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HomeMy WebLinkAboutItem 1 - Agenda 05-05-2004MEMORANDUM To: John Link, County Manager From: Gayle Wilson, Solid Waste Management Director Subject: Report - Waste Reduction, Reuse, and Recycling Fee Recommendations Date: April 13, 2004 This memorandum presents the culmination of the staff 10 -year financial analysis of the Orange County solid waste management enterprise fund and provides information on: • current and future anticipated expenditures /revenues, • projected revenue shortfall, • a proposed reduction, reuse and recycling collections fee structure that would provide supplemental income to the. fund and eliminate the projected revenue shortfall relative to recycling services, • highlight the many assumptions necessary to conduct such a financial/fee analysis, • other related issues, and • proposed schedule /timeline /process Staff requests that the Board of County Commissioners review the analysis, examine the assumptions, consider the staff recommendation, and provide feedback to staff as necessary in order that the supplemental financing process may continue toward a final decision that would allow a fee to be included on the 2004 property tax bills. Background Discussions of the need to provide supplemental financing to the solid waste enterprise fund have been taking place since at least 1993, when the Landfill Owners Group conducted its initial discussion of the topic. In 1996, once it was acknowledged. that Orange County would be unable to successfully site a new Mixed Solid Waste (MSW) landfill, discussions began again. Prior to 1996 it was generally understood that a new in- county landfill would generate surplus revenue that could substantially fund recycling and waste reduction programs indefinitely. In 1998 an Alternative Finance Committee was formed to consider the issue of how to provide additional revenue to the solid waste enterprise fund. This Committee was comprised of Managers, Finance Directors, Elected Officials, and a county citizen. While the Committee held numerous meetings, conducted substantive discussions, and thoroughly examined the issue, it did not complete its work or issue a finial report, as the member governments' focus at the time shifted to resolving matters related to shifting primary solid waste management responsibility to Orange County. In 2001 the BOCC requested that the Solid Waste Advisory Board take up the issue and offer recommendations to the BOCC. On January 27, 2003, staff presented a preliminary estimate of per household (phh) fees that would be necessary to completely fund recycling in each of those sectors: Urban Curbside - $64.50 Rural Curbside - $46.00 Multi- Family - $34.00 At that time, the Basic Services Fee (previously referred to as a Universal Services Fee) component that would fund the drop -off sites, hazardous waste collection, public education and supporting services had not been completed. In February 2003, the SWAB presented alternative financing recommendations to the BOCC that included a prepaid tipping fee component, making comparisons of those fee estimates with current fee recommendations irrelevant. The prepaid tipping fee would have had the effect of eliminating landfill fees and ensuring long -term stability and predictability of the overall solid waste enterprise fund. Following the discussion last winter /spring, staff have had the opportunity to further consider the various issues raised, have conducted ongoing discussions with the SWAB, have received informal Commissioners' feedback, communicated with the County staff that will have billing and collection responsibilities, and spoken with the Manager and various citizens on the subject. Based on this continuing deliberation staff prepared and presented a preliminary proposal regarding a fee assessment methodology to the BOCC on November 10, 2003. At that meeting the BOCC agreed in principal with the staff approach and directed that the' analysis be completed and a formal proposal be brought back to the BOCC for consideration. While no specific fees were presented at the November 2003 meeting because the analysis was not complete at that time, staff s rough estimate of the possible magnitude of the fees was in the neighborhood of $45 /phh. Staff's understanding of the Board's direction from the November 2003 work session included: • It would be a fee rather than a tax. • It would be assessed on all improved properties, including tax - exempt, residential, non - residential. •. It would be billed on the tax bill, beginning in 2004, but identified as a Waste Reduction, Reuse, and Recycling Fee. • The fee would not be assessed to the University. • Philosophically, the intent is that you will pay for the services you receive, that are available to you, or that are performed on your behalf. • There would be four categories of fees: 2 • Basic Services Fee (B) — services provided to or on behalf of everyone. Examples are HHW, electronics, drop -off site services, food waste and other recycling administration/education. • Rural Curbside Services (R) — Those who receive or have available biweekly curbside recycling collection in the unincorporated areas. • Urban Curbside Services (U) — Those who receive or have available weekly curbside recycling collection in the incorporated areas. • Multi - Family Services (M) — Those who receive or have available apartment /condominium type recycling services. • All improved properties would receive the B fee. Those properties that also fall into one of the other three categories would also receive that fee. Some properties would only receive the B fee. • The University is excluded from fees due to their having their own comprehensive recycling program and their paying a disposal tipping fee of which a significant portion is used to fund local recycling services /programs that they receive no benefits from • In FY 2004/05 the non - residential sector would only pay the B fee. Due to the significant variety of commercial establishments staff proposes to conduct further analysis and offer a refinement of fees for FY 2005/06 or later. • Upon the BOCC final decision regarding the fee staff will initiate a broad -based public education and outreach program to explain the need for supplemental financing and the new fee system. The outreach efforts would begin immediately upon the BOCC reaching a decision on the fee. It would include at least the following: • Local media editorial briefing, • Articles in local news media, • Availability of staff to conduct radio interviews or presentations, • Providing information to Orange County employees, • Press releases to local media, • Paid advertising, • Meeting with Town Managers to explain fee structure /policies, • Coordination with Revenue Collection Department regarding all information released • Additional staff person in Revenue Collection Department specifically assigned to VVRRR Fee issue, and • Insert in tax bills to explain fee Note: According to Revenue Collection /Tax Assessor staff a final fee decision in April (consistent with the BOCC 's November 10 agreement in principal) would allow the billing to proceed with a higher degree of accuracy and without unnecessarily delaying tax billing. If the BOCC's final supplemental financing decision features another 3 approach that radically alters base assumptions of the current financing framework, or is unduly delayed, administrative planning for billing may not be completed in time for the normal billing cycle. The Environmental Finance Center of the Institute of Government (EFC) at UNC has been providing county staff assistance over the past several months in developing the financial database used in the analysis and offering general financial information and guidance. The specialized financial- assistance provided by the EFC has been invaluable in our efforts to provide accurate and reliable financial information and policy advice to the BOCC. The EFC's expertise in governmental financing has resulted in several recommendations regarding financial assumptions and responsible financial management practices for enterprise funds. Statement of Problem The solid waste management enterprise fund will be unable to continue providing the same level of service in FY 2004/05 as is now provided without major financial decisions that provide additional revenue. It should be noted that no state or general fund appropriations are provided to fund recycling, nor waste reduction activities within the enterprise fund, with the exception of state reimbursements of an advance disposal fee for white goods and scrap tires and some small grants received on a competitive basis. Reimbursements for scrap tires and white goods only partially fund those programs. The proposed fee will provide the funding necessary to fund the current and future shortfall in revenue caused primarily by: • the success of local waste reduction programs in reducing waste being disposed, resulting in corresponding reductions. in tipping fee revenue that has historically funded solid waste programs /services, • investments in recycling and waste reduction programs whose recovered materials market value is significantly inadequate to pay for those recycling and waste reduction programs /services, and • Orange County tipping fees are higher than other regional disposal options Figure 1 represents an illustration of the projected county recycling expenditures and revenues over the next nine years, which forms the basis for the need for supplemental income for these financially non - sustainable programs /services. Figure 1 Cost and Revenue of Recycling 6,000,000 5,000,000 4,000,000 U) c 3,000,000 0 2,000,000 1,000,000 0 2004/2005 2005/2006 2006/2007 2007/2008 2008/2009 2009/2010 2010/2011 2011/2012 2012/2013 Year Revenue Cost Most other counties already utilize (many for several years) some type of availability or other fee to fund solid waste services. e lists examples of fees existing in other jurisdictions. This list is not a comprehensive statewide inventory of supplemental solid waste fees, but only a sampling. Fee Recommendations (FY 2004/05) Basic Services (B) Fee = $36 /per each improved property unit, regardless of location in the county or tax status (exempt or not) Urban Curbside Services (U) Fee = $39 /improved property unit within urban services area (We note a duplex would receive two fees as each side of the duplex is eligible for individual curbside recycling services) Rural Curbside Services (R) Fee = $16 /improved property unit within rural services area 5 Multi- family Services Fee = $14 /improved property unit with multi - family services available at each apartment dwelling unit, occupied or not. Mobile home parks are proposed to be billed for each mobile home occupying a lot, not for unoccupied lots as declared by the park owner in the required annual statement to Orange County. Each improved property unit will receive the $36 (B) fee. Those improved property units within one of the other three service areas will also receive a second fee that is additive to the. (B) fee._ Note: Due to .a projected surplus of tipping fee revenue over landfill operating expenses for the next five years, staff believes it possible to maintain the above fee structure for five years without adjustment. In FY 2009110 the tipping fee revenue surpluses will no longer be available and significant fee increases will be likely. Statement of Assumptions The following is a compilation of fundamental assumptions related to the 10 -Year financial analysis of the solid waste enterprise fund and calculations of anticipated revenue shortfall. The assumptions are organized in the following categories: General Revenues Expenditures Reserves Programs /Services Fee Customer Classes Fee Calculations GENERAL AS SUMPTIONS • Supplemental financing is essential for FY 2004/05 in order to continue existing services /programs. • 10 -Year Plan Financial Analysis corresponds to 10 -Year Solid Waste Management Plan submitted to State, with year 1 being 2003/04. • Fee will be transmitted on the annual property tax bill, listed separately as a Waste Reduction, Reuse, and Recycling Fee. • The Waste Reduction, Reuse, and Recycling Fee (WRRRF) will be adopted in conjunction with the FY 2004/05 budget process and included on the 2004 tax bills mailed in July /August 2004. • County Public Works Sanitation Division operations /estimates of revenue or expenditures are not included in the WRRRF model. • A WRRRF appeal process will be established as part of a schedule of values to efficiently address citizen billing questions /problems. • For reference, the average property tax bill for a Chapel Hill resident is $4,336.50. The proposed $75 fee (B plus U) represents 1.7 percent of that average tax bill. The :1 6 e property tax bill of a resident of unincorporated Orange County is $2,447. averag p p y � The proposed $52 fee (B plus R) represents 2.1 percent of that average tax bill. REVENUE ASSUMPTIONS • UNC will continue to deliver MSW to the Landfill • MSW tonnage will escalate at 1.7% annually • C &D tonnage will escalate at 1% annually • Recycling revenue estimates based on the continued operation of the existing sorting pad, and its projected 2008 relocation • Reimbursement for the jointly owned portion of the Green Tract assumed to be received beginning FY 2004/05 over a four year period • No assumption made regarding reimbursement for 60 acre County owned portion of Green Tract • Franchising private company MSW haulers is not assumed, however, it could represent an additional $250,000 annually in tipping fee revenue and an estimated reduction in the Basic Services Fee (if fully applied there) of approximately $4.50 /phh • Tipping fees, fund balance and recycling revenues will continue to be utilized to the extent practicable, with WRRRF financing only a portion of the projected shortfall of revenue used to fund recycling collection, reduction and reuse functions • Recycling revenue estimates based on reasonably conservative material market values • Tipping Fee Assumptions $$ /ton: EXPENDITURE ASSUMPTIONS • Administrative expenses are split evenly between recycling and disposal and include administrative staff, education and outreach programs, utilities, financial management and planning, clerical, telephone services, and related functions. Staff analysis VA MSW C &D Veg. /Clean Wood 04/05 45 41 15 05/06 46 41 15 06/07 47 41 17 07/08 48 41 17 08/09 49 43 17 09/10 50 43 19 10 /11 51 43 19 11/12 52 43 19 12/13 53 43 19 EXPENDITURE ASSUMPTIONS • Administrative expenses are split evenly between recycling and disposal and include administrative staff, education and outreach programs, utilities, financial management and planning, clerical, telephone services, and related functions. Staff analysis VA 8 showed that this split reasonably reflects an accurate allocation of administrative staff time between the two functions. • Debt financing of land improvement /acquisition (Transfer Station, C &D Resale Store, Administration Office Building, land acquisition, Relocation of Processing Pad, Closure) is assumed at 6 percent. • Debt financing of future equipment and vehicles is not a fundamental assumption (beyond the equipment debt already being financed), however; based on level of reserve balance and favorableness of loan rates, various equipment may be periodically debt financed. • Analysis assumes and has incorporated new costs associated with implementation of the WRRRF such as a new (time- limited) position in Tax Collection that will serve as administrative support for the WRRRF program. • A Gantt chart a = �n ffl) is provided to indicate schedule of key new expenditures over the planning period. RESERVES ASSUMPTIONS • Fund Balance (undesignated) is estimated to be maintained at a minimum 14 percent • Equipment reserve fund for both disposal and recycling is assumed to be established as a restricted fund to finance capital equipment and vehicles purchases and to minimize variability in revenue requirements • Projected existing June 30, 2004 fund balance of $1,963,201 is to be applied toward maintenance of minimum 14 percent fund balance for entire fund (including recycling division), reestablishment of landfill equipment reserve fund, and subsidizing recycling fees for five years • No landfill closure reserve fund is proposed or included in any expenditure estimates PROGRAMS /SERVICES ASSUMPTIONS • No assumptions are made regarding new emergency storm debris management facilities /services • C &D recycling functions are integrated into disposal operations and are not included in recycling expenditure /revenue estimates; these recycling activities are not funded by recycling fees • No additional materials are assumed to be added to existing recyclable materials presently collected during the 10 -year planning period, with the exception of batteries at curbside and drywall • A Materials Recovery Facility (MRF)and its attendant program expansions are not included in this 10 -Year Plan — Recycling program expansions have been minimized in response to elimination of expanded processing capabilities • Minimal program expansions are assumed in the financial plan including: • 500 homes /year plus in -fill for existing routes added to rural curbside program • in -fill development and annexations only in urban curbside program • 2 sites added in FY 04/05 and no additional expansions for food waste program • no net expansions of the restaurant and bar glass program C • approximately 100 new multi - family units on -line annually • development of Hampton Pointe and Southern Village drop -off recycling centers CUSTOMER CLASS FEE ASSUMPTIONS • Assumes four categories of fee recipients: • Basic Services Fee(B) — Imposed on all improved property except that owned by UNC that does not receive recycling services • Portion of Mebane located in Orange County will only receive (B) fee • Portion of Chapel Hill in Durham County will receive (B) and U or M fee as appropriate • Each commercial improved property, regardless of size or intensity of use, will receive the same (B) fee until such a time as a more equitable fee structure can be developed, estimated 2 -3 years • An improved residential property with more than, one home will receive the assessment on each habitable residential unit (i.e. property with one primary home with two mobile homes on the same property will result in property owner receiving 3X fee) • Sororities/Fraternities and Elderly Assisted Living —.4 persons = 1 unit for billing purposes • Granville Towers —13 students = 1 unit for billing services • Tax- exempt/public housing/land trusts —1 unit = 1 unit for billing purposes • Carol Woods —1 unit = 1 unit for billing purposes • Personal Property (single -wide mobile homes) —1 unit each for billing purposes. Where single -wide mobile homes are located in mobile home parks, the park owner shall receive the bill for all homes in the park, as no locations for mobile homes are yet designated for personal property tax bills. It will be the responsibility of the mobile home park owner to pay the bill and distribute the costs accordingly. • Urban Curbside (U) Fee — Imposed on those residences in the incorporated areas of the county that have curbside recycling services available; property owner will receive a fee for each residential unit on property • Rural Curbside (R) Fee — Imposed on those residences in the unincorporated areas of the county that have rural curbside recycling services available; property owner will receive a fee for each residential unit on property • Multi- family Fee — Imposed on those residences, including both incorporated and unincorporated areas that have multi - family services available; property owner will receive fee for each residential unit on property Special multi - family assessments are: • Sororities/Fraternities and Elderly Assisted Living (not nursing homes) — 4 persons = 1 unit for billing purposes • Granville Towers —13 students = 1 unit for billing purposes • Tax - exempt/public housing/land trusts —1 unit = 1 unit for billing purposes • Carol Woods —1 unit = 1 unit for billing purposes E r2 • Personal Property (single -wide mobile homes) — 1 unit each for billing purposes (except for those outside mobile home parks and outside areas receiving rural curbside service) FEE CALCULATION ASSUMPTIONS • Objective is to maintain rates unchanged for five years • 88 percent recovery rate assumed for collections (due to lack of statutory authority to collect as taxes) • Fee is calculated by dividing each category's revenue shortfall amount by # of units in customer class • Staff will continue service area assessments /data base computations in order to refine the number of units used for calculating fees in each service category, so the actual number of units to be billed (billing database) will continue to be perfected until the time of billing provides a summary of the comprehensive �, financial analysis and illustrates projected revenues /expenditures by program LEGAL AS SUMPTIONS • That the WRRR Fee will be structured so that legal collection options will be maximized, however, WRRRF do not have the same collection options -as those available for the collection of taxes or availability fees • The County- Attorney has included a letter that further discusses the legal issues related to the proposed fee aff a. Key Issues • .Billing will likely generate increased demand for services that will be unable to be met immediately. If fee generates income over what is necessary, additional revenue could be used to expand services beyond those modest expansions already assumed. • Difficulty in maintaining ongoing estimates of separate programs because of trend to integrate (Drop -Off Site, MF, Rural Curb., etc.) services for efficiency. • Current solid waste programs and services are based on street address at point of service. Tax billing database based on property identification numbers. Significant effort underway to convert physical addresses to PIN numbers. Additionally, many tax - exempt properties do not have assigned PIN numbers or are missing other key information such as whether it's improved, etc. • Tax Assessor recommends that m order for the 2004 tax bills to be distributed on time, that the BOCC make a final decision on the WRRRF by early to mid April, assuming only minor modifications to staff assumptions. In order for the bills to be distributed on time (first week in August), the billing database needs to be finalized 10 before May 30. Depending on the scope of possible modifications of various assumptions by the BOCC and progress toward completion of the development of the billing database, tax bill distribution may be delayed or billings may be made less accurate Interlocal Agreement Obligations The Interlocal Agreement allows Orange County considerable flexibility and discretion regarding system financing. The section of the agreement titled "Other Fees" seems to apply to the WRRRF proposal. Staff provides a summary of how this section of the Interlocal Agreement may apply as follows: • County must give the parties at least 30 days notice of the effective date of the proposed fee • County must request that the SWAB consider the proposed fee and, if the SWAB approves the fee, then the fee will be considered fully approved when the BOCC subsequently approves it • If the SWAB disapproves of the fee, then the fee may take effect only if the County and at least one other Party subsequently approves it • The fee will take effect at the end of the notice period, or, if later, the date of the last Governing Body approval necessary Next Steps BOCC to review recommendation and provide addition guidance and direction to staff regarding fee recommendation and assumptions. Staff from Land Records, Tax Collection, Tax Assessor, County Attorney, Information Systems and Solid Waste will continue to: • prepare and refine the billing database and reconciling PIN numbers with service area addresses for each of the service sectors • work out necessary policies /practices regarding collection for non - payment • develop detailed schedule of values relative to who /what /when/how fee assessments are determined and applied • consider how the tax bill document can be modified to plainly list the fee along with a possible insert explaining the fee • examine the process for inclusion the portion of Chapel Hill falling within Durham County • develop an appeals process to consider citizen complaints /inquiries • consider other legal issues as necessary • Following BOCC endorsement of the staff recommendation, to initiate a comprehensive public education and outreach campaign Staff is available to answer questions or discuss any aspect of the recommendation. 11 Revenue Requirement # Units WRRR Fee Total Fee Revenue Difference Revenue Requirement # Units . WRRR Fee Total Fee Revenue Difference Rural Revenue Requirement # Units WRRR Fee Total Fee Revenue Difference Revenue Requirement # Units WRRR Fee Total Fee Revenue Difference Disposal Surplus /Deficit June 30, 2004 Total Undesignated Fund Balance Available Recycling Subsidy Need Undesignated Fund Balance Total Minimum Undesignated Fund Balance Shortfall Total Disposal Shortfall Financial Summary Analysis 04105 05/06 06107 2,057,486 60,208 36 2,167,488 - 110,002 07108 2,123,124 61,412 36 2,210,832 +87,708 08/09 2,348,292 62,640 36 2,255,040 - 93,252 09/10 2,442,184 63,893 38.22 2,255,040 0 10111 2,512,962 65,171 39 2,512,962 0 11/12 2,589,927 66,474 39 2,589,927 0 12113 2,636,751 67,803 39 2,636,751 0 2,148,918 57,870 36 2,0831320 - 65,598 2,185,101 59,027 36 2,124,972 - 60,129 980,386 16,500 39 643,500 - 336,886 1,048,854 16,960 39 661,440 - 387,414 1,117,244 17,420 39 679,380 - 437,864 1,189,244 17,880 39 697,320 - 491,924 1,264,089 18,340 39 715,260 - 548,829 1,342,805 18,800 71.43 715,260 0 1,424,636 19,260 73.97 1,424,636 0 1,510,174 19,720 76.58 1,510,174 0 1,599,569 20,180 79.27 1,599,569 0 353,111 10,900 16 174,400 - 178,711 417,262 11,760 16 188,160 - 229,102 456,551 12,620 16 201,920 - 254,631 498,278 13,480 16 215,680 - 282,598 556,339 14,340 16 229,440 - 326,899 603,476 15,200 39.70 603,476 0 652,474 16,060 40.63 652,474 0 702,567 16,920 41.52 702,567 0 755,108 17,780 42.47 755,108 0 6 357,342 13,500 14 189,000 - 168,342 372,990 13,600 14 190,400 - 182,590 383,635 13,700 14 191,800 - 191,835 353,792 13,800 14 193,200 - 160,592 268,050 13,900 14 194,600 - 73,450 220,549 14,000 15.75 220,549 0 358,049 14,100 25.39 358,049 0 402,825 14,200 28.37 402,825 0 417,143 14,300 29.17 417,143 0 +443,218 1,963,201 2,406,419 - 749,537 1,656,882 31%. +617,607 1,656,882 2,274,489 - 859,235 1,41 5,254 25% +1,075,492 1,415,254 2,490,746 - 994,332 1,496,414 25% +561,720 1,496,414 2,058,134 - 847,406 1,210,728 18.8% +1,662,422 1,210,728 2,873,150 - 1,042,430 1,830,720 28.6% - 1,258,186 1,839,720 581,534 0 581,534 14% - 1,203,658 581,534 - 622,124 0 0 14% - 806,578 0 - 806,578 0 0 14% - 921,185 0 - 921,185 0 0 14% - 682,376 - 1,299,083 - 1,349,542 - 1,404,081 - 682,376 - 1,921,207 - 2,156,120 - 2,325,266 Fee Summary Sheet 3 04.xls03/30/2004 Solid Waste Management 10 Year Plan New or Expanded Capital /Personnel Administration and Landfill Operations Budget Cost 2004 -05 2005 -06 2006 -07 2007 -08 2008 -09 2009 -10 2010 -11 2011 -12 2012 -13 Administration Construction of Admin Building $660,000 (Payments begin for 10 Years @ $89,672) $89,672 ` } New SW Telephone System $55,000 $55,000 Additional Personnel Office Asst II (Part-Time) $15,0001Yr A a,F _ Additional Position in Revenue Coll/Tax Assessment Dept $46,6601Yr. - NAWA � MSW Install leachate sewer line $155,000 $155,000 n Land Acq. Adjacent Property for Potential Mitigation Activities $150,000 (Payments begin for 5 years @$35,609/yr) $35,609/Yr. `0� '`',''r.j= Asphalt Northside to C &D $175,000 $175,000 Last Year of Active Landfill* NA Switch to Transfer Station July 09 N/A Add 1/2 FTE to Monitor Landfill Site $29,9591Yr Transfer Station Transfer Station Design & Permitting $265,000 - Equipment Purchase 2 Front End Loaders $381,922 Equipment Purchase Yard Tractor $77,613 Transfer Station Construction $2,325,000 (includes paving from entrance to HHW and crew building) (Payment begins for 15 years @ $239,389/yr) $239,389/Yr Opening Transfer Station July 09 N/A Hauling and Disposal Fee $34.00 /ton $2,166,854/Yr Construction & Demolition Landfill Bid and Construction of C &D Resale Store $325,000 7 (Payments begin for 5 years @$77,153) $77,153/Yr, Purchase Drywall Compactor $28,943 Rebecca Holdway Solid Waste Management 10 Year Plan Gnatt ChartAs 03/30/2004 Rebecca Holdway Solid Waste Management 10 Year Plan Gnatt Chart.xls 03/30/2004 Budget Cost 2004 -05 2005 -06 2006 -07 2007 -08 2008 -09 2009 -10 2010 -11 2011 -12 2012 -13 Recycling Universal Services Construction of Hampton Point Recycling Center $100,000 Purchase 8 Cardboard Containers @$600.00 ea. $4,800 One Antifreeze Tank $2,700 One Antifreeze Tank $2,732 Construction of Southern Village Recycling Center $130,000 Rolloffs, Dumpsters for Southern Village $55,331 $55,331 One Antifreeze Tank $2,814 Relocation of Recycling Facilities $500,000 New building and all associated improvements (Payments begin for 5 years @ $118,698) $118,698 Urban Curbside Collections Batteries picked up at the curb NIA Rural Curbside Collections Battedes picked up at the curb NIA Multifamily Collections NIA Rebecca Holdway Solid Waste Management 10 Year Plan Gnatt Chart.xls 03/30/2004 Solid Waste Management 10 Year Plan New or Expanded Capital /Personnel Budget Cost 2004 -05 2005 -06 2006 -07 2007 -08 2008 -09 2009 -10 2010 -11 2011 -12 2012 -13 Administration and Landfill Operations Administration Construction of Admin Building $660,000 (Payments begin for 10 Years @ $89,672) New SW Telephone System $55,000 $89,672 $55,000 Additional Personnel Office Asst II (Part -Time) in Revenue Coll/Tax Assessment Dept $15,000/Yr $46,660/Yr. Additional Position MSW Install leachate sewer line $155,000 $155,000 Land Acq. Adjacent Property for Potential Mitigation Activities $150,000 (Payments begin for 5 years @$35,609/ r) $35,609/Yr. } " Asphalt Northside to C &D $175,000 Last Year of Active Landfill* $175,000 NA Switch to Transfer Station July 09 Add 1/2 FTE to Monitor Landfill Site N/A $29,959/Yr tlxf''rt `~ t x Transfer Station Transfer Station Design & Permitting $265,000 Equipment Purchase 2 Front End Loaders Equipment Purchase Yard Tractor $381,922 $77,613 Transfer Station Construction $2,325,000 includes paving from entrance to HHW and crew building) r (Payment begins for 15 years @ $239,389/yr) $239,389/Yr Opening Transfer Station July 09 N/A Hauling and Disposal Fee $34.00 /ton $2,166,854/Yr Construction & Demolition Landfill Bid and Construction of C &D Resale Store $325,000 (Payments begin for 5 years @$77,153 ) $77,153/Yr, Purchase Drywall Compactor $28,943 Rebecca Holdway Solid Waste Management 10 Year Plan Gnatt Chart.xls 03130/2004 Recycling Budget Cost 2004 -05 2005 -06 2006 -07 2007 -08 2008 -09 2009 -10 2010.11 2011 -12 2012 -13 Universal Services Construction of Hampton Point Recycling Center $100,000 Purchase 8 Cardboard Containers @$600.00 ea. $4,800 One Antifreeze Tank $2,700 - One Antifreeze Tank $2,732 Construction of Southern Village Recycling Center $130,000 0 Rolloffs, Dumpsters for Southern Village $55,331 $55,331 One Antifreeze Tank $2,814 Relocation of Recycling Facilities $500,000 New building and all associated improvements (Payments begin for 5 years @ $118,698) $118,698 Urban Curbside Collections Batteries picked up at the curb N/A Rural Curbside Collections Batteries picked up at the curb N/A Multifamily Collections I N/A I I I I I I I_ 1 I 1 Rebecca Holdway Solid Waste Management 10 Year Plan Gnatt Chart.xls 03/30/2004 Solid Waste Management 10 Year Plan New or Expanded Capital /Personnel Administration and Landfill Operations Budget Cost 2004 -05 2005 -06 2006 -07 2007 -08 2008 -09 2009 -10 2010 -11 2011 -12 1 2012 -13 Administration Construction of Admin Building $660,000 (Payments begin for 10 Years @ $89,672) $89,672 "TM New SW Telephone System $55,000 Additional Personnel Office Asst II (Part -Time) $55,000 $15,000/Yr Additional Position in Revenue Coll/Tax Assessment Dept $46,660/Yr. r � MSW Install leachate sewer line $155,000 $155,000 Land Acq. Adjacent Property for Potential Mitigation Activities�� $150,000 (Payments begin for 5 years @$35,609/yr) $35,609/Yr. r Asphalt Northside to C &D $175,000 $175,000 Last Year of Active Landfill" NA Switch to Transfer Station July 09 N/A Add 1/2 FTE to Monitor Landfill Site $29,959/Yr jp 7' Transfer Station Transfer Station Design & Permitting $265,000 Equipment Purchase 2 Front End Loaders $381,922 Equipment Purchase Yard Tractor $77,613 Transfer Station Construction $2,325,000 (includes paving from entrance to HHW and crew building) (Payment begins for 15 years @ $239,389/yr) $239,389/Yr Opening Transfer Station July 09 N/A Hauling and Disposal Fee $34.00 /ton $2,166,854/Yr Construction & Demolition Landfill Bid and Construction of C &D Resale Store $325,000 Payments begin for 5 years @$77,153 $77,153/Yr, Purchase Drywall Compactor $28,943 Rebecca Holdway Solid Waste Management 10 Year Plan Gnatt Chart.xls 03/30/2004 Recycling Budget Cost 2004 -05 2005 -06 2006 -07 2007 -08 2008 -09 2009 -10 2010 -11 2011 -12 2012 -13 Universal Services Construction of Hampton Point Recycling Center $100,000 0 Purchase 8 Cardboard Containers @$600.00 ea. $4,800 One Antifreeze Tank $2,700 One Antifreeze Tank $2,732 Construction of Southern Village Recycling Center $130,000 Rolloffs, Dumpsters for Southern Village $55,331 $55,331 One Antifreeze Tank $2,814 Relocation of Recycling Facilities $500,000 New building and all associated improvements Payments begin for 5 years @ $118,698) $118,698 Urban Curbside Collections Batteries picked up at the curb N/A Rural Curbside Collections Batteries picked up at the curb N/A Multifamily Collections N/A 0 Rebecca Holdwa) Solid Waste Management 10 Year Plan Gnatt Chart.xh 03/30/2004 City or Type of Annual Fee Who Pays What it covers Comments: provided from jurisdiction County Fee Wake County Household $20.00 All residential Non - landfill related Fee began 1995. In the past, revenue from the $20 household fee has not Ken McArtor, Fee occupied units programs been "ear- marked" for certain programs, but has been considered revenue Finance Dept. incl. Multifamily (including; School to the Enterprise (919) 856 -7117 Recycling Program. Fund as a whole. This year the household fee will be compared to the Convenience Center total cost of services for all the programs it is supposed to fund. A fee Program, Multi- adjustment will be Material Drop -Off requested where necessary over the 3 -yr budget. Facilities, Household Hazardous Waste Program, Special Collections, Solid Waste Education, etc. Chatham Availability Two fee system: Fees are only for Fees along with When this structure was set up, we were receiving General Fund money. County Fee and Availability Fee "all" dwelling recycling revenu Programs such as Environmental Enforcement, Environmental Education, Robert Holden, Disposal Fee $81 covers the units in es should cover HHW, Solid Waste costs of the unincorporated Hauling (H) and access to the collection centers etc. that everyone in the County has access Director collection areas. Mobile Disposal (D) costs. to, was being paid from the General Fund. Those who benefit pay. (919) 542 -5516 centers. Charged home parks are Availability fee: This year with NO general fund money, policies did not change. County to all dwelling charge per utility Current disposal tried to get payment from Town residents, but failed. When combined units in hook up. Multi cost = 23% of with recycling revenues, the fees will cover the costs of the collection unincorporated family houzing budget covers those centers, hauling and disposal. areas. complees are costs. An additional charged per unit. Disposal Fee Availability fee is {$34} is charged 69% of revenues to "dwelling units" in the Other 8% of unincorporated revenues from other area who do not sources. have a private garbage hauler. Durham County Solid Waste $65.00 Single family Convenience center Fee in place since 1993. This is not the only source of funds, SWCCs Tom Bryant Fee unincorporated, operations (4) and collect motor oil, batteries, pesticide bottles, site attendants, recycling Solid Waste trailer parks, curbside recycling staff (in house for County buildings). Director (919) exemption for 14,000+ hh's 560 -0430 vacant pads, not vacant trailers. City or Type of Annual Fee Who Pays What it covers Comments: provided from jurisdiction County Fee City of Recycling $27.00 Single family Curbside recycling Covers cost of contract only, no administrative or education costs. Billed Kernersville Fee households. on property tax bill. Mylinda Duplex pays two Jacobsen, Solid fees (2 carts) Waste Director � 336 996-6417 - City of Solid Waste $229.20 for 90g Single family Residential solid Billed on water bill monthly. The solid waste dept pays the City Wilmington Fee roll out garbage households or waste, yard waste, $400,000 year for Bill Reid cart others who can curbside recycling, HR services, IT services, billing, and other services. Superintendent $193.20 for use roll out carts bulky, all admire. of Operations smaller 40g cart e.g. small Overhead. (910) 790 -2376 General fund business pays public waste and dead animal fees. Cumberland Solid Waste $48 per year per All single family Residential solid Commercial Transfer Station Tip Fee = $37.ton. City does not pay for County Fee household. households in waste disposal residential waste because it's already covered in the household fee. Charles the County (Town doesn't pay Whittenton except Town of tip fee), use of Solid Waste Spring Lake landfill, Director (they pay tip convenience centers (910 321 -6830 fees) Complexes and HHW program. of eight or more units are commercial and must provide their own collection. Washington Solid Waste $175 Residential Contracted door to Commercial Landfill Tip Fee. Ten year contract with hauler. In -town County User Fee units. Pay per door collection of pays on its own. Chris Coudriet unit waste & recycling (252) 793 -5823 unincorporated hauling to regional areas only. landfill landfill and Optional for tip fee. White small business. goods, brush and bulky item collection on -call. 1� a City or Type of Annual Fee Who Pays What it covers Comments: provided from jurisdiction County Fee Polk County Availability $35 for every All improved & Cost of building Commercial haulers will pay separate tipping gee at Transfer Station Karim Shihata Fee improved parcel taxed properties. and operating new when it's built. (828) 894 -3301 in the County transfer station. Set regardless of type up new Department $40 additional of Environmental fee in Services to mitigate unincorporated old landfills, other area for those environmental without garbage issues.Fee will pay service to use mitigation expenses County Transfer for old landfills Station/Conven- from this new ience Center. enterprise fund. Macon County Annual $60 for use of all All households Use of Solid Waste Multi family are billed to property owner according to number of units in Joel Ostroff household the County in Macon Co. Convenience building and each unit is billed at variable rate depending on size e.g. one Recycling user fee. convenience Supports Centers and can bedroom unit might pay $6 while two bedroom unit pays $10. Range per Coordinator centers. It also convenience bring scrap metal, unit is $6 -$10 so a whole building's fee will typically be small. (828) 349 -2252 allows dropoff of centers 'as tires, white goods jostroff(E�macon other materials enterprise fund and appliances to nc.org e.g. scrap metal. (no general tax landfill with this at center. money included) permit. Craven County Annual $32 billed on tax Residents and Cost of curbside Some municipalities in Craven County don't participate. Have their own Solid Waste residential bill. Supports small business recycling. program and can opt out of the fee. Authority recycling curbside that uses roll (252) 636 -6659 program fee. recycling cart or garbage Stuart Daniels Billed as program. can (not sdanielsQco. "Recycling dumpster) are craven.nc.us Fee' billed. City of Hickory Solid Waste $67.56 Single family Curbside recycling Billed on water bill. Individual bills sent to those on private wells. Tim Bennett Fee households, Includes other It does not cover enough, 'about hal'. Should be charging about $121 - Solid Waste multifamily recycling programs, $144/ year) for the level of service provided and covering overhead, HR Supervisor under six units residential solid costs, etc. Subsidizes all (828) 323 -7439 some small waste, bulky goods, Solid Waste programs for disposal and recycling The fee is collected as businesses and white goods, yard part of enterprise fund used to pay for curbside recycling plus residential other non- waste and commercial waste collection and disposal. Any shortfalls are residential that absorbed by general fund. use one roll cart Set up in about 1996 and was in the $2 -$3 /month range then. Revised March 5, 2004 LAW OFFICES COLEMAN, GLEDHILL, HARGRAVE & PEEK A PROFESSIONAL CORPORATION 129 E. TRYON STREET P. O. DRAWER 1529 HILLSBOROUGH, NORTH CAROLINA 27278 919 -732 -2196 FAX 919 - 732 -7997 www.cgandh.com March 23, 2004 Mr. John M. Link, Jr. Orange County Manager Mr. Rod Visser Assistant County Manager Post Office Box 8181 Hillsborough, North Carolina 27278 Mr. Gayle Wilson Solid Waste Director Post Office Box 17177 Chapel Hill, North Carolina 27516 -7177 RE: Waste Reduction, Reuse and Recycling Fees Dear John, Rod and Gayle: 2,)— FROM THE DESK OF GEOFFREY E. GLEDHILL E -MAIL: geoffrcygledhill @cgandh.com This letter provides my analysis of the legal issues pertinent to.the Orange County staff-recommendation to implement Waste Reduction, Reuse and Recycling Fees ( "WRRR fees "). In a letter dated February 7, 2003, a copy of which is enclosed with this letter, I discussed how the Agreement for Solid Waste Management among Orange County, Carrboro, Chapel Hill and Hillsborough ( "Agreement ") addresses other fees. It is my view that the WRRR fees recommended by the staff are "other fees" as discussed in the Agreement. They therefore may be created or changed by the County by giving the other parties*to the Agreement 30 days notice of the fee or the proposed fee change. If the Solid Waste Advisory Board recommends the change be approved, then the change can take effect if the County subsequently approves it. On the other hand, if the Solid Waste Advisory Board recommends that the fee or fee change not be approved then the change may take effect only if the County and at least one other party to the - Agreement approves the fee or fee change. Page 2 13 March 23, 2004 Counties are given express authority to establish and operate solid waste collection and disposal facilities. Counties and cities may establish and operate joint collection and disposal facilities by joint agreement. The Agreement is such an agreement. The Board of County Commissioners is empowered to impose fees for collection of solid waste, use of disposal facilities and the availability of disposal facilities all related to.solid waste. However, "recovered material" is not considered solid waste in this regulatory scheme and is not regulated as such.- Also, solid waste in this regulatory scheme means non - hazardous solid waste and does not include-hazardous waste. Fees for handling recovered material and household hazardous waste are not subject to the.limitations placed on the County's ability to charge fees for the collection of solid waste, the use of a-solid waste disposal facility and the availability of a solid waste disposal facility. Those limitations are discussed in my February 7, 2003 letter and relate principally to the inability to charge persons not using County solid waste disposal facilities and the availability of those facilities. A recovered material is a material that has known recycling potential, can be feasibly recycled and has been diverted or removed from the solid waste system stream for sale, use or reuse. To qualify as "recovered material:" (1) a majority of the recovered material at a facility shall be sold, used or reused within 1 year; (2) the recovered material or the products or by- products of operations that processed recovered materials shall not be discharged, deposited, injected, dunked, spilled, leaked, or placed into or upon any land or water so that the products or by- products or any constituent thereof may either enter other lands of be emitted into the air or discharged into any waters including groundwaters, or otherwise enter the environment or pose a threat to public health and safety; and (3) the recovered material shall not be a hazardous waste or have been recovered from a hazardous waste. The board of commissioners of a county has broad power to charge fees for services. N.C. Gen. Stat. 9 153A -102 provides: "the board of commissioners may fix the fees ... charged by county Page 3 March 23, 2004 officers and employees for performing services or duties permitted or required by law...." Providing waste reduction, reuse and recycling services for recovered material and household hazardous waste are both services counties are either permitted to provide or required.by law to provide. Therefore, in my opinion, the County has the power to charge WRRR fees. The division of the fee into the four categories as recommended.by the County staff establishes a WRRR fee. system that is both reasonable and related to the services provided by Orange County to the improved property in the County and the cities and towns in the County whose owners receive and have the applicable services available to them. Part of Chapel Hill is located in Durham County. Since the WRRR services covered by the fees recommended by staff are provided to all of Chapel Hill, it is my opinion that those properties can be made subject to the same fees as other properties receiving the same services in the rest of Chapel Hill. Since the WRRR fees are not solid waste collection, disposal or availability fees they are not covered by N.C. Gen. Stat. § 153A -293. That statute authorizes a county to adopt an ordinance providing that a solid waste related fee may be made payable in the same manner as property taxes and, in the case of non payment collected in any manner by which delinquent personal or real property taxes can be collected. Therefore,' collection of unpaid /delinquent WRRR fees will have to be accomplished by using other remedies. The staff has projected an 88o collection rate for these fees for that reason rather than the over 980 collection rate which is typical for property taxes in Orange County. The Board of Commissioners may want to consider, either in the near term or the longer term, seeking legislation that would provide that any fee authorized by and imposed pursuant to N.C. Gen. Stat. 153A -102 can be collected in the same manner that solid waste related fees can be collected. The WRRR fees, if approved by the Board of Commissioners, should be established and maintained annually with the adoption by the Board of the Orange County Budget Ordinance. Page 4 March 23, 2004 �-15 If you have any questions about any of this, please advise. GEG /lsg Enclosure lsg :letters \linkvisserwilson.ltr Very truly yours, COLEMAN, GLEDHILL, HARGRAVE & PEEK, P.C. ledhill LAW OFFICES COLEMAN, GLEDHILL & HARGRAVE A PROFESSIONAL CORPORATION 129 E. TRYON STREET P O. DRAWER 1529 HILLSBOROUGH, NORTH CAROLINA 27273 FROM THE DESK OF 919- 732 -2196 GEOFFREY E. GLEDHILL FAX 919 -732 -7997 WEBSITE WWW.CGANDH.COM E- .VL-IL: veo[frey- 1edhi11rxgandh.com February 7, 2003 Mr. John M. Link, Jr. Orange County Manager Mr. Rod Visser Assistant County Manager Mr. Gayle Wilson Solid Waste Director Mr. Jan Sassaman, Chair Orange County Solid Waste Advisory Board Post Office Box 8181 Hillsborough, North Carolina 27278 RE: Solid Waste Alternative Financing Dear John, Rod, Gayle and Jan: This letter is a summary of the research that I have done concerning solid waste alternative financing. It will proceed in both outline and narrative form and is intended to be an overview of the result of my research. Further direction by the Solid Waste Advisory Board, the Manager and the Board of County Commissioners will demand additional work and fine - tuning. I. Agreement for Solid Waste Management. The Agreement for Solid Waste Management among Orange County and the Towns of Carrboro, Chapel Hill and Hillsborough provides the s.tepping -off point for discussion of solid waste alternative financing. The Agreement makes clear that the County operates the solid waste system in Orange County and generally has both authority and discretion in operating the system. The Page 2 February 7, 2003 1�, / Agreement further contemplates that the system will be operated as an "enterprise" and that the County has discretion in setting rates, fees and charges. There is an overriding limit on this discretion. The County may not put into effect any Material Financing Change unless the County first obtains the consent of all the parties to the Agreement. Since the financing alternatives discussed here will not, in my mind, affect a Material Financial Change, that limitation on operational control of the system does not pertain. The notion that the County's solid waste system will be operated as an enterprise; is also the solid waste system method of preference in State law. Chapter 130A of the North Carolina General Statutes,.which mandates that each county and municipality operate solid waste management systems and.provide for their financing states that counties and municipalities are encouraged to operate their solid waste management systems through use of an enterprise fund. The fee options that have been presented to the Solid Waste Advisory Board, to the Manager and to me fall into the category of "other fees" in the Agreement. Generally, these fees may be created or changed by the County by giving the other parties to the Agreement thirty days notice of the fee or the proposed fee change. If the Solid Waste Advisory Board recommends the change be approved,.then the change can take effect if the County subsequently approves it: If the Solid Waste Advisory Board recommends that'the change not be approved, then the change may take effect only if the County and at least one other party to the Agreement approves the change. "Other fees" do not-include taxes. That is, the Agreement does not prohibit funding the solid waste system with taxes. However, since the solid waste management system is to be operated as an enterprise, the only taxes that fit the model are district taxes. The Agreement expressly provides that special district taxes related to the system are not covered by the Agreement. However the Agreement notes, correctly, that North Carolina law requires consent of a town for the property located in the town to be included in any special tax district. Once a town consents, then the county controls the special district tax, in its discretion. t e Page 3 February 7, 2003 II. The Prince William County, Virginia Model. I have studied the materials made available to me. concerning-the fee system established by Prince William County, Virginia. I have also reviewed the Code of the Commonwealth of Virginia to determine the legal framework for the Prince William County system. Further I have contacted the New Hanover County Attorney's office because I have been told that that office has found "no legal impediment" to implementing the Prince William County, Virginia system in North Carolina. My research tells me that Prince William County, Virginia created a sanitary district and that the sanitary district model available in Virginia, is similar to the sanitary district model in North Carolina. Prince William County, Virginia petitioned the courts of Virginia for the creation of this sanitary district and upon receiving the court's approval, the sanitary district created can finance its system activities either by charging rates (fees) for the use of the system and /or by levying taxes on property in the sanitary district. The Prince William County Sanitary District has apparently elected to use only fees to finance its solid waste system. North Carolina law provides for the creation of sanitary districts which when created have taxing and other governmental powers, including the power to charge fees for system services. A sanitary district under North Carolina law is essentially a local government independent of the county or the city where it is located. Sanitary districts as a model are, in Orange County, I believe, obsolete. Since Virginia sanitary districts are akin to North Carolina sanitary districts and since sanitary districts in Orange County, North Carolina are essentially obsolete, the use of the Virginia model is not helpful. The rest of this document therefore focuses on the two other possibilities which are helpful and could be used independently or together. It also includes a brief discussion of franchising as a method of addressing financing solid waste in Orange County. Incidentally, during my conversation with Holt Moore with the New Hanover County Attorney's office, I was told that he did not recall opining about the applicability of the Prince William County, Virginia model for New Hanover County. And in the end, New Hanover County went to a franchise system q Page 4 February 7, 2003 after determining that the Prince William County model was not a practical solution to New Hanover County's solid waste financing concerns. III. Fees for Service. North Carolina law enables counties to charge collection, disposal and availability fees to finance solid waste enterprises. Solid waste collection fees are outside of the scope of the County's responsibility under the Agreement and are not discussed further. The' County can impose a fee for the use of disposal facilities provided by the County. This fee may not exceed the cost of operating the facility and may be imposed only on those who use the facility. The fee can vary based on the amount, characteristics-and form of recyclable materials present in solid waste. This fee is essentially a-user fee not applicable to persons not using the County's solid waste system. The Board of Commissioners.may also impose a fee for the availability.of a disposal facility provided by the County. This fee may not exceed the cost of providing the facility. This fee is not directly a user fee. Rather it is imposed on improved property in the County that benefits from the availability of the facility. This fee may not be imposed on property whose solid waste is collected by a city or a private contractor for a fee if the fee imposed by the city or the private contractor for the collection includes a charge for the availability and use of a disposal facility provided by the County. Furthermore, property served by a private contractor who disposes of solid waste collected from the property in a disposal facility providedby the private contractor is not considered to benefit from a disposal facility provided by the County and is not subject to a fee imposed by the County for the availability of a disposal facility provided by the County. Summarizing, an availability fee could be charged to everyone in orange County whose solid waste is not collected by a private contractor delivering the materials to a disposal facility provided by that private contractor. And, if the availability fee were to be applicable in the Towns of Chapel Hill, Carrboro and Hillsborough, the fees charged by orange County for delivery of solid waste to the County landfill would have to be adjusted to eliminate the cost of the availability of Page 5 `® February 7, 2003 the disposal facility. That is, if the County intends to continue its tipping fee while imposing an availability fee, the services covered by the availability fee even though charged to the landowners in Orange County, would have to be "backed -out" of the tipping and other fees now charged to the towns. The statute authorizing local governments in North Carolina to charge fees for solid waste is, at least in part, responsive to federal flow control requirements created by the federal courts which requirements are premised on Congress's ability to control commerce. Flow control principles generally do not become a problem under the North Carolina solid waste fee system because the statutory limits on fee - setting mirror, or at least capture the sense of, flow control. A fee system has at least. one advantage over a tax system in that the fees are charged to the persons using the County solid waste system, even where the property where the solid waste is generated is not taxable. A fee system may also please the towns in Orange County because it would almost certainly result in a reduction to tip fees. Solid waste fees would be established by County ordinance and, may be billed with property taxes; may be payable in the same manner as property taxes; and, in the case of non - payment may be collected in any manner by which delinquent personal or real property taxes can be collected. All of these features of a fee system would be set out in the ordinance which creates the fee. The ordinance would further make clear that delinquent fees are a lien on the real property described on the tax bill that includes the fee. Therefore, fee collection rates should be comparable to ad valorem tax collection rates. Fees under North Carolina's solid waste fee system,. without franchising being a part of that system, will only stop Orange County solid waste from leaving Orange County if they are competitive with the private sector, however. And, unlike property taxes, fees are not deductible for federal and State income tax purposes. IV. County Solid Waste Service Districts. Service districts are a viable option for Orange County and create only a tax boundary with all of the governmental Page 6 I February 7, 2003 activities being performed by the County. Orange County could create solid waste service districts that are defined by the level of solid waste service provided to the district. However, before solid waste service districts can be effective in the towns in Orange County, the towns would have to consent to their being included. Service districts under North Carolina law are special tax districts only. They are not units of government which can charge fees for services. The use of service district taxes as an alternative financing method is discussed below. County service districts for solid waste collection and disposal systems can be created based on the service provided. That is,-each district would vary depending on whether the property owner had access. to the rural solid waste collection system, rural curbside collection or town curbside collection. As mentioned previously, before a county service district can include land in a city or town, the city or town must agree to its being included within the district. All aspects of the property tax generally pertain to service district taxes. That is, properties that are exempt from property taxes generally will be exempt from service district taxes. And, property valuation will be the same as for property taxes generally. Therefore, for example, property in the use value program or homestead exempt property would be taxed at its use value or net of the homestead exemption. County service district tax rates are considered together with other County taxes for tax rate limitations. They are'in the same category as 153A- 149(c) functions that may be paid -for with county taxes, which have a combined rate limit of $1.50 per $100 of valuation. They would appear on the tax bill as a separate line item and would be collectible in the same manner as other property taxes. Service district taxes are deductible as are other property taxes for State and federal income tax purposes. .A service district tax should be relatively easy to administer because of the advanced GIS technology available to Orange County to identify and map the districts. Although service district taxes will not capture entities otherwise exempt from property taxes, they will tax all other persons using the County's solid waste system. They are, in that regard, a flow control technique which I think would avoid federal flow Page 7 z February 7, 2003 control problems. And, they would provide significant incentive to the use' of the County's solid waste system. Also,. presumably, any service district tax in the towns would be accompanied by a reduction in the landfill tip fee charges to the towns. Without those reductions the towns would, in all likelihood, not agree to being a part of the service district system. V. Franchising. Creating a franchise system whereby all solid waste has to be collected and /or hauled by franchisees is not a direct alternative financing method. Fees can be charged in the franchising process but they are minor in amount-and would be imposed mainly to cover the administration of the franchising process. On the other hand, requiring in a franchise system the solid waste hauler to deliver all of the solid waste collected and hauled to the Orange County.solid waste facilities puts off for the foreseeable future Orange County's need for alternative financing for its solid waste system. Hillsborough successfully used a franchise system when it got out of the commercial collection business. Pursuant to the* Hillsborough franchise ordinance and the franchise granted by Hillsborough, all commercial solid waste collected in Hillsborough must be delivered to Orange County solid waste facilities. This is the method elected by New Hanover County. That is, New Hanover County's franchising system requires that all the waste in New Hanover County be delivered to its incinerator. Interestingly, there is a local bill applicable to New Hanover County which allows its solid waste franchising authority to include the City of Wilmington. Thus, New Hanover County has completely addressed its solid waste financing through the franchising process. Although Hillsborough has successfully implemented a franchising system for its commercial solid waste collection activities and although New Hanover County has also implemented a franchising system, franchising squarely puts at issue federal flow control law. A franchise which requires the waste to be delivered to the Orange County facilities would prohibit out of County disposal of County solid waste altogether. Hillsborough implemented its franchising system without flow control complaint from the franchise bidders, and the bidders in Page 8 3J February 7, 2003 all of the major private collection companies operating in this area. However, New Hanover County has been put on notice by the private haulers in that area that their franchising system violates federal flow control requirements. Similarly, Wilmington is making noises about undoing the system. Before New Hanover County enacted its franchising system it had adopted a "pure" flow control ordinance. That ordinance was challenged in federal court resulting in a consent order the gist of which is New Hanover County has repealed or suspended the enforcement of its flow control ordinance. Solid waste and flow control are ongoing issues in New Hanover County. It is my opinion that although this method of franchising may be an attractive response to solid waste system financial problems, it is too risky presently to attempt.to implement particularly given the amount of time Orange.County has to respond to its solid waste financing needs. There is another franchising model (and variations of this model) which has passed flow control review by the United States Circuit Court of Appeals for the Second Circuit. In both of the cases considering variations of this model that I am aware of, the United States Supreme Court, which created the flow control doctrine, declined review. This model.begins with the creation of franchise districts and the awarding of an exclusive franchise to one solid waste collector /hauler in each district. The franchise granted requires the franchisee to operate a recycling program according to the County's specifications and requires that all waste be disposed of in the County's solid waste disposal facilities. Key to this model is that the County pays the franchisee for performing this service. The'County in turn charges the residents of the County a fee or fees in the same categories as discussed in the Fees for Service section of this letter. Using this model results in no non -users of the County's solid waste system. Therefore, everyone pays fees. Similar to the Hillsborough franchise system, this is a cutting edge approach and not without risk. I also am unable to predict how much time it would take to implement in Orange Page 9 February 7, 2003 3� County. In that regard, like the district tax approach, this franchising model would not work without agreement by the towns. Very truly yours, COLEMAN, GLEDHILL & HARGRAVE, P.C. Geoffrey E. Gledhill GEG %lsg lsg: letters \linkvisserwilsonsolwaste.ltr