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Item 12 Staff Report Adopt Resolution Making Findings Regarding the Rate Base for Green Valley Disposal Company for 1994-1996 and Establishing Base Rates for Refuse Collection in the TownDATE: TO: FROM: SUBJECT: COUNCIL AGENDA DATE: 2/6/95 ITEM NO. TOWN OF LOS GATOS COUNCIL AGENDA REPORT February 3, 1995 MAYOR AND TOWN COUNCIL / LARRY E. ANDERSON, TOWN ATTORNEY ADOPT RESOLUTION MAKING FINDINGS REGARDING THE RATE BASE FOR GREEN VALLEY DISPOSAL COMPANY FOR 1991 1996 AND ESTABLISHING BASE RATES FOR REFUSE COLLECTION IN THE TOWN RECOMMENDATION: Adopt the attached resolution which incorporates the Council's findings and decision at ite meeting of January 17, 1995. DISCUSSION: On January 3 and 17, 1995, after extensive public comments and hearings, the Council approved a rate base and rates for refuse, recycling, and yard waste collection services by Green Valley Disposal Company, Inc. PREPARED BY: LARRY E. ANDERSON, Town Attorney LEA:yfg C:\WPFILES\CNCLRPTS\GREENVLL.TCR ATTACHMENT$: Attachment 1 - Resolution Exhibit A to Resolution Attachments to Exhibit A: Attachment 2 - Letters Revised: 2/3/95 3:14 pm Findings and Decisions 1. Approved Budget for Green Valley FY 1993-1994 2. Approved Budget for Green Valley FY 1994-1995 3. Balancing Account 3-Year Amortization Schedule 4. Proposed Solid Waste Rates as of February 1, 1995 DISTRIBUTION: Jean Cushman, 16123 Loretta Lane, Los Gatos, CA 95032 Dan Williams, 304 Harding, Los Gatos, CA 95032 Margaret Woosley, 18 Fillmer, Los Gatos, CA 95032 Gene Humphlett, 18400 Overlook Road, Box 39, Los Gatos, CA 95030 Rate Review Committee Green Valley Disposal Company, Gerard Wen, P.O. Box 1227, Los Gatos, CA 95031 John Snelham, 248 Old Adobe Road, Los Gatos, CA 95030 Ron O'Neill, 509 Monterey Avenue, Los Gatos, CA 95030 Reviewed by: 9,04_ Manager Clerk Finance Treasurer COUNCIL ACTION/ACTION DIRECTED TO: PAGE 2 MAYOR AND TOWN COUNCIL SUBJECT: ADOPT RESOLUTION MAKING FINDINGS REGARDING THE RATE BASE FOR GREEN VALLEY DISPOSAL COMPANY FOR 1994-1996 AND ESTABLISHING BASE RATES FOR REFUSE COLLECTION IN THE TOWN DATE February 3, 1995 The resolution (Attachment 1) adopts findings and decision to detail the Council's decision, so that an adequate baseline is established for future rate adjustments. While we have tried to accurately write the findings and decision, the Council may want to continue the matter to revise the findings and decision. As the Council knows, Green Valley has filed a claim with the Town alleging that the Town breached the Franchise Agreement on January 17, but without specifying any particular. The Town has also received a number of additional letters regarding the rates and Green Valley service, which are found in Attachment 2. Finally, while gathering the documentation for the recycling program implementation last week, we found that Green Valley has not posted a performance bond or provided proof of insurance in accordance with the Franchise Agreement. Staff has sent a letter to Green Valley requesting an explanation and compliance: this may affect past and present operating expenses, because they may have been overstated if in fact, insurance and bonds were not purchased by Green Valley. RESOLUTION RESOLUTION OF THE TOWN COUNCIL OF THE TOWN OF LOS GATOS MAKING FINDINGS REGARDING THE RATE BASE FOR GREEN VALLEY DISPOSAL COMPANY FOR 1994-1996 AND ESTABLISHING BASE RATES FOR REFUSE COLLECTION IN THE TOWN OF LOS GATOS WHEREAS, the Town has conducted an extensive and thorough performance audit and rate adjustment proceeding regarding Green Valley Disposal Company, Inc.'s refuse, recycling, and yard waste collection services under its agreements with the Town; and WHEREAS, the attached findings and decision reflect the analysis and conclusions of the Town Council and are consistent with Resolution 1995-19 adopted by the Council on January 17, 1995, NOW, THEREFORE, THE TOWN COUNCIL OF THE TOWN OF LOS GATOS DOES HEREBY RESOLVE AS FOLLOWS: 1. The Findings and Decisions attached hereto as Exhibit A are approved and adopted. This decision constitutes a final administrative decision pursuant to Code of Civil Procedure section 1094.6 as adopted by section 1.10.085 of the Town Code of the Town of Los Gatos. Any application for judicial relief from this decision must be sought within the time limits and pursuant to the procedures established by Code of Civil Procedure section 1094.6, or such shorter time as required by state or federal law. ATTACHMENT 1 I+1 PASSED AND ADOPTED at a regular meeting of the Town Council of the Town of Los Gatos, California, held on the COUNCIL MEMBERS: AYES: NAYS: ABSENT: ABSTAIN: SIGNED: A I"1'EST: day of , 199 by the following vote. MAYOR OF THE TOWN OF LOS GATOS LOS GATOS, CALIFORNIA CLERK OF THE TOWN OF LOS GATOS LOS GATOS, CALIFORNIA 2 1 2 3 FINDINGS AND DECISION IN 1994-1995 RATE PROCEEDING REGARDING A RATE ADJUSTMENT AND ESTABLISHMENT OF A REVISED RATE SCHEDULE FOR REFUSE, RECYCLING, AND YARD WASTE COLLECIION SERVICES OF GREEN VALLEY DISPOSAL COMPANY, INC. IN THE TOWN OF LOS GATOS 4 5 I. RATE -SETTING PROCESS. 6 A. This rate -setting proceeding is conducted pursuant to the authority of the Town 7 under State law, Town Code § 11.10.030, and its franchise agreement with Green Valley 8 Disposal Company, Inc. Pursuant to public utility law and the Franchise Agreement, Green 9 Valley Disposal Company [Green Valley] bears the burden of proof in demonstrating the need 10 and extent of any rate adjustment. 11 B. The Town conducted a public forum regarding the expansion of the Town 12 recycling program, the initiation of a yard waste collection program, and the rate structures that 13 might be required to support those services. Public notice was provided to each Green Valley 14 subscriber by the Town of those forums by mail and newspaper publication. 15 C. The Town Council began its hearings on the recycling, yard waste, and rate 16 structure systems in November, 1994, and has held 3 public hearings on the matter. Notice of 17 these hearings was given by mail to approximately 500 people as well as newspaper publication, 18 and information from Town staff was widely disseminated by the Town. 19 D. The Town received extensive public comments, both oral and written, during the 20 public forum and public hearings, and the Council has considered all of those comments and 21 concerns. The Town has also provided Green Valley with approximately 12 months to respond 22 to the concerns expressed by the performance audit performed in conjunction with this rate- 23 setting, 5 years to respond to concerns about soaring disposal surcharges, and almost 12 months 24 to respond to concerns expressed by the Rate Review Committee concerning financial 25 information and rate schedules. 26 E. During the current rate -making proceeding, Green Valley has not presented the 27 Town or the Council with a rate adjustment application or an adequate Schedule of Rates. 28 Instead, the Town in cooperation with the other 3 West Valley jurisdictions has spent hundreds 1 EXHIBIT A of hours of staff and consultant time attempting to determine what rates should be esta' Zed for the provision of refuse collection services. F. The information provided by Green Valley to the Rate Review Committee, Town staff, and the Town Council has been incomplete and inadequate to resolve the significant issues presented, was received only after repeated requests by staff, and has not given the ratepayers an appropriate opportunity to comment or examine the performance of Green Valley or its assertions of profit entitlement. G. Green Valley's audited financial statements as of June 1994 were not made available to the Town until December 1994, and then only when the Town requestA them directly from the Company's offices. H. Green Valley did not provide information to the general public regarding the proposed rates. Instead, the Town had to bear the costs of mailing rate information, fielding phone and written inquiries, and conducting the community forum and hearings regarding the rates. I. During the course of this rate proceeding, Green Valley filed suit against t 'ity of Monte Sereno over its 1994 rate decisions. Even before the Town's and Saratoga's rate proceedings concluded, Green Valley filed a claim against both the Town and the City of Saratoga alleging that the municipalities' respective contracts had been breached. This approach to rate proceedings by Green Valley has not been helpful. II. FRANCHISE HISTORY. A. In 1983, the Town of Los Gatos entered into a Franchise Agreement for a 20-year period that granted Green Valley the exclusive right to provide refuse collection services in the Town in exchange for the right of the Council to set rates and generally regulate service and for payment of a 10% franchise fee on Green Valley's gross revenues resulting from its refuse collection services in the Town as defined in the Franchise Agreement. At the same time that the Franchise Agreement was approved, the Town approved refuse collection rates for Greer. Valley's services. 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 B. At the same time that the Franchise Agreement was approved, the Town approved an agreement with Guadalupe Rubbish Disposal Company, which was and is wholly and privately owned by the same 4 shareholders who wholly and privately own Green Valley. C. The Franchise Agreement provides that Green Valley's rate adjustment applications during the term of the franchise are to consist of certain designated items and be subjected to review and comment by a Rate Review Committee consisting of a member from each of 4 West Santa Clara Valley jurisdictions (Town of Los Gatos and the Cities of Campbell, Monte Sereno, and Saratoga) that share related refuse collection situations. D. The Rate Review Committee is to consider the following in reviewing the proposed schedule of rates: i. The acceptability of expenditures, performance incentives and sanctions, rate comparability, and other information as the Committee determines to be appropriate. ii. When determining the profit level, use the operating ratio method with a five (5) percent after-tax return (excluding tax credits and operating losses) as a guideline. iii. When calculating the revenue side of the operating ratio, exclude: (a) Prior years' earnings from short-term investments generated from prior profits or retained earnings in each fiscal year; (b) • Tax credits; and (c) Prior year net operating losses. E. The Committee's recommendation is then to be forwarded to the Town Council 23 for consideration and determination of what are the proper expenses to be used in the 24 calculation of a rate base after Green Valley has been given a chance to provide documentation 25 to the Town, and for a determination of what rate adjustment if any is to be made. 26 F. The 1983 rate -setting resulted in a small profit in 1983-1984 to Green Valley, 27 which it reported at .7% for the 4 or 5 jurisdictions as a whole. 28 G. Green Valley then sought a rate adjustment in 1984, which resulted in an after-tax 3 profit from the five affected jurisdictions of some 11.3% in 1984-1985 and 2.5% in 1985-1986. H. Green Valley was granted a rate increase in 1986, which resulted in ai ,ax profit of 11.6% in 1986-1987, 12.8% in 1987-1988, and 4.7% in 1988-1989 from service in the Town of Los Gatos, according to Green Valley's own reports. I. Green Valley's operations were subjected to a performance audit in 1988 by Arthur Anderson as provided in the Franchise Agreement. The audit concluded that the profits that Green Valley was making usually exceeded the 5% guideline and that revenue and expenditure projection information supplied by Green Valley was inadequate to implement the franchise language. In addition, Arthur Anderson was unable to determine from Green Valley's financial statements how much profit was attributable to each of the 4 Green Valley franchises or to non -franchise activity. J. In 1989 and 1990, a new rate -making approach was developed to dampen the, effect that soaring disposal surcharges caused. A stand-alone approach to rates was adopted. in 1990 and reapplied in the 1992 rate -making. During these years, Green Valley reported the following after-tax profits from its Los Gatos operations: 1989-1990, a loss of 2.7%; 1990-1991, unreported; 1991-1992, 2.2%; 1992-1993, 4.0%. K. Over the franchise period in which Green Valley is able to provide financial information that estimates the expenses and revenues attributed to Los Gatos service, Green, Valley has been able to average a 5.5% after-tax, net profit per year according to its own calculations. L. In 1994, the Council sought public bids for a contractor to provide collection services of a wide variety of recyclable materials and yard waste, and after considering the bids received, the Town awarded a contract for recycling collection and a contract for yard waste collection to Green Valley. Those contracts are separate from the Franchise Agreement, but the rates to support those services are established through the Franchise Agreement rate proceeding. M. The current rate -setting proceeding was made a part of the routine 5-year performance audit under the Franchise Agreement. The performance audit was paid for by the 4 1 2 3 4 5 6 7 8 9 10 11 ratepayers from the 4 West Valley jurisdictions and a portion of the County of Santa Clara, and was conducted by Hilton Farnkopf & Hobson. The performance audit was approved by the Council on December 5, 1994, while reserving consideration of the operating ratio issues. Green Valley disputed a number of recommendations contained in the performance audit as discussed below. N. The Rate Review Committee then developed a rate base analysis for each jurisdiction and recommended rates for each jurisdiction. The report of the Rate Review Committee was accepted by the Council on January 3, 1995. The Committee Report contained a number of rate base alternatives, and this decision determines which alternatives are to be applied in the Town. 12 III. ALLOWED EXPENSES. 13 A. The Council confirms the normal operating expenses involved in service by Green 14 Valley in the Town with the following disallowances: 15 $20,584 of administrative expenses allocable to services performed by the Green 16 Team, which does not serve the Town; 17 $3,067 in employee costs also allocable to the Green Team; 18 Approximately $6,974 in advertising and promotional expense that is unnecessary 19 due to the exclusive nature of Green Valley's franchise; 20 Consultant fees as described in Section (V) below; 21 An $80,000 increase in salaries not proposed until the end of the rate proceedings 22 in December 1994 by Green Valley, which was not documented or justified, and 23 which would go to shareholders. 24 B. The rate base approved for 1993-1994 and 1994-1995 consists of labor, operating 25 costs, depreciation and interest, administrative costs, disposal fees, and franchise fees as 26 presented in the performance audit and as may be more fully described in these findings. 27 C. Disposal fees plus surcharges for 1993-1994 were as follows: $43.55 per ton 28 effective July 1, 1993; $42.36 per ton effective October 1, 1993; and $42.95 per ton effective 5 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 January 1, 1994. Disposal base rates for 1994-1995 are set at $26.60 per ton and -)sa surcharges are set at $16.36 per ton. Projected tonnage for the Town of Los Gatos for 1994. 1995 is 31,849 tons. D. The total approved budgets for 1993-1994 and 1994-1995 for the 4 West Valle‘, municipalities are set forth in Attachment 1 to these findings. These budgets are approved for illustrative purposes only, because each of the other jurisdictions holds separate franchises and authority to regulate Green Valley. The approved budgets for 1993-1994 and 1994-1995 for services in the Town of Los Gatos are set forth in Attachment 2 to these findings. The approved budgets for 1994-1995 were developed by applying the annual escalation factors as listed in the performance audit to the costs in each category and consistent with the ongoing requests of Green Valley for use of these types of factors. IV. FRANCHISE FEES. A. Over the life of this franchise, the Town has calculated its franchise fees on all revenues of Green Valley, including the franchise fees themselves. This appears to dou -ee Green Valley and the ratepayers, and therefore, this rate setting ends that practice. Franchise fees for the Town will be calculated solely on gross revenues without double -counting the franchise fee itself. This will result in a reduction in revenue to the General Fund of the Town of some $38,400 in 1993-1994 and $37,100 in 1994-1995, or roughly $37,000 thereafter, which will be direct savings to the ratepayers. V. CONSULTANT FEES. A. Green Valley paid Barakat & Chamberlin, Inc. [BCI] approximately $141,000 to assist it in responding to the performance audit and the current rate -setting process. In justifying its payments to BCI, Green Valley conceded that it does not have the in-house expertise to adequately participate in a rate adjustment proceeding without consultants; this is particularly true because of the time devoted to Green Team activities. Green Valley has the obligation under Section 5(D) of the Franchise Agreement to prepare its rate applications and 6 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 rate proceedings at its own cost. However, Green Valley has not presented any budget for the future retention of such expertise, whether in-house or by contract. In addition, there is nc apparent reason that better organization and training within Green Valley would not obviate the need for such consultant assistance. B. BCI made one presentation to the Town Council on November 21, 1994. It testimony focused on the profit entitlement of Green Valley and payment of its own fees as ar operating expense, and none of BCI's work appears to have addressed any issues of efficiency restructuring of accounting or customer service practices, ratepayer needs or desires, improvec container services, ratemaking alternatives, or other central issues in this ratemakin proceeding. BCI conducted no community outreach efforts and did not participate in an community forums on refuse collection or recycling. BCI did no analysis of the benefits of various profit -basis alternatives or projections of the effect of reductions in the numbers of cans picked -up. Following the November 21 meeting, BCI did not make any presentation to the Council or the public. It is therefore inappropriate for the ratepayers to bear the costs of thi.5 consultant work. C. In addition, the one-time waiver in this rate -making proceeding of the 17 requirement that Green Valley complete and file a comprehensive application for a rate 18 adjustment means that Green Valley has avoided the non -recoverable expense of preparing anc 19 processing such an application. Instead, the ratepayers and the general funds of the West 20 Valley jurisdictions, and .of the Town in particular, have had to bear the brunt of this. 21 proceeding. 22 23 VI. LEVEL OF PROFIT. 24 A. Green Valley contends that it is entitled to a 5% after-tax profit each and ever) 25 year of the franchise. Such an interpretation is inconsistent with the terms of the Franchise 26 Agreement, the best interests of the ratepayers, and the history of the franchise since 1983. 27 B. Green Valley made such large surplus profits in the mid-1980's from its franchise 28 in the Town of Los Gatos that it voluntarily allowed some of those surplus profits to be devotec 7 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 to holding the rates of service down for a short period of time. However, none of that lus profit was assigned investment return and the excess profits in 1984 were never credited to ratepayers. In addition, it appears that Green Valley has averaged approximately 5% after-tax profit over the entire term of the franchise. Given the fact that Green Valley has suffered some shortfalls in profit during 1992-1993, it is fair that Green Valley be granted some additional rate relief to pay for this estimated shortfall in past profit, and Green Valley sought an interim rate increase in 1993 for the 1993-1994 year, which was delayed in order to complete an adequate audit of the service. On the other hand, Green Valley has not provided the Town with any evidence that these shortfalls were necessarily incurred or that Green Valley made any efforts to reduce the alleged shortfalls. Given this situation, the Town finds that the estimated shortfall in profit from service in Los Gatos is $155,105 for 1992-1993, $239,765 for 1993-1994,. for a total figure of $394,870. C. The 5% after-tax profit guideline is not contained in the Franchise Agreement language outlining the Council's review of the rate adjustment application. However, the Council believes that 5% is a useful guideline in evaluating the estimated profits that en Valley should be allowed to take out of the Los Gatos service. D. Green Valley's refuse collection service in Los Gatos continues to involve almost no risk and almost no capital investment. There is no indication that any risk has increased since 1983, and in fact, the risk may actually have been significantly reduced as the community has proven to be built -out and stable. There is no indication of any billing or collection problems and no exposure of employees to any particular risks in making collections. E. The Council finds that 5% is a guideline as explicitly stated in the Franchise Agreement and not an entitlement or guarantee. The Council believes that the 5% after-tax profit can and should be varied to apply sanctions for poor or inadequate performance or service or reward for exceptional service or risk. While the on -street performance of Green Valley has been determined by the auditor to be acceptable, the provision of financial information, rate justification, and public information on proposed rates has fallen short of a reasonable standard. Therefore, it would be appropriate under the franchise for the Town to 8 1 1 3 4 5 apply a less-than-5% profit for the coming rate cycle. However, because of the volatility and uncertainty of refuse collection during the coming 12 to 36 months as recycling and yard waste collection develop in the Town, the Council is willing to allow the 5% after-tax profit on designated expenses. F. In resolving the issue of a shortfall in Green Valley's profits during 1985 to 6 present, Green Valley shall not be allowed an after-tax profit in excess of 5% until at least such 7 time as the next rate adjustment occurs. Any profits earned in excess of the 5% until the next 8 rate adjustment shall go to fund the balancing account established in Section VIII of this rate- 9 making. Should that balancing account deficit be paid off before the next rate adjustment, any 10 profits above the 5% profit allowance shall be deposited in an investment quality account for 11 the purpose of reducing the rate adjustment required by Green Valley during the next rate 12 adjustment. Principal and interest derived from that account shall be used to benefit the 13 ratepayers. The status of the Town of Los Gatos balancing account shall be separately itemized 14 and reported on an annual basis to the Rate Review Committee in Green Valley's financial 15 statement and audit pursuant to Section 7 of the Franchise Agreement. 16 17 VII. EXPENSES ON WHICH PROFIT IS TO BE BASED. 18 A. FRANCHISE FEE$. Green Valley has requested the Town to continue to 19 authorize Green Valley to take a profit on the franchise fees imposed by the Town under the 20 Franchise Agreement. Such a profit calculation does not seem to make sense, because the 21 Franchise Agreement calls for the franchise fees to be charged on gross revenues, apparently 22 including Green Valley profit. However, profit has been allowed on franchise fees since 1983, 23 and there is no evidence that any aspect of the franchise fee or its basis has significantly 24 changed since 1983. Therefore, the Town will continue to allow the Town franchise fees to be 25 included in the calculation of the operating ratio and allowable profit for Green Valley. 26 B. DISPOSAL. BASE RATES. Green Valley has requested the Town to continue 27 to authorize Green Valley to take a profit on the disposal base rates charged to Green Valley. 28 Refuse is usually disposed at the Guadalupe Landfill, which is wholly owned and operated by 9 1 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 the Guadalupe Rubbish Disposal Company. The allowance of profit on these base r2 's a difficult question. Green Valley bears little risk with regard to these base rates, because the Town has separately contracted with Guadalupe to allow Green Valley to dispose of as much refuse and trash as Green Valley delivers from the Town. Green Valley expressly disclaims any contractual relationship with or ability to influence any operation or charge of Guadalupe. In addition, Green Valley has no incentive to seek alternative disposal sites because of the Town contract with Guadalupe and actually earns windfall profit when Guadalupe increases its charges. However, the Franchise Agreement requires Green Valley to dispose of rubbish and trash whether or not the Town has designated a disposal site. As with franchise fees, the Towr has allowed profit on disposal base rates since the inception of the franchise in 1983, anc disposal base rates have not increased dramatically since that time. Therefore, the Town wil. continue to allow the disposal base rates to be included in the calculation of the operating ratio and allowable profit for Green Valley. It is noted that Green Valley was unable to satisfy the Council's and public's concern! about the handling of yard wastes and assessment of costs by Guadalupe Rubbish I )sa Company. Green Valley asserts that it has no contractual relationship and no influence ove. the Landfill Company. Instead, Green Valley asserts that the Town alone bears responsibilir for disposal through its contractual arrangements, and Green Valley is merely a delivery service subject to Town direction in landfill matters. C. DISPOSAL SURCHARGES. Green Valley has requested the Town to resume authorization of Green Valley taking a profit on the disposal surcharges passed through Gree: Valley. At the time that the Franchise Agreement was signed, there were no surcharges o disposal base rates. The first surcharge on solid waste disposal was imposed in 1987-1988, an the total of all such surcharges remained de minimis at less than $1 per ton until 1990-1991. The surcharges on the disposal of refuse then soared dramatically beginning at $5.08 pe ton, to $15.99 per ton in 1992-1993, and reached $16.36 per ton in 1994-1995. The princip contributor to that increase has been the imposition of a disposal tax by the City of San Jos4 10 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 VIII. BALANCING ACCOUNT. Any profit on these surcharges has not been earned in any way by Green Valley, poses no risk of any kind to Green Valley operations, and would be a fortuitous windfall. Disposal surcharges, like disposal base rates, are charged to the Town by Guadalupe as part of the 1983 agreement to which Green Valley was not a party. Guadalupe Rubbish Disposal Company voluntarily incurred these fees and surcharges by initiating annexation to the City of San Jose. Neither that annexation nor the surcharges benefit the customers of Green Valley in the Town of Los Gatos. In addition, the Town along with a number of other municipalities have filed suit in a California Superior Court seeking to overturn the City of San Jose surcharges, and the Town has incurred significant legal expense in that proceeding. Green Valley has neither joined nor supported that litigation in any way. Beginning in 1990, the West Valley jurisdictions began disallowance of profit on disposal surcharges. Green Valley has not provided any persuasive argument or reason why that disallowance should not continue. Therefore, no profit on disposal surcharges will be allowed to Green Valley, but Green Valley will be allowed to recover its actual expenses for such surcharges. 19 A. According to Green Valley's testimony, the theory that there may be a balancing 20 account deficit evolved from the rate -making in 1992, in which a standalone year was used to 21 set rates. Green Valley asserts that its profits fell short of the 5% mark during the years 1992- 22 1993 and 1993-1994. Green Valley's representative, Gerard Wen, testified that following the 23 conclusion of that rate -making, Green Valley spoke to one or another unidentified city manager 24 who apparently assured Green Valley that the next rate -making would make up a profit 25 shortfall. The Town Council neither received any notice of such a side agreement nor agreed 26 to such a rate system. 27 B. A balancing account system is inconsistent with the terms of the Franchise 28 Agreement, which requires Green Valley to provide a 3-year budget as part of any rate 11 adjustment application. Green Valley has not been able to provide such a 3-year budge ing this proceeding. Town staff hypothesized that the reason for this was that the recycling and yard waste programs leave a large number of variables in any such budget, so that it is very difficult to predict the revenues and revenue sources; however, neither Green Valley nor its consultants, BCI, have provided the Council with a 3-year projection. C. Green Valley demanded that the ratepayers of the Town pay off the "balancing account" deficit in a single calendar year. Green Valley estimated that this would require an additional 100% increase in refuse collection rates above the staff recommendation, from $6.65 per can now to $21.50 per can under Green Valley's proposal. Without any financial analysis. Green Valley argued that if the Town failed to grant this immense increase, G en Valle would be unable to obtain credit lines from banks and might operate at a loss. The audited financial statements of Green Valley prepared by Hood & Strong, Green Valley's own audit firm, show that Green Valley has made a significant profit in both 1993 and 1994, and that Green Valley holds a largely unused line of credit of approximately $500,000. Green Valley has not provided any cash flow analysis that indicates that Green Valley has any fore ble expenses that would jeopardize its financial position should any such "deficit" be paid off by the ratepayers in a measured time period of 41 months, consistent with. 3-year budgeting set forth in the Franchise Agreement. Should Green Valley actually . r financial jeopardy. Green Valley is free to apply for rate relief at any time. D. Green Valley also demanded a higher calculation of a "deficit" than the Council is willing to award. Green Valley has averaged a 5% annual, after-tax profit over the life of the franchise. Green Valley's calculations discount its excess profits in the 1980's and its usage of excess revenues from Los Gatos service to reduce rates in Saratoga. The ratepayers of the Town of Los Gatos owe no more than an average 5% profit and the reasonable "deficit' amount determined in this Decision by the Council will bring Green Valley up to or above ar average 5% profit for the franchise to date. E. Green Valley also demanded that the ratepayers pay interest on the unpaic "balance" in the deficit of the balancing account. Green Valley conceded th it had no 12 2 3 4 5 6 7 8 9 10 11 12 13 14 15 attributed any interest to the excess revenues it had received in the 1980's from Los Gatos ratepayers but the loose oversight in effect at that time allowed those excess revenues to be diverted in part to support lower rates in Saratoga. Therefore, there is no quid pro quo to be served by awarding interest to Green Valley on this supposed deficit, and no interest will be awarded. F. Green Valley's audited financial statements prepared by Hood & Strong, Green Valley's auditors, do not disclose or note any balancing account, account receivable analogous to a balancing account, or any debit or credit related to any such balancing account. G. It is the intention of the Council to eliminate the use of a balancing account and fully return the franchise to the original requirements for a 3-year rate -setting in which Green Valley bears risk and is rewarded for efficient performance, and the Council hereby revokes any waiver that may have occurred with regard to the requirement of a 3-year budget submittal by Green Valley as the basis for rate adjustments. Therefore, the current rate -setting adopts the balancing account system set forth in Attachment 3 only until such time as the compromised amount is paid as shown in the Exhibit. 16 17 IX. TAX RATE FOR CALCULATION OF AFTER-TAX PROFIT. 18 A. Green Valley has an obligation to the ratepayers to seek and use the most cost 19 effective tax basis available. The Town has neither dictated nor approved any particular tax 20 status during the franchise history. 21 B. Green Valley is unable to divulge what its actual income tax rates or payments 22 have been or are estimated to be. Instead, it has urged usage of a top bracket rate of between 23 45 and 49 percent. This is based on Green Valley's current status as an S-Corp, which means 24 that the 4 individual shareholders are taxed, rather than the corporation. Green Valley is not 25 entitled to attribute more than its actual tax expense in calculating an estimated after-tax profit. 26 The Consultant who performed the performance audit recommended that a tax rate of 35% be 27 used. 28 C. The Town contacted the California Public Utilities Commission to determine what 13 1 the normal practice was with regard to privately held corporations, and the PUC app a 2 standard C-Corp so that issues of highly individualized income tax brackets, affluence, poor tax 3 planning, and so forth do not control the rates charged and penalize the ratepayers. 4 D. The Town presented Green Valley with a 40.138% tax estimate which would 5 account for a standard Federal and State C-Corp income tax bracket. Green Valley had no 6 opposition or evidence to offer in opposition to that estimate. Therefore, the tax estimate for 7 this rate setting to be used in calculating the after-tax profit shall be 40.138%. 8 9 X. DIFFERENTIAL RATES. 10 A. Many members of the public requested that Green Valley provide rates that 11 would differentiate on the basis of amounts or types of refuse as well as types of residential 12 structures. Green Valley reported that its accounting systems required manual input and did 13 not have the necessary flexibility to make these alternatives cost effective. In addition, Green 14 Valley reported that use of a mini -can rate would not create meaningful savings, and other 15 ratepayers would bear the costs of providing that service. Green Valley did not have ost 16 effective means of supervising composting customers, and once again the other rate payers 17 would bear a heavy burden for providing such an exemption. Green Valley further reported 18 that technology might lead to the use of a system that would weigh individual garbage upor 19 pick-up and provide a billing system that would charge by weight, which is the ultimate goa 20 imposed by the State Legislature for solid waste reduction; however, such a system is in th+ 21 distant future. 22 B. Therefore, the Council finds that a senior citizen/disability rate available only t 23 those receiving Supplemental Security Income from the Social Security Administration 24 approved as shown on Attachment 4, so that this rate adjustment will not have too severe a 25 impact on those least able to pay. 26 C. However, the need for recycling, yard waste disposal, and reduction in the sol 27 waste stream is community -wide, which everyone must share. The proposed rates and the wic 28 array of services that will follow make the rate structure among the very lowest in the S; 14 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Francisco Bay Area. A share of the residential cost is already being borne by the comrnercia sector. It would not be fair to families and large households to unduly penalize them and tc increase rubbish collection rates by another 100% to provide a small benefit to those whc reduce their trash flow. Because the Town does not require trash collection subscription, there are a wide variety of private efforts and arrangements that can be made that would not unduly penalize the majority of ratepayers. D. Therefore, for the current rate -making the rate schedule attached hereto a Attachment 4 is adopted. However, the Council will welcome any future proposals that woulc reward persons who reduce their solid waste stream so long as they do not unduly penalize normal users who have little or no choice in reduction. The Council expects that Green Valle\ will take the Lead in seeking such solutions. In addition, it is hoped that the recycled yard waste will be returned to residents as compost. XI. CONDOMINIUM/TOWNHOME COMPLEXES. A. The Council received a great deal of public comment regarding recycling and yarc waste collection in the condominium and townhome complexes. Green Valley assured the Council that it has a program in place to address these concerns and will pursue outreacl- programs to address these concerns and not double charge for such service. Green Valley unable to obtain the cooperation of Guadalupe Rubbish Disposal Company in creating a viable yard waste acceptance program at the Landfill. It is also noteworthy that other service providers can establish yard waste receiving facilities in Town without interfering with Green Valley's collection contract with the Town. B. Green Valley has assured the Council that the public's concern on these matters will be resolved. 25 26 XII. OPERATING RATIO. 27 A. The ultimate result of the decisions made in this rate -setting is that an operating ratic 28 of approximately 93.3% on all expenses will be established for 1993-1994 and 1994-1995. 15 1 2 3 4 5 6 7 8 9 10 11 12 l3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 B. These operating ratios are consistent with the operating ratios throughout Ba Area, and Green Valley has not demonstrated any demand from investors, banks, or potentia purchasers for any different operating ratio. C. These operating ratios will provide Green Valley with a fair and reasonable rerun on expenses. XIII. RATES ARE JUST AND REASONABLE TO THE RATEPAYERS. A. The rates established in Attachment 4 are just and reasonable to the ratepayer in the Town of Los Gatos. XIV. MISCELLANEOUS. A. Nothing contained in this decision shall be construed in any way as binding or applying to any rate -making decision or interpretation by the Cities of Saratoga, Monte Sereno. or Campbell, and this rate -making decision is made in the best interests of the refuse, recycling, and yard waste collection services for the citizens of the Town of Los Gatos alone. B. Green Valley has elected to place similar issues of profits on franchise fees and disposal costs, and other related issues before the U.S. District Court for the Northern District of California in a lawsuit against the City of Monte Sereno. The Town has acted fairly in light of Green Valley's assertions and representations; should the Federal or State Courts in the Monte Sereno litigation determine that the allegations of Green Valley regarding entitlement to profits and balance accounts are incorrect or untrue, the Town reserves the right to review those allowances as excess and unearned revenue for purposes of future rate -making. C. Green Valley has asserted that prior rate decisions, statements by Rate Review Committeemembers, or other occurrences have created ambiguities in the Franchise Agreement that have devalued the Council's authority to set rates and the ratepayers' right to a just and reasonable system. The Council does not agree with Green Valley's position, and one of the purposes of this written decision is to minimize Green Valley's opportunity to hypothecate ambiguities in the future. 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 D. Under the State Government Code and the Town of Los Gatos Town Code, any amendment to the Franchise Agreement or any agreement between the Town and Green Valley requires the authorization of the Council. E. The rates established by the Town and the approved budgets for Green Vallev1 in this rate -making process are integrated decisions, and should any part of this rate -making be determined to be invalid or illegal, the entire decision must be reconsidered and the rates and budget reevaluated in light of the invalidity or illegality, and no part of this rate -making process or budget shall be severable. 17 ATTACHMENT 1 TOTAL APPROVED BUDGET FOR GREEN VALLEY FOR FISCAL YEAR 1993-1994 (FOR ILLUSTRATION PURPOSES AS THE OTHER 3 WEST VALLEY JURISDICTIONS SEPARATELY CONTROL THEIR BUDGETS AND RATES) LABOR OPERATING COSTS DEPRECIATION AND INTEREST ADMINISTRATIVE COSTS SUBTOTAL DISPOSAL COSTS FRANCHISE FEES TOTAL OPERATING EXPENSES PRE-TAX PROFIT INCOME TAXES AI. 1 ER -TAX PROFIT $ 3,960,451 1,642,745 655,024 437,396 $ 6,695,616 $ 4,427,815 * 1,29L007 $12,414,438 $885,743 **(355,520) 530,223 +- * Green Valley underestimated fees in its proposed budget by $36,336 ** Assumes that the other 3 jurisdictions adopt a 40.138% tax rate, over which the Town has no control 18 ATTACHMENT 1 "Tb EC,t1#&r A TOTAL APPROVED BUDGET FOR GREEN VALLEY FOR FISCAL YEAR 1994-1995 (FOR ILLUSTRATION PURPOSES AS THE OTHER 3 NEST VALLEY JURISDIC:IIONS SEPARATELY CONTROL THEIR BUDGETS AND RATES) LABOR OPERATING COSTS DEPRECIATION AND INTEREST ADMINISTRATIVE COSTS SUBTOTAL DISPOSAL COSTS FRANCHISE FEES TOTAL OPERATING EXPENSES PRE-TAX PROFIT INCOME TAXES AFTER-TAX PROFIT ** $ 4,038,425 1,700,241 655,024 455,564 $ 6,849,254 $ 4,664,081 1.242.763 $12,756,098 $914,290 * *(366,978) $547,312 Assumes that the other 3 jurisdictions adopt a 40.138% tax rate, over which the Town has no control 19 ATTACHMENT 2 TOTAL APPROVED BUDGET FOR GREEN VALLEY FOR FISCAL YEAR 1993-1994 FOR SERVICE IN THE TOWN OF LOS GATOS LABOR $ 1,250,534 OPERATING COSTS 531,739 DEPRECIATION 202,566 AND INTEREST ADMINISTRATIVE 125,778 COSTS SUBTOTAL $ 2,110,617 DISPOSAL COSTS $ 1,321,721 FRANCHISE FEES 370,707 TOTAL OPERATING $ 3,803,046 EXPENSES PRE-TAX PROFIT $274,732 INCOME TAXES (110,272) AFTER-TAX $164,461 PROFIT 20 ATTACHMENT 2 'Ta EX Mar& TOTAL APPROVED BUDGET FOR GREEN VALLEY FOR FISCAL YEAR 1994-1995 FOR SERVICE IN THE TOWN OF LOS GATOS LABOR $ 1,294,549 OPERATING COSTS 550,454 DEPRECIATION 209,696 AND INTEREST ADMINISTRATIVE 130.205 COSTS SUBTOTAL $ 2,184,904 DISPOSAL COSTS $ 1,368,242 FRANCHISE FEES 383.755 TOTAL OPERATING $ 3,936,901 EXPENSES PRE-TAX PROFIT $284,402 INCOME TAXES (114.1531 AI-1 ER -TAX $170,249 PROFIT 21 Town of Los Gatos Balancing Account 3-Year Amortization Schedule 1994-95 1995-96 1996-97 1997-98 Revenue from 4,176,365 3,622,069 5,622,069 6,122,433 Current Rates (b) Revenue 4,979,552 5,558,262 5,752,801 5,954,149 Requirement Current Surplus/ (Deficit) Beginning Surplus/(Deficit) Interest on BA (803,187) 63,807 (130,732) 168,284 (394,870) (595,680) (531,873) (162,242) Ending Surplus/ (1,198,057) (531,873) (662,606) 6,042 (Deficit) before rate adj. Amortized Portion (a) 602,377 0 500,364 0 Ending Surplus/ (595,680) (531,873) (162,242) 6,042 (Deficit) Required Rate 24.10% 0.00% 8.90% 0.00% Adjustment Assumptions: Operating Ratio Inflation Rate Interest Rate 5.00% after-tax profit on op. exp. excl. disposal surcharges 3.50% 8.75% 1994-95 rate adjustment effective 2/1/95 No rate adjustment on 7/1/95 1996-97 rate adjustment effective 7/1/96 1994-95 revenue requirement includes 5 months of g/w and recycling 1995-96 revenue requirement and beyond includes 12 months of g/w and recycling (a) 1994-95 amortization includes an additional $183,000 generated from residential rates (b) 1995-96 revenues and beyond include an additional $439,200 from residential revenues ATTACHMENT 3 TD EXW/13,T A il , It- oi i st• ''J < d iii 11 I ii IP ,4 jil, I I]1 __ hi 1 t.)th iii I II xrliDTt 4 ATTACHMENT 4 &kHi/3 iT A � g H I ATTACHMENT4 -ro EX"8rr'4 ji aleleebevebe g eget et bit it of Or le be te 8��s�6^•,g7.1B$88.0888 7A M ~ Waannaniall 1 ;;Fla NMNMx Eag ss „ „Illnx!!!x!!'''q 11f11M1135;;511; ! 2!! N 0 0 0 0 0 0 0 0 0 1:3 gi -1 mA*^0000000000 Tisss 33333333J333333d X a P a 1 ATTACHMENT 4 'Tt5 5YN/Aep-A K K it K f K K K K rt li K*KKKKKKK�Ra����t��t K 2 =�'� X - 0 60 0^ E3 $�2NA�RAbi�AaRA6t5�R a ailiarmants QI $Rgq$P1881$$bt$c l88 RNila$s!aa as a�; M N N ci N n .r O 8 WI • O Of CO 0 0 0 0 0 0 0 0 0 0 a P.s CO ^ CD g 0 ;It CD I) O O O O P P o 0 0 0 0 s A 4 a I1; I 'A a ATTACHMENT 4 TO Exm8a 4 a, �g *a.eriest+,K N ry ry N N N N N agiax 888 MUddd a v N N ., Ngl A N N N N d ^ odd d ill 2.1-VaPi q;;;P: Nt '+ N .-00 0 a N N N N N (V N _xh!bit B ;;In HAIM Pinlan ^.�.►�0000 322*0v a o 0 N l0 M 1H a ATTACHMENT. 4 'TO exHi 6,7 A apg K K K K* yt K of d • r v vi N N N N N N N N qH1& aR ,. 04 ... o 0 a 1 it a K K it * K* d K♦ rt K* K 71 74 r. J C 1 N N N N N N N N N N N N N gddddriii v3 .j iiii bC «. elmmqung 51311CIIMM ggsleeoo••. .. 1 a ATTACHMENT 4 Tb eows rr A # , * 4 i'V N ry N Plii 91.1 0114 il v s .i 4 d N ry N N N ry N 8888888 kitURgikgt 88a 8888 8 N 8 a ATTACHMENT 4 - 0 pern6rf Exhibit C Page 2 DOB rates reflect a policy of having the DOB customers pay for the weight of debris. Accordingly, customers wV! be charged S52.00 per ton for the weight over the Mowed limit. Since disposal fees are based on weight, this system provides equity. CUBIC YARDS PRICE ALLOWED WEIGHTS 18 S362 1.5 tons 30 5510 4 5 tons 40 S575 5.5 tons 6 $396 N/A There is no per -ton charge for the six cubic yard box. These six cubic yard boxes are picked up by another vehicle which picks up several of these size bins before being weighed. This means the customer can put out as many tons as s/he can fit into the six cubic yard box. The price is set so that there are enough revenues to pay for the tipping fee on the expected tonnages C SD 19: k \ wildwst\dobohart sum ATTACHMENT 4 EXtiigfl JAN 2 7 January 25, 1995 Ms. Regina A. Falkner, Community Services Director Town of Los Gatos 110 E. Main Street Los Gatos, CA. 95030 RE: Green Waste Disposal Dear Ms. Falkner, On behalf of the homeowners of Los Gatos Woods, I thank you and the Town Council members for considering the special circumstances of our green waste disposal and requiring the Green Valley Disposal Company to work with us to find a mutually acceptable solution to our problem. As you know, there existed a potential for us to pay both Green Valley and our landscape contractor to provide green waste removal services, and we do not have any place on our property to put a large dumpster in which to collect this waste. However, we have discussed this issue with Mr. Phil Couchee and Mr. Mark Zanardi of Green Valley, and we have reached an agreement that we believe is acceptable to all concerned. The Town of Los Gatos will get credit for the recycling of all the green waste, and neither our homeowners nor our landscape contractor will have to pay extra to dispose of this material. We will begin this procedure effective February 1, 1995, and we will advise if there are any problems. Once again, a special thanks to you and the council members for your concern and assistance. Sincerely, William B. Phillips, President Los Gatos Woods HOA 102 Abby Wood Ct. Los Gatos, CA. 95032 Copy: Mr. Phil Couchee, Green Valley Disposal Mr. Mark Zanardi, Green Valley Disposal C,c '. loom t ATTAGMMNT. 2 170 Lester Lane Los Gatos, CA. 95032 1-21-95 Regina Falkner 110 E. Main St. Los Gatos, CA. 95032 Dear Regina We feel you have done a very good job on the Solid Waste reports, it must have been extraordinarily difficult at times, and from our point of view GVDC wasn't always very co-operative. You really got dumped on a time or two, not encouraging. Now the worst is over you might even be able to sleep at nights! The outcome is not "good" for any of us, but we are sure it is the fairest to the majority of the townspeople. Sincerely Bill & Anne Bilkiewicz ATTACHMENT 2 1• January 26, 1995 Mr. Dennis Varnie, Owner Green Valley Disposal Co. P.O. Box 1227 Los Gatos, Ca. 95031-1227 TOWN MANAGER T: (r - 2•(o pis rup0,,..) 4-, _. _ g. '4“o6.414( 125 Sioatom6:lea i'ay lot C'-intot �.aLi f a 030 Dear Mr. Varnie I am single living on a small fixed income. My neighbor is single living on a fixed income. We both have garden service, therefore we do not create yard trash and create very little garbage. I don't take the news paper, therefore I don't create any paper. My neighbor takes the news paper and creates about one small box a week. Between us we have about one small box of bottles (plastic/glass) and cans per month. Since we are both on a fixed income would Green Valley Disposal Co. consider picking up garbage at one address only so my neighbor and I can share the bill? 1 a- (4), We are being squeezed to death with bills. Your rate increase effective February 1, 1995 of $15.75 per month compared with current $6.65 for the same service is ludicrous. Sincerely yours, Howard G. Theobald cc: David W. Knapp,Los Gatos Town Manager Susan Hammer, Mayor, City of San Jose Jim Cunneen, Assembly Member Twenty -Fourth District Norman Y. Mineta, Congress of The United States Connie Skipitares, San Jose Mercury News Dale Bryant, Editor Los Gatos Weekly -Times ATTACHMENT 2 eAret TOWN MANAGER Roca! To: t14• pr 1� _7 i l Cyr To: \ 2- I. - - — / Muir / ;/ 74-e Z41- 74C---17, 42_ 46--C-14 E , l /7ijc ,/laa �.fvP p ATTACHMENT. 2 Account No. 1900637 January 30, 1995 Green Valley Disposal Company, Inc. P.O Box 1227 Los Gatos, Ca. 95031 Steven A. McDonald 205 Caldwell Ave. Los Gatos, Ca. 95032 7--- "S • FEB —1! Dear Sirs: This letter is a STRONG protest against the new collection rates and service. Presently I am paying $59.85 for three cans every three months. With the new rates, I will be paying $151. 17. This is almost three times the present rate and is totally unacceptable. I tried to call all day long on January 30, 1995, but got busy signals each time. For an age of communications, this is also unacceptable. You should at the very least have an answering service that can either take messages or put the caller in a queue. I do NOT want the large brown 96 gallon container. We have a very small lot, and there is no place to put this where it would not be an eye sore. I will NOT be using this container, as I have a gardener that comes weekly and takes away the clippings. Even when we didn't have a gardener, I never had as much clippings as you suggest in your letter. Consequently, I would like the following performed: a) Reduce the number of cans from three to two. b) Let me know when you want me to place the large 96 gallon container out for you to pick up and take away. c) Reduce our monthly fee to compensate for not using the 96 gallon container. I am sending a copy of this letter to the Town of Los Gatos as well. I would appreciate a quick response to the above. Could you please send me correspondence that indicates you have addressed the above requests. Thank -you for your quick response. Sincerely, CC Town Of Los Gatos ATTACHMENT. 2 �C. - tC 123 Vasona Oaks Drive Ot3 .jAN 2 Los Gatos, CA 95030 January 27, 1995 Town Council Re: Garbage Rates Dear Town Council Members: You have just approved raising the garbage rate 137% on my stre& without doing anything additional for us! We are a planned development and pay our gardening service to dispose of our yard clippings. If our service pays more to recycle those materials the cost gets passed on to us. We pay twice! The CPI is up about 2% this year. You are raising our rates 68 times as much as the CPI!!! Green Valley Disposal was in business for profit prior to this rate hike. It was unconscionable for you to raise rates on PUD's that haul their own yard clippings the same as everyone in single family neighborhoods. We do not need nor will we accept 96 gallon recycle bins. No garbage company money will be spent on the additional recycling in this development. All the PUD's in Los Gatos represent a sizeable portion of your constituency. Perhaps we need better representation. Sincerely, 4—LAI Harvey Orndorf 408 358-1111 X 106 cc: David Knapp Los Gatos Weekly ATTACHMENT 2 January 5. 1995 JAN j Da\ c Knapp. Town Manager T. ,cc n , Nt Los Cato. Los Gatos. C.a. 95030 RE. New garbage recycling program. Dear Da' e. A, .a single u„man. 1 ha\c worked kcn hard it' maintain. improne and keep my hi 'me in Los Gatos !especially :liter sustaining he:i earthquake damaec i...\. a homeow nor in L. Gatos since 1976. . 1'c e rev er w rtuen to request help. until now . But I hays encountered a problem in trying to comply pith the new recycing requirements. I am requesting the To n's help in the follow ing matter. `lv house on Rose .-Avenue is at the end of a 180 toot -lung do enay that 1 share with my neighbor. For 19 scars. I ha\c contracted v ith Green Valley Disposal for "remote pickup .en ice "---- a Green Valley Disposal person 'without the truck) comes up the narrow Uri cw ay to get the garbage cans. When thc recycling of cans. `_lass and plastic bottle was initiated. I called Green Valle% and requested remote pickup for those as w ell. I w as told that they w ouldn't do it. Recytmg means six to eight 360 toot round tnps of garbage -carrying weekly for myself and my secondary unit. I recycle infrequently. in good weather. when my back is not out, only plastic and alumumin. 1 have never, frankly. recycled my glass new papers. magazines and cardboard (they arc just too heavy to carry so tar). No one should be expected to Jeopardize their health in order to cam' irtuully all their garbage literally miles eyes month in any weather ( 8 round trips n 360 feet x 4 weeks = 11,520 feet or approx. 2 miles). Nor should one expect a renter to do the same ( there may be liability issues for me as a landlord to request a tenant haul their trash that distance). Further. raising the rent on y' hat is currently affordable housing to maintain the current remote pick up sell ice is a ridiculous and unnecessary penalty. 1 recently called Green Valley Disposal hoping the expanded recycling program would necessitate a revision of their policy on remote pickup. t got the same answer i.e. carry. all my recyclables 180 feet to the curb ....or pay the high new charges. maintain the remote pickup service and don't recycle. I do not understand not do I appreciate Green Valley's poor approach to customer sen ice. With the new recycling program, they will be charging me as much as I pay now for less service or more money for thc same sen ice. Green Valley Disposal should be providing the same level of pickup service for non -recycled rad recycled material. And it they won't pro\ ide equi\ alent pickup service for recycled matenal. then I should not be financially penalized with increased tees for non -recycled remote pickup. 1 understand that the Town of Los Gatos, needs its citizenry to recycle and 1 want to cooperate. Ethically and morally. 1 prefer to recycle and would do so-- it Green Valley would provide some reasonable solutions for people who don't be on normal streets. ft doesn't make any sense, to discourage a citizen's nght actions by eliminating the service that enables and facilitates the performance of that action. Please help me in changing this unfair rule that Green Valley has created to its own advantage at the expense of customer service. Sincerely. Patncia (Patti) Wilson 15880 Rose Avenue Los Gatos, CA, 95030 354-1964 cc: Town Council. Mayor of Los Gatos, Green Valley Disposal TOWN MANAGER Reco veg: - / S ' ys To:- [K} Atlon-1..�t i/if �wsr1L latummeoot '6aryT« ATTACHMENT. 2