What Is a URCO Waste Diversion Plan and Does Denver Have a Form?

A Waste Diversion Plan is the written document showing how a covered Denver property meets URCO's recycling and composting requirements. Denver has not published an official form or template, which means the safest approach is a superset document broad enough to satisfy any reasonable interpretation of the rule.

That absence of a template is the whole problem. This post breaks down what the plan needs to contain, which section matters most, and why waiting for a city form is the wrong move.

Why there is no official template, and how to build a plan that holds up anyway.

What is a Waste Diversion Plan?

It is your program on paper.

The plan documents what streams you provide, what containers exist and where, how much capacity you have in gallons, who hauls the material, where it goes, how you educate the people using it, and how you handle problems when they come up.

If an inspector asks how your property complies, the Waste Diversion Plan is the answer. Verbal explanations do not scale and do not survive staff turnover.

Is there an official Denver form?

Not as of this writing. Denver has not published a standalone Waste Diversion Plan template.

That sounds like a gap. It is actually a strategic problem, because "no form" does not mean "no requirement." It means you are responsible for producing a document that satisfies a standard nobody has reduced to a fill-in-the-blank PDF.

The wrong response is to wait for a form. The right response is to build a document broad enough that it satisfies the requirement under any reasonable reading, and to update it if a template later appears.

What should the plan contain?

At minimum:

1. Property and responsible party identification. Address, premises type, unit count or seat count, owner, and the responsible party as URCO defines it (owner, rental license holder, association, or managing agent).

2. Covered status and basis. Why this property is covered. For multifamily, the unit count. For food service, the food waste producer classification.

3. Stream inventory. Trash, recycling, and organics. Container count, size, and location for each.

4. Capacity calculation in gallons. Weekly service capacity by stream, expressed in gallons per §2.29, showing container volume multiplied by collection frequency. This is the section most plans get wrong by expressing capacity in tons or pounds.

5. Hauling arrangement. Hauler name, City of Denver license status, service days, and the destination facility for organics.

6. Signage and labeling. What signage is posted, where, and in which languages. English and Spanish at minimum.

7. Education plan. How staff are trained, how tenants or customers are informed, at what intervals, and in what formats.

8. Contamination management. How contamination is identified, documented, and corrected.

9. Recordkeeping. What records are retained, where, and for how long.

Why does the capacity section matter most?

Because it is the section that is objectively checkable.

Signage can be photographed. Education can be described. But capacity is arithmetic, and arithmetic is either right or wrong. A plan that states organics capacity in gallons, shows the container-by-frequency math, and matches what is physically on site is a plan that holds up.

A plan that says "we compost" and attaches an invoice is not a plan.

Who needs one?

Every covered property. Multifamily with 8 or more units, food waste producers, and hotels.

Portfolio operators need one per premises, not one per company. The premises is the unit of compliance.

What happens if you do not have one?

It becomes a documentation violation on top of whatever operational gap it would have revealed. Denver Municipal Code §48-47 fines start at $150 and escalate to $500 and then $999, with each continuing day a separate offense under §1-13.

The plan is also your best asset during a cure period. A property that can hand over a complete Waste Diversion Plan and a records file is in a very different conversation than one that cannot.

Frequently asked questions

Can I write my own Waste Diversion Plan? Yes. The risk is not authorship, it is completeness, particularly the gallons-based capacity math and the recordkeeping structure.

How often should it be updated? Any time service, containers, hauler, or destination facility changes. A hauler or processor change also triggers re-education obligations.

Does one plan cover a whole portfolio? No. Build one per premises.

Is the plan submitted to the city? It is compliance documentation you maintain and produce when required. Keep it current and accessible on site.

Let us build it

Writing Waste Diversion Plans is core to what Melly's Recycling does. We are a Denver URCO compliance company, not a hauler. We build the plan as a superset document, calculate your capacity in gallons, produce matching bilingual signage, train your staff, and maintain the records file behind it. Hauling service is coordinated separately through licensed Denver haulers on a sealed-bid basis.

You finish what you started.

Request your free URCO compliance audit and we will tell you what your plan is missing.