HomeMy WebLinkAboutCity of Diamond Bar WM Letter Response 1.19.2021 Final-signed (002)
January 19, 2021
Via Electronic Mail
Mr. Daniel Fox
City Manager
City of Diamond Bar
21810 Copley Drive
Diamond Bar, California 91765-4178
Re: Waste Management’s Response to City of Diamond Bar’s January 7, 2021
Correspondence – Force Majeure Notice Due to COVID-19 and Resulting
Declarations of Emergency and Executive Orders
Dear Mr. Fox:
On behalf of USA Waste of California, Inc. (Waste Management), this letter responds to the City
of Diamond Bar’s (City) correspondence dated January 7, 2021. The speed with which the COVID-19 is
ravaging our communities has forced the State and local governments to issue sweeping Stay-At-Home
orders and directives aimed at preventing the spread of the coronavirus including quarantine and isolation
requirements for all workers. Waste Management has made every effort to provide essential services
throughout the global COVID-19 pandemic while simultaneously complying with these orders, vital to
protecting our employees and the communities in which we serve. In this regard, we have implemented
strict screening protocols, social distancing, mandatory use of masks, regular cleaning and disinfection,
testing, remote working, etc.
As of January 19, the County of Los Angeles has over 1 million COVID-19 cases and nearly 14,000
deaths and daily counts are shattering prior records. In spite of our significant efforts, the COVID-19
pandemic has unfortunately struck our staffing levels both in the field and in customer service. We have
been forced to immediately implement modifications to our service – specifically, alternating recycling
material and green waste collection service – to avoid interruption of essential trash collection and disposal
services. This situation is not unique to Waste Management and, in fact, Waste Management has taken
less drastic steps than those service modifications authorized by the County of Los Angeles or implemented
by other haulers in the region. Indeed, the County of Los Angeles, recognizing the serious impacts caused
by the pandemic to waste hauling companies, has authorized postponement of certain services such as cart
exchanges until at least July 1 and permitted:
• 3-week delay in Bulky Item collection
• Extending collection hours to 8:00 p.m.
• Commingling of trash, green waste and recyclables.
The County Public Works has taken these necessary steps in response to these extraordinary times in order
to support the industry in providing continued essential waste collection services.
WASTE MANAGEMENT
9081 Tujunga Avenue
Sun Valley, California 91352
(800) 926-9693 Customer Service
(818) 252-3252 Customer Service
(818) 252-3247 Fax
Mr. Daniel Fox
January 19, 2021
Page 2
As I am sure you can appreciate, the operational change – alternating weekly recycling material
and green waste service – we implemented to accommodate for our serious COVID-19 staffing impacts has
far less impact on the City and its residents than what has been deemed appropriate in these times. Contrary
to the City’s assertion, Waste Management’s plan to temporarily alternate recycling material and green
waste services does not amount to “unliateral” actions that are somehow in default of the Agreement.
Section 11.4 of the Agreement expressly excuses performance due to force majeure events. The
City fails to cite the entire provision at issue and instead focuses on language that appears to support the
City’s position, but actually does not. First, the COVID-19 pandemic indisputably qualifies as a
“catastrophic event.” Second, the next paragraph makes it clear that Contractor’s performance is still
excused even if other services “such as . . . electricity, gas, water or commercial solid waste collection
services” are not disrupted. The relevant provision which was overlooked states:
Notwithstanding the foregoing, however, if Contractor is excused from performing its obligations
hereunder for any of the causes listed in this section, City may contract with another provider to
perform all or part of this Agreement until such time Contractor is able to perform. If Contractor
is unable to renew its performance of this Agreement for a period of thirty (30) days or more, where
the City is not significantly impacted by the catastrophic event, City shall nevertheless have the
right, in its sole discretion, to terminate this Agreement by giving ten (10) days' notice.
Based on this provision, the City cannot insist on performance during such a catastrophic event, but it can
try to obtain substitute service until the Contractor “is able to perform.” Moreover, the City’s position that
Waste Management is precluded from asserting force majeure due to the catastrophic COVID-19 pandemic
because “electricity, gas or water” continue to be delivered flies in the face of logic and would render the
provision superfluous, a result loathed by courts. The delivery of electricity, water or gas simply does not
require staffing (i.e., drivers). In any event, those utility services have in fact been modified and limited to
the extent personal visits are required to a customer’s residence. In sum, there is no question that the force
majeure provision has been triggered.
Finally, Waste Management’s contract with the City requires Contractor to “comply with all
applicable laws and regulations of the United States, the State of California, and any federal, state, regional
or local administrative and regulatory agencies, now in force and as they may be enacted, issued or
amended.” Contract at Section 12.02. Waste Management is doing exactly that. Indeed, as noted in our
previous correspondence, Waste Management has taken swift and aggressive action to comply with federal,
state and local mandates and directives in connection with the current public health crisis, including the
recent quarantine, isolation and testing protocols and procedures mandated by CalOSHA. Waste
Management cannot be penalized for complying with laws that then result in a temporary change in
services.
We are disappointed that the City has chosen to challenge and threaten Waste Management with
default. Our teams are working around the clock to meet the challenges of the COVID-19 pandemic. The
City was notified in March and recently by telephone and email on December 24, 2020, that certain services
would be altered due to this force majeure event. These notifications were prompt and timely under these
circumstances where material changes in our operating conditions are occurring daily. With regard to
notifications to customers, as our PSS Manager explained we did commence notifications to customers
regarding the alternating recycling material and green waste service; however, we had significant technical
difficulties that have since been resolved. In addition, as we have informed the City, our customer service
center has reduced staffing due to impacts from COVID-19. We look forward to and urge the City to
partner with us through these unprecedented times to best serve the community and protect the health and
safety of its residents.
Mr. Daniel Fox
January 19, 2021
Page 3
The following responds to each of your specific requested actions:
1. Submit a formal operational plan with requested service changes, necessary metrics or other
conditions that need to be achieved to restore full services, and a planned end date.
Attached to this letter as Exhibit A please find the requested operational plan. With respect to the
City’s request that we provide an estimate of when regular collection operations will resume, we have no
reasonable way to predict that at this time. However, we will provide the City with prompt notice once the
decision has been made after the staffing impacts from COVID-19 have ended.
2. Identify an appropriate credit for affected customers and identify how that will be implemented.
We are unable to offer a credit for the temporary imposition of alternative recycling material and
green waste service. While such service is alternating, we are still collecting and processing the same
volume of recycling material and green waste and, to mitigate any impact to the customers, we have also
agreed to accept bagged material, which requires extra work. Moreover, this modification in service has
not resulted in cost savings.
Throughout this pandemic, our staff has worked 24-7 and has made every effort to deliver essential
services. Indeed, Waste Management has incurred substantial additional costs in responding to this
pandemic including costs for overtime, equipment, supplies, enhanced cleaning operations, etc. Moreover,
because most people are at home, the amount of material collected for processing and disposal has
substantially exceeded prior years. For example, from March 19 through December 2020, we collected an
excess of 12,000 residential tons from San Gabriel Valley cities as compared with collections at the same
time in 2019. Also, we have collected an additional 7,687 Bulky Item pickups (including 1,363 additional
Bulky Item pickups in Diamond Bar) as compared with 2019 Bulky Item pickups. Waste Management has
absorbed all of these unforeseen and extraordinary costs. Thus, while we appreciate the City’s request, we
cannot provide the requested credit.
3. Provide written notification to all customers with information on service schedule
modifications and any fee credits to be offered once the operational plan has been approved
by the City.
We are preparing and printing postcards to deliver to the customers regarding the temporary change
in service due to the COVID-1 pandemic. We shared the draft postcard with the City on January 14. With
the City’s approval of the content, we will mail these postcards to customers on or before January 25, 2021.
Draft copies of this postcard were shared with the City on January 14, 2021. In addition, we contacted all
of the HOAs in Diamond Bar, where residents do not have individual accounts, and developed a strategy
with each HOA to provide schedule information to their residents.
4. Provide weekly updates to City Staff on service impacts and adherence to the approved
operational plan. Weekly updates may be held in coordination with other San Gabriel Valley
cities that are experiencing similar service modifications.
We look forward to our weekly meetings, which will be coordinated with other San Gabriel Valley
cities.
Under the circumstances of the current crisis, which is unprecedented in scope and severity, we
urge the City to work with us as partners to get through this State of Emergency. We look forward to
Mr. Daniel Fox
January 19, 2021
Page 4
working with the City and achieving our common goal of providing essential collection services to maintain
a safe, healthy, and sanitary environment within the City while also protecting the residents and our
employees from this pandemic.
Please let us know when you would like to have a conference call regarding the above matters.
Very truly yours,
USA WASTE OF CALIFORNIA, INC.
By: _____________________________
Doug Corcoran
Vice President
Month May Jun Jul Aug Sep Oct Nov Dec Jan
Days Lost 17 40 57 31 27 32 24 125 132
Confidential –Business Proprietary/Trade Secret Information – Not a Public Record – Not to be
Disclosed to Public
Projection:
Return to
Weekly
Collection
December lost work days were up 420% from November
January lost work days are trending higher yet with a projected 450% increase over November
Quarantines / positvity rates in the general population are not trending better, they're trending worse.
We tend to see and fall in line with these trends
After we have no more than 20 work days lost over a four-week period, then recycling and green waste
operations will return to weekly collection. This is designed to avoid a scenario where services are
resumed and then interrupted again due to COVID-19 impacts.
As discussed, we will hold weekly progress meetings with all of our cities to provide updates to lost days
(weekly / cumulative). Once stabilized, we will work togehter to notify customer of our return to
normal schedule.
0
20
40
60
80
100
120
140
May Jun Jul Aug Sep Oct Nov Dec Jan
Scheduled Work Days Lost
EXHIBIT A