National Solid Wastes Management Association 6210 Campbell Road, S-200, Dallas, TX 75248 214-368-0909 Phone 214-692-5959 Fax

September 9 2011 Honorable Mayor Mike Rawlings City of Dallas 1500 Marilla Street Dallas, Texas 75201 Dear Mayor Rawlings:

VIA FAX TO:

214-670-0646

We appreciate your offer to meet with us again to discuss the detailed statistics we provided you concerning the negative financial impact flow control would have on our 16,800 Dallas customers. Briefings to the Dallas City Council continue to materially misrepresent key issues that will lead to the $19 million in cost increases our analysis has projected.

Issue
190 haulers will compete for the business preventing a price increase

Facts
There are not 190 franchised haulers competing for our business. Four competitors currently serve 77% of the market. The high barriers to entry in our industry ($500,000 or more per route) will not generate more competition. The inefficiencies and higher costs created by flow control will actually drive smaller companies out of the market. Staff has consistently failed to mention they will charge $35 a ton at the transfer station (a 94% increase in current disposal cost) to cover the citys additional costs. It is unlikely any haulers will use the transfer station at that price. No one has addressed very limited operating hours at either Bachman or McCommas. The Roseville facility cost $100 million and charges $68 per ton for a tipping fee. It would take four of these plants to handle the material coming into the landfill now. Roseville has a credible recycling rate of 31.91% of municipal solid waste. They also collect waste differently (source separated green waste, bottle deposit bill etc.) Even if the city could recycle 90% of what comes into the landfill now it would still be left with 140,000 tons of material to dispose of in the landfill. There is a landfill next to the Roseville plant where the remaining 68.1% of the municipal solid waste processed is still buried.

The Bachman transfer station will reduce mileage to the landfill

TheRoseville, California Materials Recycling Facility would be a good fit for Dallas

The city will eventually eliminate landfills

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But the most important issue remains the ghost tax. It has been frustrating to present detailed financial information with backup from local and national firms only to hear that the city staff doesnt agree with the numbers. Despite the fact that this discussion has been going on since 2010 the staff has yet to provide any specifics beyond their unsupported and self-serving opinions. We are asking for another meeting with you, council leadership and city staff if necessary, to go over the information that you requested and provide any additional insight that would be helpful. We understand that you have taken the position that you would not support flow control if it will create a hidden tax on businesses. The city staffs own presentation indicated that the costs for some businesses will increase under flow control. We can demonstrate that these increases will occur citywide. Finally, we would like to discuss and recommend other ways of creating an economic development fund for Southern Dallas. We believe there are many alternatives that would allow the city to operate more efficiently and provide real economic opportunities in the community. The Roseville MRF does create jobs but they are almost all for people who will be sorting garbage. We can do better. We will be contacting your office to set up another meeting. Sincerely,

Tom Brown Texas President National Solid Wastes Management Association