Residential Trash, Recycling, and Compost Services

A composite of three photos showing 1) compacted recycling materials, 2) trash at the landfill, and 3) processed compost.

Objective

The objective of our audit of the city’s residential trash, recycling, and compost services was to:

  • Assess how efficiently and effectively the city is ensuring timely trash, recycling, and compost service for residents and is reducing illegal dumping in city neighborhoods.
  • Evaluate how effectively the city is achieving its environmental goals and improving recycling rates.

Background

The Solid Waste Management Division provides trash, recycling, and compost pickup for about 180,000 Denver households. The division also responds to illegal dumping.

Our audit work occurred between February and July 2022, as the division sought City Council approval to change residential trash service to a volume-based pricing, or “pay as you throw,” model. In 2023, Denver households will pay for waste disposal based on the size of their trash carts. Recycling and compost will be included at no extra charge.

Why this matters

The Solid Waste Management Division does not serve residents efficiently and effectively at current service levels. Its trucks are aging, it is understaffed, and it does not have enough plans, policies, and resources to support its workload.

Therefore, it is ill-prepared to expand to a “pay as you throw” pricing model in 2023, which will put more demands on division staff. The division risks providing worse service to Denver residents, and the city also risks failing to achieve goals meant to address climate change.

Findings

FINDING 1 – The Solid Waste Management Division Lacks Strategic Direction and Quality Data to Inform How It Provides Services to Residents

The division does not have up-to-date strategic plans and written policies and procedures to support efficient and effective service to Denver residents.

The division cannot demonstrate how it changed service routes and pickup schedules in early 2022 — a change that was associated with a spike in resident reports of missed service. The division also uses flawed data to measure how well it responds to service requests.

FINDING 2 – The Solid Waste Management Division Has Insufficient Resources to Collect Residential Waste, Respond to Illegal Dumping, and Support Its Other Work

The division has unreliable and costly older trucks, with no systematic plan to replace them. Driver vacancies increased in 2020, the first year of the COVID-19 pandemic. The shortage has continued, even as the city will need to hire more drivers in 2023. Meanwhile, the division lacks enough inspectors and support staff to address improper recycling and composting and teach the public about correct practices.

Already these issues are resulting in unfinished routes, missed pickups, and other service-delivery issues.

FINDING 3 – The City Is Inadequately Prepared for Its New Volume-Based Pricing Program, which May Worsen Existing Service-Delivery Issues for Residents

Officials did not follow leading practices to design the program with informed knowledge about how prepared the city is to expand recycling and compost services. They received minimal input from residents, and officials cannot say whether they might have to raise fees to ensure the program is self-sustaining as they intend.

Recommendations

1.1 Create a Strategic Plan — The Solid Waste Management Division should develop a strategic plan that identifies specific objectives, goals, and needs of the division with particular focus on its role to deliver services to residents.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.2 Develop Internal Controls – The Solid Waste Management Division should develop an internal control framework that includes a comprehensive set of detailed and documented policies and procedures at both the system and operational levels. Such policies and procedures should include, at a minimum: level-of-service policies, route policies, and cost-accounting policies.

Agency Response: Agree, Implementation Date – Dec. 31, 2023

1.3 Create and Maintain Documentation of Route Design Process – The Solid Waste Management Division should follow guidance from the Environmental Protection Agency and develop a standard process for routinely reviewing route efficiency. This should include documenting the data the division uses and the steps it takes to develop new route designs based on its review process.

Agency Response: Agree, Implementation Date – May 31, 2023

1.4 Establish Consistent Data-Tracking – The Department of Transportation & Infrastructure should coordinate guidance and training across all customer service teams and systems — including Denver’s 311 program, Denver Utilities Online, and PocketGov — to establish consistent data-entry and case management practices and ensure performance dashboards report accurate, reliable data for informed decision-making.

Agency Response: Agree, Implementation Date – Sept. 30, 2023

2.1 Develop a Fleet Replacement Schedule – The Solid Waste Management Division should work with the Department of Finance and the Fleet Management Division to develop a documented fleet replacement schedule that ensures long-term fleet reliability and regular, staggered replacement of aged trucks to ensure efficient delivery of waste collection services. Once it develops this schedule, Solid Waste Management should develop and implement procedures to follow it — including monitoring and oversight.

Agency Response: Agree, Implementation Date – June 30, 2023

2.2 Conduct Staffing Analysis – The Solid Waste Management Division should determine how many drivers, inspectors, and program support staff it needs to ensure continuity of operations and provide the additional services required by the city’s new volume-based pricing model. Such an analysis should consider:

  • How many staff are needed to complete all routes as scheduled.
  • How many inspectors are needed to provide adequate coverage for all areas of the city.
  • How many staff or contractors are needed to replace the efforts of staff who were transferred to the Office of Climate Action, Sustainability, and Resiliency in 2020 and to cover expanded service needs for education and outreach under volume-based pricing.

Agency Response: Agree, Implementation Date – Dec. 31, 2022

2.3 Document Job Duties – After implementing Recommendation 2.2, the Solid Waste Management Division should define and document roles and responsibilities for inspectors and program support staff related to addressing cart contamination and responding to illegal dumping.

Agency Response: Agree, Implementation Date – Dec. 31, 2022

2.4 Create Memoranda of Understanding – If the Solid Waste Management Division will rely on other city agencies or third-party contractors to provide program support for education and outreach related to the volume-based pricing program, the division should draft memoranda of understanding or otherwise document such agreements to define the roles and responsibilities to be carried out by such partners.

Agency Response: Agree, Implementation Date – Dec. 31, 2022

3.1 Conduct Annual Performance Review – Within the first year of the volume-based pricing program, the Solid Waste Management Division should plan, document, and implement processes to regularly review the division’s performance for service delivery and how well it is increasing waste diversion behaviors of the Denver households it serves.

Such review processes may include a cost-of-service rate analysis, a resident satisfaction and service preference survey, and an environmental cost analysis. The division should complete such reviews in the second year of program operations, which will help position the division to meet the program reporting requirement defined in city ordinance.

Agency Response: Agree, Implementation Date – Sept. 30, 2023

Auditor's Letter

November 17, 2022

We audited residential trash, recycling, and compost services provided by the Solid Waste Management Division of the Department of Transportation & Infrastructure. We assessed how well the city is ensuring timely service for residents and reducing illegal dumping in city neighborhoods. We also evaluated whether the city is achieving its environmental goals and improving recycling rates. I now present the results of this audit.

The audit found the Solid Waste Management Division lacks strategic guidance and quality data, has an aging fleet of waste collection trucks, and does not have enough staff for its current operations. Meanwhile, the department is about to switch to a volume-based pricing, or “pay as you throw,” program in 2023 — where residents will pay for trash collection based on the size of their cart, with weekly recycling and compost service included. We found this new program was not effectively designed to ensure stable funding or to advance the city’s environmental goals, and it may worsen existing service-delivery issues for residents.

By implementing recommendations for stronger policies, plans, and progress monitoring, the Department of Transportation & Infrastructure will be better able to provide reliable waste collection services to residents, address illegal dumping, and contribute to the success of the city’s environmental goals.

This performance audit is authorized pursuant to the City and County of Denver Charter, Article V, Part 2, Section 1, “General Powers and Duties of Auditor.” We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

We appreciate the leaders and team members in the Department of Transportation & Infrastructure who shared their time and knowledge with us during the audit. Please contact me at 720-913-5000 with any questions.

Denver Auditor

Auditor's Signature
Timothy O'Brien, CPA

 


 

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AUDITOR TIMOTHY O'BRIEN, CPA
Denver Auditor



Denver Auditor´s Office

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