Solid Waste Facilities (SWF) Questions and Answers

Transfer/Processing Facilities and Operations (14 CCR, Division 7, Chapter 3, Article 6.0)

Source Separated Organic Waste Handling (Section 17409.5.6)

Q: Does Section 17409.5.6(b) imply a general ban on sending recovered organics to disposal?

No. This section only describes requirements for how source separated organics will be handled at a transfer/processing facility or operation and indicates where source separated organics can be transported from the facility/operation.

Q: Can source separated organics be processed with other solid waste streams?

No. Source separated organics and mixed waste organics are to be stored and processed separately. However, the recovered organic waste from both waste streams and the material sent for disposal from both waste streams can be combined once measurements have been performed on each stream (see Section 17409.5.6).

Q: Is a source separated organics stream required to meet the 75 percent organic waste recovery efficiency described in Section 17409.5.1?

No. Facilities that receive only source separated organic waste collection streams would not be subject to the organic waste recovery efficiency requirement.

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Mixed Waste Organic and Source Separate Organic Measurements (Sections 17409.5.2 through 17409.5.5, 17409.5.7, and 17409.5.8)

Q: What are the measurement requirements for transfer/processing facilities and operations?

If a facility receives source separated organic collection streams (SSO) and/or mixed waste organic collection streams (MO), operators are required to measure:

(1) all organic material types that are separated from those streams at the facility and sent off-site for recovery, further processing or, end-use, and
(2) all material sent for disposal from those streams.

For details on how to perform these measurements, see the MO and SSO detailed sampling guides.

If a facility receives more than 500 tons of gray container waste from a single jurisdiction, then the operator is required to take one 200-pound measurement of the incoming gray container waste stream per quarter. For details on how to perform gray container waste evaluations, see the Gray Container Waste Evaluation Guidance

Q: Is the operator required to measure each organic waste type?

Yes, the regulation requires a measurement of each organic waste type after processing that is sent off-site for recovery, further processing, or end-use as well as material destined for landfill disposal.

Q: The regulation states that the sampling shall be performed on each organic waste type. An operator could handle roughly 20 paper types. Are operators expected to conduct measurements by each paper type?

In this example, the operator would take a sample that is representative of the loads going to the same paper recycler. If the operator sends specific paper types to different end-use destinations, then the operator must sample those specific paper types.

Q: How will an operator measure mixed organics such as drywall nailed to lumber, or carpet stapled to wood strips?

If the organic material cannot be separated, then the operator may determine that the mixed material is incompatible material and report it as such.

Q: How should operators consider difficult-to-handle materials such as food-soiled paper or biodegradable or compostable product when calculating the incompatible material measurement?

Operators must follow the protocols for sampling and measuring incompatible materials as described in sections 17409.5.2 – 5.5. If operators are unable to implement the requirements, then they may propose an alternative measurement protocol.

Q: What is the sampling measurement frequency for facilities open fewer than 10 consecutive days (e.g., 2 times a week)?

The requirement is for the operator to take samples for 10 consecutive operating days per reporting period, and there are four reporting periods per year (one per quarter). If the facility were open two days a week, then the operator would take samples for five consecutive weeks. The sampling is still required once per quarter. In addition, the regulations allow the operator to propose an alternate sampling frequency to the EA for approval, with concurrence by the Department, provided that it will be as accurate as the requirements.

Q: What is the measurement frequency for facilities that don’t send out material every day?

Facilities and operations would only perform a measurement on the day material is sent out within the 10 consecutive operating day period. Per the measurement protocol, the organic ratio of the sample is determined and then applied to the total amount of material sent out for that operating day.

Q: Can measurements occur prior to processing?

No. An operator must take samples after processing and prior to sending material to a destination for end-use, recovery, further processing, or disposal.

Q: How are Material Recovery Facility (MRF) fines handled during the measurement requirements?

MRF fines are not defined in the regulations. Processed material fines can consist of organic and non-organic materials. Transfer/processors that send processed material fines for further processing or disposal must sample the material to determine the organic fraction of that material.

Q: How can operators measure organic material that is completely containerized? For example, a slurry produced using a screw press processing method that is containerized and sent either to a wastewater treatment plant or an anaerobic digestion facility.

The regulations allow the operator to propose to the Enforcement Agency an alternative measurement protocol for determining the organic waste quality standard for approval, with concurrence by the Department, provided it will be as accurate as the requirements.

Q: If a facility is only processing non-organic recyclables, is the facility required to conduct sampling measurements?

No. The sampling measurement requirements are only for facility operators that receive mixed waste organic collection streams or source separated organic waste streams for processing. It is not required for facilities that are only receiving and processing non-organic recyclables.

Q: What is the definition of a high diversion organic waste processing facility?

A high diversion organic waste processing facility refers to transfer/processing facilities and operations that handle mixed waste organic collection streams as defined in Section 17402(a)(11.5) and meet the 50 percent (by 2022) or 75 percent (by 2025) mixed waste organic recovery rates set forth in Section 18815.5(e).

Q: Is Construction and Demolition debris required to be measured?

Construction and demolition debris is not subject to the measurement requirements at a transfer processing facility if the material meets the definition of Section 17381 and the material is kept separate from the source separated organic and mixed waste organic collections stream [see Section 17409.5.6(a)(2)].

Q: If a transfer/processing facility receives self-haul waste, is it considered part of the mixed organic waste collection stream?

A facility that receives a self-haul load of mixed organic waste that meets the definition of Section 17402(a)(11.5) shall consider the load part of the mixed organic waste collection stream. A facility that receives a self-haul load of only green or yard waste that meets the definition of Section 17402(a)(26.6) shall consider the load part of the source separated organic waste collection stream.

Note that generators also have their own self-haul requirements. Generators of organic waste may self-haul consistent with Section 18988.1. Self-haulers may comply by either source separating all organic waste generated on their premises in a manner consistent with Sections 18984.1 and 18984.2, or self-haul mixed organic waste to a high diversion organic waste processing facility as specified in Section 18984.3. The generator will then haul source separated organic waste to a solid waste facility operation, activity, or property that processes or recovers source separated organic waste. Article 7 also requires jurisdictions that don’t have a waiver for collection requirements to adopt an ordinance if they allow for self-haul.

Q: Is organic material collected from homeless encampments considered part of the gray container waste stream or mixed waste organic collection stream?

A jurisdiction is allowed to send homeless encampment waste directly to landfill for disposal pursuant to Section 18984.13, thus it need not go to a transfer/processing facility or operation.

However, if the material is sent to a transfer/processing facility or operation, then the material could meet the definition of mixed waste organic collection stream and be subject to the applicable measurement requirements. If the organic material was sorted form other wastes prior to being loaded it may be considered source separated.

Q: If the operator receives less than 200 pounds of material in an operating day, how much of the material is required to be sampled?

If there is less than 200lbs of an organic waste type after processing, the operator will sample all the material that is available (see sections 17409.5.2 through 17409.5.5).

Q: During the ten-day measurement period, what should a facility do if it gets a lot of incoming material at the end of the operating day? If that material is not incorporated in the sample because the sample has already been chosen, can the sample be considered “representative”?

A sample must be taken so that it is representative of a typical operating day. If it is typical that a large amount of material is received late in the day, the sampling protocols should take that into account.

Q: Does the facility need to perform measurements on an outgoing organic waste type sent for recovery if there is no processing occurring on that specific waste type?

Yes. If source separated organic waste collection streams (SSO) or mixed waste organic collection streams (MO) are being received by a transfer/processing facility or operation that is not a consolidation site, then those SSO and MO streams must be measured prior to sending that material off-site for recovery. For more information about consolidation sites, please see CalRecycle’s Consolidation Site Guidance and contact your EA.

Q: Are gray container waste evaluations required for solid waste from the gray container collection stream that is sent directly to solid waste landfill?

No. Section 17409.5.7 only applies to permitted transfer/processing facilities and operations that do not meet the definition of a consolidation site as defined in Section 17402(a)(.5) or the requirements of Section 17409.5.10.

Q: What should a facility do if weather conditions make it difficult to do outdoor sampling?

It is the operator’s responsibility to designate an area for measurements that is also consistent with their facility’s design and operation. The operator should discuss proposed changes to their facility’s operation or design with their Local Enforcement Agency.

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Incompatible Material Limits in Recovered Organic Wastes (Section 17409.5.8)

Q: What is the definition of incompatible material?

Incompatible material means any human-made inert material, including, but not limited to, glass, metal, plastic, and also include waste for which the receiving end-user, facility, operation, property, or activity is not designed, permitted, or authorized to perform organic waste recovery activities, as defined in Section 17402(a)(7.5).

Q: What constitutes end-use, recovery, or further processing in the definition of incompatible material?

End-use and recovery may include, but is not limited to, activities that recover organic waste such as recycling at a recycling center , composting, and in-vessel digestion activities and other activities that constitute a reduction in organic waste landfill disposal as defined in Section 18983.1(b).Further processing may include but not be limited to, transportation to another transfer/processing activities where the material will be further processed (i.e., volume reduction, etc.).

Q: Will operators have flexibility on how to implement the measurements?

Yes. The regulations allow the operator to propose an alternative measurement such as a different sampling frequency and/or weight, or a different methodology for determining organic waste quality standard provided it will be as accurate as the requirements to the Enforcement Agency for approval, with concurrence by the Department, provided it meets the requirements within the Section (see Section 17409.5.9).

Q: Is the determination of incompatible materials calculated on a per-load basis or aggregated over a period of time?

The percentage of incompatible material found in a sample is applied to the total outgoing tonnage of the material type being sampled. A facility will calculate the total amount of incompatibles sent out each day of the measurement period (that a sample is taken).

Q: Does the incompatible materials limit apply to remnant organic material?

No. Remnant organic material as defined in Section 17402(a)(23.5) only applies to the organic material collected in a gray container collection stream as defined in Section 17402(a)(6.5).

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Alternative to Measurement Protocols (Section 17409.5.9)

Q: Can an operator apply for a lesser sampling frequency?

Yes. The regulations allow the operator to propose an alternative sampling frequency to the Enforcement Agency for approval, with concurrence by CalRecycle, provided the operator can demonstrate that the measurement will be as accurate.

Q: For materials like fiber that have third-party inspection processes, can an operator establish an alternative to the measurement protocols?

Yes. The regulations allow for a substitute or waiver of requirements of the measurement protocols, provided that the Enforcement Agency can verify that the person, entity, or solid waste facility accepting that organic material type imposes quality standards on the operator [see Sections 17409.5.9(c)]. The receiving facility shall demonstrate that the sampling protocol they use is designed to accurately reveal the percentage of incompatible material by weight present in their samples. This is necessary to allow the operator the flexibility to use the receiving entity’s quality standard in-lieu of the sampling requirement if the quality standard meet or exceed the levels established in the proposed regulations.

Q: How should an operator conduct measurements on residuals that are in slurry form?

The regulations allow for the Enforcement Agency to approve, with concurrence from CalRecycle, an alternative measurement to determine how much organic waste is recovered and send for disposal, as long as the method proposed by the operator is as accurate as the prescribed protocol (see Section 17409.5.9).

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Solid Waste Handling at Consolidation Sites (Section 17409.5.10)

Q: What is the definition of a consolidation site?

Consolidation sites are facilities or operations that receive solid waste for the purpose of storing the waste prior to transfer directly from one container to another or from one vehicle to another for transport and which do not conduct processing activities. [Therefore, a transfer/processing facility or operation whose sole purpose is to receive solid waste for storing only and does not conduct any processing regardless of the amount or type of waste received would be considered a consolidation site.] Consolidation activities can include limited volume transfer operations, sealed container transfer operations, direct transfer facilities, and activities that do not conduct any processing as part of their operations. The term “consolidation site” is used to identify which transfer/processing solid waste facilities and operations are not subject to measurements or record keeping requirements.

Q: Can a source separated organic collection stream and a mixed organic waste collection stream be combined at the consolidation site before being transferred to a transfer/processor?

No. A consolidation site must keep source separated organic waste collection streams separate from other solid waste streams [see Section 17409.5.10(c)].

Q: Are consolidation sites newly created sites that only receive source separated recyclable material?

No. Consolidation sites are sites that have and continue to receive waste but do not do any processing of the waste. An example is a transfer operation that only reloads waste. The term is used to differentiate between sites that conduct processing from those that do not in order to determine if the activity is subject to the measurement and reporting requirements.

Q: Are transfer/processing operations or facilities that meet the definition of a consolidation site required to send all material to a transfer/processing facility or operation that complies with 14 CCR Section 17409.5.1?

No. Only material that is part of the Source Separated Organic (SSO) Waste Collection Stream [as defined in Section 17402(a)(26.6)] or the Mixed-Waste Organic (MO) Waste Collection Stream [as defined in Section 17402(a)(11.5)] that is subject to the measurement requirements are required to be transported to a transfer/processing facility or operation that complies with Section 17409.5.1. The intent of Section 17409.5.10(d) is to require any consolidation site that does not conduct any processing activities to transport material from the MO or SSO collection stream to a transfer/processing facility or operation that will process and measure that material as described in the regulations.

Q: Can a consolidation site transport waste directly to a landfill for disposal?

Waste from the Source Separated Organic (SSO) Waste Collection Stream and Mixed-Waste Organic (MO) Waste Collection Stream must be transported to a transfer/processing facility or operation that complies with the organic waste recovery efficiency requirements found in Section 17409.5.1. Other solid waste streams, such as gray container waste as defined in Section 17402(a)(6.5) can be transported directly to landfill disposal.

Q: Could the solid waste material sent to a transfer/processing operation or facility from a consolidation site include any organics?

Yes. The material transported from a consolidation site may include organic waste. The material would have to be transported to a transfer/processing operation or facility for further processing.

Q: Are operators expected to conduct measurements at consolidation sites if they are deemed to be a recycling center?

No. Recycling centers are not subject to the transfer/processing regulatory requirements under Title 14 of the California Code of Regulations. [See Section 17402.5(d) for definition of Recycling Center.]

Q: Are Enforcement Agencies expected to inspect the consolidated sites?

Yes. Consolidation sites is another term for transfer/processing operations or facilities that do not conduct processing, and include, but are not limited to, limited volume transfer operations, sealed container transfer operations, and direct transfer facilities.

Q: Is there a restriction for consolidation sites to receive and handle bagged organics in a single-container service?

No. However, no level of processing shall occur at consolidation sites, such as removing the bags from the loads.

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Transfer/Processing Enforcement Agency Verification Requirements (Section 17409.5.12)

Q: How many measurements should the Enforcement Agency oversee to verify a facility is in compliance with measurement requirements?

The Enforcement Agency should observe as many measurements as necessary to ensure that the operator is compliant with the requirements.

Q: Who is responsible for monitoring and enforcing solid waste facilities’ compliance with the Title 14 regulations?

Enforcement Agencies will be responsible for enforcing compliance with design and operational requirements at solid waste facilities and operations.

Q: What are the Enforcement Agency requirements for verifying measurements?

The regulations require the Enforcement Agency to verify the measurements conducted by the operator through review of records as well as through periodic, direct observation of the measurements.

Q: How does the Enforcement Agency determine if the measurements do not accurately reflect the records?

Reviewing the records in combination with observing measurements will help the Enforcement Agency determine if the measurements are accurate and representative of the waste stream.

Q: What measurements should the Enforcement Agency observe?

The Enforcement Agency must observe all the types of measurements to ensure compliance with state minimum standards.

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Recordkeeping and Reporting Requirements (Section 17414.2)

Q: Can conversion factors be used if a scale is not used to record weights?

If scales are not accessible, the regulations allow the Enforcement Agency to approve, with written notification to the Department, an alternative method including, but not be limited to:

  • If an operator records self-haul load by volume, then they may estimate disposal tonnage by using volume-to-weight conversion factors.
  • If an operator records self-haul loads by vehicle size and/or type, then they may estimate disposal tonnage using the weights estimates for each vehicle size and/or type. [See Sections 17409.5.9(b), 18815.9(g).]

Q: Do scales have to be a certified?

No, so long as entities using non-certified scales to measure a transaction by weight shall use that measurement and not an estimated based on volume when compiling and submitting their report.

Q: Can records be kept electronically or are paper records required?

All records shall be made available in a form and manner approved by the Enforcement Agency.

Q: What is the organic waste recovery reporting frequency for all facilities, including composting and in-vessel digestion activities?

The reporting frequency requirement is per “reporting period,” which is on a quarterly basis. The four reporting periods in each calendar year are:

(A) Reporting Period 1- January 1 to March 31

(B) Reporting Period 2 -April 1 to June 30

(C) Reporting Period 3 – July 1 to September 30

(D) Reporting Period 4 – October 1 to December 31

Q: Are MRF fines that contain organics included in the reported organics?

MRF fines are not defined in the regulations. Processed material fines can consist of organic and non-organic materials. Transfer/processors that send processed material fines for further processing or disposal must sample the material to determine the organic fraction of that material.

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Composting Facilities and Operations (14 CCR, Division 7, Chapter 3.1, Articles 2 & 6)

Q: What are the measurement requirements for composting facilities and operations?

The measurement requirements are to determine the amount of organic waste present in material sent for disposal. However, any organic wastes that are textiles, carpet, hazardous wood waste, non-compostable paper, human or pet waste, and material subject to a quarantine on movement issued by a county agricultural commissioner, are not required to be measured as organic waste. For details on how to perform the measurement protocol see Section 17867(a)(16).

Q: Are composters required to measure each organic waste type?

No. Composters only need to determine the overall amount of organic waste present in materials sent to disposal. They do not need to determine the amount by type. [See Section 17867(a)(16)].

Q: How are composting operators expected to remove organics that are stuck to plastics?

The purpose of the regulations is to measure how much organic waste is sent for disposal. The regulations do not outline methods a facility may use to remove contamination in source separated organics or mixed waste organics. [See Section 17867(a)(16).]

Q: What measurements should the Enforcement Agency observe?

The Enforcement Agency should observ e the operator conduct the measurements to determine the amount of organic content in the material sent for disposal and to assure applicable protocols are being followed. [See Section 17867(a)(16].

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In-Vessel Digestion Facilities and Operations (14 CCR, Division 7, Chapter 3.2, Articles 1, 3, 4, & 6)

Q: What are the measurement requirements for in-vessel digestion facilities and operations?

The measurement requirements are to determine the amount of organic waste present in material sent for disposal. However, any organic wastes that are textiles, carpet, hazardous wood waste, non-compostable paper, human or pet waste, and material subject to a quarantine on movement issued by a county agricultural commissioner, are not required to be measured as-organic waste. For details on how to perform the measurement protocol see Section 17896.44.1.

Q: How is a measurement performed on residuals in slurry form?

Section 17896.44.1(d) allows for the Enforcement Agency to approve, with concurrence from CalRecycle, an alternative measurement for determining the amount of organic waste contained in the residuals, provided that the method proposed will be as accurate as described in subdivision (a)(1) and (2).

Q: What measurements should the Enforcement Agency observe?

The Enforcement Agency will observe the operator conduct the measurements to determine the amount of organic content in the material sent for disposal and to assure applicable protocols are being followed [see Section 17896.44.1].

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Landfills (27 CCR, Division 2, Chapter 3 & 4)

Alternative Daily Cover (Landfills Only)

Q: Would compost overs, with less than 10 percent organic content, that are used as beneficial reuse or alternative daily cover count as disposal?

Compost overs that meet the requirement of activities pursuant to 18983.1(b), such as land application or erosion control, are considered a reduction of disposal. However, the use of organics (compost overs) as an alternative daily cover would be considered disposal pursuant to Section 18983.1(a).

Q: Since MRF fines contain some measurable organics, are MRF fines used as daily or alternative intermediate cover included in the measurement of organic material sent for disposal?

MRF fines are not defined separately in the regulations. Since processed material fines can consist of organic and non-organic materials, they are included in the measurement. Since alternative daily cover (ADC) and alternative intermediate cover (AIC) are defined as disposal pursuant to Section 18983.1(a)(2)(A), transfer/processors must include these streams in their overall representative sample of the material sent to disposal. In sum, only the organic fraction of the material used as ADC or AIC is measured as disposal of organic waste. [See Sections 17409.5.1, 17409.5.3, and 17409.5.5.]

Q: Do the regulations ban the use of digestate as alternative daily cover?

No. Nothing in the regulatory text prohibits the use of digestate as alternative daily cover. However, the use of organic waste as alternative daily cover constitutes landfill disposal of organic waste.

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Organic Disposal Reduction Status Impact Report [Public Resources Code (PRC) Section 21695]

Q: Section 21695(c) requires that the waste types be identified. Is this the same as the waste types listed in the permit?

The Organic Disposal Reduction Status Impact Report (SIR) should include any changes to the waste types listed in the solid waste facilities permit and in the Report of Disposal Site Information and/or the Joint Technical Document (JTD).

Q: Will the Air Resources Board landfill gas survey information be sufficient to meet requirements of subdivision (c)(3)(A)(4)?

Yes, as long as it is the most recent annual report filled under 17 CCR, Section 95470(b)(3).

Q: Is a description of the changes to the final grading plan acceptable or is a stamped drawing required?

Section 21695(b) requires that a California-licensed civil engineer or licensed engineering geologist prepare the SIR and certify changes to the final grading plans.

Q: How detailed and analytical should the SIR be?

The operator is required to submit a SIR that has been prepared by a California-licensed civil engineer or licensed engineering geologist to determine any potential impacts from the reduction of waste flow to their landfill. The SIR should be detailed enough to assist operators with the reduction of waste flow to the landfill.

Q: Section 21695 involves the operator reporting to CalRecycle. What is the Enforcement Agency’s role in the SIR?

The Enforcement Agency is not required to review or take any action regarding the SIR itself but to direct the operator based on CalRecycle’s review and determination. Subsections (g) and (h) explain the Enforcement Agency’s role and responsibility if CalRecycle determines that an amendment to the Joint Technical Document is needed.

Q: Are there any exemptions that allow for a jurisdiction that owns and operates a landfill to be excluded from the requirements of a Status Impact Report (27 CCR, Section 21695)?

No. There are no exemptions for this requirement. All solid waste landfill operators are required to comply with the requirements of a Status Impact Report.

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Permitting

Q: Does measurement/auditing constitute processing?

No, performing the measurement protocol is not intended to constitute processing as defined under Section 17402(a)(20). The purpose of the measurement is to determine the total weight of organic content contained in the waste stream that is sent for recovery and disposal.

Q: If specific areas for organics storage areas are not already in the Facility Plan or Transport Processing Report, will the operator need to apply for a permit action?

Yes. Section 21620 identifies the type of changes in a design or operation of a facility and the process to incorporate those changes into a solid waste facilities permit and/or the operating document as determined by the Enforcement Agency pursuant to Section 21665. For questions specific to an activity or permit, the operator should contact the Enforcement Agency in their jurisdiction.

Q: Will there be any changes to organics handling permits?

Most likely. If the operator proposes to change the design or operation of a facility to handle organic waste, an application would be submitted to the Enforcement Agency for a determination under Section 21620. For questions specific to an activity or permit, the operator should contact the Enforcement Agency in their jurisdiction.

Q: Do the measurements need to be written and included in the Facility Plan or Transfer Processing Report (TPR)?

Yes. The incorporation of the methodology into the operating document may be handled through an application for a Report of Facility Information amendment. For questions specific to an activity or permit, the operator should contact the Enforcement Agency in their jurisdiction.

Q: If the Transfer Processing Report does not allow for processing of organics in specific facility buildings, how can measurements be taken?

The regulations do not specify where on the permitted boundary the measurements must be performed. If the building does not have adequate space to conduct the sampling methodology, the operator would be required to find another location within the permitted boundary to perform the measurements. Note that performing the measurement protocol does not constitute “processing” [see Section 17402(a)(20)].

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Miscellaneous

Q: If a transfer processing facility or operation receives material from a jurisdiction that has a Department-issued low population waiver or rural exemption for that material, would that material be subject to the organic waste handling and measurements?

No. If a facility receives material from a jurisdiction (or part thereof) or entity with a Department-issued waiver or exemption under sections 18984.12(a) or 18984.12(c), then that material would not be subject to the measurement requirements.  However, any waste received from a jurisdiction (or part thereof) or entity that is not subject to an exemption or waiver would be subject to the measurement requirements. 

Q: If a transfer processing facility or operation receives material from a jurisdiction that has a Department-issued elevation waiver for food and food-soiled paper, would that material be subject to the organic waste handling and measurements?

A jurisdiction implementing a three-container collection service that provides a gray container, which by definition prohibits organics from that container, may allow food and food soiled paper in that container. This gray container may be considered a part of the gray container collection stream and be subject to the applicable gray container evaluation requirements.

A jurisdiction implementing a two-container collection service or unsegregated one-container collection service which provides a gray container that allows organics, including food and food soiled paper, would be considered a mixed waste organic collection steam and be subject to applicable measurement requirements.

Q: Are there any penalties or restrictions on how much organic material the landfill can dispose?

There are no penalties or restrictions for the landfill operator.

Q: Would organic waste required to be sent to a renderer licensed by the California Department of Food and Agriculture (CDFA) constitute a reduction of landfill disposal?

Subdivision (b) of Section 18983.1 provides a list of facilities, operations, and activities that are deemed to constitute a reduction of landfill disposal, including an activity that meet any of the definitions contained in 14 CCR, Section 17402.5(c). Rendering activities are defined in 14 CCR, Section 17402.5(c)(7), and means a licensed animal food manufacturing activity, or a rendering activity which is authorized by CDFA pursuant to Section 19300 of the Food and Agricultural Code, and in which no solid waste feedstock bypasses the manufacturing or rendering process. If a facility meets all parts of this definition, then organic material sent to the facility to be manufactured into animal feed or to be rendered will constitute reduction of landfill disposal.

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