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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.

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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.

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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

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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.

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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
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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

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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.

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Carlsbad – Sustainable Materials Management Plan

Carlsbad - Sustainable Materials Management Plan

R3, with subconsultant Cascadia Consulting Group,  was engaged by the City of Carlsbad (City) to develop a Sustainable Materials Management Plan (SMMP). The purpose of the SMMP was to identify specific policies and ordinances, programs and services, service provider contractual requirements, and facility capacity that Carlsbad should pursue to achieve its sustainable materials management objectives. The SMMP was organized into the following three phases:

  • Phase 1) Ensure compliance with all state solid waste regulations currently in effect.
  • Phase 2) Achieve regulatory compliance with all SB 1383 regulations.
  • Phase 3) Establish sustainable materials management systems throughout Carlsbad.

Implementation of Carlsbad’s SMMP and the completion of Phase 3 will result in the following:

  1. Sustainable materials management systems in all city government departments;
  2. Sustainable materials management systems throughout Carlsbad’s residential and commercial sectors, and public areas and venues; and
  3. Establishing the city as a leader in sustainable materials management.

The SMMP’s “actions” for each of the 3 Phases are presented in the context of the following three elements of sustainable materials management systems (life-cycle phases), with the major types of actions associated with each element noted:

  1. Upstream Design and Production – Designing and producing sustainable materials and products that have high post-consumer recycled content and contain no or minimal raw (virgin) materials, have no or limited packaging, are non-toxic, and are readily recyclable.
    • Major related actions include: Sustainable Procurement, Material Bans (Product Bans) | Disposal Bans, and Product Stewardship | Take Back Ordinances.
  2. Consumption and Use – Consuming and using sustainably produced materials and products in a manner that is consistent with the hierarchy of waste reduction, reuse, and recycling.
    • Major related actions include: Waste Prevention | Source Reduction, Material Reuse, and Sustainable Materials Market Development and Support
  3. End-of-Life Management – Maximizing diversion of materials and the production of post-consumer recycled content feedstock for upstream design and production of sustainable materials (i.e., closing the loop).
    • Major related actions include: Diversion Programs and Regional Advocacy and Support.

In support of city’s the end-of-life management objectives, it will need to negotiate changes to its existing collection contract and Palomar Transfer Station (PTS) operating contract, and/or draft new agreements and conduct competitive procurement processes for collection and transfer station services when the current contract terms expire. The City will also need to establish policies, enact or amend ordinances, and provide other support activities as deemed appropriate in support of its sustainable materials management objectives.

The SMMP has been well received by the City and its elected officials. The City’s planned next steps are the development and execution of a detailed Implementation Plan.

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Yolo Food Bank – Capacity Expansion Support & SB 1383 Compliance

Yolo Food Bank

R3 is providing the Yolo Food Bank with assistance to support the Yolo Food Bank’s efforts to expand its capacity by 50% and assist in the development and execution of a Distribution and Sourcing Plan to secure and distribute an additional 2+ million pounds of healthy food annually.

R3’s primary tasks for this engagement are as follows:

  • Initial evaluation of the Yolo Food Bank’s programs and services, current sources of food, and its Partner Agencies’ operations, capacities and other available relevant data;
  • Operational Review of the Yolo Food Bank:
    • Assessing key aspects of Yolo Food Bank’s operations; and
    • Determining if, and under what conditions, additional capacity could be increased to more than the planned 50% capacity increase if necessary;
  • Food Sourcing Assessment:
    • Assessing the Yolo Food Bank’s current sources for food;
    • Projecting the amount of additional pre-consumer edible food in Yolo County that is currently disposed from farms, manufacturing/wholesale sources, and consumer-facing businesses;
    • Projecting the total available SB 1383 Tier 1 and Tier 2 edible food, and percent of that total currently captured;
    • Developing a Sourcing Plan to secure 2 million additional pounds of food annually.
  • Partner Agency Capacity Assessment & Distribution System Assessment:
    • Assessing the capacity that exists within the Partner Agency network based on existing staffing and resources (number of additional meals per day that can be distributed if available); and
    • Assessing and documenting the geographic need within Yolo County and for each willing Partner Agency.

R3 is also assisting the Yolo Food Bank in maintaining compliance with the requirements of SB 1383 related to Edible Food Recovery Services and Organizations, as well as SB 1383 reporting requirements placed in edible food generators.

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Rancho Cordova – Legislative Compliance & Solid Waste Support

Rancho Cordova

Rancho Cordova is one of R3’s longest-standing clients—a partnership that began in 2004 and continues strong today. Over the past two decades, we’ve earned the City’s trust by consistently delivering reliable guidance through California’s constantly evolving waste regulations. This enduring relationship reflects the confidence City leadership has in our team’s expertise and our deep understanding of their community’s unique needs. We’ve worked alongside multiple city managers and staff transitions, providing the continuity and institutional knowledge that allows the City to adapt to new requirements without disrupting service to residents.

We handle the full spectrum of waste program management—from creating public outreach materials and updating ordinances to reviewing franchise agreements and monitoring hauler compliance. Our team develops branding, website content, social media posts, and educational guides that help residents and businesses understand new recycling requirements in plain language. We also work behind the scenes to identify which commercial generators must comply with state laws, verify their participation, and coordinate with local food recovery organizations to redirect edible food from landfills. This combination of public education and technical enforcement ensures high participation rates and regulatory compliance.

Our financial oversight includes conducting annual rate reviews to verify that hauler costs are reasonable and that residents pay fair prices for collection services. We review hauler reporting, evaluate contract amendments, negotiate service terms, and provide recommendations that balance quality service with cost control. We’ve helped the City update its waste hauler contracts and municipal code to incorporate new state requirements while protecting the City’s interests and maintaining good relationships with its service providers.

Twenty years of collaboration has made us an extension of the City’s team. Rancho Cordova trusts us to manage complex regulatory requirements, represent their interests in hauler negotiations, and provide honest guidance on difficult decisions. This partnership has resulted in streamlined operations, successful grant applications, and consistent compliance with state mandates—all while allowing City staff to focus on broader community priorities knowing their waste programs are in capable, experienced hands.

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Merced – Solid Waste Rate Study & 5-Year Financial Plan

City of Merced

R3 assisted the City of Merced with updating its solid waste and recycling rates following the repeal of a local utility tax that had previously funded waste programs. When the tax was eliminated in January 2018, the city needed to restructure its rate system to maintain service levels while complying with California’s strict Proposition 218 requirements for how municipalities can charge residents for waste collection. Building on a rate model we developed for Merced in 2014, our team calculated new rate adjustments that would cover the revenue gap and meet evolving state recycling mandates. Our work included analyzing whether additional revenues were necessary, developing multiple rate scenarios, and conducting surveys of comparable cities to ensure Merced’s pricing remained competitive.

The result was a transparent, Excel-based financial planning tool that allows the city to project revenues and expenses on a cost-of-service basis over a five-year period. This model helps Merced plan for future rate adjustments, capital improvements, and operational changes while maintaining compliance with both Proposition 218 and California’s expanding waste diversion requirements. We also reviewed the city’s municipal code to identify updates needed for new state laws on commercial recycling, organics collection, and food waste reduction. This comprehensive approach gave the city financial stability for its waste programs and a clear roadmap for adapting to future regulatory changes.

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