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San Francisco – Detailed Rate Application Review and C&D Third-Party Verifications

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.