Possible Barriers to C&D Reuse and Recycling in California

1. Business Difficulty for Recycler/Processor

  1. Hauling/transportation cost.
  2. Inadequate separation/storage space.
  3. Insufficient cost-effective decontamination technologies.
  4. Start-up/operating cost.
  5. Unpredictable/unreliable C&D debris material flow.
  6. Unstable commodity prices.

2. CalRecycle and Legislative Issues

  1. C&D debris is not statutorily banned from landfill disposal.
  2. Difficult for C&D processing operations to compete due to relatively cheaper costs for beneficial reuse at landfills.
  3. Inconsistent, conflicting, and/or over-restrictive:
    • CalRecycle regulations, and/or
    • California Environmental Quality Act (CEQA)
  4. Lack of documentation available on recycling end uses.
  5. Material Recovery Facilities (MRFs) without a mandatory recycling rate for C&D debris.
  6. No statutory requirement for reuse and recycling of C&D.
  7. Overuse and/or misreporting of C&D debris used for landfill alternative daily cover, and/or “beneficial reuse”, thereby undermining C&D reuse and recycling markets as a highest and best use.
  8. Statutory requirement that non-disposal facility be identified in a jurisdiction’s NDFE for the permit to be found in Conformance with that planning document.
  9. Waste streams are not prevented from direct landfill disposal nor is preprocessing of C&D debris for recycling required.

3. Facilities

  1. Siting difficulties.
  2. Mixed processing, especially for higher and best use markets, often costs more than disposal.
  3. Too few C&D debris recyclers/processors.
  4. Too few “last chance,” “buy-back,” C&D debris reuse/salvage operations.
  5. Too few “resource recovery parks.”

4. Industry Education/Training

  1. High rate of workforce turnover.
  2. Inadequate cost-benefit data.
  3. Inadequate education materials on “how to” recycle C&D debris.
  4. Inadequate information on “where to” recycle C&D debris in my area/project area or what site-specific recycling opportunities exist.
  5. Lack of training for designers on the standards and use of recovered C&D materials.
  6. Lumber is used extensively for mulch, ADC, or biomass fuel thereby undermining reuse markets as a highest and best use.
  7. Project manager and deconstructor miscommunication.
  8. Waste Management Plan requirements not adhered to or appropriately monitored and tracked to verify compliance.

5. Local Enforcement Agency

  1. High permit and inspection fees.
  2. No C&D debris diversion support.
  3. Minimal monitoring of landfill beneficial reuse activities, by category and weight.

6. Local Mandates

  1. Franchise haulers that aren’t required to take C&D debris in roll-offs to C&D debris recyclers,
  2. Inconsistent, conflicting, and/or over-restrictive:
    • local planning dept requirements, and/or
    • use permits
  3. Not differentiating for diversion purposes, between inerts and mixed solid waste materials entering a processing facility,
  4. Not having a 50 percent recycling provision for all construction or demolition projects regardless of the project size.
  5. Not having a separate franchise hauler agreement for C&D debris.
  6. Not imposing a landfill disposal surcharge or business tax on C&D waste haulers and C&D waste contractors.
  7. Not lowering franchise hauler tipping fees if the hauler meets certain C&D debris recycling requirements.
  8. Not posting a newspaper advertisement for salvage material types and quantities before permitting a demolition project.
  9. Not requiring deconstruction as part of demolition permitting.

7. Local Ordinances, Plans, Policies, Programs & Procedures

  1. Deconstruction project, land use, and zoning restriction approvals that don’t consider timing, scheduling, and cost issues.
  2. Inadequate local ordinance enforcement.
  3. Insufficient local C&D debris diversion ordinances.
  4. Insufficient local economic incentives, e.g.:
    • Disposal fee exemption for C&D debris recyclers is lacking.
    • Building permit C&D debris diversion deposit is too low or lacking.
  5. Jurisdictions working independently of neighboring jurisdictions on C&D Debris Recycling Plans, policies, reporting requirements, or diversion programs.
  6. Pressure to discourage jurisdictions from having Recycling Plans, policies, reporting requirements, or diversion programs that require higher diversion rates or higher and better market use requirements than neighboring jurisdictions.

8. Lower-cost Options

  1. Demolition instead of deconstruction.
  2. Grinding materials for:
    • Biomass, or
    • Landfill alternative daily cover
  3. Disposal.

9. Markets

  1. Inadequate markets for discarded carpet.
  2. Inadequate markets for gypsum/wallboard debris.
  3. Inadequate markets for asphalt roofing and wood shingles.

10. Public Education

  1. Inadequate education materials on “how to” recycle C&D debris.
  2. Lead and asbestos contamination fears.
  3. “Not in my back yard” (NIMBY) issues.
  4. Public apathy.

11. Recycled Content Product (RCP) Difficulties

  1. High initial procurement cost.
  2. Inadequate industry standards.
  3. Inadequate proven, performance-based specifications.
  4. Inadequate test methods.
  5. Inadequate local public works and Caltrans contract specifications for recycled materials in roads, road base, trenches, backfill and erosion control.
  6. Inferior quality bias.
  7. Long procurement lead time.
  8. Multiple green building rating systems.
  9. No incentives for designers.
  10. Outdated ordinance and building code product requirements.
  11. Product test cost.
  12. Unavailability.
  13. Unstable supply.
  14. User training needs.

12. Regulations for C&D Debris Processing

  1. 60% recycling requirement of the medium volume processing tier.
  2. “Construction work” definition limitations.
  3. Low permit tier placement thresholds.
  4. No new facility “phase-in” allowance to higher permit tiers.
  5. Public Hearing requirement.
  6. Scale requirement.
  7. “Solid waste handler” versus a “recycler” regulatory status.
  8. The “no residual” restriction on “C&D-like” loads.

13. Other

  1. List any alternate barriers.

For more information contact: C&D Program Staff, cdrecycling@calrecycle.ca.gov