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RPVCCA_CC_SR_2012_08_21_E_Letter_Re_Proposed_Mandatory_Organics_Diversion_LegislationCfTYOF MEMORANDUM RANCHO PALOS VERDES TO: FROM: DATE: SUBJECT: REVIEWED: Project Manager: HONORABLE MAYOR &CITY COUNCIL MEMBERS JIM HENDRICKSON,INT.DIRECTOR OF PUBLIC WORK~ AUGUST 21,2012 LETTER OF CONCERN REGARDING PROPOSED MANDATORY ORGANICS DIVERSION LEGISLATION CAROLYN LEHR,CITY MANAGER Cl9.- Lauren Ramezani,Sr.Administrative Analyst 'ii--- RECOMMENDATION Authorize the Mayor to send a letter on behalf of the City of Rancho Palos Verdes to California legislators expressing concern regarding the proposed mandatory organics diversion legislation. BACKGROUND The State has various mandates to promote recycling,reuse and waste reduction.In that pursuit,the City has implemented several successful recycling and waste reduction programs to divert recyclable material from going to landfills.One such program is green waste recycling.Approximately 40%of the waste generated in the City is green waste.This material is collected at curbside and later taken to a composting/mulching facility for recycling,and/or to a facility that processes the green waste for use as Alternative Daily Cover (ADC)at landfills.Currently,the City gets diversion credit for the green waste that is mulched and used as ADC.The City exceeds the State's 50% diversion mandate. DISCUSSION CalRecycle has prepared a white paper,"California's New Goal:75%Recycling" discussing ways to improve the State's recycling.Based on that,the State legislature is expected to shortly introduce major solid waste legislation that may have significant impacts on local jurisdiction solid waste management programs and waste hauling contracts.One such legislative initiative is described as "organics management" legislation,with the goal to mandate the diversion from landfills of 50%of organic waste,which includes such materials as green waste, by 2020. E-1 Letter Regarding Organics Recycling August 21,2012 Page 2 The overall goal is to increase composting of organics wastes,and to minimize the organic material going to landfills,even if it is beneficially reused.Although composting is considered the "true"recycling of green waste,however,there are very few composting facilities in Southern California.Furthermore,those facilities are a distance away adding to haulers transportation costs,which ultimately get passed down to customers.As a result,the use of green waste as ADC has been a practical and cost effective alternative and/or supplement for many cities. The County Sanitation Districts of Los Angeles County has urged agencies to send a letter of concern regarding this legislative proposal.This legislation might include both the imposition of a tip fee surcharge of $1.40 per ton and a phase-out of diversion credit for green waste used as ADC. Banning the use of ADC as diversion,would impact the rates of most cities,especially if they generate significant green waste like RPV.Furthermore,haulers including EDCO and UWS would most probably pass down the tip fee surcharge to their customers, increasing their monthly rates.Such a pass through of costs is eligible and allowable per their contracts with the City. Furthermore,the current legislative proposal appears to short circuit the public review process and moves to implement some of the proposals without any consideration of the input received. Finally,the City is a member of Los Angeles Regional Agency (LARA)which has sent a letter to CalRecycie providing comments.The City of Los Angeles has also sent a detailed letter outlining the areas of support and concern for the proposed legislation. Attached is a draft letter.If staff's recommendation is approved the Mayor would sign the letter on the City's behalf.Staff will then send the letter to the appropriate State Senate and Assembly members and CalRecycle. ALTERNATIVE Do not to send the letter.The letter sent by LARA represents all member cities, including RPV. FISCAL IMPACT There will be no impact at this time. Attachments:Draft Letter for the Mayor's Signature Letter from Los Angeles County Sanitation Districts W:\Pam\Staff Reports\2012\08-21-12\mayor letter re ADC.doc E-2 DRAFT LETTER August _,2012 The Honorable Wesley Chesbro,Chair Assembly Committee on Natural Resources 1020 N Street,Room 164 Sacramento,CA 95814 Dear Chairman Chesbro: Concerns Regarding Proposed Mandatory Organics Diversion Legislation On behalf of the City of Rancho Palos Verdes,I am writing to express our concerns about legislation that we understand may be introduced in August to mandate that local jurisdictions divert 50% of organic waste from landfills by 2020.I understand that you are considering introducing such legislation,and I urge you not to rush to enact a proposal of great importance to local government without an opportunity for full deliberation of the costs and benefits of such a proposal.Given that the Legislature will adjourn on August 31 st,there is not enough time left in the session for that to occur. We understand that,among other things,you are considering prohibiting recognition of the recycling value of greenwaste when it is used at landfills as alternative daily cover (ADC),and that you may apply a tip fee surcharge of $1.40/ton to greenwaste recycled in this manner.Greenwaste ADC has many benefits and should not be classified as disposal,since it meets the definition of recycling;namely, ADC involves the processing of materials that would otherwise be solid waste and returns them to the economic mainstream in the form of a necessary use in the marketplace.The use greenwaste as ADC reduces the need to obtain dirt for cover,and is a valid type of recycling.Use of greenwaste for ADC also conserves space in local landfills,which helps keep solid waste management costs reasonable for local jurisdictions. While we understand that your goal may be to increase compo sting infrastructure,it is important to understand the difficulties in siting such facilities in urbanized southern California,given challenges such as stringent air quality regulations in the South Coast air basin.In Los Angeles County,local composting infrastructure is very limited and new facilities are likely to be located in outlying areas, thereby increasing truck hauling,with the associated expense,traffic congestion and air pollution. We are also concerned that rushing to enact legislation to mandate organic waste diversion is short-circuiting the process enacted in AB 341,which you authored last year.At the local level, jurisdictions are fully occupied with implementation of mandatory commercial recycling,and,at the state level,Cal-Recycle has only recently begun an l8-month stakeholder engagement process to determine the best path forward to meet the ambitious 75%diversion goal adopted in AB 341. E-3 Page 2 In conclusion,it is premature for the Legislature to move forward now with new solid waste management mandates,and,instead,we ask that you fully engage with local government and other interested stakeholders to determine the tools and programs that are necessary to reach the 75%diversion goal that was catalyzed by AB 341. Sincerely, Anthony Misetich,Mayor cc:Assembly Speaker John Perez Senate Pro Tern Darrell Steinberg Senator Joe Simitian,Chair,Senate Committee on Environmental Quality Caroll Mortensen,Director,Cal-Recycle E-4 COUNTY SANITATION DISTRICTS OF LOS ANGELES COUNTY 1955 Workman Mill Road,Whittier,CA 90601-1400 Mailing Address:P.O.Box 4998,Whittier,CA 90607-4998 Telephone:(562)699-7411,FAX:(562)699-5422 www.lacsd.org Boards of Directors County Sanitation Districts of Los Angeles County Directors: August 3,2012 GRACE ROBINSON CHAN Chief Engineer and General Manager Proposed Mandatory Green Waste Diversion Legislation Recently I learned that major solid waste legislation is expected to be introduced after the Legislature returns to Sacramento on August 6.This initiative may have major impacts on local jurisdiction solid waste management programs and hauling contracts.The opportunities to participate in the Legislature's consideration of this legislation will be very limited,given that the Legislature will adjourn on August 31 and the normal legislative process will be extremely truncated. This legislative initiative is being described as "organics management"legislation,the goal of which is to mandate the diversion from landfills of 50%of organic waste,which includes such materials as greenwaste,by 2020.The overall goal is to increase composting of organic wastes,and to minimize the organic material going to landfills,even if it is beneficially reused.While I have not seen any proposed language,I have been told by legislative staff that the legislation may include both imposition of a tip fee surcharge of $1.40 per ton and a phase-out of diversion credit for greenwaste used as alternative daily cover,which is a key element of your jurisdictions'waste diversion programs.The tip fee surcharge would be imposed when the legislation takes effect,and the phase-out of diversion credit would be required by 2020.These proposals will surely increase local solid waste management costs,and are likely to exacerbate local traffic congestion and air pollution due to the need for increased truck hauling of organic waste to rural areas,where compo sting facilities are typically located. Cal-Recycle recently released an early draft of a report titled "California's New Goal:75% Recycling,"for public review,which includes some of these same adverse concepts,but in which the Executive Director committed to an l8-month stakeholder process that would include multiple opportunities for input.The current legislative proposal short-circuits that process and moves to implementation of some of the draft report's proposals without any consideration of the input received. I will be infonning legislators of our major concerns about this legislative proposal,and I urge you to do the same.A sample letter is attached for your consideration.I will keep you apprised as further information becomes available. Very truly yours, Grace Robinson Chan Enclosure GRC:SNG:djm cc:City Mangers Public Works Directors DOCS:2319322 ft Recycled Paper ~.tE-5 SAMPLE LETTER [Date] The Honorable Wesley Chesbro,Chair Assembly Committee on Natural Resources 1020 N Street,Room 164 Sacramento,CA 95814 Dear Chairman Chesbro: Concerns Regarding Proposed Mandatory Organics Diversion Legislation On behalf of the City of {fill in},I am writing to express our concerns about legislation that we understand may be introduced in August to mandate that local jurisdictions divert 50%of organic waste from landfills by 2020.I understand that you are considering introducing such legislation,and I urge you not to rush to enact a proposal of great importance to local government without an opportunity for full deliberation of the costs and benefits of such a proposal.Given that the Legislature will adjourn on August 31 51 ;there is not enough time left in the session for that to occur. We understand that,among other things,you 'are considering prohibiting recognition of the recycling value of greenwaste when it is used at landfills as alternative daily cover (ADC),and that you may apply a tip fee surcharge of $1.40/ton to green waste recycled in this manner.Greenwaste ADC has many benefits and should not be classified as disposal,since it meets the definition of recycling;namely, ADC involves the processing of materials that would otherwise be solid waste and returns them to the economic mainstream in the form of a necessary use in the marketplace.The use green waste as ADC reduces the need to obtain dirt for cover,and is a valid type of recycling.Use of greenwaste for ADC also conserves space in local landfills,which helps keep solid waste management costs reasonable for local jurisdictions. While we understand that your goal may be to increase composting infrastructure,it is important to understand the difficulties in siting such facilities in urbanized southern California,given challenges such as stringent air quality regulations in the South Coast air basin.In Los Angeles County,local composting infrastructure is very limited and new facilities are likely to be located in outlying areas, thereby increasing truck hauling,with the associated expense,traffic congestion and air pollution. We are also concerned that rushing to enact legislation to mandate organic waste diversion is short-circuiting the process enacted in AB 341,which you authored last year.At the local level, jurisdictions are fully occupied with implementation of mandatory commercial recycling,and,at the state level,Cal-Recycle has only recently begun an 18-month stakeholder engagement process to determine the best path forward to meet the ambitious 75%diversion goal adopted in AB 341. In conclusion,it is premature for the Legislature to move forward now with new solid waste management mandates,and,instead,we ask that you fully engage with local government and other interested stakeholders to determine the tools and programs that are necessary to reach the 75%diversion goal that was catalyzed by AB 341. Sincerely, cc:Assembly Speaker John Perez Senate Pro Tern Darrell Steinberg Senator Joe Simitian,Chair,Senate Committee on Environmental Quality Caroll Mortensen,Director,Cal-Recycle E-6