Alternative Daily Cover (ADC)


NOTE: This webpage only describes ADC for the purposes of measuring a jurisdiction’s annual 50 percent per capita disposal rate ( Public Resources Code (PRC) Section 41781.3) and does not pertain to what is allowed for in the SB 1383 regulations. Alternative daily cover (ADC) means cover material other than earthen material placed on the surface of the active face of a municipal solid waste landfill at the end of each operating day to control vectors, fires, odors, blowing litter, and scavenging. Federal regulations require landfill operators to use six inches of earth material as daily cover unless other materials are allowed as alternatives. CalRecycle has approved 11 ADC material types. Generally, these materials must be processed so that they do not allow gaps in the exposed landfill face.

Currently, jurisdictions and regional agencies receive diversion credit for ADC use, as it is not reported as disposal (Public Resources Code (PRC) Section 41781.3). However, beginning January 1, 2020, the use of green material used as ADC will not constitute diversion through recycling and will be considered disposal.


    • “Jurisdiction” means a city, county, or a regional agency with the responsibility for meeting Integrated Waste Management Act requirements.
    • “Active face” means the working surface of a landfill upon which solid wastes are deposited during the landfill operation, prior to the placement of cover material.
    • “Vector” includes any insect or other arthropod, rodent, or other animal capable of transmitting the causative agents of human disease, or disrupting the normal enjoyment of life by adversely affecting the public health and well-being as defined in Title 27, California Code of Regulations (27 CCR), Chapter 2, Article 2.
    • “Green material” has the same meaning as “processed green material” as defined in 27 CCR Section 20690.

CalRecycle-Approved ADC Material Types

CalRecycle has approved 11 ADC material types. Generally, these materials must be processed so that they do not allow gaps in the exposed landfill face. Other ADC materials may be approved by CalRecycle on a case-by-case basis; see Daily/Intermediate Cover and Alternative Daily/Intermediate Cover Guidelines. All types of ADC must be approved by the enforcement agency (EA) in writing prior to use. Site-specific demonstration projects are not required for the following 11 material types.

Waste-Derived Materials. Material types that are approved by CalRecycle and can be reported as diversion:

    • Ash and cement kiln dust
    • Treated auto shredder waste
    • Construction and demolition waste
    • Compost
    • Green material *
    • Contaminated sediment
    • Sludge
    • Shredded tires

* Note: As of January 1, 2020, the use of green material as ADC does not constitute diversion through recycling and shall be considered disposal pursuant to PRC Section 41781.3. (2)(A).

Non-Waste-Derived Materials. Material types that are approved by CalRecycle and cannot be reported as diversion:

    • Foam products
    • Geosynthetic fabric or panel products (blankets)
    • Spray-applied cement

For detailed descriptions of CalRecycle approved ADC material types, see 27 CCR, Section 20690(b)

Reporting Requirements for ADC Use

    • Permitted landfills must track the types and tonnages of materials used for each beneficial reuse category. This tracking includes origin information for green material ADC only.
    • Permitted landfill operators report quarterly beneficial reuse information to CalRecycle.
    • Per (PRC) Section 41781.3. use of ADC, except for green material used as ADC, is considered diversion for a jurisdiction or regional agency.
    • Green material used as ADC will not be considered diversion as of January 1, 2020.
      Note: Jurisdictions must include information about how they intend to divert green material used as ADC by 2020 starting in their 2017 Electronic Annual Report, due August 1, 2018 to CalRecycle, and continuing annually as long as there is green material used as ADC and assigned to the jurisdiction, per Chapter 719, Statutes of 2014 (Williams, AB 1594).
    • Overuse of ADC waste-derived materials is considered disposal.

For a detailed description of the Recycling and Disposal Reporting System, see 14 CCR, Chapter 9, Article 9.25

Updates and Reports

    • A listing of jurisdiction disposal and ADC amounts by facility, through calendar year 2019, may be accessed on CalRecycle’s Local Government Central Jurisdiction Disposal and ADC by Facility report. Beginning with 3rd quarter 2019, only green material ADC is tracked by jurisdiction of origin, this information can be viewed by jurisdiction and destination facility on Jurisdiction Disposal and Beneficial Reuse By Destination.
    • 2008 Policy item on ADC. Presented at March 2008 California Integrated Waste Management Board (CIWMB, now CalRecycle) meeting.
    • 2009 White paper on ADC. History of ADC regulations in California, ADC use in California, regulatory issues identified by stakeholders and options for addressing issues.
    • Update on Green Waste ADC Usage. Presented at December 17, 2013 CalRecycle monthly public meeting. Trends in ADC usage in California from 1998 to 2012.
    • Alternative Daily Cover Investigation Report (August 2014). Investigation of 15 facilities to assess usage trends and anomalies in reporting or usage.

Legislation, Statutes, Regulations, and Advisories

Chapter 978, Statutes of 1996 (Bustamante, AB 1647). ADC constitutes recycling through diversion.

Chapter 719, Statutes of 2014 (Williams, AB 1594). Green material used as ADC is not considered diversion as of January 1, 2020.

PRC Section 41781.3 et seq., ADC Use

Title 14, California Code of Regulations

    • Chapter 9, Article 9.25, Recycling and Disposal Reporting System

Title 27 California Code of Regulations (27 CCR)

    • Chapter 2, Article 2, Specific Definitions.
    • Chapter 3, Subchapter 4, Article 2, ADC General Requirements and Description of ADC Material Types.

Local Enforcement Agency (LEA) Guidance

For more information contact: Local Assistance & Market Development, or (916) 341-6199.