32.0% 0.0% 2.8% 18.0% 6.1% 9.1% 0.2% 7.3% 2.5%1.2% 2.0% 12.4% 19.6%6.8%Other Organics 8.8% 4.8% 2.2% 11.1% 22.9% 20.0% 30.9% 12.4%10.1% 10.7% 0.0% 10.0%12.0% 11.2% 0.0% 4.0% 0.7% 27.6% 0.5% 0.0% 3.6%0.0% 2.4% 8.3% 2.5%5.1%Organics Subtotal24.7% 36.9% 45.5% 57.4% 52.1% 57.8% 52.9% 48.2%41.5% 42.5% 39.7% 59.5%46.6% 12.1% 2.8% 22.1% 6.8% 41.7% 0.6% 7.3% 6.1%1.2% 4.4% 21.3% 22.2%12.4%Recyclable C&D0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.0%Other C&D 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 2.3%4.0% 0.2% 0.1% 1.0%0.7% 0.0% 0.0% 0.0% 0.3% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.0%C&D Subtotal0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 2.3%4.0% 0.2% 0.1% 1.0%0.7% 0.0% 0.0% 0.0% 0.3% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.0%Electronics 0.5% 0.0% 0.6% 0.0% 3.4% 0.0% 0.0% 1.7%0.1% 3.5% 0.1% 0.5%0.9% 0.0% 0.0% 0.4% 5.8% 0.0% 0.0% 0.0% 0.0%0.0% 0.2% 0.0% 0.0%0.5%HHW3.2% 0.0% 0.0% 0.4% 0.1% 0.3% 0.0% 0.1%0.2% 0.0% 0.0% 0.0%0.4% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.0%Bulky Waste 0.0% 0.0% 0.0% 1.2% 11.0% 2.2% 0.0% 6.8%0.0% 0.0% 0.0% 0.0%1.8% 0.0% 0.0% 0.0% 10.3% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 0.0% 0.0%0.9%Problem Material Subtotal3.7% 0.0% 0.6% 1.6% 14.4% 2.5% 0.0% 8.5%0.4% 3.5% 0.1% 0.5%3.0% 0.0% 0.0% 0.4% 16.2% 0.0% 0.0% 0.0% 0.0%0.0% 0.2% 0.0% 0.0%1.4%Other Inorganics 18.1% 7.9% 0.0% 4.9% 1.4% 0.0% 2.7% 0.4%2.4% 7.4% 0.0% 0.0%3.8% 0.0% 0.0% 4.3% 0.0% 0.0% 0.0% 0.0% 0.0%0.0% 0.0% 3.7% 0.0%0.7%Fines 4.4% 2.8% 2.7% 7.3% 2.7% 3.2% 1.7% 3.1%2.6% 3.6% 4.4% 2.4%3.4% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.6%0.0% 0.0% 2.7% 1.0%0.4%Other Subtotal22.5% 10.7% 2.7% 12.2% 4.1% 3.2% 4.4% 3.5%5.0% 11.1% 4.4% 2.4%7.2% 0.0% 0.0% 4.3% 0.0% 0.0% 0.0% 0.0% 0.6%0.0% 0.0% 6.4% 1.0%1.0%Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%OtherPaperPlasticMaterial Breakdown (%)Material Breakdown (%)C&DProblem MaterialsRecyclingGarbageMetalsGlassOrganicsBurns & McDonnell
City of DentonMulti‐Family Garbage and Recycling Composition ‐ November 2020Overall Sample No.6‐G 11‐G 15‐G 6‐R 11‐R 15‐RGeneratorMulti‐familyMaterial Group Material Average AverageTotal Refuse Samples Sorted3Newsprint 1.2% 0.3% 0.9% 0.8% 3.3% 2.7% 0.7% 2.3%Total Recycling Samples Sorted3Recyclable OCC 6.3% 0.1% 3.7% 3.4% 36.7% 15.0% 27.8% 26.5%Recyclable E‐Commerce OCC 0.4% 0.1% 1.0% 0.5% 0.2% 18.3% 4.7% 7.7%Pizza Boxes 0.2% 0.2% 1.6% 0.6% 0.0% 0.4% 0.0% 0.1%Recyclable Material in Refuse21.6%Non‐Recyclable OCC 0.9% 1.0% 1.2% 1.0% 1.1% 1.2% 0.8% 1.0%Residue in Recycling Samples25.0%Kraft Paper/paperboard 1.9% 1.4% 2.7% 2.0% 7.7% 6.3% 11.1% 8.4%High Grade Office Paper 0.3% 0.2% 0.5% 0.4% 0.3% 1.7% 0.5% 0.8%Magazines/ Glossy 0.2% 0.2% 0.0% 0.2% 0.0% 1.0% 5.3% 2.1%Polycoated/ Aseptic Containers 0.4% 0.1% 0.4% 0.3% 0.1% 0.5% 1.2% 0.6%Mixed (Other Recyclable) 1.8% 2.6% 0.3% 1.6% 1.2% 2.1% 3.4% 2.2%Other (Non‐Recyclable) 6.6% 8.0% 12.2% 8.9% 3.1% 7.6% 3.1% 4.6%Paper Subtotal20.3% 14.3% 24.5% 19.7% 53.8% 56.9% 58.6% 56.4%PET Containers 2.4% 1.7% 3.7% 2.6% 4.9% 3.2% 4.1% 4.1%HDPE Containers ‐ Natural 0.3% 0.4% 0.4% 0.3% 0.9% 0.8% 0.5% 0.7%HDPE Containers ‐ Colored 1.3% 0.1% 0.4% 0.6% 0.3% 0.0% 0.8% 0.4%#3 ‐ #7 Containers 0.9% 0.2% 0.2% 0.4% 0.0% 0.1% 0.3% 0.2%Polypropylene 0.1% 1.0% 1.9% 1.0% 0.1% 0.4% 0.9% 0.5%Non Recyclable Plastic 7.5% 7.2% 8.4% 7.7% 4.6% 8.3% 7.8% 6.9%Plastic Subtotal12.4% 10.7% 14.9% 12.7% 10.9% 12.9% 14.4% 12.7%Aluminum Used Beverage Containers 0.6% 0.2% 2.0% 0.9% 1.6% 0.8% 1.2% 1.2%Ferrous Metal Food Containers0.4% 0.7% 0.9% 0.7% 1.9% 1.0% 1.3% 1.4%Other Ferrous Metal 2.5% 0.4% 0.7% 1.2% 0.0% 0.0% 0.4% 0.1%Other Non‐Ferrous Metal 0.3% 0.3% 0.5% 0.3% 0.0% 0.3% 0.0% 0.1%Metals Subtotal3.7% 1.6% 4.2% 3.1% 3.5% 2.1% 3.0% 2.8%Recyclable Glass 5.0% 4.2% 6.6% 5.3% 25.7% 10.3% 10.5% 15.5%Non‐Recyclable Glass 0.7% 0.1% 0.8% 0.5% 0.4% 2.1% 2.8% 1.8%Glass Subtotal5.7% 4.3% 7.5% 5.8% 26.0% 12.5% 13.3% 17.3%Yard Waste 0.0% 0.4% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0%Wood (non‐C&D) 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Food Waste 23.5% 35.2% 30.1% 29.6% 5.5% 1.2% 7.4% 4.7%Other Organics 10.9% 12.1% 8.5% 10.5% 0.1% 0.5% 0.3% 0.3%Organics Subtotal34.4% 47.7% 38.6% 40.2% 5.5% 1.7% 7.6% 5.0%Recyclable C&D0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Other C&D 0.0% 0.0% 0.1% 0.0% 0.0% 4.3% 0.0% 1.4%C&D Subtotal0.0% 0.0% 0.1% 0.0% 0.0% 4.3% 0.0% 1.4%Electronics 0.0% 4.6% 0.0% 1.5% 0.3% 8.9% 3.1% 4.1%HHW 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0%Bulky Waste 13.9% 8.3% 4.4% 8.9% 0.0% 0.0% 0.0% 0.0%Problem Material Subtotal13.9% 13.0% 4.4% 10.4% 0.3% 9.0% 3.1% 4.1%Other Inorganics 5.2% 5.0% 3.7% 4.6% 0.0% 0.0% 0.0% 0.0%Fines 4.4% 3.5% 2.2% 3.4% 0.0% 0.7% 0.0% 0.2%Other Subtotal9.6% 8.5% 5.9% 8.0% 0.0% 0.7% 0.0% 0.2%Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%OtherGarbageRecyclingMaterial Breakdown (%)Material Breakdown (%)PaperPlasticMetalsGlassOrganicsC&DProblem MaterialsBurns & McDonnell
City of DentonCommercial Garbage and Recycling Composition ‐ November 2020Overall Sample No.3‐G 4‐G 5‐G 9‐G 10‐G 14‐G 16‐G 17‐G 3‐R 4‐R 5‐R 9‐R 10‐R 14‐R 16‐R 17‐RGeneratorCommercialMaterial Group MaterialAverageAverageTotal Refuse Samples Sorted8Newsprint 0.0% 0.2% 0.0% 0.2% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Total Recycling Samples Sorted8Recyclable OCC 2.9% 0.8% 0.7% 0.6% 0.2% 2.1% 0.7% 0.0% 1.0% 82.2% 90.3% 22.2% 88.3% 95.6% 76.9% 3.2% 95.8% 69.3%Recyclable E‐Commerce OCC 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 11.5% 0.0% 0.0% 0.0% 0.8% 0.0% 1.5%Pizza Boxes 0.0% 0.2% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Recyclable Material in Refuse12.0%Non‐Recyclable OCC 10.5% 2.1% 0.3% 0.0% 0.0% 1.6% 6.5% 4.0% 3.1% 0.8% 0.0% 0.0% 11.7% 0.0% 5.4% 14.8% 1.9% 4.3%Residue in Recycling Samples21.4%Kraft Paper/paperboard 0.5% 0.9% 2.7% 0.8% 1.6% 0.9% 0.3% 0.0% 1.0% 2.5% 2.0% 1.8% 0.0% 0.0% 0.4% 4.9% 0.7% 1.5%High Grade Office Paper 0.0% 0.2% 18.2% 2.7% 0.5% 0.1% 0.4% 0.0% 2.8% 0.1% 0.0% 13.2% 0.0% 0.0% 0.0% 0.2% 0.0% 1.7%Magazines/ Glossy 0.0% 0.3% 0.7% 0.1% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 5.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.7%Polycoated/ Aseptic Containers 0.1% 0.0% 0.2% 1.1% 0.0% 0.4% 0.0% 0.1% 0.2% 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.3% 0.0% 0.1%Mixed (Other Recyclable) 0.1% 0.5% 1.7% 1.7% 3.9% 0.0% 0.1% 0.2% 1.0% 0.1% 0.0% 6.3% 0.0% 2.6% 0.0% 0.1% 0.0% 1.1%Other (Non‐Recyclable) 8.6% 7.1% 31.4% 8.1% 8.1% 21.7% 7.4% 19.3% 13.9% 0.6% 0.3% 36.7% 0.0% 0.0% 0.7% 18.9% 0.2% 7.2%Paper Subtotal22.7% 12.2% 56.0% 15.4% 14.2% 26.9% 15.3% 23.5% 23.3% 86.7% 92.5% 96.9% 100.0% 98.3% 83.4% 43.3% 98.6% 87.5%PET Containers 1.2% 3.0% 1.4% 0.5% 1.1% 0.3% 1.0% 0.2% 1.1% 0.2% 0.3% 0.8% 0.0% 0.0% 0.1% 1.3% 0.2% 0.4%HDPE Containers ‐ Natural 0.4% 0.6% 0.0% 0.2% 0.3% 0.1% 0.0% 1.5% 0.4% 0.0% 0.0% 0.3% 0.0% 0.0% 0.0% 0.7% 0.4% 0.2%HDPE Containers ‐ Colored 0.1% 0.2% 0.3% 0.2% 0.0% 0.2% 13.0% 0.0% 1.8% 0.3% 0.1% 0.0% 0.0% 0.0% 0.0% 8.2% 0.0% 1.1%#3 ‐ #7 Containers 0.0% 0.3% 1.7% 0.0% 0.2% 0.1% 0.1% 4.3% 0.8% 0.1% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Polypropylene 0.3% 0.3% 0.2% 0.1% 0.2% 0.6% 0.1% 0.0% 0.2% 0.0% 0.0% 0.2% 0.0% 0.0% 0.0% 0.4% 0.2% 0.1%Non Recyclable Plastic 4.7% 11.3% 22.3% 8.9% 51.4% 11.9% 4.2% 15.5% 16.3% 4.6% 0.8% 0.7% 0.0% 1.7% 1.5% 15.2% 0.5% 3.1%Plastic Subtotal6.7% 15.6% 26.0% 10.0% 53.2% 13.2% 18.3% 21.5% 20.6% 5.3% 1.3% 2.0% 0.0% 1.7% 1.6% 25.8% 1.3% 4.9%Aluminum Used Beverage Containers 0.6% 0.3% 0.3% 0.2% 0.1% 0.1% 0.3% 0.1% 0.2% 0.1% 0.1% 0.3% 0.0% 0.0% 0.1% 0.4% 0.1% 0.1%Ferrous Metal Food Containers 0.2% 1.9% 0.7% 0.3% 0.0% 0.4% 0.0% 1.2% 0.6% 0.0% 0.1% 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.1%Other Ferrous Metal 0.1% 0.2% 0.4% 5.2% 0.5% 0.0% 55.9% 0.4% 7.8% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 3.4% 0.0% 0.4%Other Non‐Ferrous Metal 0.0% 0.3% 0.2% 1.0% 0.1% 0.0% 0.5% 0.2% 0.3% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.8% 0.0% 0.1%Metals Subtotal0.9% 2.7% 1.6% 6.7% 0.6% 0.5% 56.7% 2.0% 9.0% 0.3% 0.2% 0.7% 0.0% 0.0% 0.1% 4.6% 0.1% 0.7%Recyclable Glass 1.8% 0.4% 0.9% 0.1% 0.0% 0.4% 0.3% 1.3% 0.6% 0.0% 0.5% 0.4% 0.0% 0.0% 0.4% 0.0% 0.0% 0.2%Non‐Recyclable Glass 0.0% 0.8% 0.0% 0.0% 0.0% 0.0% 0.0% 7.3% 1.0% 0.0% 2.7% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.3%Glass Subtotal1.8% 1.2% 0.9% 0.1% 0.0% 0.4% 0.3% 8.6% 1.7% 0.0% 3.2% 0.4% 0.0% 0.0% 0.4% 0.0% 0.0% 0.5%Yard Waste 0.5% 0.4% 0.0% 36.4% 18.5% 0.0% 0.0% 0.0% 7.0% 0.1% 0.0% 0.0% 0.0% 0.0% 8.1% 0.0% 0.0% 1.0%Wood (non‐C&D) 0.0% 0.0% 0.1% 0.6% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Food Waste 64.1% 61.3% 11.3% 26.1% 5.0% 53.4% 3.2% 34.6% 32.4% 7.4% 2.4% 0.0% 0.0% 0.0% 1.0% 0.1% 0.0% 1.4%Other Organics 1.0% 4.7% 2.6% 0.7% 1.8% 1.2% 0.4% 3.4% 2.0% 0.2% 0.2% 0.0% 0.0% 0.0% 0.0% 3.6% 0.0% 0.5%Organics Subtotal65.6% 66.4% 14.0% 63.8% 25.2% 54.6% 3.6% 38.0% 41.4% 7.7% 2.9% 0.0% 0.0% 0.0% 9.1% 3.7% 0.0% 2.9%Recyclable C&D0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Other C&D 0.6% 0.0% 0.0% 2.1% 0.0% 0.0% 0.0% 0.0% 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 5.5% 0.1% 0.0% 0.7%C&D Subtotal0.6% 0.0% 0.0% 2.1% 0.0% 0.0% 0.0% 0.0% 0.3% 0.0% 0.0% 0.0% 0.0% 0.0% 5.5% 0.1% 0.0% 0.7%Electronics 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 1.9% 0.0% 0.2%HHW 0.0% 0.1% 0.0% 0.0% 6.2% 0.0% 5.8% 0.0% 1.5% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 17.3% 0.0% 2.2%Bulky Waste 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Problem Material Subtotal0.0% 0.1% 0.0% 0.0% 6.2% 0.0% 5.8% 0.0% 1.5% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 19.2%0.0% 2.4%Other Inorganics 0.0% 0.0% 0.0% 0.0% 0.0% 0.1% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%Fines 1.7% 1.7% 1.6% 1.8% 0.6% 4.3% 0.0% 6.4% 2.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3.3% 0.0% 0.4%Other Subtotal1.7% 1.7% 1.6% 1.8% 0.6% 4.5% 0.0% 6.4% 2.3% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 3.3% 0.0% 0.4%Total 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%OtherGarbageRecyclingMaterial Breakdown (%)Material Breakdown (%)PaperPlasticMetalsGlassOrganicsC&DProblem MaterialsBurns & McDonnell
Burns & McDonnell Engineering Company, Inc.
8911 N Capital of Texas Hwy
Building 3, Suite 3100
Austin, TX 78759
(512) 872-7130
www.burnsmcd.com