Item 002.1 - C&D Policy Options Table — original pdf

Backup

C&D Committee — Policy Options Decision Current Option 1 – Residuals Threshold preferred Option 2 – No-Minimum ADR Option 3 – Eliminate QP Must projects use a qualified processor (QP)? Not required YES Source separated facilities do not need to be qualified YES Source separated facilities do not need to be qualified NO QP program eliminated Type of audit and auditor QP Reporting requirements Average diversion rate* Registered evaluator or RCI Residuals Threshold* City-contractor Average diversion rate (ADR)* City-contractor Report ADR every six months. Report also includes: types of materials recovered, beneficial uses for the materials One annual validated residual audit +++ Quarterly unverified ADR sent by facility, posted on dept website One annual validated ADR audit +++ Quarterly unverified ADR sent by facility, posted on dept website None Projects submit weight tickets None Who pays for the audits? QP Annual Residual audit – City Subsequent, if failed, QP Annual ADR audit – City Subsequent, if failed, QP No Audit 1. Dept. suspends registration 2. QP sent notice of suspension 3. QP given time to correct violation 4. If not corrected, no longer a QP. QP may file appeal within 20 days after suspension. 1. Notice from dept. identifying 1. Notice from dept. identifying No audit to fail violation violation 2. 90 days to get in compliance via follow-up audit at facility’s expense or correction of other violations not requiring an audit 2. 90 days to get in compliance via follow-up audit at facility’s expense or correction of other violations not requiring an audit 3. Fail to correct violation, 3. Fail to correct violation, suspend QPs registration in accordance with code 15-6- 164 suspend QPs registration in accordance with code 15-6- 164 NO YES — ≤10%, materials TBD NO NO If a facility fails audit Residuals Threshold? * In addition to audit, must meet Minimum requirements (rules/code): includes things like compliance with all federal, state, and local regulations, ability to weigh materials, supplying customers with documentation and disposition of diverted materials C&D Committee — Option Strengths and Tradeoffs Current Option 1 – Residuals Threshold preferred Option 2 – No-Minimum ADR Option 3 – Eliminate QP Strengths - Flexibility for facilities to choose whether to register as QP - Projects using QP have reduced reporting burden - Transparency for projects to view facility residuals and ADR on Department’s website - Transparency for projects to view all facilities’ ADR on Department’s website No QP registration or audit program to run - Focus on what is landfilled, in line with shift to disposal rate - Less of a change from what currently exists - Facilities will be less - No minimum diversion rate for dependent on incoming materials being highly recyclable (can be less selective) - List of unacceptable residual materials can be adjusted based on market conditions - More cost-effective for the processor (compared to financing own ADR verification) facilities allows less dependency on incoming materials being highly recyclable (can be less selective) - More cost-effective for the processor (compared to financing own ADR verification) Tradeoffs - Low utilization of QP & RE programs - Third party verification costs to the facility Annual audit cost to the City Annual audit cost to the City - More reporting burden on projects - No transparency on facilities and destination of recycled materials Decisions for the Committee 1. Require all affected projects to use a QP? 2. Qualified processors must have audit of diversion rate or residuals? o Diversion rate audit would be similar to existing 3rd party verification, but no minimum diversion rate requirements. o Residuals will be audited for listed recyclable materials before shredding or grinding, with size thresholds so small materials won’t count. Study will be conducted to create list. 3. Replace the registered-evaluator program with a City-contracted, City-paid auditor. o Contractor should be able to verify ADR and Residuals; a registered evaluator could become a City contractor. o Consideration: continue to allow RCI certification as alternative, with the caveat that biofuel is excluded? (only applies to option 2) 4. Have ARR post verified audit and facility-supplied unverified ADR quarterly to department website. o Having only one audit of either ADR or Residuals saves money. o Posting unverified ADR at least three other times a year to the dept. website increases market transparency and makes it easier for contractors to compare rates. Potential Future Discussion Items 1. Increase project diversion rate from 50% to 65%, based on recent reported diversion rates o Median diversion rate from projects who submitted diversion plans ran 66.81%, 69.23%, and 75.32 % for 2024-2026 o Require submittal of weight tickets and follow any applicable federal, state, and local laws. 2. Create a separate option for source-separated, single-processer facilities to become recognized by the City o No audit of facility required. o Require submittal of weight tickets and compliance with federal, state, and local laws. Definitions Beneficial Use = means productive use of materials reclaimed through separation, processing, deconstruction, or other means and made availab le for recycling or reuse but does not include placement in a disposal facility, used as daily cover in a disposal facility, or used for energy recovery. Facilty Average Diversion Rate = The % of all inbound commingled material over a period of time that a facility diverts for beneficial use. Project Disposal Rate = the total pounds of material generated by a project and disposed per square foot of the project. Project Diversion Rate = the percentage of the materials generated by the project and diverted for beneficial use onsite or offsite. Residual = the quantity of non-recyclable material left over at the end of a recycling process; often expressed as a percentage (i.e. amount of material remaining after the resource recovery process, divided by the total amount of materials processed).