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Identify where to capture diversion data
For each type of generation source, the jurisdiction must
determine the best place in the waste flow cycle to capture the diverted
tonnage and material type data.
Recycling systems are complex market systems. Diverted materials are commodities, moving
quickly as they are easily bought and sold. Recyclables can be collected in the jurisdiction and moved for processing
to another location. For example,
grocery stores may ship their compostables to a central composting facility
outside the jurisdiction, and department stores may send their recyclables back
to a central redistribution center. The
jurisdiction must always specify time periods and locations to avoid
double-counting errors.
It is important to remember that many waste disposal facilities also produce diverted
materials, and that unmarketable diverted materials can flow back into the
disposal system. Also note that
diversion facilities such as thrift stores and buyback centers may accept
materials from multiple jurisdictions.
If you can’t measure specific diversion
activity, don’t count it. When
quantifying diversion activities, actual data are required to document the
disposal reduction realized as a result of such activity.
Included in this guide is a “big picture” evaluation
checklist for field review (Appendix
B). The intent of this checklist is to
provide the jurisdiction with a starting point for determining the recycling
activities underway. The following list
identifies sources for capturing diversion data from the residential and
non-residential sectors.
Residential and non-residential service
providers
Note: When surveying service providers, it is
important to ensure that diversion tonnage is not double counted.
- Haulers: Haulers that provide recycling services
(e.g., separate recycling roll-off recycling containers, old corrugated
cardboard bins, compactor loads, mixed paper pickup, curbside recycling
programs, etc.) to the residential and non-residential customers in a
jurisdiction should have volume or tonnage estimates of collected recycled
materials. Haulers may also provide
unattended drop-off recycling bins in a jurisdiction. Jurisdictions should consider including a diversion tonnage
reporting requirement in hauler or franchise contracts and/or permits.
- Drop Box Haulers:
Haulers that provide drop boxes, such as for construction and demolition waste,
are a potential source of diversion data. Drop box companies should be identified as a source of diversion data.
- Recyclers: Some jurisdictions require reporting of
diverted tonnage as a condition of operating a business in the
jurisdiction. This is the easiest
method of obtaining private sector data. Surveys of recyclers, materials brokers, and end users have been used
with mixed success. Participation in
the surveys by the recyclers who operate buyback facilities is key. Professional and business associations may
be willing to help collect data from their members. Great care must be taken in the design of the survey to avoid
double counting of diversion tonnage. A sample cover letter and a recycling form for cities are contained in
Appendices C and D.
- Composters: Many composters collect material from self-haulers.
The facility should have tonnage information
they can provide to the jurisdiction.
- Transfer Stations/Material Recovery Facilities (MRFs): Many transfer
stations, and all MRFs, salvage recyclable materials such as paper, plastics,
metal, glass, wood, etc. Many of these
facilities also operate drop-off areas for recyclables. The CIWMB Solid Waste Information System
(SWIS) facility database includes listings of
all such facilities within each jurisdiction. Contact each facility for specific information regarding diversion
tonnage.
- Landfills: Many
landfills salvage recyclable materials such as scrap metal and wood waste. Also, many landfills have drop-off areas for
recyclables. Contact the landfill for
diversion tonnage.
- Alternative
Daily Cover (ADC): This data should
be collected from the Board’s Disposal Reporting System. A report of jurisdiction ADC tonnage by
material type is available through your CIWMB local assistance staff
representative.
- Garage sales: Many communities promote garage sales as an opportunity to divert
reusable materials. To calculate
diversion tonnages, the jurisdiction should conduct a survey.
- Thrift stores: For many communities, product reuse through thrift store sales can
be an extremely successful diversion program. To calculate diversion tonnages,
the jurisdiction should conduct a statistically significant survey or collect
data from individual thrift stores.
- Backyard composting: Many communities promote backyard composting by providing
subsidized or free compost bins and training workshops. Jurisdictions must determine the number of
households participating in backyard composting by surveying participants. If appropriate, jurisdictions may be able to
use conversion factors to estimate the tonnage being diverted (see Appendix
I).
- Grasscycling: This diversion activity has become more common as many jurisdictions
have implemented regional educational campaigns to encourage grasscycling.
To quantify this activity the jurisdiction
must complete a survey to determine the number of households
participating. See Appendix J for
sources of conversion factors.
- Xeriscaping: The practice of landscaping with slow-growing, drought-tolerant
plants to conserve water and reduce yard trimmings is becoming more
popular. To quantify this activity the
jurisdiction must complete a survey to determine the number of households
participating and tonnage diverted.
- Horse manure
composting: Some residential areas
may have small horse lots or community stables. Survey these stables to determine if the manure is collected and
composted. The composter or hauler
should be able to provide tonnage data or see Appendix I
for sources of conversion
factors of amount of manure generated per animal.
Non-residential sector activities
- Non-residential
sector generators: The first step is to identify all the businesses,
governmental agencies, and industries in the jurisdiction. The business licenses of the jurisdiction
can serve as a data collection tool. This can help identify the businesses operating within the jurisdiction
as well as the number of employees working at the business. Another data collection tool is the hauler’s
customer database. This database can
identify the businesses and contacts within those businesses that are dealing
in recycling and waste. These contacts
can be extremely useful when conducting the diversion surveys. Other sources include utility billing lists
and business tenant lists.
- There are other commercial business
databases that maintain business data by jurisdiction, such as Dunn and
Bradstreet and ABII.
(Note: A business with a license to do business in the jurisdiction but
that is physically located elsewhere is not a potential sample point. This minimizes selection of businesses that
are home-based and/or mailbox businesses.) Matching multiple data sources should
increase the accuracy of your survey population.
- Large non-residential sector enterprises
generally have ongoing diversion programs as part of their standard operating
practices. These diversion programs may
represent substantial diversion tonnage that can be identified with waste
reduction and recycling surveys.
- Telephone surveys and written surveys must
be carefully designed to minimize the time required for the business to
complete the survey. Try to reduce
survey question bias while addressing the issue of self-selection bias among
respondents.
In larger communities, businesses have been successfully
approached for survey cooperation through state and regional industry
associations and business organizations. A list of several commercial businesses (Appendix E) is provided to
assist in collecting diversion information.
- Large
turf areas: Many communities throughout California have not taken
grasscycling activities into account when calculating diversion
activities. Implementation of
grasscycling can have a significant impact on the overall diversion for a
jurisdiction. Managers of large turf
areas, such as golf courses, parks, and cemeteries, should be surveyed to
determine the acreage that is being grasscycled (see Appendix
I for sources of
conversion factors).
- Xeriscaping: The practice of landscaping with slow-growing, drought-tolerant plants to conserve
water and reduce yard trimmings is becoming more popular. To quantify this activity the jurisdiction
must complete a survey to determine the number of non-residential generators
participating and tonnage diverted.
- Confidential
document destruction companies: Contact these companies to
determine the amount of paper that is being collected and recycled from the
non-residential sector in the community.
- Food
banks/food rescue services within the community: Contact food banks/rescue services to determine the amount of
food that is diverted from restaurants, supermarkets, catering businesses, etc.
- Rendering/Tallow
companies: Survey renderers and tallow companies to determine diverted
tonnage.
- Tire
shops: Identify and survey
tire shops in the community. Get number
of tires diverted and total weight. Note: If using just number of
tires, you may claim credit for smallest tire.
- Construction
companies: Contact companies that provide construction and remodeling
services in the community to determine diversion activities they
undertake. Include roofers.
- Sewage
sludge: (must be diverted through landspreading, composting,
etc.): Jurisdictions that have a wastewater treatment plant that diverts
sludge can count the diversion. See
Appendix H, “What Counts Toward Diversion” for guidelines on counting sludge.
When quantifying
source reduction, the focus should be on disposal-based quantification that is
reducing the amount of material that would actually go to landfill. The surveyor
should count the incremental difference of a material being diverted versus
looking at it in perpetuity.
Any source
reduction activities identified should be explained in detail in the Board’s
Base-Year Modification Certification sheet. The
Board has indicated that it will be scrutinizing more closely any source
reduction amounts that are greater than 5 percent of the total generation. Therefore, requests above this amount should
include more detailed information describing, documenting, and verifying the
methodology, assumptions, and results used.
It
is important to note that when quantifying diversion activities that the Board
and staff will scrutinize this information. You will need to clearly document and justify your results to receive
diversion credit, and you will need to present the information clearly to the
Board. See the CIWMB Base-Year
Modification Request Certification sheet for more information.
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