, , ,

Duarte – SB 1383 Implementation + Solid Waste Coordination Services

Napa Recycling and Waste Services

R3 has partnered with the City of Duarte since 2022 to oversee waste collection services and ensure compliance with California’s recycling and organics laws. We monitor hauler performance, manage annual rate reviews, and complete required state reporting so city staff can focus on other priorities. Our team provides technical support to help residents and businesses meet expanding waste diversion requirements while keeping costs reasonable. We’ve guided the City through major regulatory changes, ensuring quality service without overwhelming city resources.

Our work has included coordinating the City’s Electronic Annual Report to state agencies, establishing new waste collection programs at City facilities and the food recovery center, and updating municipal codes to reflect current regulations. We’ve also helped the City navigate commercial waste requirements, supported construction and demolition recycling programs, and provided staff training during organizational transitions. This hands-on approach ensures Duarte meets all regulatory deadlines while maintaining strong relationships with residents and service providers.

/by
,

Recycled-Content Paper Procurement Webinar

The R3 team recently hosted an SB 1383 Recycled-Content Paper Procurement webinar, which consisted of sharing tools and resources related to the required purchases of recycled-content and recyclable paper products.

R3 works with clients throughout California and understands that jurisdictions are at various levels of compliance with these procurement requirements. Common challenges related to the requirements include the lack of a consistent internal procurement process, decentralized purchasing, the increased expense of compliant paper products, and a scattered record-keeping history. R3 shared some best management practices for confronting these challenges and also opened the floor for peer-to-peer resources sharing. R3 is always inspired by the experience of the jurisdictions we serve, and we believe we can all make better progress by learning from each other’s trial and errors, as well as successes!

R3 hosted the first Recycled-Content Paper Procurement webinar on February 27, 2025 and a follow-up session on March 5, 2025. Two sessions were held because we believe the opportunity to ask questions and share resources in a live setting is vital to meaningful progress toward effective compliance.

* * * * *

We welcome any direct questions regarding compliance in your jurisdiction. If you’d like to get in touch with a consultant, please contact Peggy Paulsen at ppaulsen@r3cgi.com. We’d also love to hear about any other topics you’d like R3 to cover in future webinars – so please don’t hesitate to share your ideas! 

Resources

Webinar Recordings

February 27, 2025 Webinar: https://youtu.be/d3TV9-5lHuI

March 5, 2025 Webinar: https://youtu.be/JlacI3-2q8g

/by
, ,

Glendale – Hauler Fee, Performance, and Compliance Audits

R3 provides annual comprehensive audits of waste hauler operations in Glendale, to verify that companies are properly reporting their services and paying required governmental fees. Our team reviews the performance for the City’s four franchised haulers as well as several permitted debris box haulers, checking that their billing records match what was actually collected and recycled. We interview hauler staff, examine thousands of individual financial transactions, and cross-check tonnage reports against actual weight tickets from disposal and recycling facilities. We also verify that businesses generating significant waste are receiving proper recycling and organics collection services as required by California law.

Our findings gives the City a clear picture of its waste collection system and identified areas for improvement. The audits confirm whether fee payments are made correctly, validate tonnage reporting accuracy, and ensure that contractors will meet their obligations to the City. We provide recommendations to strengthen City oversight and help resolve any discrepancies between what haulers report and what actually occurred. This annual independent verification protects the City’s interests while ensuring residents and businesses receive the services for which they pay.

/by
, , ,

Garden Grove – C&D Program Implementation

For the past four years, R3 has supported the City of Garden Grove’s construction and demolition recycling program by providing the City with staff augmentation in reviewing contractor plans, verifying recycling documentation, and ensuring projects meet state building standards. We use the City’s specialized tracking software to monitor what materials are hauled, where they go, and how much is recycled versus sent to landfills. Our team communicates directly with contractors to explain requirements, correct common mistakes, and help them improve their recycling performance. We provide weekly reports to City staff on project approvals, rejections, and ongoing compliance issues.

Beyond day-to-day project reviews, we’ve helped the City streamline its entire construction recycling program. We developed guidance documents that make it easier for City staff to manage the program consistently and for contractors to understand what’s required. Our contractor education efforts focus on practical solutions – like proper source separation of materials and correct documentation – that lead to better recycling outcomes. This hands-on approach helps the City meet state reporting requirements while building a more effective, user-friendly program for the construction community.

/by
,

Compliance Corner – December 2022

While our efforts towards SB 1383 implementation and sustainment will carry on for the foreseeable future, we’re sad to say that our yearlong dedication to SB 1383-related blog posts is coming to an end.

We’ve covered topics ranging from Education & Outreach to Route Reviews & Enforcement, and everything in between. As we close out the year, we are giving you one last post covering information all about Hauler Programs / Management of Haulers.

Ultimately, jurisdictions are the ones responsible for the implementation and maintenance of SB 1383 requirements, however, these goals can only be achieved by working in partnership with the haulers. Franchise agreements have been, and will continue to be, drafted or amended to include SB 1383 language, including specific hauler proposed programs and measures of compliance to ensure that progress is made in the advancement and application of those programs.

Hauler Programs

Whether through sole-sourced negotiations, or through Request for Proposals (RFP) process, jurisdictions are including SB 1383 provisions in the form of a Sustainability and Compliance Plan (nomenclature may vary by agreement) and specific hauler required programs.

The hauler’s proposed plan must describe:

  1. How the hauler will provide outreach and education to residents, schools and businesses.
  2. The material that will be developed and distributed, including its format and distribution method
  3. How the hauler will maintain compliance with the State’s Mandatory Commercial and Organics Recycling mandates (SB 1383, AB 1826, AB 939, AB 341), including when and to whom letters will be sent, how compliance will be documented and reported.
  4. The hauler’s plan for waste audits, route audits, meeting cart color and labeling requirements, and site visits.

The plan also requires the hauler to document and report implementation of each of the plan’s components and other compliance data in an online waste reporting system or another format as designated by the jurisdiction.

Management of Haulers

Hauler programs are incorporated into respective franchise agreements to list specific actions that the hauler will take to assist the jurisdiction that they serve in achieving the requirements of SB 1383. You may ask yourself how jurisdictions are ensuring that haulers are applying the practices described in their proposed plans and franchise agreements.

There are several ways in which jurisdictions are ensuring that SB 1383 related hauler programs are being implemented, such as:

  1. Requirement of Staffing
    • Haulers are required to add a dedicated full-time Sustainability/Compliance Representative, whose responsibilities include conducting site visits and providing outreach and education in support of meeting Franchised and CalRecycle Diversion requirements and to meet State mandates, and all amendments and related subsequent legislation.
  2. Submission of a Sustainability and Compliance Plan
    • This plan can carry a different name, but essentially details the hauler’s plan of action to assist the jurisdiction in which it serves, in all the areas listed under the “Hauler Programs” section above.
  3. Regular Reporting
    • Jurisdictions can monitor and/or manage hauler progress through required reports that are provided monthly, quarterly, and/or annually (or some combination of the three). Some jurisdictions have begun to include a reporting line item requiring the hauler to list efforts made towards, and measured impact from, the reduction of Greenhouse Gas (GHG) emissions.
  4. Right-Sizing of Containers
    • In an attempt to further increase diversion efforts, haulers are required to proactively assist multi-family and commercial customers in the rightsizing of containers, which includes an evaluation of material generation and increase/decrease of container size and/or frequency of collection.
  5. Administrative Charges
    • If a hauler fails to perform to the agreed upon standards of the franchise agreement in which it operates, jurisdictions have the ability to assess administrative charges to force correction of an identified issue
/by
,

Compliance Corner – November 2022

Enforcement

For November, we’re focusing on SB 1383 enforcement requirements. Although not the most popular topic, enforcement is imperative to accomplishing California’s climate and organic waste diversion goals by the year 2025!

A jurisdiction’s role in SB 1383 compliance monitoring, inspections and enforcement will include approving and issuing waivers to organic waste generators and accepting and investigating written complaints about non-compliance. Beginning in 2024, enforcement will include issuing a Notice of Violation and may progress to issuing administrative citation for repetitive offenses. Jurisdictions may designate provision of Notices of Violation to haulers, but the City must administer the associated penalties.

Managing the Enforcement of SB 1383 Requirements

  • Develop a contamination monitoring and inspection protocol.
  • Many collection haulers have developed contamination tags to be used as an educational tool for generators when contamination has been identified.
  • Follow-up outreach and education and/or Notices of Violation in response to observed violations.
  • Beginning in 2024, it will be beneficial to collect supporting documentation to assess administrative citations as necessary.

CalRecycle Enforcement

CalRecycle released an SB 1383 Compliance Process Guidance document to outline their escalating enforcement process for when jurisdictions are non-compliant. CalRecycle will conduct compliance reviews to identify violations. When CalRecycle identifies a compliance gap during a compliance review they may choose to address the issue informally or issue a Notice of Violation to the jurisdiction, which triggers the following enforcement process.

  • Notice of Violation (NOV): If a jurisdiction is found to be violating one or more requirements, CalRecycle may issue the Notice of Violation with a timeline of between 90 and 180 days to correct the violation.
  • Corrective Action Plan (CAP): When violations are caused by extenuating circumstances, such as natural disasters, delays in obtaining permits, or delayed recycling of organic waste, and the jurisdiction has made substantial efforts towards compliance; a Corrective Action Plan can be placed allowing up to 24 months to comply with an extension of 12 months.
    • Substantial effort is where a Jurisdiction has done everything within its authority and ability to comply. Does not include circumstances where a decision-making body of a jurisdiction has not taken the necessary steps to comply with the chapter, including, but not limited to:
      • Failure to provide adequate staff resources to meet its obligations, or
      • Failure to provide sufficient funding to meet its obligations, or
      • Failure to adopt the ordinance(s) or similarly enforceable mechanisms.

 

Helpful Links

/by
, ,

Butte County – Rate Review

Butte County

R3 was recently engaged by Butte County (County) to assist with solid waste planning efforts for the County’s Enterprise Fund and Neal Road Recycling and Waste Facility (NRRWF). R3 is providing a variety of services including:

  • Reviewing and confirming the Interim Year Rate Applications for the County’s three haulers: Waste Management, Recology, and Northern Waste and Recycling;
  • Assisting the County with SB 1383 Capacity Planning by projecting organic waste tons disposed by the County and its incorporated jurisdictions as well as projecting the required additional edible food recovery capacity;
  • Providing the County with draft franchise agreement language for all three haulers to incorporate compliance with AB 1826 & SB 1383, and assisting in contract negotiations with the haulers;
  • Conducting Base Year (Detailed) Rate Reviews for each of the County’s three haulers;
  • Performing a rate study and creating a rate model for the County’s Enterprise Fund; projecting different rate adjustment scenarios over 20 years to ensure revenues can accommodate required expenses;
  • Creating draft ordinance language for the County to comply with SB 1383; and
  • Performing on-call work, as needed, including CalRecycle regulatory assistance, community engagement assistance, grant preparation assistance, and local task force assistance.
/by
, ,

RecycleMore – Planning Assistance in Response to SB 1383 Organic Waste Reduction Mandates

SB 1383

R3 is currently leading a team consisting of SCS Engineers, Abbe & Associates, DKC Consulting, and Cascadia Consulting Group to provide initial planning support for RecycleMore and its Member Agencies in implementing Senate Bill (SB) 1383.

Project tasks include the following:

  • Analyze current RecycleMore organics collection programs for all sectors, including processing, and determine adequacy to support compliance with SB 1383 requirements; and
  • Provide an estimate of additional collection and/or processing capacity needed to achieve the SB 1383 requirements;
  • Analyze existing RecycleMore program compliance requirements and new compliance requirements under SB 1383, consider the listed activities under all state mandates; and
  • Provide recommendations for the most effective implementation of required activities, which include:
    • Education and Outreach;
    • Inspection and Enforcement, including the assessment of penalties and contamination monitoring;
    • Edible Food Recovery Programs;
    • Regulation of Self-Haul Sector;
    • Purchasing Policy Changes;
    • Municipal Code Updates; and
    • Container Color and Labeling Requirements.
  • Provide a recommendation and description for accurate record keeping and monitoring of recommended RecycleMore activities to determine their performance effectiveness and contribution to organics reduction.

Anticipated project benefits are enhanced compliance with SB 1383, as well as improved coordination on legislative compliance between RecycleMore and its Member Agencies.

/by
, ,

Zero Waste Marin – Zero Waste Strategic Planning and Organizational Assessment

Zero Waste Marin

R3 was recently selected by Zero Waste Marin to conduct an Organizational Assessment of the JPA and provide recommendations on Best Management Practices and agency design that will improve the JPA’s ability to support Marin’s efforts to reduce waste going to landfill; as well as a zero waste feasibility study update that identifies five short-list strategies and a roadmap toward implementation of those strategies.

Project tasks include the following:

  • Research, analyze, develop findings, and prepare recommendations regarding the JPA’s Board of Director’s structure and composition, including potential alternatives to current practices;
  • Research, analyze, develop findings and prepare recommendations for future JPA staffing, that would be necessary to implement potential future alternative JPA structure and/or composition (such as contract staffing, support costs, expanded program costs, etc.);
  • Research, analyze, and develop findings regarding per capita (and/or per ratepayer) funding levels for other similar (and/or model) solid waste and recycling joint powers authorities, including descriptions of zero waste achievement and programs and services provided by the comparison agencies;
  • Conduct workshops with the Executive Committee and/or Board on best management practices in other zero waste communities and similar joint powers authorities;
  • Utilize our expertise to provide advice and recommendations on possible updates the 1996 Joint Powers Agreement; and
  • Map out the next steps the JPA could take to effectively move towards its zero waste goals and objectives, and identify five short-list zero waste strategies for implementation based upon updated waste and diversion modeling, stakeholder input, and best practices in zero waste.

Anticipated benefits include enhanced organizational effectiveness and improved zero waste programs.

/by
, , ,

Richmond – 5-Year Conditional Use Permit (CUP) Review

West Contra Costa Sanitary Landfill

R3 is currently engaged by the City of Richmond (City) to conduct the City’s 5-Year Review of Republic Services’ (Republic’s) Conditional Use Permit (CUP) for the West Contra Costa Sanitary Landfill Bulk Materials Processing Center (inclusive of Golden Bear Transfer Station and associated solid waste facilities) for the period of January 2012 through March 2017.

R3 performed a high-level review that focused on key CUP terms and conditions relating to facility operations, such as hours of operation, maximum daily quantities, maximum storage capacity, odors, airborne bioaeresols and endotoxins; resource recovery diversion rate, and resource recovery best practices. The review also included, but was not limited, to the following areas: transfer station, materials recovery facility (MRF), and compost operations; illegal dumping mitigation; leachate containment and handling systems; and health and safety practices in place at the facilities. Separate reports were prepared for the City’s information for specified areas of particular concern.

R3’s major tasks for the review included:

  • Review of relevant background materials, including the Conditional Use Permit (CUP), Solid Waste Facility Permit (SWFP), California Environmental Quality Act (CEQA) documentation and other relevant permits;
  • Preparation of the letter to Republic announcing the City’s intent to Review;
  • Preparation of an appendix detailing the data required for Republic’s submittal of a CUP compliance assessment; and
  • Facilitation of a meeting with City staff and Republic to discuss the process and answer questions.
  • Comprehensive verification of Republic’s submitted compliance assessment through site visits, observations of operations and evaluation of supplemental information from Republic.

Upon completion of the review, R3 assisted the City in drafting and negotiating changes to the CUP and a staff report to the Planning Commission, which included the recommendation to conduct ongoing monitoring for the period of one (1) additional year.

The additional year of monitoring is currently underway, and R3 has been engaged by the City to complete this review. R3 has held various meetings with the City and Republic to discuss the results of the review, incorporate comments, and provide clarifications and recommendations before finalizing the Review and presenting it to the City Planning Commission.

/by