All You Ever Wanted to Know About Omaha’s Snow Removal Program, an Interview with Austin Rowser
25 minute read
Introduction
Omaha was hit with measurable snowfall every day from January 8th to January 12th of 2024, with plummeting temperatures to follow. By Thursday of that week, I noticed some roads were clear, yet some still seemed messy. So, I emailed Austin Rowser, Assistant Director of Transportation for the City of Omaha, as I know him personally and had seen him featured in various media stories regarding the City’s snow removal efforts.
In my email, I requested an interview with him as I mentioned seeing what I considered “subpar” street cleaning around the city. In my role as co-founder of Safe Omaha Streets, we believe clean streets can lead to safer commutes, as poorly maintained streets can result in shorter stopping distances, crashes, and financial burdens. Austin promptly replied that he’d “love the opportunity to set the record straight.” We met on the morning of January 29th, and it was an informative and enjoyable interview.
While I’d spent a year on the Vision Zero Technical Advisory Committee with Austin, this would be our first one-on-one conversation, and I was a bit anxious about it. Austin was always knowledgeable and communicative in the TAC meetings, but his presence seemed physically imposing. He’s a former defensive lineman with a poker face and a powerful beard. However, Austin was forthcoming, transparent, and incredibly welcoming; I had no reason to be nervous.
Originally from Utah, Austin moved to Omaha in 2012 from Arkansas, where he attended college. From that time, he ran street maintenance and construction for the City of Omaha, with a few months stint away from the city, until he replaced Todd Pfitzer as City Engineer in February 2023 after Todd was elected to Douglas County Engineer.
Beyond Austin’s day-to-day responsibilities, he also educates others about snow removal. He teaches snow removal classes for the University of Wisconsin’s professional education series and presents at the annual Western Snow Conference most years. Speaking of conferences, Omaha was the host city for last year’s North American Snow Conference, which Austin helped plan. If you’re an equipment and public works nerd like me, you understand why conferences like this are weirdly exciting!
The Scale of Omaha
The first question I asked Austin was,
“Is there something you want people to know about your job that they may not know?”
His answer was immediate,
“I think the biggest thing that’s hard for people to understand is the scale. We work with 5,000 miles of street.”
He compared this amount to the number of road lane miles in Papillion (340 lane miles) and Council Bluffs (675 lane miles). He drove home that Omaha has nearly 10 times as many lane miles as Council Bluffs.
“It’s hard to see that because people tend to see things from the perspective of their neighborhood, or their commute, or where they go to the grocery store, and things are a lot bigger than people realize.”
The Challenge of Changes in Mobility
Trilety:
“There are a lot of challenges for cities now regarding snowplowing, such as fuel prices, increasing insurance for contractors, competition for drivers, the work is hard, etc. What are the specific challenges for Omaha?”
I honestly was not expecting the answer that Austin gave:
“I think this will resonate really well with you and your interests; I think one of the biggest challenges is the change in mobility. We’ve been such a car-focused-city snow removal program for so long, now the challenge has become making sure all of our accessible routes are uncovered and that people can cross the streets.”
He further explained that high occupancy rates in metered parking make plowing more difficult. Back in the day, metered parking may be empty overnight, but now there’s a 24/7 occupancy rate in metered parking, making getting to the curbside more difficult. Beyond these challenges, Austin offered this last one, “And then scale, same as your previous question. I mean if you think about it, we are driving to San Francisco and back.”
“With this change in mobility then, how do you manage those issues going forward?” I asked.
Austin didn’t hesitate to offer up another totally unexpected answer:
“With a lot of the alternative mobility issues, we are at a point where we need a change. We are looking at a special projects crew that does this; you know, in the summer, they have a bucket of work assignments to specialize in, such as soft area right-of-way maintenance, erosion, median type maintenance, and things that are outside the typical realm of pavement maintenance. And then in the winter, we’ll give them an assignment of urban core mobility snow removal so that they can specialize in that and be able to have a group that does it year in and year out. . . it will be beneficial for us.”
We discussed sidewalks and mobility later in the conversation, so keep reading if that’s your jam! And, like I explained to Austin, while SOS is just as concerned about sidewalks and accessibility as we are with roads and drivers, Mode Shift Omaha is the forerunner powerhouse for pedestrians and accessibility issues. We love to assist MSO’s efforts, but we also don’t want to step on any toes. Make sure to check out their website and their walkability team if you haven’t already.
All You Ever Wanted to Know About Omaha’s Snow Program
Normal Winter Weather Vs. Extreme Winter Weather
Beyond learning as much as possible about the city’s snow removal program, I also wanted to talk about the recent 2024 storm in particular. One of the first misconceptions Austin cleared up was that this past storm was not defined as “normal winter weather.” It was defined as “extreme winter weather.”
“I’m proud of the job we did in that last storm. It was an extreme storm, and our snow plan is written for normal winter weather. It says right up front that levels of service are based on normal winter weather, which we define. You know, normal winter weather is roadway temperatures that are above 15 degrees, for winds that are less than 20 mph, and snowfall rates that are less than an inch an hour; that’s normal winter weather.”
He pulled the "Winter Operations Plan and Procedures" manual from his bookshelf and said these different weather types were all defined in that document. When I asked if the public could also access these documents, he asked if I was familiar with the City’s snowplow tracker site because much of the information the public would need is already presented on that site. He was proud of the website and emphatically explained, “It’s a story map, too!”
Until a few days ago, it had been a while since I accessed the Snow Plow Tracker site, but it presents a load of information about the City and its snow removal plans. When you visit the site, you’ll find eight tabs:
Current Operations,
Introduction,
Level of Service Goals,
Defining a Spread Route,
What is a Residential Area,
Sidewalks,
Parking, and
Contact.
You’ll also find a reference to extreme weather under the “Level of Service” tab: Level of service goals do not necessarily apply to extreme winter weather events with
abnormal rates of snowfall,
extreme cold temperatures,
and/or excessively high winds.
Snowfall rates greater than 1” per hour,
freezing rain,
air temperatures below 10 degrees Fahrenheit, and
sustained winds greater than 20 miles per hour qualify as conditions that individually will classify a snowstorm as outside the bounds of normal winter weather.
If you haven’t checked the Snow Plow Tracker site in a while, bookmark it for the next winter storm as it’s a helpful tool.
The Orange Plow or The Pick-up Truck
For anyone who’s lived in Omaha longer than 15 years, you remember a time when the big orange plows were the royalty of the road. I asked Austin when the City switched from using exclusively city-owned plows to contractor-owned trucks.
The use of contractors for snow removal assistance began after the 2007/08 winter. Austin explained that traditionally, the City would clear all the arterial and collector streets first before starting to do residential streets, meaning residential streets wouldn’t be plowed for days after a snow. After the rough winter of 2007/08, the city generated a plan to provide faster service to residential streets based on feedback from a survey of some of Omaha’s residents. That plan included using contract forces to clear residential streets while the city plows cleared the rest. This new policy started in 2009.
I asked Austin how these contractors are held accountable or how the City manages the quality control of these contractors. He explained that the Public Works Department treats the snow removal contractors like any other contractors; they have contract administrators, superintendents, and engineering firms. For example, if an engineering firm is contracted to administer the contracts, they have all the specs, standards, drawings, and details regarding how the city wants streets plowed. Those engineers track behind the contractors to ensure that all specifications are met, and then the engineers report back to the City with all sorts of information, such as the start time, what kind of trucks were used, how many plows, etc.
As Austin said, “All the details are tracked and watched and managed.”
Currently, the City employs about 220 plow drivers (110 drivers per 12-hour shift) and between 20 and 25 contractors, totaling an additional 175 to 200 drivers.
Depth Matters – Four Inches or Two Inches
I walked into the meeting with nearly 30 questions, yet our conversation flowed so naturally that most of my questions were answered as we chatted. One question I did ask specifically, though, was this:
“I think there are differing expectations among the public, and between the city and the public, about the idea of a clean street. Can you speak to what the City’s expectation of a clean street is?”
Austin answered the question casually and confidently, a man at ease in his work,
“So, the city doesn’t have an expectation for what a clean street is, we have an established level of service (LOS) and those are all written down. We say if it’s an arterial street, this is our LOS; if it’s a collector street, this is our LOS; if it’s a residential street, this is our LOS; if it’s an alley, this is our LOS.”
You can find the definitions for these varying levels of service on the Snow Plow Tracker website.
While these levels of service reflect policy, and the City does not want to deviate from the stated policy, the levels of service are also periodically evaluated and updated as needed. For instance, while many of us in the city know that residential streets are only plowed after 2 inches of snow has accumulated, Austin explained, “We used to have a 4-inch level of service.”
This change also came about because of resident feedback. The City conducted another citizen survey after a rough winter in 2015/16. Most residents expressed that they were generally satisfied or happy with the City’s services, but the survey also showed that most residents wanted a 2-inch LOS instead of a 4-inch LOS. The new level of service, which we still currently have, was instituted originally during the winter of 2016/17.
As Austin and I talked about the Christmas Eve storm of 2015, he told me that the storm wasn’t accurately forecasted; thus, the City had to “react” rather than “plan.” At that point, I made a comment about the lack of accountability with weather forecasts, and he countered, “Forecasting takes an understanding of the science AND the limitations on the science.” We continued talking about forecasting, and he explained to me,
“We get forecasts from many sources. We have three paid forecasting services as well as what’s publicly available, and 24/7 on-call forecasters.”
How Long to Plow
Since we were speaking of levels of service, I asked if there was a reason why the city doesn’t continue to clear streets even after the LOS is met because the roads continue to get slushy and shitty after that, and then it’s like they were never plowed.
Like many of Austin’s answers, this one surprised and educated me,
“We plow and get it down as best we can. But what happens with snow that is packed down, is it then warms up and it fluffs. If it was a half inch of snow on the pavement, then that expands because it gets all that air mixed in it; that’s called snow fluff.”
While prepping for my interview with Austin, I’d read about snow fluff, and it seems that sometimes snow fluff can make a street look like it was never plowed.
Austin continued, “We don’t typically go back for that because we’ve met our LOS, but we will take requests.” One of the other reasons they don’t go back is that a lot of that snow is dragged from people’s driveways or on-street parking spaces.
Additionally, some people have been seen snow blowing or shoveling snow back into the street. Austin said they’ll actually yell at anyone they see doing that. While the City has a mechanism for assessing property owners if the City must provide cleanup for snow placed illegally in the right-of-way, it’s a cumbersome process so not often used unless there’s a very serious and costly problem.
Austin clarified,
“We would like to have the ability to issue simple citations on the spot when we see this behavior, however, this is something we have only discussed, and we are not actively working to make any municipal code changes for implementation.”
Additionally, while I’ve read that the City of Council Bluffs continues to plow their streets for days or weeks after snowstorms, just the scale alone would make that physically and financially tricky in Omaha.
The Mis-expectation of Bare Pavement
Another issue of LOS is the incorrect expectation of bare pavement. The level of service for residential roads is not “bare pavement,” the City states this on its website, the snow plow tracker site, and in the snow removal plan. Austin mentioned that he’s heard people complain about their streets not being plowed to bare pavement, “but what bare pavement means in residential areas is salt.”
The only way to get bare pavement is with salt.
. . . . Salt, Sand, or Brine
In preparation for our meeting, I watched an informative interview with Austin and Waverle Monroe from Channel 7 about the city’s brine production. I wanted to know more about the difference between salt, sand, and brine, and Austin gave me all the info I would ever need! And he made it entertaining as well,
“Any chemical that we use, whether it’s brine or salt - we make our own brine - if we don’t make the liquid, salt on the street makes brine, it’s the same thing – salt on the street becomes brine. So if you say you like salt better than brine, you’re saying you like eggs better than eggs.”
Regarding road application, I didn’t understand if the materials laid down were for traction, melting, or something totally different. And Austin summed up the goal clearly.
“The goal in all of that – this goes back to environmental concerns, the cost, the operations – the goal for any chemical use, there’s only one goal Trilety, that is to prevent a bond from forming between the snow and ice, and the pavement. Whether we are putting it down as brine before it snows, in liquid form, or if we are putting salt down during the storm, we are trying to prevent the bond from forming. . . .because once it’s bonded, you’ve got a mean scary animal to deal with and then you’ve got that fluff afterwards.”
But here’s the kicker, many of us are so concerned with what’s being applied to the roadways that we don’t understand that’s not where the heavy lifting happens in snow removal.
As Austin explained,
“95% of the job of snow and ice removal is moving it off the pavement – it’s clearing it – it’s mechanical. The chemicals we use are to assist our mechanical efforts, to help us get it off the pavement faster. Our goal is not to melt all the snow and ice because that takes way too much salt; it’s to melt it enough that we have a membrane there so that we can have free-flowing snow and ice on top of the pavement.”
Basically, when the snow is unbonded, it’s easier to move. And most of snow removal isn’t “removing” snow so much as “moving” snow.
When it comes to salt or brine, there are two types of applications: anti-icing and de-icing.
Anti-icing:
“Anti-icing is when we put something down proactively, and we typically use brine because it comes in liquid form so it’s easier to distribute. You put it on the pavement, and it sticks to the pavement. If I put salt down before a storm, what happens to the salt? It rattles and bounces around and sticks to cars. It gets pushed out of the way, but if I put it down in a liquid, then it stays in place and doesn’t get kicked out by cars. So that’s why we use brine as an anti-icing treatment before a storm. So now that first bit of snow that falls won’t bond, and it’s easier for us to push off when we come through with the plows.”
De-icing:
is when the city continues to apply salt to prevent any additional snow from bonding.
Salt works down to about a 15-degree pavement temperature, which can sometimes be stretched to 10 degrees in the right conditions, but once the pavement temperature drops below that, the salt is ineffective. Sand is the only option available at super cold temperatures like we had earlier this month. Sand provides roughness, texture, and traction. Beyond those frigid temperatures, the City doesn’t depend much on sand because studies have shown that the “bounce and scatter associated with sand” means that it gets kicked out of the travel lanes anyway.
Snow Emergency or No Snow Emergency
As someone who grew up in Omaha, I remember snow emergencies being declared more so in the past than now. A snow emergency was not declared in this last extreme storm, so I asked Austin to give me the rundown on snow emergencies and why or why not they are declared. The snow emergency ordinance states that in areas east of 72nd Street, if it’s an even date, then residents need to park on the even side of the street, and if it’s an odd date, then people need to park on the odd side of the street. This allows plows to have wide berths and ample clearance to plow the roads.
I was surprised to hear that Austin believes the snow emergency ordinance, as it’s currently written, is ineffective for a couple of reasons.
The first ineffective aspect of the snow emergency ordinance is that people
“think they have to move their car at midnight, which is a hassle for residents, but that’s the way the ordinance is written. From a practical standpoint, how does this really work, and what are the mechanics of it? The second thing is that when you look at our LOS, we’ve gotten pretty fast at snow removal compared to how we used to be. The way we define our LOS now, we want to have pretty much everything really done within 12 hours from the end of the accumulating snow.”
The timing becomes problematic when the snow is cleared so much faster than in the past.
As Austin explained,
“Let’s say we have a snow emergency that starts at 2 am with less than 4 inches of snow, and it’s 2 pm, and they’re done with half. The city crews continue to work and spread, but the contractors, as far as THEIR job, they can’t go back and do the other side until the next day, so they’re sitting around with nothing to do.”
Additionally, since the city now tries to have the contractors get snow removed within 12 hours, the timebound aspect of the snow emergency ordinance just pushes back the city’s efforts.
I asked why contractors can’t just work on something somewhere else during that time, but each contractor is assigned a section of the city, and they work only in their designated area.
Another issue Austin raised about the snow emergencies is the low compliance rate from residents. In prior snow emergencies, he estimated that compliance was about 50/50. “It’s not malice by any means, it’s about understanding,” he said about low compliance. The fact that we have such a variety of information sources, vs in the past when most people received their information from a much smaller pool of sources, also makes it hard to get the word out.
So, with so many obstacles or disadvantages to the snow ordinance, what are Austin’s thoughts as we move forward?
“Ideally, the best snow emergency to me would be you can’t park on the street during a snow emergency, period. That presents a problem in certain parts of our city where there’s no access to off-street parking. And that’s a relatively small area, so we have talked about maybe creating zones or tiers, but it’s really something that we should address because the ordinance we have is pretty ineffective.”
Now on to the Sidewalks & Crosswalks
While I was meeting with Austin mainly to talk about streets, I’d heard complaints from people and seen photos of poorly cleared sidewalks throughout the city. Unplowed or icy sidewalks are a safety hazard and a slap in the face for pedestrians and vulnerable users. So, I asked what sidewalks the City is responsible for clearing.
Austin clarified,
“The vast majority of sidewalks under city code are the responsibility of the property owner. The public has a right to access the sidewalk, and under city ordinance, that sidewalk is the responsibility of the adjacent property owner.”
Austin listed the types of sidewalks that are the City’s responsibility:
Sidewalks in all city parks
Sidewalks on any property the City owns, such as floodplain property or vacant lots
Sidewalks on bridges (generally) - the Parks Department clears them on behalf of Public Works
Any sidewalks associated with double-frontage lots that are ALSO along an emergency snow route - Double-frontage lots are lots that abut up to two streets that do not intersect.
Crosswalks are also the responsibility of the City, though not necessarily the sidewalks that lead to them.
Whose Responsibility?
If you see any clearance issues with crosswalks or the sidewalks listed above, submit a complaint to the city as soon as possible.
Since the city takes complaints about errant property owners who don’t remove snow by the 24-hour time limit, and the city currently has a backlog of sidewalk maintenance complaints, I asked Austin how snow removal issues on sidewalks are dealt with urgently.
He reiterated the burden of responsibility by saying,
“The bottom line with snow removal is if the property owner is responsible for it, then they should just do it. That’s the city’s stance. As far as urgency goes, you should clear your sidewalks. And property owners are responsible for clearing it whether they get a complaint or not.”
So I asked,
“What would you recommend people to do if it’s a business that isn’t clearing the sidewalks, especially in high pedestrian areas? Beyond complaining to the Mayor’s hotline, is there a better avenue for that?”
Austin encourages residents to contact the property owner first because the City’s process is an established bureaucratic process that will take days. Property owners are given 24 hours to clear their sidewalks, so if you want to complain to the city, that process will start after those 24 hours. The city will then send inspectors out to look at the issue, which can sometimes be 36 to 48 hours later. Once the inspector assesses the situation, they will send out notices to the property owners giving them 24 hours to clear the sidewalks. The inspectors go back out to check, which is potentially another 24 hours. After that, a contractor must be mobilized, and any cost from the contractor is assessed back to the property owner.
Austin further explained that these contractor costs are often high because they’re dealing with icy snowpacks that are laborious to remove.
So, instead of waiting for the City to go through its process, Austin recommends first complaining to the property owners because clearing your sidewalks is a law.
“Always complain to the person first. Ask them to clear their sidewalk.”
How To Make Complaints to Property Owners or the City
After our meeting, I went to the Douglas County Assessor’s website to see who the property owners were for some of the sidewalks around the 72nd & Dodge Street area, as we’d seen passionate citizens shoveling sidewalks in this area to keep them clear for pedestrians. Since it’s the property owners, not the City, who are responsible for most sidewalks, I was curious just how easy identifying and contacting the property owners would be.
While you could go into businesses in this area, like PetCo or Scooters (using these businesses for this specific example, not calling them out for poor snow removal), the folks who work there are NOT the property owners.
In fact, the property owner for PetCo is listed as
“72 Dodge Investors LLC, 8101 College Blvd. #100, Overland Park, KS 66210,”
and the property owner for the Scooters building is listed as
“RS Holdings I LLC, 202 S 73 Street, Omaha, NE 68114.”
At least the address on 73rd Street would be easy to access locally.
Since many businesses along high pedestrian areas are located on property owned by large companies or anonymous-sounding organizations, I emailed Austin and asked if the City has any better way for residents to contact these amorphous property owners. He replied that, unfortunately, they do not have any better way of contacting the owners than what is listed in the County’s records.
My suggestion for the public, at this point, would be to do all three of these things at a minimum:
Complain to the business
Complain to the property owner or holding company directly, which will likely have to be by post
Lodge a complaint regarding repeatedly errant property owners to the City and the City Council representative.
Keeping property owners accountable to the residents of this city will require a coalition of people and some creative efforts. Jim, the other co-founder of SOS, has already had fun coming up with a few entertaining possibilities, but for now, remember to start at the source and complain to the business and property owners first.
I’m mainly referencing businesses here, as homeowners are a different animal altogether. But with homeowners, approach them first, offer to help, or start a neighborhood-wide snow removal group!
What are your thoughts on encouraging, incentivizing, or shaming property owners into clearing their sidewalks?
Regarding submitting complaints or feedback regarding snow removal to the City, I asked Austin which complaint platform is best for Public Works.
“The best source for us is if people put it on omahahotline.com; that request gets directly routed to our system and to the foreman. They can also call the Mayor’s Hotline (402.444.5555) as that’s a good source for us. Or they can call the street maintenance line, which is a 24-hour number that’s really good for emergencies like a water main break at night that gets icy. We can dispatch someone 24/7 from that number: 402.444.4919.”
He doesn’t recommend initially complaining to City Council as the complaint will need to go through a lot of hands before it reaches Austin, and as he reminded me, “In our form of government, we don’t work for City Council, we work for the Mayor.”
As we were wrapping up the topic of complaints, I asked Austin if he’d heard any complaints from residents that he felt were warranted or if there were any things the City could do better next time.
He immediately answered me,
“Metered parking and sidewalks, yea. The sidewalks that are the City’s responsibility, I was not proud of that job. But we are always trying to improve.”
Similar to the whole interview, Austin was objective, measured, and honest. The amount of pride he takes in his job is matched by his humility.
Where the Snow Goes
Prior to my interview with Austin, I put a text out to our family thread to see if any of my family members had questions to ask, and my mom immediately popped back with, “Where do they store the snow they remove from parking lots, etc, the snow they load into haul trucks?”
As explained earlier, much of the snow in the city is “moved,” not “removed.” However, it’s a different case in the downtown business district where the City creates windrows of snow in the middle of the streets to keep the roadside improvements, i.e., sidewalks and metered parking, clear of snow. When clearing the windrows, snowblowers will deposit snow into trucks. That snow is taken to one of two locations in the city: 11th & Locust (Parks Department property) or in the middle of the south side of the cloverleaf interchange at 72nd & Center Street.
Lastly, let’s look at Funding
As much as I like to keep up on all-things-Omaha, I am ignorant about how street and sidewalk clearing is funded, so I asked Austin all about funding sources.
Any snow operations that are the City’s responsibility are funded
“from the street allocation, and that comes from gas tax primarily, but there’s also the wheel tax that we collect in the City, and then there’s vehicle sales tax. None of it comes from property tax, zero. The only thing that public works is funded for by property tax is the graffiti abatement program and solid waste. We provide solid waste services to residents without charging them anything.”
The Snowclusion
By the time we were wrapping up our interview, Austin had generously given me over an hour of his time. And like his answers to many of my questions, his answer to my last question surprised me!
I ended with this query,
“Have you ever driven a snowplow?”
He answered with a grin as if he was busting a myth,
“I have not.”
I was aghast, and he was not shocked. Austin chuckled and told me I’m not the first to look at his physical appearance and position and assume he’s driven a snowplow. But this bearded fella is a vest-wearing, dapper dresser who drives a Kia Soul.
The Snow Summary of it All. . .
Hey, you made it to the end of a 5,000 word long-form article, good on you!
Here are a few takeaways:
Omaha has 5,000 lane miles of road, compared to about 700 in Council Bluffs
The City is thinking about ways to address the challenge of changing mobility, ie the special projects team
Understand the definitions the City is working with when it comes to winter weather, roads, level of service, etc. Residential streets are only plowed after a 2-inch snow and they are not plowed/salted to bare pavement.
Contractors and city plows work together, and both are held to city standards
Levels of Service can be reassessed as the needs of the city change
The current snow ordinance is difficult to navigate, so the City is already thinking creatively about alternatives
Most sidewalks in the city are the responsibility of property owners, not the City. Complain directly to property owners first.
Post your other snow complaints to the city’s omahahotline.com website
Snow removal is not funded via property taxes, but instead via the gas tax, wheel tax, and vehicle registration.
One last SOS observation. . .
All throughout my year serving on the Vision Zero TAC, I repeatedly said that I believe the City has a communications problem. If residents had more information about what and why the City does things, I believe there’d be less ire between residents and the City. This is one reason why I think this article is so important and should be shared widely.
Communications and the City could be improved if:
The City had a standalone position for a Communications Director.
The City had improved and interactive social media platforms.
The City actually sent out a newsletter – when you go to the City’s website, it encourages you to sign-up for the newsletter, but after years of being signed up, I’ve yet to see a newsletter.
Lastly, the department that is a great model for communication is the City’s Solid Waste Program – Wasteline. Their newsletters, website, text messages, and all-around communication are stellar. I’d LOVE if every department, or the City in general, would follow the Wasteline model.
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