II - AB 341
Protecting our community's health and the environment by providing solid waste and sewer collection services.
www.cmsdca.gov
C OSTA M ESA S ANITARY D ISTRICT
. . . an Independent Special District
Memorandum
T o: The Board of Directors
From: Scott Carroll, General Manager
Date: September 11 , 2012
Subject: AB 341
Summary
On October 5, 2011, Governo r Brown signed into law AB 341. AB 341 will set a policy
goal of the state that not less than 75% of solid waste generated by source reduced,
recycled, or composted by the year 2020. It also requires CalRecycle, the state
agency responsible for enforcing state mandates on solid waste, to provide a report to
the Legislature that provides strategies to achieving the policy goal. The report is due
on January 1, 2014.
One of the primary purposes of AB 341 is the creation of green jobs. The landmark
law of AB 939 in 1989 has created 125,000 jobs over the past two decades. The
industry generates $4 billion a year in salaries and produces $10 billion worth of goods
and services annually. “Recycling is a powerful fuel that helps propel California's
economic engin e," AB 341 author Assemblymember Chesbro (D -North Coast) said.
“AB 341 will not only create more green jobs, but will protect the environment and
conserve energy by reducing the amount of waste that ends up in landfills ”, according
to Assemblymember Ches bro . CalRecycle has developed its draft plan to comply with
AB 341, but they are proposing a p aradigm shift by changing its focus from diversion
to recycling .
Staff has finished reviewing the draft plan and has provided an overview below along
with staff ’s proposed positions in support or opposition to certain aspects of said plan.
Staff Recommendation
That the Board of D irectors directs staff to send comments on CalRecycles’s draft
plan.
Board of Directors
September 11 , 2012
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Analysis
In 2007, SB 1016 was signed into law that changed the way the state and local
agencies report solid waste generation. Instead of reporting a diversion rate (e.g.
50%) agencies must now report a per capita disposal rate. SB 1016 also changed the
base tonnage generation to 2003 -2006. The State’s base genera tion from 2003 -2006
is 12.6 pounds per resident per day , so under AB 341 the goal for the State is to
achieve 3.15 pounds per resident per day .
However, CalRecycle believes 2003 -2006 base tonnage is too high because during
those years was strong economic growth that resulted in historical disposal generation.
Therefore, CalRecycle is recommending the average tonnage of 1990 -2010, which will
change the base generation significantly to 10.7 pounds per resident per day, which
means the new goal to achieve fr om AB 341is 2.7 pounds per resident per day.
As mentioned earlier, CalRecycle is proposing a paradigm shift by changing its focus
from source reduction diversion to recycling. Under the current source reduction goal,
the state achieved a 65% diversion ra te in 2010. To reach a 75% diversion goal,
CalRecycle will have to reduce the statewide disposal by 9 million tons. However, if
you take out the recycling credits (e.g. alternative daily cover) then CalRecycle is
achieving a 49% recycling rate. To reach a 75% recycling goal, Calrecycle will have to
reduce the statewide disposal by 19 million tons, a significant difference.
CalRecycle is determining the potential growth in traditional disposal and disposal
related activities and amount of additional recy cling needed. Their proposal projection
in 2020 is as follows:
• 36 million tons plus 7 million tons of previous excluded waste = 43 million tons
of potential disposal related activity if no additional steps are taken to increase
recycling.
CalRecycle wants to expand or site more facilities to accommodate higher recycling
volume, which will create more recycling based jobs in Calif ornia . CalRecycle a lso
wants to require stronger markets for recycled materials within our state and
successful implementat ion of other policies and greater participation in recycling
behaviors by the public. If successful, CalRecycle believes 200 million tons of
statewide land fill capacity will be preserved from 2014 -2025
CalRecycle is proposing the following Social, Econom ic and Environmental Drivers for
developing a Plan:
1. Preserve natural resources
2. Maximize source reduction
3. Decrease reliance on landfills
4. Minimize the impact of problematic waste materials
5. Increase protection of public health and the environment
Board of Directors
September 11 , 2012
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6. Reduce GHG e missions, and reduce localized air pollution
7. Reduce dependence on oil by increasing in -state production of
bioenergy/biofuel
8. Reduce the overall energy demand
9. Increase economic opportunity, manufacturing, and jobs in California
10. Reduce costs to local governm ents
11. Preserve local control
12. Provide stable state funding as necessary to implement and maintain a
sustainable materials management program.
Based on these drivers, CalRecycle wants to focus on ten areas that they believe are
critical to achieving the 75 r ecycling goal.
1. Increase Recycling Infrastructure
2. Organics
3. Increase Commercial Recycling
4. Establish Extended Producer Responsibility
5. Reform Beverage Container Program
6. Increase Procurement/Demand
7. Other Materials
8. Governance/Funding
9. Source Reduction
10. The Other 25%
CalRecycle has identified several implementation concepts for each of the 10 areas
mentioned above. Not all of the concepts are described below, but you can view the
concepts and the Plan in it ’s entirely by downloading the document at
http://www.calrecycle.ca.gov/75percent/Plan.pdf .
1. Increase Recycling Infrastructure
New recycling manufacturing/processing infrastructure - Estimate that a dozen
and perhaps over 100 new or expanded faciliti es are needed. Potential funding
sources include landfill tipping fee increase. 75% goal likely cannot be reached unless
instate manufacturing and energy generation facilities are developed.
Regulatory Oversight – Increase oversight and inspections on ex isting and future
facilities to ensure they operate in a manner that continues to be protective of public
health, safety, and the environment and they continue to be good neighbors and part
of a sustainable infrastructure – Indirect contribution to 75% goa l
Modify RMDZ Program to be Statewide – Two options: 1) keep current zones as is,
but allow for loans to be available to recycling manufacturers statewide where
partnerships exist with local governments. 2) Change to a statewide RMD loan and
assistance pr ogram. No specified zone areas. CalRecycle will focus on technical and
financial assistance to any recycling manufacturer
Board of Directors
September 11 , 2012
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CMSD proposed position – Supports new and expanded facilities but funding for
these facilities should be done on tax breaks and/or incentives for the private industry.
CMSD opposes increasing tipping fees because the fees will be passed onto CMSD
residents. Oppose CalRecycle increasing oversight and inspections because that
would mean the hiring of additional staff, which would put a burden on the state
budget. Additional inspections should be conducted on a county level with the option
of using private inspectors. Support option 2 for modifying RMDZ program statewide.
However, additional funding for loans may be required. CalRe cycle does not identify
the funding source.
2. Organics
Repeal Alternative Daily Cover (ADC ) and other waste materials beneficially used
at Landfills as diversion – Alternative approach to require all green waste used for
ADC be subject to tipping fee
Phase out of landfilling organics - One approach to require organics to be source
separate for collection and then prohibit the landfilling of source separated organics.
Funding for Organic Infrastructure – Compostable organic materials constitute 1/3
of landf illed material. Financial incentives are needed to facilitate the development of
dozens new organics management facilities in California, include anaerobic digestion
facilities. Funding source – landfill tipping fee increase.
Cross -Agency Regulatory Iss ues – Work with other federal and state agencies to
eliminate duplication in regulations.
CMSD proposed position – Oppose repealing ADC as diversion. Green waste used
as alternative daily cover is an inexpensive and environmentally sound method for
cover ing at the landfill. Oppose phasing out landfilling organics until more organic
management facilities are developed. Do not support source separating organics
because in CMSD that would require additional trucks, which increases operations
expenditures. Support funding for organic infrastructure, but not through increased
tipping fees. Give the private industry tax breaks and/or incentives for developing new
infrastructure. Support streamlining regulations.
3. Increase Commercial Recycling
Reduce Thresho lds for Commercial Recycling – 2 variations – 1) Lower the
threshold from 4 cubic yards/week to 2 cubic yards per week and include all
multifamily complexes. 2) Keep the current threshold but require regulated businesses
to recycle greater than 50% and do cument tonnage recycled.
Increase Requirement for MRF Performance – There may be great potential for
more recovery at mixed waste MRF’s and lower end clean MRFs. MRF performance
standards could be based on recovery rate, amount of recyclables in residual s,
implementation of BMP.
Board of Directors
September 11 , 2012
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Establish Business Enforcement Component – Either done by local jurisdiction or
by CalRecycle that focuses on businesses and multifamily complexes that do not
comply with commercial recycling requirement.
Grants for Multi -Family Recycling Programs – Support and/or augment current
commercial recycling requirements by providing grants to jurisdictions, waste haulers,
non -profit organizations, colleges, and regional partnerships for multi -family complex
recycling programs.
CMSD pro posed position – S upports the second variation for reducing threshold for
commercial recycling but CalRecycle needs to define multifamily complexes. What
about complexes that have 4 or less units? Can they use automated cart services?
Supports the use o f dirty MRFs for more recovery at mixed waste facilities . Dirty
MRFs cut down on the number of trucks in the street and have proven tec hnology of
the benefits. Oppose establishing businesses enforcement component. CMSD
believes that businesses need less government bureaucracy to be successful and
fears that an enforcement component will lead to businesses leaving the state along
with their valuable tax revenues. Support grants for multi -family recycling, but
recommends funds to be used to deter scavengi ng to purchase lockable containers,
enforcement and public education.
4. Establish Extended Producer Responsibility
Authority to decide products and targets – Establish a process for CalRecycle to
select products requiring management under an Extended Produc er Responsibility
(EPR) approach and to set enforceable end of life targets for those selected products.
Packaging – Comprise of nearly 1/3 of U.S. municipal solid waste stream and it
continues to grow in volume. According to the US EPA containers and pa ckaging
generation increased by 13 million tons since 1990. A comprehensive approach has
been difficult to discuss in part because packaging encompasses an enormous array
of products and material types. 2 options to consider
1) select a small set of problemat ic products/materials (e.g. non CRV
beverage containers) and establish a statewide pilot program that is
operated for several years before requiring additional packaging EPR
programs.
2) Conduct a pilot that is comprehensive in terms products/materials, but i s
limited to a small geographic area (e.g. coastal areas concerned with
marine litter)
CMSD position - Oppose CalRecycle overseeing and enforcing manufacturers
because it would require additional staffing that would be a burden on the State’s
budget. The additional enforcement could also place a burden on manufacturers that
may require them to relocate out of the state. CMSD does support option 1 for
packaging and suggest CalRecycle focus on Styrofoam.
Board of Directors
September 11 , 2012
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5. Reform Beverage Container Program
Program Expansi on of All Ready to Drink Beverages – Program will include all
ready -to -drink beverages for human consumption, except specified drinks (e.g. milk,
medical food, baby formula. By consumers returning their containers to buy -back
centers instead of curbside b ins, there is less contamination and the quality and
quantity of recycled material is greater.
Elimination of 14581 Fixed Dollar Expenditures - Eliminate automatic continuous
appropriation (e.g. $10.5 million to cities/counties for their recycling activit ies) and
develop a planning process that lay out proposed programmatic priorities for surplus
funds, which would be expended if available and if appropriated in those years by the
Legislature .
CMSD proposed position : Oppose consumers returning their all ready to drink
beverage containers to buy back centers, because the revenue from these containers
in curbside programs help offset the cost of providing a curbside recycling collection
program. Furthermore, if CalRecycle is going to focus on increasing di rty MRFs
performances, than contamination of recyclable materials should not be an issue.
Oppose 14581 fixed dollar expenditures because under the proposed plan CMSD
believes surplus funds will never be available and the Legislature will not appropriate
fu nds for recycling activities but rather they will use the money to balance the state
budget
6. Increase Procurement/Demand
Increase PCRC and EPP Purchases by the State . Reform Environmentally -
Preferable Purchasing (EPP) and Post Consumer Recycled Content (PC RC) law and
work with California’s Department of General Services and other state purchasing
entities (which may account for about 40% of state purchasing) to give higher priority
to PCRC products and EEP
CMSD proposed position: None
7. Other Materials
Plas tics – Finding a path forward to the management of plastic in California is one of
the keys to a more sustainable climate for the production and recycling of this
resource.
Construction and Demolition – Nearly 16% of material used as ADC is C&D. In
addit ion, nearly 29% of the disposed waste stream is C&D, which includes woody
debris and lumber. AQMD is reclassifying existing mobile crushers and grinders as
stationary resources, funding is needed to help processors remain in compliance.
Consider a grant program funded by a tipping fee on ADC or a loan program that is
either an expanded RMDZ program or utilizes other funding.
Fiber – Cardboard is still one of the largest components of the waste steam despite
being one of the more recyclable commodities.
Board of Directors
September 11 , 2012
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CMSD proposed position: S upports a more sustainable climate for the production
and recycling of plastics and encourage CalRecycle to collaborate with local
government, non -profit entities along with the plastic industry. Oppose a tip fee on
ADC to fund a program to make wood grinders be in compliance with AQMD. CMSD
recommends funding from AQMD to help with compliance. S upport s a progra m that
will recycle more cardboard.
8. Governance/Funding
New models for funding waste/materials management – The CIWM Act of 1989
requires each operator of a disposal facility in the state to pay a quarterly fee to the
State Board of Equalization. The current fee of $1.40 per ton is so low as to offer little
disincentive to landfilling. CalRecycle could research and analyz e the various models
employed in other states and countries for solid waste programs.
CMSD proposed position: Supports CalRecycle conducting research and analyze
various models employed in other states and countries, but opposes raising the tipping
fee as this fee will be passed on to our customers.
9. Source Reduction
Organic Food Programs, Backyard Composting, Vermicomposting – Gra nt
program focused on reducing generation of food waste.
Promotion of Local Zero Waste Activities – Promotion of and guidance on zero
waste activities, which could include: developing new information for CalRecycle
website, assessing definition of zero waste, conducting or participating in workshops
on zero waste “best practices” for communities and businesses.
CMSD proposed pos ition: Supports a grant program to promote reducing food waste
through backyard composting and vermicomposting. In 2010, CMSD was successful in
procuring a grant from OC Waste & Recycling where composting machines and
vermicomposting are offered a substant ial reduced rate. The grant also pays for
community composting workshops and a vermicomposting program for schools.
CMSD has sold 775 composting machines and 22 vermicomposting machine.
However, CMSD opposes a grant program funded by increasing the land fill tipping fee.
CMSD recommends funding the grant program by other means that would not require
a pass -through to CMSD residents. CMSD supports the promotion of local zero waste
activities. CMSD is in the process of developing its own Zero Waste Plan.
10. Other 25%
Define Post -Recycled Residuals – Define post -recycled residuals used for energy
recovery as those materials that have less than a total specified amount of designated
recyclable/compostable materials, unless the recovery facility operator can p rove there
is no feasible market for any remaining recyclables above a specified minimum
standard.
CMSD proposed position: None
Board of Directors
September 11 , 2012
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Strategic Plan Element & Goal
This item will achieve the objective and strategy of CMSD’s Strategic Plan Element
2.0, which s tates:
Objective: “Our objective is to manage the collection and recycling of residential
trash in the most economical and environmentally friendly way”
Strategy: “We will do this by looking for ways to improve efficiencies, achieve high
customer satisfa ction, and considering prudent new recycling methods.”
Legal Review
Not applicable
Financial Review
The cost to draft and send comments to CalRecycle is minimal.
Committee Recommendation
Not applicable.
Public Notice Process
Copies of this report are on file and will be included with the entire agenda packet for
the September 11 , 2012 Board of Directors meeting at District Headquarters and on
District website.
Alternative Actions
1. Do not send comments to CalRecycle and direct staff for more inform ation.