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"Innovations" Case Studies: C&D Recycling Plans and Policies

Case Study: Hawthorne C&D Waste Minimization Plan

The C&D waste minimization plan for the City of Hawthorne was part of the city’s response to complying with the 50 percent waste diversion goals of the IWMA.

Project Approach

The City of Hawthorne recognized that this plan needed to build on decisions that had been made (for example, the structure of the existing franchise and city ordinances) and existing operations in the area. Also, there were limitations on the amount of construction and demolition data that could be obtained in the time allotted. This was particularly true because of the lack of quantitative reporting on local disposal and recycling activities in the past.

The city’s consultants first obtained as much information as possible from the city and the city’s franchised hauler, H&C Disposal. The city also sought the perspective of other businesses in the city, including waste haulers, recyclers, contractors, waste generators, and developers. The city’s consultants contacted city departments to identify some businesses that may be impacted by the new franchise. The consultants made a presentation at the local Kiwanis club to solicit additional input. The city prepared a flyer about the franchise requirements for distribution by city building and planning departments and sought input from many other contacts in the area.

The City of Hawthorne updated the Los Angeles C&D recycling directory for use by H&C and city contractors and worked to evaluate any particular constraints about operating within the City of Hawthorne, given the city ordinance and exclusive franchise. The city also contacted many other cities in the Los Angeles region to update information on their policies, practices, and rates and fees. Based on other successful programs, the city confirmed the best practices for C&D recycling, reporting, and monitoring.

The city also reviewed city documents related to the terms of the city’s solid waste franchise and contract agreement. Municipal code language related to solid waste and recycling activities permitted in the city was also reviewed, as well as current reporting practices and requirements for H&C and other haulers and recyclers.

The terms of the franchise agreement with H&C and the municipal code limit the city’s ability to require H&C to provide information on existing solid waste costs, tonnages landfilled, and tonnages and types of material recycled. However, H&C cooperated by providing information about their operations and by meeting with the city.

The City of Hawthorne tried to identify the amount of C&D activity in Hawthorne over the past year. Unfortunately, there was insufficient data available in Hawthorne to properly determine how much material was collected, diverted, and disposed of over the past several years.

After local research was completed, the city evaluated C&D programs based on their practicality, cost effectiveness, and potential diversion impacts. The City of Hawthorne was particularly concerned with the cost impacts of recommendations, both short-term and long-term. The city also wanted to protect itself against likely major cost increases from projected disposal cost increases.

Since the primary impetus for the development of the C&D plan was compliance with the 50 percent diversion mandate, there was an overriding need to maximize waste diversion and meet State reporting requirements. By building a sustainable infrastructure for policies, programs, and reporting on C&D debris recycling, the city was able to understand and control future costs. Throughout the plan, the City of Hawthorne adopted incremental steps to be taken to accomplish individual tasks to reach the desired objectives.

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H&C Disposal Exclusive Franchise for C&D

The city chose to award an exclusive right to collect and dispose of C&D debris to its franchised hauler, H&C Disposal. The city directed H&C to implement recycling programs for C&D debris they exclusively collect, and to report to the city the amounts of C&D materials recycled and disposed.

H&C had been the franchised hauler for residential and commercial wastes in Hawthorne for more than 40 years. On May 24, 1999, the City of Hawthorne approved an amendment to the agreement for refuse collection services between the city and H&C to provide H&C an exclusive right to collect, transport, and dispose of the following materials in Hawthorne:

  • Construction and demolition debris.
  • Discarded appliances and furniture and other similar goods.

Not included in this exclusive authority are the following exceptions:

  • C&D debris hauled by contractors in their own or leased vehicles from their own job sites when the hauling is an incidental rather than a primary part of the contractor’s services.
  • Carpeting, furniture, appliances, white goods, or similar goods hauled by persons or entities delivering new goods, when the hauling is an incidental part of the delivery of new goods.
  • Scrap lumber incidentally included in yard waste hauled by gardeners or landscapers, when the hauling is an incidental part of the gardening or landscaping services.
  • Recyclable materials sold or donated to someone other than H&C Disposal, if the materials have been separated at the source and the hauler was not paid by the waste generator for collecting, processing, or transporting those materials, or a consulting fee for recycling services.
  • Appliances and white goods hauled by utility companies as part of a rebate or buyback program.
  • C&D debris generated by any public project of the City of Hawthorne.
  • Materials excepted by the city manager due to special circumstances.

H&C agreed to pay the city a 10 percent billing fee and a 15 percent franchise fee for all C&D wastes collected.

The city council determined in its adoption of the exclusive franchise for C&D debris for H&C disposal, that:

“CONTRACTOR represents and warrants to City that it has the experience and qualifications to conduct recycling programs for the recovery of recyclables from construction and demolition debris, discarded appliances, discarded furniture and other similar goods, to provide City with information sufficient to meet the City’s reporting requirements under AB939 [the IWMA], to arrange to collect, transport and recycle or dispose of these materials in a safe manner which will minimize the adverse effects of collection vehicles on air quality and traffic.”

Based on these determinations, the C&D plan noted that it was incumbent upon H&C to detail its plans to provide C&D recycling services to the satisfaction of the city in a comprehensive C&D operations plan (see below).

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City C&D Recycling Resolution: Requirements for C&D Recycling Reporting

The IWMA requires the City of Hawthorne to develop a diversion requirement and reporting system to document the amount of construction and demolition waste diverted from landfills, along with the total amount disposed. The reporting systems outlined for C&D waste are critically important for the city to more accurately project the need for C&D services in the future. The report data also serves as a guide to set rates that are fair to both ratepayers and the franchised hauler and to provide incentives for recycling services. These can be evaluated on an ongoing basis by city staff.

City staff recommended a council resolution that established a policy to require the reuse, recycling, and/or composting of C&D waste and the documentation of C&D waste recycling by all the key participants in Hawthorne.

The resolution adopted by the city council on September 13, 1999:

  • Required all city departments and H&C Disposal to implement a construction and demolition debris recycling program.
  • Required the city manager to complete and begin to implement a comprehensive C&D waste minimization plan by October 1, 1999, that details activities by city departments, H&C Disposal, and all private sector C&D projects in Hawthorne to increase the reuse, recycling, and composting of C&D materials.
  • Required the chief of general services and public works to include a specification for construction and demolition waste management in contract documents for all public works construction, including:
  • Guidelines and requirements for reuse, recycling, and/or composting of C&D materials from city construction and demolition projects.
  • Submittal of a C&D waste management plan and quantitative reports for C&D materials generated by all contractors for City of Hawthorne construction and demolition projects as a condition of approval of progress payments to be paid by the city.
  • Required all private construction or demolition projects over 10,000 square feet in gross floor area to divert the maximum feasible amount of construction and demolition materials.
  • Required all private developers, construction and demolition contractors, waste haulers, and others handling these materials to report the quantities diverted and disposed to the city upon completion of the project in a format approved by the city, either directly or through H&C Disposal.
  • Established detailed measures for monitoring and enforcing the reporting requirement on private construction, demolition, or land clearing projects over 10,000 square feet in gross floor area by:
  • Requiring submittal of quantitative reports for C&D materials generated as a condition of issuance of building or demolition permits.
  • Requiring a $250 deposit with building permit fees from private contractors when they obtain building or demolition permits. The deposit is to be returned at project completion if contractors demonstrate that they have supplied the C&D reports.
  • Requiring that satisfactorily completed C&D reports are received by the city before issuance of a certificate of occupancy for new construction projects.
  • Required H&C to submit quarterly reports to the city on the amount of C&D materials collected by material type, the destination to which each of those materials were taken, and the amount of diversion documented to have been achieved at each of those facilities.

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Principal Findings of C&D Plan

The C&D plan was adopted by the city manager on October 1, 1999, as directed by the city council. The City of Hawthorne found that there were many opportunities to increase C&D diversion in Hawthorne. Key findings included:

  1. Construction and demolition contractors in Hawthorne are already recycling some C&D materials, particularly inert material and metal, but those activities have not been well documented. Similarly, salvaging of reusable material and selected recyclables is also taking place, although harder to quantify. A considerable amount of inert material is crushed and processed on site for use in the construction process, and this activity has also not been documented. Reporting requirements can capture this information.
  2. Many contractors already meet the definition of “self-haul” and will continue to haul their own material. Reporting requirements for all public and private projects can capture this information.
  3. A large amount of recyclables from C&D debris in Hawthorne is still going to disposal facilities. The city believes that contractors and haulers in Hawthorne can still recycle far more C&D material with minimal impacts on costs or operating efficiencies. These could be stimulated through price incentives, city policies and requirements, additional hauling service options, technical assistance to contractors, and H&C subcontracting or joint venturing with recyclers.
  4. City staff is already implementing many recycling practices through their day-to-day functions, including imposing recycling and recycled-content requirements in contracts. However, these practices are not widely recognized. A more formal monitoring system and better reporting would help to document these activities.
  5. City staff is in a position to help educate contractors about service options through the distribution of literature at their service desks. The staff can also collect data by requiring reporting with permit and EIR requirements and by implementing clear enforcement of these requirements (for example, withholding signoff or deposits).
  6. H&C appears open to many different strategies that would allow them to use recycling facilities that are competitive in price with their current transfer station tip fees. Nearly all C&D rolloff materials are delivered at transfer stations at this time.
  7. In addition to H&C, approximately 100 independent companies are currently able to provide reuse, recycling, and composting services in Hawthorne for any materials donated or sold by waste generators. The materials must be kept separate for reuse, recycling, or composting.
  8. The city prepared a construction and demolition debris recycling directory that provides detailed information on all those companies, including contact information, types of materials accepted/processed, specifications that need to be met for materials accepted, services offered, and end-products made. The Hawthorne directory is adapted from a directory developed over many years by the City of Los Angeles, modified for Hawthorne policies and programs.
  9. Of particular note are the service providers that can accept loads of mixed C&D materials. While these service providers may vary in their recycling processes, capacity, diversion rates, specifications, reporting, and collection services, they offer a starting point to help H&C supplement source separation practices and achieve high rates of diversion at prices competitive with current transfer station fees.
  10. Mixed C&D processing capacity in the region is expected to continue to increase substantially in the coming 12 to 24 months. At least one new facility will open before the end of 1999. The State is currently in the final stages of adopting regulations that will monitor and oversee these new types of recycling facilities. Currently, processors of mixed C&D materials are:
  • American Waste Industries, Los Angeles.
  • Bradley Landfill and Recycling Center, Sun Valley, Calif.
  • Community Recycling and Resource Recovery Transfer Station, Sun Valley
  • Looney Bins, Sun Valley, Calif.
  1. Rates to recycle C&D materials are now competitive with local transfer station rates. Although there may be a small incremental cost in some cases to recycle mixed C&D at reuse, recycling, or composting facilities by H&C when compared to landfilling, that is offset by the need to comply with State recycling mandates.
  2. Clear cost savings opportunities (for example, recycling concrete and scrap metal) combined with incremental cost increases for mixed C&D disposal should provide an aggregate cost savings to H&C. With the risk of $10,000 per day fines under the IWMA considered by the city, it is also clearly in the city’s interest to maximize the amount of materials diverted from C&D. Recommendations were made in this C&D plan on how to accomplish that.
  3. Interviews with contractors, Hawthorne businesses, hauling companies, and recycling companies showed a very broad range of prices for disposal and recycling services. There was considerable concern about costs increasing and less recycling occurring as a result of the additional city franchise and billing fees required as part of the C&D franchise. C&D practices vary, with some contractors using H&C and others self-hauling. Many use other hauling and recycling companies, and some contractors and businesses using the services of small companies that combine clean-out services with recycling and hauling.

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Last updated: October 26, 2007


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Larry N. Stephens: lstephen@ciwmb.ca.gov  (916) 341-6241