The Board has continually affirmed that compliance with
AB 939 involves both achievement of the diversion mandates and implementation of
diversion programs. The Board is
committed to ensuring that local governments are implementing the programs
described in their Source Reduction and Recycling Elements and their Household
Hazardous Waste Elements. In
upholding the intent of AB 939, the Board also is expecting jurisdictions to
demonstrate real disposal reduction and not to simply quantify preexisting
diversion activities to reach the 50 percent diversion mandate.
The checklist is a guidance tool for jurisdictions
submitting a base-year study to the Board. The base-year proposal should contain good documentation, solid
calculations, strong methodology, and clear summaries.
Prior to submitting a final proposal to the Board, submit
a draft to your local assistance
staff contact, so they can review the proposal and provide
feedback.
(This is not an on-line form. Please print the checklist out and
fill it in manually.)
Methodology
If extrapolation was used, check to make sure that the
methodology is clearly documented and that all of the necessary information has
been provided to clearly document how the method was performed, including: type
of sampling method; source for identifying population; total population and
sample size; survey data collection tool(s) and approach; confidence level and
margin of error; explanation of outliers. Note: diversion tonnages from extremely large businesses, or those with
atypical diversion practices, should not be extrapolated to the entire
population.
If jurisdictions are doing a study jointly; e.g., a county
and associated cities, then they should use population for residential programs
and taxable sales combined with employment for commercial programs when
allocating diversion from regional facilities. For example, the jurisdictions
would use taxable sales and employment for allocating landfill salvage tonnage
from a regional facility to the various jurisdictions.
All conversion factors that are used should be referenced
in the proposal. Check the factors to make sure they are consistent with the
Diversion Study Guide. If they are different, explain why they are different in
the proposal and provide sources. The conversion factors provided may not be
representative of every jurisdiction within the state and should be used only
if they accurately reflect the weight of items and materials submitted in the
jurisdiction’s diversion study.
Make sure that there is no double-counting of diversion
data. For example, check that the non-residential sector data is not also
captured in the reports from the haulers, MRF operators, and/or composters.
Diversion
The diversion should be well documented. Documentation
provided should demonstrate that the jurisdiction is actually sending materials
to a diversion facility. Note: If a
jurisdiction claims diversion, for example, and yet there is no information
from the business stating that the jurisdiction’s residents send materials to
their facility, then the diversion shouldn’t be counted.
Make sure the types of diversion activities are described.
The new base-year request should contain a good explanation of what type of
program generated the diversion (material types and diversion tons should
correspond)
Compare waste prevention, recycling, and composting categories to see if one
seems abnormally high. This is an indicator. If one is extremely high, then an
explanation should be provided in the proposal.
If any particular diversion activity is extraordinarily
high when compared to the other diversion activities, provide an
explanation. For example, if landfill
salvage is high compared to the other recycling tonnage, provide an explanation
that justifies the diversion. Check
curbside recycling tonnage against total residential diversion and see if it is
high; e.g., 18 percent or higher. If it is high, explain why you are getting
such a high diversion rate; e.g., the jurisdiction has a high participation
rate, automated program, 96-gallon recycling containers, includes greenwaste,
etc.
For quantifying source
reduction, a disposal-based quantification method should be used. The tonnage
for source reduction should be counted as the incremental difference of a
material being diverted versus looking at it in perpetuity. For example, when quantifying the reuse of
wood pallets you should determine the normal life expectancy of the pallet;
e.g., wood pallets are not typically bought and disposed of after one use. Thus, if a
business uses 1,000 pallets and the life expectancy is 25 uses per pallet,
diversion would be quantified as 1,000 pallets being diverted, not 25,000
pallets diverted.
If sludge is being counted, be sure to refer to the "What
Counts" section in the Diversion Study Guide (DSG) and also PRC 41781.1 and 14 CCR section 18775.2.
Sludge certification is required for the
material to be counted as diversion.
If using an inerts landfill (Nuway, Peck Rd.) confirm that
the material being claimed for diversion was actually beneficial use and not
“filling the hole.” An explanation
should be included for the diversion from an inerts landfill.
If inerts, scrap metal, white goods, or agricultural waste is being counted,
check to see if the restricted waste criteria applies. The proposal should
specifically address restricted waste (see the "What
Counts" section in the
Diversion Study Guide for additional information).
If businesses were surveyed for the purposes of
extrapolation, make sure a large enough sample was obtained. Provide the
sampling methodology in the base-year request certification sheet that is
submitted to the Board. (See Appendix J for recommended sample sizes.)
Note: Do
not extrapolate diversion tonnages from extremely large businesses, or those
with atypical diversion practices. Add
the actual diversion tonnages from all very large businesses to the diversion
tonnage extrapolated from the randomly selected businesses.
The diversion data should be for the same year. If multiple
years are used, there should be a strong explanation that is logical.
If biomass or transformation is listed as a diversion
activity in the base-year proposal, it can only be counted as diversion in the
year 2000. If the proposed base year is
prior to the year 2000, the jurisdiction cannot count that diversion.
If tires are being counted as diversion, the jurisdiction
should explain how the tires are being diverted. For tire diversion to count, the jurisdiction should address that
the tires were reused or recycled. In many tire-burning facilities, metals and
other materials are separated from the tire before they are burned, and this
material could also be counted as diversion. The jurisdiction which hosts the facility would receive diversion credit
for any materials which are diverted after the tires have been burned such as
metals or ash that is diverted. NOTE: Since transformation could
not be counted until the reporting year 2000, tires that were burned cannot
count prior to 2000.
If the pounds/person/day (generation) is high, you will need to provide an
explanation.
Disposal
Double check that the disposal data is accurate according to the Disposal
Reporting System.
If the disposal tonnage went up significantly from the previous year and yet
the base year change is a high rate, you should provide an explanation.
