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HomeMy WebLinkAboutMINUTES - 07111995 - C119 C. 115 through C. 119 THE BOARD OR SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA Adopted this Order on July 11, 1995 by the following vote: AYES: Supervisors Rogers, Smith, DeSaulnier, Torlakson, Bishop NOES: None ABSENT: None ABSTAIN: None ------------------------------------------------------------------------------ Subject: Correspondence C.115 Letter from Clifford J. Bates, Manager, Round Hill Estates North Property Owners Association, P. O. Box 3428, Danville, California 94526, inquiring into the status of a previous request for exemption of special district assessments against the Association's common parcel. ***REFERRED TO TREASURER-TAX COLLECTOR AND ASSESSOR FOR REPORT C.116 LETTER from The Honorable John C. Minney, Presiding Judge, Superior Court, County of Contra Costa, endorsing and urging the Board to implement the recommendations of the Juvenile Hall Replacement Advisory Committee. ***REFERRED TO PROBATION OFFICER AND COUNTY ADMINISTRATOR C.117 LETTER from Edward M. Steffani, General Manager, Stockton East Water District, P. 0. Box 5157, Stockton, California 95205-0157, requesting the Board to review its position opposing the completion of the San Luis Drain. ***REFERRED TO WATER COMMITTEE C.118 LETTER from R. J. Law, Dutch Slough, P. 0. BOX 1109, Bethel Island, California 94511, commenting on the increased level of truck traffic on the Dutch Slough levee road, and urging the Board to bring the levee up to the standards of the Federal Emergency Management Act. ***REFERRED TO PUBLIC WORKS DIRECTOR FOR REPORT C.119 Letter from Richard Granzella, President, Richmond Sanitary Service, Inc. , P. O. Box 4100, Richmond, California 94804-0100, commenting on the Regional AB949 Plan. ***REFERRED TO DIRECTOR, GROWTH MANAGEMENT AND ECONOMIC DEVELOPMENT DIRECTOR IT IS BY THE BOARD ORDERED that the recommendations as noted (***) are APPROVED. cc: Correspondents Treasurer-Tax Collector Assessor Probation Officer i hereby certify that this Is a tare and correct copy of County Administrator an action taken and entered on the minutes of the Water Committee Boar!of Supervisors on the date Mown. Public Works Director ATTESTED: a Director, GMEDA PHIL OTCHSCOR,Clerk of the Board of Supe/Jrvis�orrs,aand,County Administrator by .—,Deputy c . t Iq ~ RICHMOND SANITARY SERVICE tea ®_ 3260 BLUME DRIVE RICHMOND, CALIFORNIA 94806 June 29, 1995 DECEIVED Honorable Gayle Bishop, Chair L v 01995 Members of the Board CONTRA COSTA COUNTY BOARD OF SUPERVISORS 651 Pine Street, Room 106 CLERK BOARD OFSUFERVIS4RS Martinez, CA 94553 CONTRA COSTA CO. Re: Regional AB939 Plan Dear Honorable Bishop and Members of the Board: The West County Solid Waste JPA is putting together a Regional AB939 Plan which will be the blueprint for our efforts to comply with California AB939, the recycling law. Compliance with AB939 really means achieving 25% recycling from 1995 through 1999 and 50% recycling in the year 2000. RSS currently is achieving a 36% recycling level in West County - exceeding the 1995 mandated goal by 11%. The only thing required to comply with the year 2000 goal is an additional 14% diversion, and then only by the year 2000. We at RSS believe that the JPA's plan is not carefully enough thought out. The proposed plan takes a shotgun approach, naming many programs, .all of which are costly and only some of which are cost effective or necessary. RSS has identified the 5 most cost effective programs (some of which are in the JPA plan) . RSS is willing to guarantee that our 5 programs will divert the necessary additional 14% by the year 2000. The JPA plan proposes implementing 51 different programs to meet the state requirements. In our comments on the Plan which are enclosed, we lay out what we think is a more rational and less expensive approach to solving the mandated goals. West County ratepayers should only be forced to pay for the most cost effective programs necessary to meet the 50% goal. In light of the imminent rate increase to pay for the transfer station, our ratepayers cannot afford to pay for excessive programs which are not necessary to meet the AB939 goals. One main point, as you will see in our comments, is that we in West County do not need to expand the JPA from its current 4 full time employees - ($450,000 to $500,000 budget) to a 9 employee JPA with a $1,000,000 budget. Please take the time to read through our comments and share your thoughts with your representatives on the JPA. Please feel free to call me, Dennis Varni, my partner, or John Williams, the project manager for the IRRF, if you have any questions. truly yours, Richard Granz a, Pr ident RICHMOND SANI RY SER ICE, INC. RG:slh Enclosures cc: Philip Batchelor, County Administrator MAILING ADDRESS: P.O. BOX 4100, RICHMOND, CA 94804-0100 DEPARTMENTS: AREA CODE (510) ADMINISTRATION 262-1640 • ENGINEERING 262-1660 ACCOUNTING 262-1680 FAX 223-1591 \DOC\R0004056\121586 TjRICHMOND SANITARY SERVICE O 3260 BLUME DRIVE RICHMOND. CALIFORNIA 94806 June 19 , 1995 The Honorable Joe Gomes, Chair WEST CONTRA COSTA INTEGRATED WASTE MANAGEMENT AUTHORITY One. Alvarado Square San Pablo, CA 94806 Re: AB 939- Regional Plan Dear Joe : I have been president of RSS for over twenty years and my compan-v has been responsible for taking care of the solid waste needs of West Contra Costa County. It is no accident that the West County is far ahead of the rest of Contra Costa County and the whole state of California in the most complicated and difficult areas of solid waste that face us today - landfill ; closure and AB 939 compliance. As my associate Len Stefanelli reported at the meeting of the JPA on June 8 , RSS was not happy to read your staff ' s AB 939 Regional Integrated Waste Management Plan (Staff ' s Plan) which completely ignores the excellent performance of RSS and will force the local rate payers to pay for hundreds of thousands of dollars worth of useless programs over the next decade. RSS has been planning to meet the AB 939 responsibilities for all of its franchisors . The best evidence of RSS ' efforts over the years is the fact that we are 11% over the 25% goal` right now and just 14% away from the year 2000 goal . , We accom-1 ; shed this very high rate of divers4on :ith prograt s that work. We have five additional programs on the drawing board which we think will get West County over the 50% diversion goal over the next five years . I believe that RSS ' franchisors, the cities and the County, want us to start up the five programs over the next five years only on an as needed, when needed basis, in the order of their cost effectiveness . We all agree that it would be foolish for the JPA or any of the cities to spend more money on solid waste programs than -is necessary to meet the State ' s goals . My understanding is that the leaders of our cities and the County have identified plenty MAILING ADDRESS: P.O. BOX 4100, RICHMOND, CA 94804-0100 DEPARTMENTS: AREA CODE (510) ADMINISTRATION 262-1640 • ENGINEERING 262-1660 ACCOUNTING 262-1680 FAX 223-1591 r'E � • r y � The Honorable Joe Gomes, Chair June 19 , 1995 Page 2 of other social programs that deserve the resources of our rate payers more than chasing diversion rates in excess of 50% . The five programs that RSS proposes are : .1. Increase source- reduction through existing publications and educational activities 2 . Expand curbside recycling to include additional materials 3 . Implement a curbside green waste program 4 . Develop a wood recovery, program . that qualifies for diversion credit 5 . Commence the processing of rich mixed commercial loads at the IRRF It would be a mistake to start all of these programs right now. The AB. 939 Plan. must first identify the RSS programs that have brought us to 36% and then lay out a menu of prioritized programs to bring us the remaining 14% diversion. We need to sit back and take stock of how we are doing over the next five years and then implement the programs in the order of cost effectiveness as necessary to meet the 50% goal. The philosophy of leaving open our options and adding services as needed is central to our plans for the IRRF and should also be central to the AB 939 plan. The implementation of these programs will likely add more to garbage bills than they will save. Therefor, we ought to be very careful not to spend more than is necessary to do the job. We hired Brown, Vence and Associates (BVA) to take a look at Staff ' s Plan. `BVA has prepared no less than 78 AB 939 Plans and an equal or greater number of SRRE ' s. I thought that it was worth the expense to get experts to look at Staff' s Plan in light of the fact that the JPA' s SRRE' s were rejected by the same California Integrated, Waste Management Board (CIWMB) that will look at the Staff ' s Plan. I understand that West County accounted for three fourths of the rejected SRRE' s in the whole State of California. It would be expensive and embarrassing for West County to be singled out as failing the State ' s requirements for a second time. The Honorable Joe Gomes, Chair June 19 , 1995 Page 3 The JPA has to get in synch with the rest of California in . order to present an AB 939 Plan that meets the state' s requirements. We simply cannot ignore the fact that Staff ' s Plan has West Countyspending and staffing at a level that is way, way out of line with other communities. A careful comparison with other communities is included •in the BVA letter. The former Chair of the JPA, Rosemary Corbin, has stated publicly on more than one occasion that she believes that "RSS has dropped the ball" on AB . 939 planning. Staff has not disagreed with her. I resent these untruthful statements. It is especially angering when the criticism comes from members of a board that has failed to meet the requirements of the state while, at the same time; has spent far more money than the average for similar agencies. On the other hand, RSS has performed better than almost any other private company in achieving diversion and has done so under a rate structure that is historically among the lowest in Contra Costa County and remains the lowest back yard service in the region. I have included a copy of BVA' s review of Staff ' s Plan. . I hope that you and your Board cons'ider Mike Brown' s report carefully and make the changes necessary to satisfy the legal requirements of the state and to make the plan cost effective.' I look forward to receiving the detailed reply of your staff . But even more importantly, I hope that the Board gives' consideration to the rate payers and directs staff to change Staff ' s Plan to provide that program costs will be allowed only as and when necessary to meet state requirements. If you and the Board are of a mind to acknowledge the accomplishments of RSS in AB 939 compliance to date and to work out a mutually agreeable, prioritized list of programs to meet the diversion requirements of AB 939 , then RSS will be willing to indemnify the cities of the West county against AB 939 fines and penalties. At the beginning of my letter, I patted RSS on the back for being at the top of our industry in meeting the biggest T The Honorable Joe Gomes, Chair June 19 , 1995 Page 4 challenges of our business . Don ' t forget that, before you even got to West County, RSS and the individual cities were leaders in the State of California in working out the closure of the WCCSL in a way that was fair and that avoided the kind of litigation that Central County is having over Acme. We believe in working with the West County cities to do our job. . History shows that no other company has done a better job in our business and for that, we are both proud and thankful. Finally, in my experience in the solid waste industry, I have found it is always cheaper for government to work with its private collection company on solid waste issues than for government to try to do the job itself. I promise you that each program included in the Staff ' s Plan could be done better and cheaper. by my companies than by government. Please take a careful look -at Mike Brown ' s analysis of Staff' s Plan and consider working with me and my company in taking `care of the last 14% of diversion that West County has to achieve over the next five years . If RSS didn 't have the background, skill and experience to do the job, believe me, we wouldn ' t offer to be responsible for the penalties that will be charged if we fail. Ver truly yours Richard Granze la, resident Richmond Sanitary. Service, Inc. cc: . Bill Davis, Executive Director Members of the WCCIWMA Members .of Member Cities City Councils Members of the Board of Supervisors - Brown,Vence &Associates June 19, 1995 Energy and Waste Management Engineers 120 Montgomery Street Mr. Richard Granzella Richmond Sanitary Service Suite 1000 3260 Blume Street, Suite 210 San Francisco CA 94104 Richmond. CA 94804 415/434-0900 Subject: Comments on the WCCIWMA 415/956-6220 FAX May 12 Draft Regional Plan An Equal Opportunity Dear Richie: Employer At your request, Brown, Vence & Associates (BVA) reviewed the West Contra Costa Integrated Waste Management Authority's (Authority) May 12, 1995 Public Review Draft of the Regional Integrated Waste Management Plan (Regional Plan). We presented an overview of our comments to the Authority on June 8 during the Public Hearing. This letter documents our comments on the draft Regional Plan. We believe that the Regional Plan does not adequately acknowledge the cities' success in achieving a 36-percent diversion level through the existing source reduction, recycling, composting, and public education programs, most of which have been implemented by RSS. The 36-percent diversion level brings the cities into compliance 'with the 1995 25-percent diversion goal and well on the way to meeting the 2000 50-percent diversion goal. The Regional Plan should document the existing programs and their success and specify continuation of these programs. The Regional Plan should then identify the additional programs needed to accomplish an additional 14-percent diversion to meet the 50-percent goal. The additional program requirements should focus on selecting cost- effective programs. Furthermore, the programs proposed in the Regional Plan should be prioritized so that programs are implemented only if additional diversion is necessary. The Regional Plan identifies an exhaustive set of programs which will be implemented to meet the 2000 diversion goal. The Regional Plan does not recognize that only some of these programs are needed. To achieve the 50-percent diversion goal the Regional Plan does not prioritize the implementation of the identified programs so that the most cost-effective programs providing the most significant diversion are focused on first. The Regional Plan should clearly state that the Authority does not intend to implement all programs, but will select programs from the comprehensive plan. Many of the programs should be listed as optional or should be eliminated in an effort to control costs and staffing levels. Printed on Recycled Paper by Y Mr. Richard Granzella Richmond Sanitary Service June 19, 1995 Page 2 BVA has numerous concerns regarding this Regional Plan, Our letter focuses on those comments that relate to* the overall approach and message of the Regional Plan. We have provided more detailed comments in Exhibit 1. Our letter includes: 0 Evaluation of the Regional Plan * A listing of RSS's existing diversion programs * Programs required to achieve 50-percent diversion 9 Other programs identified in the Regional Plan 0 Staffing levels of WCCIWMA and other jurisdictions 0 Costs of unnecessary programs and staffing PART 1: EVALUATION OF THE REGIONAL PLAN Needs to recognize the region's existing programs resulting in 36-percent diversion. BVA does not feel that:the Regional Plan recognizes the region's existing diversion programs. These programs resulted in a 36-percent diversion level by 1993, exceeding the 1995 AB 939 goal of 25 percent. These existing programs are, for the most part, provided by RSS and in many cases were initiated by the company. The Regional Plan represents a baseline of 9-percent and the need for an additional 41-percent diversion. While accurate for 1990, this can be misleading to readers. The existing programs and the' 36-percent diversion level should serve as the foundation for the Regional Plan. In particular, BVA recommends that Table 2 of the Executive Summary be revised to include a column for 1993 diversion and the column for new diversion be adjusted to show only 14-percent additional diversion is required. Furthermore, we recommend that the existing programs be clearly identified in the document and new programs called out separately. Proposes duplicate programs. The Regional Plan proposes to duplicate existing RSS programs. For example, the Regional Plan proposes a home composting program requiring a budget of $55,000. RSS has been providing home composting workshops for several years. These home composting workshops have been performed at a very low-cost and have been highly successful. Also the University of California Extension Program provides a very successful Master Compost Program. It is our feeling that an Authority-sponsored program is redundant. Providing technical assistance to businesses is another example of a duplicate program, to which the Authority allocated $90,365. RSS routinely provides technical,assistance to businesses. It is a task and cost associated with "doing" business. RSS is best suited for this service because the company sees its refuse customers at least weekly. RSS routinely works with businesses to r t f Mr. Richard Granzella Riclunond Sanitary Service June 19, 1995 Page 3 establish successful recycling programs and.will continue with this aspect of its customer service program to meet the customers needs. Another duplicate program is the school education program. RSS, in cooperation with the West County Times, developed an award-winning-curriculum. This award winning curriculum has been adopted by Waste Management Technologies (WMX) and Browning-Ferris Industries (BFI). Furthermore, the California Integrated Waste Management Board (CIWMB) and other jurisdictions have developed and make available curriculum materials. The Authority has included $81,475 to develop, distribute, and assist in implementation of school curriculum resource packets, to develop and provide classroom activities, and to develop and provide annual school assemblies. This program duplicates some existing activities and resources. Other duplicated programs include development of drop=off/buy-back centers, market development, pilot food waste composting program, newsletter, information kiosk, business awards, and .others. These duplicate programs and additional costs should be eliminated from the Regional Plan. Cost savings associated with the elimination of duplicate program are described in Exhibit 2. Requires ratepayers to fund unnecessary programs. Several programs are proposed in the Regional Plan that will not provide much diversion but will incur costs to the cities. BVA has determined that only five new programs are needed to achieve the additional 14-percent diversion required. The Regional Plan identifies too many programs. The CIWMB requires programs identified in the plan to be implemented or the Regional Plan will need to be modified in the future to reflect changes. For this reason, the Regional Plan should only identify the diversion programs that will be needed to achieve the 50-percent goal. Other programs that, provide minimal diversion should not be included; should be included as options for each city to consider, or identified as low priority or backup programs. Minimizing the programs outlined in the plan will simplify the compliance process and will not require the ratepayers to fund unnecessary programs. Excludes information required by state regulations. The Regional Plan does not include all of the elements required by the California Code of Regulations, Title 14, Chapter 9, Articles 6.1 and 6.2. These deficiencies may result in its rejection. Estimates inadequate budgets for some planned programs. The Regional Plan estimates the costs for the implementation of several diversion programs. Although the plan indicates that all costs are "Order of Magnitude Cost Estimates" (+50% or -30%), the costs for the expanded residential curbside collection and yard waste collection may be underestimated. BVA,, in consultation with RSS, has provided cost estimates for these programs in Part 3 of this letter. i, � t Mr. Richard Granzella Richmond Sanitary Service " June 19, 1995 Page 4 PART 2: EXISTING PROGRAMS The Regional Plan identifies many of the existing programs as though they are new programs or has shown a shift in responsibility from RSS to the Authority. The Regional Plan should recognize all existing programs and RSS's role as the responsible party. Shifts in responsibilities should not be made when current programs axe working effectively, when RSS's costs are less than the cost requirements for the Authority's implementation, or when it makes more operational sense to have RSS continue to provide the service. The existing programs are a part of RSS's business. The company provides these services in .order to best serve its customers. Responsibilities for these programs are spread across several employees and are implemented in a cost-effective manner. By duplicating RSS's services, the Authority will not be able to realize cost savings by eliminating RSS staff. These employees serve various vital functions and perform additional tasks as a part of their jobs. For example, RSS has provided a newsletter to its customers with the bills on a quarterly basis since 1990. The newsletter "Waste .Watch" provides information regarding new programs, results of existing recycling programs, information on the recycling hotline, reuse businesses, and other source reduction and waste diversion activities. The company's customers are familiar with this publication. RSS has been providing space to the Authority in "Waste Watch" for several months. The .Regional Plan indicates that the Authority will be developing and distributing several types of printed materials. BVA does not recommend creating additional materials when "Waste Watch" offers an appropriate location for information and can avoid costs. Exhibit 3 provides a list of all the programs identified in the Regional Plan. Existing programs and the party that implements them have been clearly marked on this table. PART 3: PROGRAMS REQUIRED TO ACHIEVE 50-PERCENT DIVERSION BVA, in consultation with RSS, has identified five key programs (Key Programs) that we estimate will attain at least 14-percent additional diversion if implemented in the next five years. All of these programs are currently identified in the Regional Plan. The Regional Plan does not, however, highlight the significance of these programs as the "big diversion getters." The five Key Programs include increasing selected source reduction activities, expansion of the residential curbside collection program, implementation of a residential green waste collection program, development of a.wood waste recovery program, and the IRRF processing operation. Depending on the participation levels in the programs and the extent of the IRRF development, the five Key Programs will result in 14 to 25 percent diversion bringing the region into full compliance with the 50-percent diversion goal. Exhibit 4 shows the Key Programs and the anticipated diversion of each. Our recommendation is that these programs be identified in the Regional Plan as the priority programs for implementation with all other programs being postponed until the achievements of these programs can be evaluated. We further suggest that the programs be { T Mr. Richard Granzella - Riclunond Sanitary Service r June 19, 1995 Page.5 implemented in phases with as many costs as possible deferred until late in the 1990s. This implementation approach will allow the Authority to evaluate the progress towards the 50-percent diversion goal,. monitor the regulatory environment, and adjust the planned programs as appropriate. A brief description of each Key Program is described below and a discussion of the estimated costs for these programs is included. Increased source reduction. BVA recommends continued encouragement of source reduction activities through public education efforts and rate structure incentives. Source reduction has been encouraged through RSS's public education efforts for five years. The continued use of "Waste Watch" will serve as a vehicle for sending source reduction information to all of the RSS customers. In addition, the continuation of RSS's educational efforts with the commercial sector in the area of source reduction will increase diversion levels. At no additional cost to the region, RSS will consider designating an area at the Central Processing Facility site for Goodwill Industries or other reuse business to site a drop-off for clothing and other reusable items. Rate structure incentives have proven to be an effective method for encouraging source reduction and recycling. BVA sees three points at which rates can be adjusted to provide economic incentives for waste generators to take source reduction, recycling, and composting action. The rate structure mechanisms include the disposal site rates, the IRRF rates, and the franchised collection rates. The WCCSL rates establish reduced rates for source-separated materials. For example, green wastes and wood wastes tipping fees are $8.00 per cubic yards and clean concrete and asphalt tipping rates are $9.00 whereas refuse rates are $10.00 per cubic yard. The landfill has seen an increase in the volumes of materials being received.in a source-separated form. This rate structure program will be continued at WCCSL and reexamined to determine if other adjustments to the rate structure would be advantageous. WCCSL offers reduced rates for source-separated recyclable materials to be competitive with other facilities. IRRF rates may also be structured to provide incentives for customers to deliver recyclable rich loads which are easy to process. The Authority, as described in the IRRF service agreement, is obligated to set rates. This rate-setting process will occur with or without the Regional Plan. The Authority's budget to cover the rate-setting process associated with the IRRF tipping fees will come out of the Authority's IRRF budget. No additional funds should be allocated in the Regional Plan'for this effort. The other rate structure option is available to each city through the franchise agreements. The cities can adjust the residential and commercial collection rates to encourage source reduction, recycling, and backyard composting. Mini-can service for residential customers can be offered to provide further incentives. Mr. Richard Granzella Richmond Sanitary Service June 19, 1995 Page 6 Expanded curbside program. BVA suggests the expansion of the residential curbside collection program to include collection of cardboard, magazines, and junk mail. The expanded program will capture a large fraction of the remaining residential recyclables. It is estimated that the expanded program will result in roughly`a 30 percent increase the volume of recyclables collected through the residential curbside program. The addition of the mixed paper fraction will require additional collection route time using the existing collection fleet or additional collection vehicles and will require more processing labor at the IRRF. The Regional Plan erroneously assumes that no additional collection vehicles or collection route time will be needed. Residential curbside yard waste collection program. Implementation of a curbside yard waste collection program will be part of the key programs for accomplishing the 50-percent diversion goal. Capturing the yard waste portion of the residential waste stream should provide an additional 2 to 4 percent diversion. RSS can implement yard waste collection programs where yard waste quantities justify the costs and the configuration of the city streets allows for curbside collection. The collected yard waste will be transported to the WCCSL composting operation and composted into a useful product. The Authority staff estimates the cost of this program at $1.80 per household per month for collection and processing. BVA has reviewed the costs of several yard waste collection programs in the Bay Area. The Central Contra Costa Sanitary District received bids in March 1995 from four companies for the collection and processing of yard waste. The costs for this service ranged from $5.75 to $7.16 per household per month. RSS will provide the yard waste collection and processing costs cheaper than any Central Contra Costa Sanitary District proposer including Waste Management Industries, Browning-Ferris Industries, and the Green Team .' Wood waste recovery program. BVA recommends giving priority to a program that will divert wood wastes from the waste stream. RSS is pursuing a business arrangement with a company that produces particle board from wood waste. The particle board production would require a significant annual supply of wood waste. RSS could expand its wood waste recovery program to segregate wood waste from self-haul, commercial, and industrial wastes. The waste generators would be encouraged through the rate structure to segregate loads of wood waste. In addition, floor-sorting activities at the CPF would focus on extracting wood waste from mixed loads of self-haul and drop-box refuse because of the development of a local market. BVA estimates that approximately 4 to 6 percent diversion can be accomplished through the wood waste recovery program, depending on the participation level. 'This yard waste collection and processing cost does not account for system wide revenue losses due to reduction in the number of refuse cans serviced as a result of the green waste diversion Mr. Richard Granzella Richmond Sanitary Service June 19, 1995 Page 7. The implementation of this program may not require any costs on the ratepayers' behalf. All costs for the development and operation of the particle board facility would be incurred by the developer. RSS's costs to separate and deliver the materials could be wholly or partially offset by the market pricing and avoided transportation and disposal costs. IRRF. West County Resource Recovery, Inc. (WCRR), under agreement with the Authority, is developing the Integrated Resource Recovery Facility (IRRF). As part of the IRRF, the CPF is being constructed. The CPF will be used to house materials recovery activities. This facility will serve as a key Program to accomplishing the 50-percent diversion goal. The design of the IRRF allows phasing of the materials recovery activities as necessary to accomplish required diversion. Phase I would involve floor-sorting targeted loads of drop-box and self-haul refuse. Phase Il would include installation of a commercial processing line to recover recyclables from the commercial waste stream. In Phase 111, an additional processing system would be provided to remove recyclables from the residential waste stream. It is the company's intention that one or more of these phases will be implemented as necessary to achieve the 50-percent diversion goal depending on the recovery economics. For example, Phase II and III may not be necessary if the expanded curbside collection, yard waste collection, and wood waste recovery programs are very successful. . Therefore, implementation of each phase will occur only if necessary to achieve the AB 939 goal or to the extent they are cost effective compared to long haul and I disposal. The cost for Phase 1, floor-sorting, is included in the IRRF existing budget as presented in Exhibit E of the Service Agreement, Other costs can not be clearly estimated at this time. The Phase 11 and Phase III needs and costs will be defined in the future based on the results of the Key Programs and Phase I IRRF activities. PART 4: OTHER PROGRAMS IDENTIFIED IN THE REGIONAL PLAN The existing RSS programs and the five key new programs needed to accomplish the 50 percent goal cover many of the programs identified in the Regional Plan. However, the Regional Plan identifies several other new programs and expansion or reallocation of responsibilities for implementation from RSS to the Authority of existing programs that require staffing and funding to implement. While some or all of these programs may be desired by one or more cities or the Authority, these other programs are not needed to meet the 50-percent diversion goal and should not be forced on all the communities because they are not required. BVA recommends that the' .programs be eliminated from the Regional Plan or be indicated as optional or low-priority programs that would receive funding only in the event that the existing programs and key new programs do not bring the cities into compliance with the 50-percent-diversion. The elimination or prioritizing of the programs will reduce the overall cost of the AB 939 programs. If the programs remain in the Regional Plan and the 50-percent diversion goal is not accomplished, the state will expect the cities to implement these other programs in order to avoid fines. A plan required with only the programs necessary to achieve the State mandates would avoid the risk of penalties and eliminate the expense of unnecessary programs. Mr. Richard Granzella Richmond Sanitary Service June 19. 1995 Page 8 PART 5: STAFFING LEVELS OF WCCIWMA AND OTHER JURISDICTIONS To get a sense of how the Authority's current and proposed staffing levels compared to other jurisdictions in the state, BVA conducted a telephone survey of several other JPAs and counties. The survey was focused on assessing, the number of staff specifically designated to performing AB 939 activities. Staff that handles franchise agreements, rate reviews, landfill and operations contracts. facility development, etc. were not included in the staffing count. To provide a basis for comparison, the staffing information was compared In termsof the number of full-time equivalent staff persons. per 100,000 population. The findings of the survey are presented in Exhibit 5. As this exhibit illustrates, the Authority's current staffing level dedicated to AB 939 activities is average in comparison with the other jurisdictions surveyed. The Authority's proposed staffing levels are, however, very high compared to the others surveyed. BVA believes that the Authority staffing levels are higher than necessary given the experience of other and the socioeconomic conditions of the region. The South Bayside Transfer Station Authority (SBTSA) serves as an excellent example of a JPA in situation similar to WCCIWMA. The SBTSA includes 10 cities, portions of San Mateo County, and a sanitary district. These entities rely on their franchised collector to provide programs to accomplish AB 939 goals. The cities do not need to have, nor do they have large recycling staffs to implement programs. In most cases, the cities have less than a full-time person assigned to AB 939 compliance tasks. The franchised collector has accepted responsibility for AB 939 fines if levied by the state for noncompliance with AB 939 requirements; SBTSA currently has a part-time contract consultant who is equivalent to a 0.25 full-time person. At this time, SBTSA does not anticipate expanding this staff by 2000. This staffing levels equals 0.08 AB 939 staff persons per 100,000 population. The SBTSA budget includes the 0.25 staff person and $50,000 for outside consulting, services, a total budget of approximately $75,000. RSS is serving the same type of role as the franchised collector provides SBTSA. The'Company has Implemented diversion programs that brought the region 36-percent diversion and compliance with AB 939's 1995 25-percent diversion requirement.is proposing The Company c� the implementation of the five Key Programs will result in an additional 14-percent diversion.over the next five years and achievement of the 50-percent diversion goal by 2000. Furthermore, the Company is willing to accept responsibility for the AB 939 fines. Given these similarities, BVA questions the need for maintaining the existing staffing level once the Regi.onal Plan is written, and does not see any justification for the proposed additional 4.5 staff and expenses amounting to a budget of $450,000. A comparison of WCCIWMA and SBTSA conditions is provided in Exhibit 6. PROGRAIM COSTS If the Authority follows RSS's recommendations to continue all the existing programs and - implement only five Key Programs to meet the 50 percent diversion goal, the estimated implementation costs for the Regional Plan will be reduced. Significant savings will.occur if Mr. Richard Granzella Richmond Sanitary Service June 19, 1995 Page 9 unnecessary programs and associated staffing are eliminated. BVA made an assessment of the cost of the Authority's programs as presented in the Regional Plan, BVA's more realistic estimate of' the Authority's proposed programs, and RSS's proposed programs. This cost assessment is presented in Exhibit 7. It shows that savings that can be realized by implementing the RSS plan, which scales back the scope of.the Regional Plan. The estimated savings amount to $328,000 to $683,000 per year as summarized in Exhibit 7. This projected savings was made to the best of our ability given the limited nature of the cost information in the Regional Plan and the Order of Magnitude Cost Projections. It is our professional opinion that the changes outlined will provide the region with the means to meet the AB 939 goals in a cost-effective manner. I hope that our comments are seriously considered and are reflected in the final Regional Plan. Very truly yours, Michael D. Brown President F:\SW\95028\COM,\4ENTS.BVA:19Jun95 •' .�XgXgYTS r EXHIBITS 1 Detail Comments on Plan 2 Duplicate Programs 3 Proposed Programs 4 Key Programs to Achieve 50-Percent Diversion 5 Staffing levels of WCCIWMA 6 WCCIWMA and SBTSA 7 Program Costs t EXHIBIT I DETAIL COMMENTS ON PLAN Exhibit 1 Detailed Comments on the Plan The following are detailed comments on the May 12, 1995 Public Review Draft Regional Integrated Waste Management Plan (Plan) 'prepared by the staff of the West Contra Costa Integrated Waste Management Authority (Authority) on behalf of the cities of El Cerrito, Hercules, Pinole, Richmond and San Pablo. The draft Regional Plan includes 'numerous.duplicative programs and unnecessary ,additional In Authority staff. The following individual comments are listed by chapter, page and paragraph number. Source Reduction and Recycling Element Chapter I Introduction 1. Page 1-1-17 The cities in the Region have previously identified programs they wish to implement in order to achieve the diversion mandates. Given that the Region as a whole was a 36 percent diversion in 1993, BVA questions the appropriateness of implementing the numerous additional programs identified by the Authority in order to achieve an additional 14 percent diversion. Except for El Cerrito, the Member Cities previously selected the following programs for their individual SRREs: Source Reduction Variable rates Procurement policies Recycling Adding materials to curbside program Self-haul drop-off at the IRRF Commercial and industrial processing at IRRF Concrete and asphalt recycling Office paper recycling Christmas tree.and phone book recycling Composting Curbside collection and composting of yard waste H:\SW\95028\EXH1B1T.1 06/19/95 4:13 pm Exhibit 1 (cont.) Detailed Comments on the Plan Self-haul yard waste composting Composting of fines (from wood waste shredding) ID El Cerrito selected the following additional programs: Source Reduction Disposable diapers reduction Business assistance and education Home composting Junk Mail Free Zone Recycling Drop-off center Ferrous metals and plastics recovery from self-haul construction and demolition debris Composting Seasonal collection of yard waste Food waste composting I The Authority selected the following additional programs for the Regional Plan: Source Reduction Collection rate structure modifications IRRF rate structure modifications Bin distribution Demonstration gardens Xeriscape planting Food donation Reuse businesses Tool lending library Waste assessments Activities and guidelines Public education program School education program Recycling Bulky metal goods collection Weekly schools collection Special schools collection H:\SW\95028\EXHIBIT.1 06/19/95 4:13 pm 2 S Exhibit I (cont.) Detailed Comments on the Plan Commercial corrugated cardboard collection Drop-off centers Buy-back centers Pricing incentives for private facilities Recycling plans for large generators End-use markets for materials Education Regional logo Annual media campaign Video Consumer awareness campaign We recommend eliminating all of the programs not previously selected by the cities. None of. the additional program accounts for any significant diversion. The Region as a whole should not have to implement special programs desired by El Cerrito. Chapter 2 Waste Characterization 2. Page 1-2-4, fourth paragraph The assumption that there is no commercial or industrial waste that is self-hauled in El Cerrito due to franchised collection and the presence of the El Cerrito Recycling Center is unreasonable. Each of the other cities has franchised collection and the Interim Recycling Center (as well as other private recyclers) provides drop-off and buy-back opportunities for Richmond area businesses and residents. We recommend redistributing the disposal amounts to account for El Cerrito commercial and industrial self-hauled wastes. Chapter 3 Source Reduction General comment: Source reduction is an important waste management strategy. Education and public awareness are central components of an effective source reduction program: However, many of the programs proposed by the Authority are duplicative of existing programs. Additionally, we believe the diversion estimates for some of the proposed.programs are over- stated. HAM9502MEXHIBIT.1 06/19/95 4:13 pm 3 Exhibit I (cont.) Detailed Comments on the Plan 3. Page 1-3-7, sixth paragraph Home composting workshops have been offered by RSS since 1990. Implementation of this . program by the Authority is duplicative and.should be eliminated from the Regional Plan. 4. Page 1-3-8, first paragraph Community composter training courses are offered by the University of California Cooperative Extension. Implementation of this pro-ram by the Authority is duplicative and should be ,eliminated from the Regional Plan. 5. Page 1-3-8, fourth paragraph Xeriscape planting is desirable for water conservation. However, promotion of xeriscaping'iscapinmay have the effect of encouraging residents and businesses to remove existing vegetation and may actually promote the generation of vegetative waste. Xeriscaping should be promoted for new plantings and new developments. RSS can easily promote xeriscaping through its existing newsletter Waste Watch and will be demonstrating xeriscaping at the IRRF. This pro-ram should be eliminated from the Regional Plan. 6. Page 1-3-8, fifth paragraph Food donation is an appropriate activity provided that there is an infrastructure for collecting and distributing the left-over food. The Authority proposes to promote food donation. However, it is unclear that existing soup kitchens and food banks have the capability to accept perishable food left-over from special events and restaurants. Local health codes may also limit this practice. These concerns should be evaluated before the Authority includes this program in the Regional Plan. 7. Page 1-3-8, sixth paragraph The Authority assumes that the Home Composting program will be able to recruit and maintain 380 new composting households (or 4 percent) per year. This estimate seems very,optimistic. The Alameda County Home Composting Program has been operating with a large budget since 1990 and has achieved a total of 5.7 percent of households in Alameda County. Alameda HASM950281EXHIBITA 06/19/95 4:13 pm 4 Exhibit Z (cont.) Detailed Comments on the Plan County's Home Composting budget is in excess of $500,000 in.the coining fiscal year. This concern should be evaluated and, if appropriate, corrected in the Regional Plan. 8. Page I-3-9, seventh paragraph The Tool Lending Library is an inappropriate program for the Region. Home repair and yard maintenance tools do not end up in the waste stream. A Tool Lending Library would be very expensive to develop and maintain. Liabifity and theft would be constant concerns and the library would not offer any significant. diversion opportunities. This program should be eliminated from the Regional Plan. 9. Page I-3)A 1, third paragraph The Junk: Mail Free Zone program consists of promoting the reduction of junk mail through the publication of the 800 phone number to request removal from mailing lists. This phone number has been distributed by RSS in Waste Watch and need not be a special program of the Authority. This program should be eliminated from the Regional Plan. 10. Page I-3-12, second paragraph RSS currently performs on-site waste assessments for its commercial customers. This is a normal part of doing business for the company. The development of an additional program would be duplicative. Many state associations and agencies offer awards to"businesses. RSS recognizes outstanding companies in Waste Watch. A business awards program would be time-consuming and, therefore, costly to the Authority. We recommend eliminating this program and instead, nominating businesses in the Region for other existing awards. 11. Page I-3-12, fifth paragraph RSS and the West County Times have already developed an award-winning source reduction and recycling curriculum. In addition, school curriculum resource packets and special classroom activities have already been.developed by the California Integrated Waste Management Board. The Board offers H:\SW\95025\EX HIBIT.1 06/19/95 4:13 pm 5 Exhibit I (cont.) Detailed Comments on the Plan training for teachers and the curriculum for free. The Authority should eliminate this program, rely on the RSS/West County Times curriculum and, refer the school districts to the Board's program. 12. Page 1-3-16, Table 3-3 RSS and the Authority have already implemented rate structure modifications. Implementation of the IRRF will require additional rate structure modifications. The expectation of diversion of 7,800 tons of material per year through additional rate structure modifications is questionable. Authority staff have provided no basis for this very high estimate. This concern should be evaluated and, if appropriate, corrected in the Regional Plan. Chapter 4 Recycling 13. Page 1-4-10, third paragraph RSS had previously offered a bulky metal goods collection program to the City of Richmond. This pro-ram was rejected by the city. It is inconsistent that the Authority would now select a program that has already been rejected by the Region's largest generator. This concern should be evaluated and, if appropriate, the program should be eliminated from the Regional Plan. 14. Page 1-4-10, fourth and fifth paragraphs RSS has already implemented a weekly collection and special collection program for the schools. Implementation of this program is duplicative and should be eliminated from the Regional Plan. 15. Page 1-4-11, sixth paragraph RSS has already implemented a construction and demolition debris recycling program. There are already price incentives that encourage source separation. Implementation of this program is duplicative and should be eliminated from the Regional Plan. 16. Page 1-4-12, first and second paragraphs RSS has already implemented recycling programs at the Regions public offices and hospitals. Impleme ntation of this program is duplicative and should be eliminated from the Regional Plan. H:\SW\95028\EXH1B1T.1 06/19/95 4:13 pm 6 Exhibit 1 (cont.) Detailed Comments on the Plan 17. Page I-4-12, fourth paragraph Drop-off centers currently exist at the Interim Recycling Center and at the landfill. The El Cerrito drop-off center is used by residents and business throughout the Region. There will be a drop-off center at the IRRF. Additional drop-off centers are costly and unnecessary. We recommend eliminating this program from the Regional Plan. 18. Page 1-4-13, second paragraph There are 11 certified buy-back centers within the Region offering residents and businesses ample opportunity to earn money for their materials. Additional buy-back centers are costly and unnecessary. We recommend eliminating this program from the Regional Plan. 19. Page I-4-14, fifth paragraph The Authority has no authority over other public agencies or private businesses within the Region. Therefore, the Authority cannot require these large generators to produce recycling plans. We recommend eliminating this program from the Regional Plan. 20. Page I-4-14, sixth paragraph The existing Contra Costa Industrial Shoreline Recycling Market Development Zone is responsible for market development and outreach. Economic development staff are strained in business,development and retention. Authority staff do not have the expertise to replace the existing program and implementation of this program by the Authority is duplicative. We recommend eliminating this program from the Regional Plan. Chapter 5 Composting 21. Page I-5-6, last paragraph Yard waste collection and processing should logically be procured together. RSS has already developed a composting operation at the landfill and markets the material to end-users. As with all other collection programs, education, public information and advertisement can be most expediently performed by the contractor. Implementation of this program by the Authority would be duplicative and unnecessary. H:\SW\95028\EXHIBIT.1 06/19/95 4:13 pm 7 t Exhibit I (cont.) Detailed Comments on the Plan Chapter 6 Special Waste - No comments. - Chapter 7 Disposal Facility Capacity - No comments. Chapter 8 Nondisposal Facility Element - No comments. Chapter 9 Funding and Integration 22. Page I-9-5, last paragraph The Authority anticipates shifts in responsibility for implementation of existing activities from the franchised haulers and the city of El Cerrito to the Authority. However, the Authority has provided no rational basis for the change. The existing service providers have achieved a 36 percent diversion rate for the Region and are poised to achieve the additional 14 percent diversion through the provision of a few cost-effective additional programs. There is simply no justification for changing the status quo. There is no evidence that the Authority would be able to implement programs more effectively and efficiently than the present providers. Therefore, we recommend that the Authority not undergo this change in responsibility at this time. 23. Page I-9-10, third paragraph This section describes the Authority's costs for implementing the programs described in the previous chapters. The Authority anticipates needing 4.5 additional staff to implement these programs. We believe that these additional staff members are totally unnecessary (as described below). 24. Page I-9-11, first paragraph The Authority anticipates requiring one full-time equivalent staff person responsible for monitoring, reporting and rate structure modifications. This is entirely unnecessary. The monitoring and reporting function is perfunctory and merely requires taking RSS reports and combining them with El Cerrito reports in order to generate the desired information. Existing Authority staff can easily handle these additional tasks. Rate structure modifications are certainly the responsibility of the Authority's Executive Director and should not be delegated. H:ASW195028\EXH161T.1 06/19/95 4:13 pm 8 Exhibit 1. (cont.) Detailed Comments on the Plan 25, Page 1-9-11, second and third paragraphs The Authority anticipates requiring one full-time staff person responsible for Public Agencies and Business Technical Assistance Programs and one full-time staff person for Education and Public Information Programs. As part of its service to its customers, RSS already provides technical assistance to public and private sector waste generators. In addition, the Authority already has an existing Manager of Source Reduction and Recycling Programs. It is unclear ID what that person would do if two more staff were to undertake these programs. We recommend eliminating this staff position from the Regional Plan. 26. Page 1-9-11, fourth paragraph The Authority anticipates requiring three-quarters of a staff person for Schools Programs. This staff time is entirely unnecessary. RSS has already developed an award-winning curriculum. If additional assistance is needed, the California Integrated Waste Management Board has several people on staff whose full-time responsibility is to perform outreach to the school districts and train teachers in the existing Source Reduction and Recycling Curriculum. We recommend eliminating this staff position from the Regional Plan. 27, Page 1-9-11, fifth paragraph The Authority anticipates requiring three-quarters of a staff person for the Composting Program. However, RSS currently has people on staff who are able to provide workshops and training for home composting. RSS could easily accommodate additional tasks, such as bin distribution and development of demonstration gardens at the IRRF and landfill sites. RSS staff could work with the existing Authority staff on this project. Education and Public Information Program 28. Page 11-7, sixth and seventh paragraphs Given the Region's fiscal constraints, it seems unjustifiable that the Authority would need to devote the resources to developing a Region Logo and Annual Media Campaign. The Region's consumers already have information about source reduction.and recycling from state (California Integrated Waste Management Board, Department of Conservation, Local Government Commission, etc.) and federal (Environmental Protection Agency) agencies, as well as private H:\SW\95028\EXH1B1T.1 06/19/95 4:13 pill 9 Exhibit 1 (cont.) Detailed Comments on the Plan entities, such as the Enviromnental Defense Fund. Information about local programs is provided through existing sources, such as Waste Watch. Consumers are used to receiving information about local programs from the local hauler. It is unnecessary to have another layer of bureaucracy promoting itself and duplicating information provided by other entities. We recommend eliminating this program from the Regional Plan. 29. Page lI-9, last paragraph and page I1-10 fifth paragraph Feedback to residents on programs is already provided by RSS through Waste Watch. No additional program is necessary. We recommend eliminating this program from the Regional Plan. 30. Page II-10, last paragraph As previously mentioned, both RSS and the California Integrated Waste Management Board has developed an extensive Source Reduction and Recycling Curriculum. Each curriculum is available for free to school districts and individual teachers. The Board performs outreach to school districts and free training for teachers. The Authority's schools program is unnecessary and duplicative. We recommend eliminating this program from the Regional Plan. Appendix A Solid Waste Generation Study 31. The Solid Waste Generation Projections section (required by state regulations) is missing from the Solid Waste Generation Study. We recommend developing this section of the. study and circulating it for public review before the Authority adopts the Regional Plan. HAM950MEXHIBIT.1 06/19/95 4:13 pm 10 EXHIBIT 2 DUPLICATE PROGRAMS , c o r r N p of) N { O c) •yG N N.ry 53.., CO p u. � .O v � •� � N a, O o `�, o J ✓ cD ,. 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O N U N bA O O r w d N '✓. a N N a J O yG O G id O -0 "C5 y cd o 3 rJ o,Cd cid v cd Of N i N �` N z, r J d ✓ G ' O N d 0 J O G L) a T O µ N p G R d y W dcd GO p Ga u �Ry O cd cryo p a� J '� T o O c2 p ti CI U J W U J O J i .� N N tj N JO cd N C� ce O p 0 'r J cTj 0 v p o5 ,J J P jo t N n UI F- "d •7 0 1, oz o Lf) 1.3 27 ' Q r y J r t ,fl Nn y G O O O J c O L) .� n c* bD O p Q v O J d oO 0 0 o (Af o^ I d � o C:) o 0 Q cl� oo Oin Gt O N O p ¢ O N P cJ V O pO n C o y y y 0Ile. cd G J O O T '✓ ^ O a Np. 6` cC cd _ •N O N apVn 04) O P n bA .r ce p, v O fl R v J—r rn r J am ~ J cd � 7 O � O ✓ N In P' p p 'j � •7 .N ,�'�, � O U J cc p J y o P' o v Q a P N TN . .G V)c3 O J 0 0 EXHIBIT 3 PROPOSED PROGRAMS l CE O C-+ Q bA Chi � G Q • U p G .4 Q � Ca CIO p O G i + PLA G U N CIO �� v ct vo a 0 0c QIrl Q r46w C3 o � 0 v o U Ln 0 a pCIS Q va 1-4 Cd W d � e , •u � CO U � c n o Ln x U _ G d LD T t � o `" aO ZLoll aGi a> G 7, G G K) O v Cd p ' E..4 •� '� ,"'� .Y P-+ � 'Vi TS ° � � � ,Si CCS O O O aO .}�` �i' cc •L� KS p G O O cd U U rn W c> E- ¢� Q , o • to U � � o rn � F o � U cn Q qa c 0 ora > ON O °n N O o M O 1-4 W NO pp C]. O o. 0 c,> an d; cI� 0 o o v a p •�, °> � � -cs as Vr ,— v °� � � U41ccS da cd .U N U Cl) 4 Lf j a Qy 4. az cr w_ O czs a3 aJ U O • • {, O O ca w M � � o 0 oncli0 tit >, W tn cz o o •--• M � T M M CT O W Z Cl) o an D a w z o o z 2t N 0 Q Q1 cti G cd +--� C7 m o o 0 O rn v C wC,j N 54 cn G c� •3 cd to to Qo E �'x` c3 U — N •Z: GJ U ,� bo , rn o0 ai �DC4 � GU � W t� C7 cx va ai �; y , EXHIBIT 4 KEY PROGRAMS TO ACHIEVE 50-PERCENT DIVERSION Exhibit 4 Key Programs to Achieve 50 Percent Diversion` Diversion New Programs Estimate Increased source reduction 1 - 2% Expanded curbside program 2 - 3% Residential curbside yard waste collection 3 - 5% Wood waste recovery 3 - 5% IRRF 5 - 10% • Phase 1: Floor sort Phase.II: Coirnrnercial waste processing • Phase III: Residential waste processing Total Diversion 14 - 25% "14% in 5 years= 50% diversion by 2000 F:\Sw\95028\CORRES\50PERCEN.EXH 06/19/95 4:01 pni 1 EXHIBIT 5 STAFFING LEVELS OF WCCIWMA y Exhibit 5 Staffing Levels of WCCIWMA and Other Jurisdictions 3 2.5 0 c� CL 2 0 0 C) ` o 0 1 .5T L . Q� y- 4- n 1 C Co m Q 0.5 0 � mO o >1 > C: L) ° c c c c c n Y m m R C d L O O O m O O O' O cC7 L y U) V) (n U j U U U a U U U U L U O 4) LL y a N 'D Q. �p m a C U j 7 E E m Cc A Q 3 U O 0) m y C C a cn c 3 E c z v m y o cm o m. a - Cz O U O to C a m C m U > U n. m y U U) m m L 0 m 3 U)3y 30 0 o r N a a 9502870 RSSUurisdictioV488A EXHIBIT 6 WCCIWA4A AND SBTSA r Exhibit 6 Comparison of WCCIWMA w and South Bayside Transfer Station Authority WCCIWMA SBTSA Population 178,550 331,700 Median household income $38,700 $47,900 Participating entities 5 12 Current AB 939 staff 1.25.FTE. 0.25 FTE Total proposed AB 939 staff 5.75 FTE 0.25 FTE Aruival AB 939 budget $453,085 $50,000 a G:\WPC\95028\COM PARE.EXH 06/19/95 4:02 pm I \ i a EXHIBIT 7 PROGRAM COSTS } Exhibit 7 ' Unnecessary Program Costs - Program Proposed Authority Costs Monitoring and reporting $21,500 - $46,000 Rate structure modifications $21,500 - $46,000 Hoene composting $43,000 - $83,000 Public agencies source reduction & $10,000 - $23,000 recycling program Education and public information - $40,000 - $85,000 general programs Education and public information - $30,000 - $60,000 special programs Education and public information - $30,000 - $65,000 recycling and composting promotion events Education and public information - $60,000 - $125,000 schools program Education and public information - $65,000 - $135,000 business technical assistance Market development $7,000 - $15,000 Drop-off/buy-back $65,000 - $145,000 IRRF $1,005,000 - $2,155,000 Total Savings $1,398,000 - $2,983,000 F:\SW\95028\CORRES\PROGRAM.CST 06/19/95 4:10 pm 1