August 11, 2015

Mayor Michael B. Hancock and  Members of Denver City Council

Scott Gilmore, Acting Executive Director, Denver Parks and Recreation

Members of the Parks Advisory Board

City and County of Denver

Re: Resolution on Denver Zoo Incinerator

Dear Mayor Hancock, Members of City Council, Mr. Gilmore and the Parks & Recreation Advisory Board:

Inter-Neighborhood Cooperation, Denver’s association of Registered Neighborhood Organizations (RNOs) from neighborhoods throughout Denver is celebrating its 40th Anniversary this year. Founded in 1975, INC’s mission is to advocate for Denver citizens by bringing together, informing and empowering Denver neighborhood organizations to actively engage in addressing city issues.

On December 15, 2014, Denver City Council approved CB14-0941, a bill for an ordinance that granted a certificate of designation to the Denver Zoological Foundation, Inc. to operate a waste-to-energy system at the Denver Zoo. Since that time, a great deal of information relating to “biomass incineration” processes has been learned from national and world-wide sources.

Questions have been raised regarding public health and safety as to how this information relates to the operation of the Denver Zoo’s waste-to-energy system. The Denver Zoo and the Denver Zoo Foundation, however, have not been forthcoming with answers to these questions.

Section 7 of the above referenced Ordinance, provides that City Council can reconsider its approval of the certificate of designation through a public hearing process. It is the official position of INC that the serious nature of the concerns regarding placing an incinerator in the heart of the City, in the middle of a zoo with thousands of animals including some that are endangered, in the middle of Denver’s premier park, surrounded by well established residential neighborhoods calls for extraordinary diligence on the part of Council and the Mayor.

Upon recommendation of the INC Parks and Recreation Committee INC Delegation voted unanimously at the August 8, 2015 monthly meeting to approve the following Resolution. The vote was 26 in favor, no opposed and no abstaining.

INC Resolution on City Park Solid Waste Incinerator

WHEREAS, City Park, in which are located the Denver Zoo and the Denver Museum of Nature and Science, is important as a regional park hosting more than an estimated, 3,400,000 visitors per year, as the neighborhood park for the Denver citizens living in its heavily populated adjoining neighborhoods, as home to a variety of wildlife including numerous species of birds and wild animals and as location of the Zoo which houses rare and exotic species, some of which are endangered, and

WHEREAS, the City of Denver’s, City Council issued a a Certificate of Operation s/b Certificate of Designation in December, 2014 authorizing the Denver Zoo to burn solid waste at an incineration plant defined by the Environmental Protection Agency as an “Other Solid Waste Incinerator” (OSWI) inside City Park, and

WHEREAS, in March, 2014, without public notice, the Executive Director of Denver Parks & Recreation sanctioned the burning of waste within City Park, an area zoned as open space (OS-A Zone District), by declaring incineration of animal waste, zoo trash and park waste a valid“park use.”, and

WHEREAS, The Denver Zoo’s OSWI Incinerator plant is an industrial use deemed not suitable in other cities and counties, including but not limited to Ada County, Idaho, Green Bay, Wisconsin, Cleveland, Ohio, Fredericksburg, Virginia and , New York City or at other zoos or in areas zoned as Residential or Open Space, such as City Park and its surrounding neighborhoods, and

WHEREAS, Denver citizens and City Park’s neighbors, who rely on the park’s green space areas for recreation, fitness, and enjoyment, have not been fully informed and included in a decision that affects the park and its visitors and that may place their neighborhoods and City Park at risk, and

WHEREAS, The Denver Zoo’s OSWI Incinerator is a unique design, never before built or operated and there are numerous concerns and questions about the safety of the incinerator and its health effects on people, children and animals, and

WHEREAS, the Denver Zoo, its Foundation, and the City and County of Denver have not released technical and operational characteristics of the Denver Zoo’s OSWI Incinerator, public information or evidence that analyses have been conducted regarding the plant’s emissions or waste by-products nor are they willing to answer concerns and questions raised by the community,

THEREFORE, BE IT RESOLVED that Inter-Neighborhood Cooperation calls upon

1.) the Denver Zoo to document relevant, substantive technical and operational details of its OSWI Incinerator and release this information to the public, and 

2.) the Denver City Council to conduct a substantive and technical review of the Zoo’s OSWI Incinerator plant through hearings before its designated Infrastructure and Culture Committee, and when necessary, using its full subpoena powers, taking testimony from Denver Zoo Foundation administrators, engineers, scientists, environmental experts including qualified and credible third parties along with representation from environmental justice groups, Registered Neighborhood Organizations and City Park neighbors to determine the safety and health risks posed by the use of the incinerator, before it be allowed to proceed and to operate.

Thank you for your attention and consideration of this important public policy and public safety issue.

Respectfully submitted by:

Larry Ambrose

President, INC