CIWMP Enforcement Part I: Plan Adequacy
As approved by the Board on November 17, 1993

Evaluation Process

• Source Reduction and Recycling Element (SRRE) Criteria

• Solid Waste Generation Study (SWGS) Criteria

A Source Reduction Recycling Element (SRRE), Household Hazardous Waste Element (HHWE), Nondisposal Facility Element (NDFE), Countywide Siting Element (CSE), and Countywide Integrated Waste Management Plan (CIWMP) would be evaluated by Board staff based on the above analysis. Staff would present recommendations for approval or disapproval by the Board. If the Board approves an element, the Board must adopt written findings that implementing the element will achieve the diversion requirements. A disapproval decision by the Board would generate a Notice of Deficiency (NOD). The NOD must include specific recommendations on how to correct the deficiencies in the element or plan.

If a plan or element is not submitted, that would constitute failure to have adequate planning. Enforcement actions, which will be discussed in Section Two of the report, would then be considered by the Board.

The following criteria addresses the evaluation process for SRREs and NDFEs since these are the first planning documents that will be submitted to the Board in April, August and December 1994. Criteria will be established for HHWEs, CSEs, and CIWMPs in Section Two. Criteria evaluated by Board staff will include whether disposal and diversion quantity data are shown in the SRRE and whether diversion program planning by the local jurisdiction occurred. In addition, the following would be analyzed in evaluating an element and plan for adequacy and approval:

Source Reduction and Recycling Element (SRRE) Criteria

1. Will diversion programs operated by a local jurisdiction be monitored and evaluated and meet the 25 percent and 50 percent waste reduction mandates?
2. Did the element and plan meet the content needed for a determination of adequacy?
3. Was there a logical methodology to the planning process?
4. Were the diversion program alternatives evaluated for feasibility and selection?
5. Were the evaluation criteria defined by the local jurisdiction and the definitions contained in the element and plan?
6. Was there a discussion of both existing and future local market development activities?
7. Was there a discussion of the existing permitted landfills and transformation facilities, the combined permitted disposal capacity for each facility, and a disposal facility projection estimating the need for additional disposal capacity for a 15-year period?
8. Were cost estimates included for the source reduction, recycling, composting, special waste and public information and education programs scheduled for planning, development and implementation?
9. Were contingency funding needs identified by funding source?
10. Were feasible diversion programs selected?
11. Has the local jurisdiction specified their policies, goals and objectives toward meeting the hierarchy specified in PRC section 40051?
12. Has the local jurisdiction committed resources and revenues for planned diversion programs in a timely manner?
13. Does the element and plan have internal consistency?
14. Did local adoption of a SRRE, HHWE, NDFE, CSE and CIWMP occur?
15. Did public involvement, as prescribed in statute and regulations, occur?
16. Did the plan and element identify generators targeted for education and public information programs?
17. Did the element and plan explain how selected source reduction, recycling, composting, and special waste programs would combine to meet the diversion requirements?
18. Did the element and plan contain an implementation schedule identifying all tasks for new and expanded diversion programs?
19. Did the element and plan explain how each of the selected programs jointly achieve the diversion mandates and will the programs be effective?
20. Are diversion facilities that will be used by local jurisdictions described?
21. Are the diversion facilities identified by their name, type and who uses the facilities?

Solid Waste Generation Study (SWGS) Criteria

1. Were annual diversion tonnage data provided, by waste type and sector, from the jurisdiction’s source reduction, recycling and composting activities?
2. Were annual disposal tonnage data provided, by waste type and sector, from permitted landfill and transformation facilities used by the jurisdiction?
3. Were the wastes sampled representative examples of waste types and quantities generated by the jurisdiction’s residential, commercial, industrial, and other significant sectors?
4. Was a discussion of seasonal variations in generated waste tonnages provided?
5. Was a discussion provided demonstrating the representativeness of the sampling method used?
6. If conversion factors were used to calculate waste diversion and disposal tonnages, were the factors used accurate?
7. If comparable data were used to identify a jurisdiction’s waste stream composition, did the discussion demonstrate the comparability of the jurisdictions’ populations, economic and demographic bases, and percentages of residential, commercial, and industrial sectors?
8. Was text or a table provided demonstrating that all waste types claimed as diverted were at least .001 percent of the jurisdiction’s disposed waste stream?
9. Were explanations provided in the SWGS on how diversion amounts were determined? Did the jurisdiction identify the diversion program/facilities it used to obtain these diversion amounts?
10. Was documentation provided showing that:

1. baseyear diversion of agricultural wastes, inert solids, scrap metals and/or white goods (i.e., restricted waste types) was/were the result of a specific local action?
2. historical disposal amounts for each restricted waste type claimed as diverted in the baseyear are not less than the claimed diversion amounts?
3. Diversion programs selected in the SRRE are, or will be implemented by the local jurisdiction?

As approved by the Board on November 17, 1993.

Last updated: November 01, 2007