Napa Recycling and Waste Services

Napa County (County) engaged R3 to conduct a Performance Review and Billing Audit of its franchised hauler Napa County Recycling and Waste Services (NCRWS) in 2009, 2013, and 2020. R3’s objectives were to determine the extent of NCRWS’ compliance with the Franchise Agreement, billing and remittance practices, and make recommendations to the County for improvement of services. NCRWS provides all commercial and residential solid waste, recycling, and green waste collection services in the unincorporated area of Southern Napa County.

The major objectives of R3’s Performance Review and Billing Audit of NCRWS were to:

  • Determine the extent to which NCRWS has materially complied with the provisions of the Franchise Agreement;
  • Verify that NCRWS is properly billing customers and accurately remitting payments to the County; and
  • Make recommendations, as appropriate, for improvement of services.

As part of the review, R3 performed on-site reviews of records, conducted staff interviews, analyzed policies, procedures, and internal controls, and conducted field audits. A total of more than 140 separate contractual requirements were identified and reviewed.

In addition, the following aspects of NCRWS’ operations were reviewed:

  • Management and Administration;
  • Policies and Procedures, and Job Training;
  • Safety Issues and Safety Record;
  • Billing and Franchise Fee Payments;
  • Collection Operations Efficiency and Roll-Off Box Service Management;
  • Public Education and Diversion Plans; and
  • Vehicle Maintenance, Repair and Replacement.

R3 also compared NCRWS’ performance for various safety, customer service, collection productivity, diversion rate, and vehicle maintenance benchmarks to the industry standards.

As a result of our reviews, Napa County gained the following benefits:

  • Determination of NCRWS’ contract compliance;
  • Verification that NCRWS is properly billing customers and accurately remitting payments to the County;
  • Review of performance for various safety, customer service, collection productivity, diversion rate, and vehicle maintenance benchmarks to the industry standards; and
  • Recommendations for improvement of services.
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.

Monterey County - Solid Waste Flows

From 2014-2015, R3 was engaged by the County of Monterey (County) to evaluate and analyze its Solid Waste Management System, with the objective of developing an integrated regional approach as an alternative to the existing “split” between the two sub-regional solid waste management agencies. R3’s primary goal was to develop options to provide an efficient solid waste system to the entire Monterey region in a way that protected public health and the environment, provided benefits to all rate-payers, was committed to the highest and best use of materials, was adaptable and responsive in managing materials, and ensured that services were accessible to all customers.

R3’s work efforts included modeling tonnage flows between each community, transfer stations, processing facility and disposal facilities to determine the most environmentally sound and cost-efficient manner to manage solid waste on a regional basis. The modeling efforts addressed costs, GHG reductions, increasing diversion from landfill, closure of landfills, and location of transfer stations. The study’s results were presented in a series of regional workshops that facilitated the collaboration between all parties involved to remove barriers that previously had undermined cost-effective regional efforts to benefit all ratepayers. to identify and develop a consensus on operational, financial, political, and legal issues as alternatives to the status quo.

Clients of this regional engagement included the County of Monterey, Monterey Regional Waste Management District, Salinas Valley Solid Waste Authority, Pebble Beach Community CSD and the cities of Carmel-by-the-sea, Del Rey Oaks, Gonzales, Greenfield, King, Marina, Monterey, Pacific Grove, Salinas, Sand City, Seaside and Soledad.

Lane County Facilities

R3 (with the assistance of Abbe & Associates and Blue Ridge Services) was engaged by Lane County (County), Oregon, with a three (3) phased master planning process: conducting an Operational Review, developing a Regional Strategic Master Plan, and developing Jurisdiction-Specific Action Plans. The County operates a series of 16 transfer stations, a large landfill and a special waste facility.

Phase I: Operational Assessment

R3 reviewed the operations and finances of Lane County’s landfill and transfer station system, and material recovery operations, and identified opportunities to improve the safety, cost, diversion, and overall system performance. Recommendations were very well received by Lane County and include: reconfiguring Lane County’s rates for material recovery facility residuals to provide more effective incentives to divert material, revising operations at the landfill and at the County’s central transfer station, and closing various rural transfer sites. The Phase I Operational Assessment Final Report was presented and well received by the County Board of Commissioners. A major goal was to identify at least $1.5 million in annual cost savings for the Division; R3’s recommendations are projected to save the County $1.8 million annually.

Phase II: Regional Master Plan

Phase 2 of the project involves conducting a needs assessment and developing a strategic Regional Master Plan, with the goal of achieving a Countywide diversion rate of 63%. The Phase II Regional Waste Master Plan involves identifying, evaluating and recommending programs and policy options, and projecting funding needs associated with the recommended Master Plan components.  R3 also led the stakeholder involvement process as part of Phase II. As part of the development of the Regional Master Plan, R3 designed the supporting stakeholder involvement process that included:

  • Developing a short- and long-range vision (initially working with Lane County staff, then with stakeholders);
  • Developing a communication plan to compile information and feedback from representatives of the various cities in Lane County, the private solid waste haulers and facility operators, non-profits, and residents and businesses; and
  • Conducting stakeholder engagement and outreach efforts (workshops, public meetings, publications, websites, etc.) to obtain feedback, ideas, and “buy-in.”
  • As part of this phase, R3 leveraged the County’s regional food recovery programs to develop recommendations for increased edible food recovery.

Phase III: Jurisdiction-Specific Action Plans

Phase III of the project involved working with the cities of Eugene and Springfield to develop jurisdiction-specific Action Plans to guide the implementation of solid waste management system polices, programs, and facilities in those jurisdictions that are aligned with the County’s Regional Master Plan.

Recently, R3 was selected to further assist the County with the following:

  • Drafting and executing waste disposal agreements with each of the incorporated cities that currently deliver their waste to the County’s waste management transfer station and landfill system;
  • Assessing  the pros and cons of establishing a countywide solid waste joint powers authority, and each of the jurisdiction’s level of interest in forming a JPA, and identify next steps; and
  • Drafting and negotiating a memorandum of understanding for coordinated county-wide solid waste management reporting requirements,;
  • Assess the pros and cons of the various collection system structures available to the County for the regulation of its private haulers in the Eugene-Springfield Urban Growth Boundary and the other more rural unincorporated areas of the County, and recommend a preferred structure
    based on the County’s objectives for its solid waste management system;
  • Drafting a performance-based high-recovery “model” franchise agreement, with private hauler input, that the County can use to regulate haulers within the County based on the preferred collection system structures determined above; and
  • Assisting the County with the executing performance-based high- franchise agreements with the private haulers operating in unincorporated Lane County.
San Francisco

Detailed Rate Application Review

R3 assisted the City of San Francisco Public Works Department (SFPWD) with a high-level review of Recology San Francisco’s (Recology) Rate Year 2017 Rate Application. R3’s role included a detailed examination and analysis of the rate adjustment application to determine if Recology’s calculated costs, revenues, and assumptions were reasonable, appropriate and accurate. As part of the review, R3 also evaluated Recology’s proposed changes to the single-family and multi-family rate structure – specifically, changes to the fixed and variable portions of the single-family and multi-family rates, and the associated impact on ratepayers. To assist the SFPWD in determining whether to accept the changes, R3 assessed how the fixed/variable rate structure compared to Recology’s fixed/variable expenses, and developed comparative scenarios for consideration by the SFPWD.

Over the course of this engagement, R3 provided the SFPWD with recommended programmatic changes to achieve higher levels of material diversion from landfill in support of SFPWD’s zero waste goal, and recommended adjustments to operating costs, revenues, and projection assumptions to better represent service area conditions and balance Recology’s needs with the interests of the SFPWD and its ratepayers. Additionally, R3 evaluated a complex change in collection services, which resulted in an increase of 23 collection routes throughout the SFPWD’s service areas and a net increase in the capacity for the collection of diversion waste streams.

Following R3’s verification of the application, the SFPWD successfully adopted Recology’s requested rate adjustment.

Currently, R3 is conducting a review of the reporting requirements outlined in the City and County of San Francisco’s 2017 Director’s report and Recommended Orders on Recology’s 2017 Rate Application. The review consists of comparing assumptions in the 2017 Rate Application to actual performance, reviewing the standardized format for the rate application, proposing changes in the rate-setting methodology and quarterly and annual reports, and assisting staff with developing changes to the application and supporting schedules. R3 has conducted an in-depth analysis of the hauler’s operating ratio, cost of living adjustments, and a variance analysis of projected to actual expenses and revenue to provide future recommendations to staff.

C&D Third-Party Verifications

R3 is currently an approved Third-Party Verifier for the City of San Francisco (City) Department of the Environment, conducting third-party verifications of facilities seeking to receive and process construction and demolitions (C&D) debris generated in the City as required under the Department of the Environment’s C&D Debris Recovery Ordinance. R3’s primary role as a Third-Party Verifier is to conduct on-site facility evaluations of facility recovery rates and verify the operational effectiveness of facilities to meet the City’s minimum 65% recovery rate.

R3‘s Third-Party Verification process typically includes these steps:

  • Engagement letter of third-party verification with the facility;
  • Review of validity of facility’s solid waste facility permits and certifications;
  • Receiving and reviewing 12 months of facility data including summaries, by material type, of facility input and outbound tonnage data (incl. marketed materials, residuals, and materials used as Alternative Daily Cover at landfill);
  • Scheduling site visit to review scales and verify best practices of facility;
  • Preparing agenda and preparing facility for site visit, which may include one or more phone calls;
  • Conducting site visit;
  • Resolving any discrepancies and conducting any follow-up data requests and/or site visits, as necessary; and
  • Preparation of electronic final letter report of facility certification, including recommendation for approval or denial.

R3 was selected by the City of Santa Clara (City) in 2017 via a competitive procurement process to conduct an audit of the City’s 10 Non-Exclusive Franchised (NEF) haulers. The NEF haulers provide garbage, recycling, organics, and construction and demolition (C&D) debris collection services within the industrial-zoned areas of the City.

The objectives of this original engagement were to review the period of July 2016 to June 2017 and verify the following:

  1. The accuracy of the haulers’ quarterly reports;
  2. The accuracy of the haulers’ franchise fee payments; and
  3. The haulers’ compliance with the requirement not to provide garbage service to commercial customers that generate 4+ cubic yards per week and are in violation of the City’s mandatory recycling and organics requirements.

R3’s review identified significant underpayments of franchise fees by the haulers, ultimately amounting in a net total of $102,000 owed to the City. R3 communicated the results of the recalculations to the NEF haulers, and all agreed to the mathematical accuracy of franchise fee amounts owed to/from the City.

R3 also provided the City with the following:

  • Identification of haulers that were non-compliant with the commercial recycling and organics subscription reporting requirements specified by their Agreements;
  • Consolidated list of customer listings from each hauler, with updated status of customers’ commercial recycling and organics compliance or exemption status; and
  • Revisions to the NEF Hauler Agreements to include the following:
    • Simplification of the tiered franchise fee calculation by switching to a flat franchise fee on all gross billings;
    • Promotion of diversion through alternative mechanisms, including:
      • Universal bundled services for garbage, recycling, and organics; and
      • Specifications involving minimum diversion rates for facilities that process collected materials;
    • Clarification of the language pertinent to gross billings; and
    • Incorporation of language to facilitate compliance with state legislative requirements.

As a result of the initial audit, R3 was retained by the City to conduct two more NEF hauler audit cycles, as well as to support the implementation of our recommendation to revise the NEF Agreements to facilitate future compliance with state legislation. Our most recent audit for the period of July 2017-2018 identified an additional net total of more than $160,500 in underpayments owed to the City. R3 will conduct the next audit for the City between July 2019 and December 2021.

R3 has conducted a wide range of projects for the City of Santa Rosa (City), including the following:

Zero Waste Plan

R3’s Zero Waste Plan (Plan) was tailored to the unique disposal and waste reduction trends and goals of the City, executable within, and measured by, 5-, 10-, and 20-year milestones.For this project, R3 formed a project team of leading experts in the fields of Zero Waste public engagement, waste stream modeling, and municipal solid waste planning. Aided by the expertise of two subconsultants, Ruth Abbe of Abbe & Associates and Cascadia Consulting Group, R3’s primary goal for this project was to provide the City with a Plan that sets the new standard in its specificity, rigor, and vision.

In developing the Plan, R3 provided the City with a quantitative, practical guide to residential, commercial and City programs that will achieve the City’s Zero Waste goals. The Plan also provided the City with cost estimates of the Zero Waste programs that would be necessary to achieve those goals, which included an analysis of current disposal and diversion tonnage and trends in the City and an estimate of what can actually be diverted with the Plan.

Core components of the Plan included developing a Waste Diversion Model and implementation outreach strategy, conducting a vigorous stakeholder engagement process, and designing a comprehensive Plan document that includes policy, program, partnership, and facility diversion options for the City. R3 also provided the City with an analysis of the economic, diversion, greenhouse gas, and financial impacts of the Plan, as well as the timeline and actionable steps for its implementation.

R3 shepherded Council adoption of Plan with recommendations for $600,000 in annual program funding.

Performance Review(s)

R3 is currently engaged by the City to conduct a comprehensive Performance Review of the City’s franchised solid waste hauler, Recology Sonoma Marin (Recology), for the calendar year 2018 and the first quarter of 2019. The review included the following main tasks:

  • Franchise Agreement (Agreement) and Regulatory Compliance Review;
  • Operational Performance Review, including management and administration, collection operations, customer service and financial management practices, and vehicle and equipment upkeep;
  • Billing Audit and Financial Assessment; and
  • Legislative Compliance Review.

R3 is working with Recology and the City to review Recology’s existing services through data analysis, observations, and on-site reviews. For this engagement, R3 is specifically addressing Recology’s efforts in support of the City’s compliance with AB 1826 and SB 1383, as well as the hauler’s achievement of its 40% diversion requirement.

Procurement Assistance

As a result of a performance review conducted by R3 in 2015, we were engaged by the City to provide assistance in procuring a new hauler for the City’s solid waste and recycling collection and processing services.  As with all of our procurement projects, R3 worked closely with City staff to complete the following tasks:

  • Conduct community workshops and City Council meetings;
  • Prepare written RFPs and Agreements;
  • Oversee the competitive procurement process;
  • Analyze waste hauler proposals; and
  • Manage the evaluation of proposers and selection of a provider for City services.

This project resulted in a high-diversion, state-of-the-art residential and commercial exclusive Agreement (that complied with AB 1826 and SB 1383) and RFP. The City received five (5) proposals for the provision of collection service – R3 reviewed and analyzed proposals, interviewed and negotiated with the highest-ranked companies, conducted site visits at proposed facilities, and provided the City with high-level information about how each company could affect the goals and collection within the City.

During this process, The Ratto Group sold its company to Recology. R3 assisted in a review of Recology to establish findings regarding the proposed contract assignment, on behalf of the various jurisdictions in Sonoma County (including Santa Rosa) holding solid waste collection franchise and other agreements with The Ratto Group. Currently, R3 is providing contract management assistance and developing a Zero Waste Plan for Santa Rosa.

MTWS Performance Review for Los Altos - Project Analysts Claire Wilson and Ryan Calkins

Performance Review

R3 was engaged by the City of Los Altos (City) to conduct a Performance and Billing Review of Mission Trail Waste Solutions (MTWS) as included under their Collections Service Agreement (Agreement) to provide solid waste, recycling, and organic collection services for the City. R3’s high level review of MTWS consisted of two main tasks: a performance review and a financial compliance assessment. The primary goal was to determine MTWS’ compliance with the applicable terms and conditions of the Agreement, review the effectiveness of current operations; and identify opportunities for program improvement.

R3 worked with MTWS management and City staff to assess MTWS’ compliance with the reporting requirements and performance standards of the Agreement, as well as verify customer billing rate calculations and service levels, franchise fee calculations, and reported diversion percentages.

R3 utilized a variety of methods in the execution of the performance review, including analysis of relevant documents, on-site and field observations, and interviews. The Performance Review addressed the following major aspects of MTWS’s operations:

  • Collection Service Agreement Compliance Review;
  • Collection Operations Review;
  • Management and Administration Review;
  • Vehicle and Equipment Maintenance, Repair and Replacement Review;
  • Customer Service Review (including customer feedback);
  • Monthly, quarterly and annual report assessment;
  • Diversion Programs, Performances and Good Faith Efforts; and
  • Outreach and Education Services.

R3 conducted the financial compliance assessment to determine that customers are being charged the proper service rate based on their service level; service rate revenues are properly recorded and accounted for by the contractor; franchise fees are properly calculated, paid and received. R3 conducted three tests to accomplish this goal:

  • Test of Subscribers to verify that service subscribers are billed the correct rate for the level of service provided;
  • Test of Revenue Transactions to verify that the billed amounts to City residents and businesses, and the corresponding payments received are properly recorded in the MTWS billing and accounting systems; and
  • Test of Franchise Fee Transactions to verify that the franchise fees are calculated correctly, and based on the correct level of recorded revenues.

Our review found that MTWS is in compliance with the vast majority of the Agreement’s requirements. Collections are performed in a safe, courteous, and cleanly manner; coordination between the drivers, customer service, shop, and management is facilitated by an effective system of work orders; fleet maintenance operations and vehicles have consistently received satisfactory ratings from the California Highway Patrol; and MTWS is operating a sophisticated and professional customer service operation.

We determined that the most significant area for improvement relative to the Agreement’s terms and conditions is in outreach and education, which is not being performed according to the Agreement’s requirements.

Project benefits include:

  • Verification of MTWS’ compliance with the vast majority of the Agreement’s provisions;
  • Recommendations for MTWS’ improved compliance with the existing requirements of the Agreement regarding meeting reporting requirements, outreach and education activities, and paying the City franchise fee and administrative fees; and
  • Recommendations for revisions to the Agreement with regards to HHW collection services, rate requirements, and the billing schedule.

High Diversion Planning

R3 has been working with the City of Los Altos (City) since 2010, when we were originally engaged to provide procurement assistance resulting in the award of the Franchise Agreement (Agreement) with the City’s current hauler, Mission Trail Waste Systems (MTWS), that requires 78% diversion of franchised waste.

In service of our ongoing diversion support for the City, R3 has recently:

  • Completely revised the City’s Solid Waste Ordinance to align with the Agreement with MTWS, facilitated complete subscriber compliance with two State of California Assembly Bills (AB), AB 341 (mandatory multi-family and commercial recycling) and AB 1826 (mandatory commercial organics diversion), and facilitated increased diversion of recyclables and organics from commercial, industrial, and multi-family waste generators;
  • Undertaken an SB 1383 preparedness exercise in which we identified opportunities for the City to obtain needed support from MTWS in complying with the regulations;
  • Assisted the City in identifying enforcement thresholds for mandatory recycling and organics service: drafting enforcement letters which include notification of state law for generators covered under AB 341 and AB 1826, exemption forms, and a self-haul tonnage reporting form; and site visits to covered generators to encourage compliance;
  • Reviewed implementation of services in the field, including lid-flip assessments of waste from the top 50 generators in the City, as well as an assessment of MTWS’s outreach and education pertaining to increased diversion of recyclables and organics;
  • Developed a technical assistance plan and framework in support of the City’s commitment to providing diversion-related technical assistance and outreach;
  • Revised the City’s Construction and Demolition (C&D) Debris ordinance in alignment with CALGreen, establishing a system of facility certification;
  • Certified facilities and revised the City’s mandatory building checklist to include the certified facilities and other approved means of compliance such as deconstruction and purchase of a debris box from the City’s franchised hauler;
  • Conducted a street maintenance impact fee study for refuse vehicles used in the City; and
  • Completed the City’s Electronic Annual Report to CalRecycle for the reporting years 2016-2019.

R3 has also been engaged to assist the City with contract extension negotiations with MTWS, which includes support for some SB 1383 requirements, including universal roll-out of organics service to all businesses in the City.


In early 2016, R3 was engaged by the City of Rolling Hills Estates (City) to conduct a Performance Review of their franchised hauler, Waste Management (WM), with the objective of assessing WM’s collection operations prior to the Franchise Agreement’s (Agreement) expiration.

Overall, WM received a positive review, although R3 found that they were out of compliance on vehicle weights and diversion standards, and they were substantially undercharging for manure collection and processing, which in turn negatively impacted their other required services.

Rather than seeking competitive bids, the City opted to work with the hauler to correct the compliance violations and renegotiate the contract, because of the City’s unique service requirements (e.g., unlimited multiple container sizes for recycling and organics at no cost; required use of smaller collection trucks; and required no-cost service for hard-to-service areas). R3 subsequently worked on the City’s behalf to negotiate the new Agreement, which assists the City in complying with state legislation (e.g., AB 939, AB 341, AB 1826, and AB 1594), prevents negative impacts on customer rates, and includes these beneficial features: a very specific public education program; a contamination monitoring and reporting program; and universal rollout of organics to all commercial and multi-family customers as a base service requirement.

R3 is currently assisting the City with modernizing and streamlining the language in the City’s municipal code to include legislative requirements for recycling and organics diversion (AB 341, AB 1826, SB 1383, and AB 1594).

In 2004, the City of Stockton entered into a franchise agreement with two waste haulers, Republic Services (previously Allied Waste), and Waste Management (USA Waste), the number #1 and #2 largest solid waste management operators in the Country. The 15‐year agreement provides a residential and commercial 3‐cart waste collection system that includes recyclables, green and food waste. The franchise agreement with both haulers is due to expire in 2019, unless it is extended. Read more