Base Year/Reporting Year Change Policy

Working Group Recommendations

Solution Options

The working group recommends that a jurisdiction dealing with inaccurate base-year and/or reporting-year data be allowed to select from a flexible range of solution options. These proposed options would allow a jurisdiction to select what they believe to be the most cost-effective option(s) for increasing their base-year and/or reporting-year accuracy. The potential solution options are described below and are summarized in the following table.

Base Year

The first option, to correct the existing base-year data, is the starting point for most jurisdictions. A jurisdiction selecting this option would need to determine the nature of the base-year inaccuracy(ies) and then quantify the correction(s). Attachment A provides a current list of staff’s acceptable/ unacceptable base-year revision methods, based on the 1995 annual reports. The Board will determine the acceptability or unacceptability of additional revision methods as they are submitted to the Board. If staff deems a jurisdiction’s method(s) as unacceptable, the jurisdiction may challenge this decision by requesting a hearing by the LAPC and the Board. [In January 2000, the Board decided to allow correction of Base years within three years.]

It should be noted that the magnitude of the base-year generation revision is a major concern regardless of what revision method is used. Staff recommends that revisions of a large magnitude be documented with actual, auditable data if at all possible. A method which relies heavily upon rough estimations or extrapolations might be appropriate for a revision of a small magnitude; however, such a method might not be acceptable for a revision of a large magnitude. In some instances, staff might request that a jurisdiction provide further documentation. The burden of proof is upon the jurisdiction to demonstrate the reasonability of their base-year revision request.

To utilize this first option, there must be sufficient sources of information (e.g., consultant/jurisdiction/other personnel and waste hauler/landfill/other records) available to determine the methodologies used and the derivation of the data presented in the waste generation study, and to quantify waste amounts excluded from the study (if applicable). More current data may also provide some assistance in the analysis process; however, since conditions have usually changed significantly over time, it may not be possible to apply more current data to the base-year when making corrections. Some jurisdictions that have attempted this correction process have expressed concern regarding the time and cost intensiveness of this process and the difficulty in obtaining the necessary information.

Regional Agency

The second option, to become a regional agency, is an option that is already available to all jurisdictions that meet the statutory/regulatory requirements. Since a regional agency may report to the Board as a single entity, many of the allocation errors can be eliminated for jurisdictions that form a regional agency. However, many jurisdictions have expressed concern about their potential liability for Board penalties if some of the other regional members do not adequately implement their diversion programs. Local political problems have also been cited as a barrier for the formation of regional agencies.

Generation-Based Study

The third option would allow jurisdictions to provide an annual generation-based analysis to the Board each year. Since the disposal tonnage is now being tracked annually in the DRS, a jurisdiction that is also tracking large tonnage diversion programs (such as curbside recycling in combination with composting, or a MRF) might easily demonstrate goal compliance using readily available disposal plus diversion (i.e., generation) data. A generation-based analysis eliminates the need for base-year data since an estimate of the reporting-year generation is no longer needed when actual data is available. For those jurisdictions with this type of data, this option could provide a no-cost solution.

New Diversion Study

Similarly, the fourth option would be to create a more current base-year by using the disposal tonnage from the DRS and diversion tonnage from a newly conducted diversion study. This option would provide a generation-based analysis for the year in which the study was conducted, and then provide a new base-year for future disposal-based analyses. Since many jurisdictions have expressed concern regarding the time/cost intensiveness and difficulties in obtaining diversion data, the Working Group recommends the application of a modular approach when conducting a new base-year study. A jurisdiction should begin with the most readily available diversion data and then proceed in the most cost effective manner, focusing on the businesses and industries that are believed to divert the largest amounts of solid waste.

Reporting-Year

The fifth option, revising reporting-year data, allows a jurisdiction to present a more accurate estimate of its waste disposal than the estimate from the DRS. To effectively revise reporting-year data, a jurisdiction needs detailed origin and/or quantity information. Some jurisdictions that have attempted this correction process have expressed concern regarding the time and cost intensiveness of this process and the difficulty in obtaining the necessary information.

Table of Contents | Summary Recommendations

Last updated: October 26, 2007