Model Studies

C&D Recycling Plans and Policies: A Model for Local Government Recycling and Waste Reduction

Overview Local governments have adopted a wide variety of A major opportunity exists for meeting the State’s policies and programs to divert C&D debris from waste diversion goals by recycling construction landfills. This model study highlights the process and demolition (C&D) debris. Mixed C&D of developing a comprehensive C&D recycling recycling facilities in the state are routinely plan and some of the policies and programs that recovering 60 to 90 percent of all the materials could be included in such plans. brought to them. Literally hundreds of reuse, In 1999, for the first time, two communities in recycling, and composting businesses are available California developed comprehensive C&D to process source-separated materials from C&D recycling plans. In May 1999, the County of Santa throughout the state. Barbara found that 14 percent of the total waste The California Integrated Waste Management deposited at the county’s landfill was C&D debris. Board (CIWMB) recognizes the importance of The City of Hawthorne, Calif., also developed and C&D recycling in meeting the State’s 50 percent adopted a community C&D plan on October 1, waste diversion goal. In November 1997, the 1999. CIWMB adopted C&D recycling as one of four major initiatives in its strategic plan to achieve the C&D practices are changing rapidly, creating requirements of the California Integrated Waste many opportunities to increase C&D diversion. Management Act of 1989 (AB 939, Sher, Chapter The best plans use a variety of tools and strategies 1095, Statutes of 1989 as amended [IWMA]). that are effective regardless of the success or failure of any one program component. C&D materials originate in the construction and demolition of buildings, roads, homes, tenant C&D processing facilities that extract recyclables improvements, landscaping, hardscaping (non- from mixed waste are beginning to emerge organic materials used in landscaping design), and throughout the state. Cities are adopting a wide site clearing activities. This waste stream includes, range of initiatives to encourage and/or require among other items: concrete, asphalt, soils, C&D recycling, including mandates that set gypsum, wood, ferrous and non-ferrous metals, minimum recycling requirements on haulers and brick, corrugated cardboard, soils, trees, shrubs, contractors. These efforts allow better tracking of and many miscellaneous and composite materials. local C&D practices. Approximately 11.6 percent of solid waste Tools and Strategies for C&D Plans disposed in California is C&D debris. This Communities can reduce C&D debris using the amounts to more than 4 million tons of waste following tools and strategies: disposed every year.  Promotion, education, and technical Community C&D Recycling Plans assistance. Community C&D recycling plans provide  Planning requirements (for example, by information on how local governments can contractors and project developers for waste encourage companies hauling C&D materials to management). reduce their disposal in landfills. They can also encourage reduction and reuse of wastes at the  Reporting requirements (results of the waste source of generation. management plans).  Diversion requirements.  Deconstruction requirements (for example, a region. Many communities are now developing allow for deconstruction before demolition). specialized C&D directories to highlight reuse, recycling, and composting businesses that can  Pre-processing requirements (processing of all assist C&D contractors and developers. The C&D debris before landfilling). CIWMB provides an excellent base, with more  Pre-approved sites (sites arranged before the than 500 such businesses listed by county on its need for managing diverted materials arises; Web site at http://www.ciwmb.ca.gov/. especially useful as part of disaster plans). In addition to producing such directories,  Economic tools (for example, deposits and communities are holding brief training sessions, franchise fees that decrease as recycling rates facility tours, and meetings with service providers increase). and contractors to build bridges between the different disciplines and industries at work.  Market development (for example, create demand through buying recycled building Regional or countywide staffs that are products for projects). knowledgeable about C&D practices and services in the area can provide invaluable technical C&D plans allow communities to determine the assistance to C&D contractors and project tools and strategies that best apply to local developers to assist them to voluntarily increase economic conditions, political realities, and reuse, recycling, and composting of materials from individual projects. These tools and strategies may the C&D waste stream. be applied to those initiating or involved in the project: city agencies and departments, In Alameda County, a good example of a franchised/non-franchised haulers, recyclers, voluntary effort was the Citation Homes project in construction contractors, demolition contractors, Union City. In 1999, Citation Homes completed builders, developers, permit applicants, and/or the first phase of the Inspirations at Foothill Glen homeowners or property owners. project, a development of 95 large single-family homes ranging in size from 1,875 to 2,300 square How a community uses a tool or strategy might feet. In partnership with its recycling depend on the type of project, such as those in the subcontractor, Citation was able to recover and following categories: municipal only, private only, recycle more than 1,000 tons of materials during projects of a particular dollar amount or size, or all the construction phase—86 percent of all waste construction and demolition activities within the generated on the project. city. Rather than paying to haul construction waste Sample ordinances, permit language, and materials, and then paying to dispose them at the additional materials are available from the C&D landfill Citation Homes contracted with Green technical assistance staff of CIWMB at Waste Recovery to collect and transport the excess www.ciwmb.ca.gov/ConDemo/. These can be wood, asphalt, concrete, gypsum, and metals from useful when considering, adopting, and the job site for recycling. Leftover wood became implementing any of these tools and strategies as mulch or fuel for co-generated power. Sheetrock part of a C&D planning process. scraps were turned into a gypsum soil amendment. Following is a summary of some of the C&D Concrete and asphalt were ground and used as program planning tools. road base. Recycling efforts provided added value to the project by keeping the construction site Promotion, Education and Technical picked up on a daily basis, which made work more Assistance efficient and safer. Most communities recognize the value and importance of promotions, education, and Planning requirements technical assistance. Throughout the state, cities Many communities are requiring contractors and and counties have developed directories of reuse, project developers to plan for how they will reuse, recycling, and composting businesses, either recycle, compost, and/or dispose of their wastes. individually or together with other communities in These requirements can be included as conditions of permits or mitigation plans in environmental within the city that are 1,000 square feet or review of projects. Often plans required are only a greater. page or two, with the applicant identifying the Hawthorne, Calif. The Hawthorne C&D types and amounts of wastes to be produced and recycling resolution requires all private how they plan to handle those materials (for construction or demolition projects over 10,000 example, identifying whether they will reuse, square feet in gross floor area to comply, as well recycle, compost, or landfill those materials, and as all city projects. where they will take those materials to accomplish that). Palo Alto, Calif. Projects over 10,000 square feet involving construction, remodeling, or demolition One of the key factors that varies by location is the must submit recycling plans and reports. threshold level (or who is required to submit plans). The threshold level may vary based on the City of Sacramento, Calif. A “Statement of number and size of average C&D projects in the Recycling Information” is required for each new community. It may also depend on the amount of commercial, office, industrial, public/quasi-public, staff available to review plans and reports that may and multifamily residential development be required. Local economic conditions will often consisting of five or more units prior to issuance determine the threshold levels that are appropriate of a building permit. A statement of recycling —a high threshold level is not appropriate if most information may also be required from each C&D is created from individual homeowners and existing business. small commercial businesses remodeling projects. The City of Sacramento statement of recycling Examples of different thresholds are highlighted information must include: below:  A diagram showing the flow of recyclable Oakland. The city requires C&D contractors for material from each portion of the development all city C&D projects to meet planning and to the recycling and trash enclosure(s), reporting requirements where project costs exceed including location of receptacle(s), frequency $150,000. of collection, who is responsible for collecting and transporting recyclable materials, and ACWMA Model Ordinance. The Alameda specific materials targeted for recycling. County Waste Management Authority (ACWMA) has prepared a model ordinance for all cities  A site plan with location and design within the county to adopt. In that model specifications of recycling and trash ordinance, ACWMA recommends that all enclosure(s) and receptacle(s) that meet city construction, demolition, and renovation projects volume and material requirements. within the city exceeding $50,000 total costs  A construction plan specifying any recycled comply with the planning and reporting material to be used in the construction of the requirements. proposed development. Applicants for projects whose total costs are less  A demolition plan to specify any proposed than $50,000 are encouraged to divert at least 50 recycling of reusable or recyclable building percent of all project-related construction and material in the demolition of any structure on demolition debris. The ACWMA model ordinance the subject site. offers two options for all city-sponsored construction, demolition, and renovation projects:  An education/public relations program to either to require them to comply “regardless of instruct users of the development about the cost” or only if the project’s “total costs are equal benefits of recycling and how to recycle. to or greater than [$50,000],” with a number to be The Sacramento requirements and similar determined at the local level. ACWMA offers an planning requirements in Palo Alto and Oakland option for the threshold to be set for all are all available on the CIWMB Web site at construction, demolition, and renovation projects www.ciwmb.ca.gov/ConDemo/. The Palo Alto and Oakland requirements—and the ACWMA The City of Cotati requires that prior to any public model ordinance—include sample short forms for or private demolition, all materials that can be the contractors to fill out. These three cities all reused or recycled shall be made available for require contractors to submit reports as well after salvage. Any entity seeking to demolish a structure the project is completed (see below). within the City of Cotati is required to make Reporting Requirements known publicly its intent to demolish the structure and the availability of potentially salvageable Communities could require reports on what materials by: happens to C&D wastes together with plans, or they could require only the reports.  Placing an advertisement in a newspaper of general circulation with the address of the site Hawthorne requires only reports of the quantities and the hours and dates that the materials will diverted and disposed upon completion of the be available for salvage, making such project in a format approved by the city, either materials available for at least 10 days. directly or through the local franchised hauler. Hawthorne did not require a plan to be submitted  Mailing or delivering a written notice to all initially by contractors because city staff time parties on file at the City of Cotati wishing to available to review such plans is limited. The receive such notice with the address of the site requirement of reports would be sufficient to and the hours and dates that the materials will inspire contractors to increase C&D recycling be available for salvage. significantly. In addition, the city may choose to take the above Palo Alto, Oakland, and the ACWMA model actions in the place of the entity wishing to provide forms for contractors to fill out. The demolish the structure. reports document the types and amounts of Pre-Processing Requirements materials generated at the construction or Communities could require that all C&D materials demolition site and how much was reused, be delivered to reuse, recycling, or composting recycled, composted, salvaged, or landfilled. facilities for pre-processing prior to landfilling. Diversion Requirements The Hawthorne C&D plan recommends that the Many communities require some level of diversion franchised hauler reuse, recycle, or compost all as part of their new C&D recycling requirements. C&D materials to the maximum extent possible. Hawthorne requires private projects to divert the No greater than 10 percent of C&D materials “maximum feasible amount of construction and collected under the exclusive franchise should be demolition materials.” Hawthorne also set a goal taken directly to a landfill by the franchised hauler of achieving a 50 percent diversion for all C&D or by an intermediary for disposal or use as materials collected by the franchised hauler for alternative daily cover in a landfill. calendar year 2000, to be revisited after that. Instead, to the fullest extent possible all C&D In Palo Alto, the city requires that contractors materials collected under the exclusive franchise recycle materials when there is a viable recycling should be processed to recover all reusable, company available. In the ACWMA model recyclable, and compostable materials. In no event ordinance, it expects contractors to divert at least should less than 90 percent of C&D materials be 50 percent of all C&D debris generated by the taken to a facility for preprocessing for reuse, project. recycling, or composting. Processing residue may Deconstruction Requirements be used as alternative daily cover (ADC) and, as a last resort, landfilled. Communities could require contractors to contact firms specializing in deconstruction before issuing Hawthorne felt comfortable in adopting this demolition permits to determine if there is enough requirement. Their research had found more than salvageable material to warrant the labor involved. 100 businesses that reuse, recycle, or compost C&D materials. The city found four different sites (within a reasonable commute distance) that could In some areas (for example, Del Norte County), receive mixed C&D debris for recycling. the contract requires recycling rates to be no more Pre-Approved Sites than 75 percent of the rates charged for similar disposal services. Local governments could arrange sites in advance for reuse, recycling, or composting of C&D In San Jose, the permit for the Zanker Road materials, or certify facilities that might be eligible Landfill written by the city local enforcement for different economic incentives (see below). agency required Zanker to offer lower rates for This approach is particularly useful for disaster source-separated materials than for mixed loads. plans. This provides waste generators with an economic incentive to keep their loads clean and more After the Northridge earthquake, the City of Los recyclable. This is one of the factors that help the Angeles arranged for sites to accept C&D debris Zanker Road Landfill achieve a 94 percent waste for recycling. The city also coordinated diversion rate for the last five years. reimbursements for staff services at those sites by the Federal Emergency Management Fees and Taxes Administration (FEMA). Field inspectors directed Local governments have established a wide variety contractors to the closest recycling site to of solid waste fees and taxes in California. Section maximize the diversion of C&D debris from the 41901 of the IWMA authorized local governments earthquake. This encouraged private operators of to establish IWMA fees to directly cover the costs the recycling sites to invest FEMA monies into of preparing, adopting, and implementing equipment that has enabled them to continue to programs in its source reduction and recycling provide excellent C&D recycling services to the element or county integrated waste management area ever since. plan. Economic Tools Many communities have established franchise fees Some communities have experimented with on exclusive or non-exclusive franchised different types of economic tools to provide price collectors. The structure of these franchise fees signals to generators, haulers, and landfill can be used to encourage haulers to maximize operators to maximize waste diversion. Some of waste diversion—including C&D debris—if the key tools used are rates, fees, and taxes; included in the franchise. deposits; and advance recycling fees. These Santa Clara has established a system where the economic tools are described below. franchised hauler pays a lower franchise fee if it Rates meets certain recycling requirements detailed by The rate structures adopted by communities for the city. In Monrovia, the franchise fee for non- franchised hauler collection services, transfer exclusive franchised haulers is reduced directly stations, and landfill gate fees could have proportional to the level of recycling achieved significant economic impact on the operations of (that is, up to 24 percent recycling, the franchise C&D contractors. If C&D hauling is under an fee is 16 percent; at 25 to 49 percent recycling, the exclusive franchise, then cities could make sure franchise fee is 12 percent; and over 50 percent that the rates charged for such services were less recycling, the franchise fee is 8 percent). than recycling services from that hauler. Business taxes or surcharges on landfills can also Two leading economists for solid waste and be powerful economic incentives for waste recycling, Skumatz Economic Research diversion. Waste haulers (including C&D Associates (SERA) and Sound Resource contractors) are more motivated to decrease their Management Group (SRMG) have both found that wastes as the costs for disposal increase. Alameda the proper structuring of rates can increase County enacted a $6 per ton landfill surcharge in reduction and recycling rates dramatically. SRMG 1990 via a public referendum to pay for aggressive reported in 1999 that proper rate structures have recycling programs throughout the county. San reduced waste by as much as 25 percentage points, Jose enacted a disposal facility tax (DFT) of $13 holding other factors constant. per ton as a major revenue generator for the city. In the structure of the DFT, San Jose exempted the project’s C&D waste has been accepted by a materials recycled by the landfill operators. This city-certified recycling facility or diverted by other exemption played another important role in means, including reuse. As part of the program, stimulating landfill operators to recover as much the city will provide to contractors a list of material as possible, rather than just burying it in certified recyclers and information on how to keep the landfill. C&D waste out of landfills. Deposits Market Development A number of communities have enacted financial Communities need to create demand for recycled- deposits as part of the implementation of C&D content building products as part of their programs. Generally they are a nominal amount to comprehensive C&D recycling programs. encourage applicants to submit their plans and to Communities could help increase the demand for report on the amount of materials recycled. these products through direct city purchases and contract requirements for publicly funded projects. The town of Atherton, Calif., has a creative Communities should document the results of these structure for the deposit. The town requires a actions and promote them widely, to encourage deposit of $50 per ton for all waste required to be other public and private organizations to follow recycled. Atherton’s ordinance No. 506 requires their lead. that 50 percent of waste from construction, remodeling, re-roofing, and demolition projects be A range of recycled-content products is available recycled and/or reused. on the market that can be included in specifications for city buildings and private At completion of the project, the contractor must developments. More than 3,000 such products are show that it has recycled at least 50 percent of the now listed in the Harris Directory, which is waste generated. If the contractor meets the 50 accessible free on the CIWMB Web site. Many percent goal, the full deposit is refunded. If less products are fully tested, meet building codes, are than 50 percent is recycled, the town keeps $50 for available locally, and are cost-competitive. each ton below the 50 percent goal that was not Starting from the ground up, they include recycled. materials such as recycled road base, rubber- In Cotati, a $200 deposit is required to be posted, modified asphalt pavement, recycled plastic site and it is refunded after proof of reuse, recycling, furnishings, carpeting, wallboard, insulation, paint, or attempts thereof. In the ACWMA model and ceiling tiles. ordinance, a deposit of the lesser of 3 percent of Communities could obtain lists of recycled- total project cost or $10,000 is required. content building products, specifications, and Acceptable forms of this deposit include the samples of products to promote their use locally. following: performance bonds, surety bonds, The goal should be for the city to be its own best money orders, letters of credit, and certificates of customer. In addition, communities should deposit. maintain current lists of publications on recycled- The City of San Jose has proposed a C&D deposit content building products available throughout the for diversion (CDDD). The city proposes to collect United States and locally. City staff could display a deposit when a building permit is issued for those materials at permit counters and in work construction, demolition, and alteration projects. sessions with developers and contractors prior to The deposit is to be paid by the project’s general awarding of permits. Such documents should also contractor or property owner based on the type and be maintained regularly in public view as a library quantity of C&D waste to be generated. The for residents and contractors alike. deposit will be set at a level sufficient to encourage generators to take their loads to C&D Recycling Plan Process certified recycling facilities. Community C&D recycling plans need to be To have their deposits returned, contractors will recognized as part of an evolving process to have to provide receipts or records showing that collect additional data and to test the recommended approaches. The process should Step 1: Identify C&D Debris Generated also evaluate the strengths and weaknesses of what Locally has been proposed and what actually gets This is one of the more difficult aspects of C&D implemented. Although a plan may be adopted at planning in most communities. C&D debris varies one moment in time, to be truly effective it needs by season and year, as construction and demolition to recommend ongoing processes and projects vary from year to year. implementation steps that will inevitably lead to Building-related C&D debris is generated from a the desired outcomes of the plan. C&D plans will wide variety of construction, renovation, and be successful if they provide strategies to harness demolition activities. Figure 1 highlights the the forces of the marketplace to maximize waste relative percentages of building-related C&D diversion. They must also document that success debris. for the local government to share with the State. In addition to building-related C&D debris, National Building-Related C&D Debris substantial amounts of C&D debris are produced Source (1996) Tons Percent from road, bridge, and land clearing activities that are managed by the same processors and landfills (000s) that manage building-related C&D debris. Residential Information may be obtained from homebuilders, Construction 6,560 11 homeowners, remodelers, commercial developers, building contractors, highway and street Renovation 31,900 55 contractors, bridge builders, pavement contractors, Demolition 19,700 34 site grading contractors, demolition contractors, roofing contractors, drywall specialists, and Subtotal 58,160 100 excavation specialists. Nonresidential C&D debris may be produced from many types of Construction 4,270 6 projects, including: Renovation 28,000 36  Site clearance (brush, soil, trees, and stumps). Demolition 45,100 58  Excavations (earth, fill, and rock).  Roadwork (concrete slabs, concrete and Subtotal 77,370 100 asphalt chunks, asphalt millings, scrap metal). Total  New construction, renovation, remodeling, or Construction 10,830 8 repair (wood, sheetrock, metals). Renovation 59,900 44  Demolition, wrecking, implosion, dismantling, and deconstruction (all of the above). Demolition 64,800 48  Disaster debris (all of the above). Total 135,530 100 Source: Characterization of Building-Related Construction The amount of C&D debris will vary based on the and Demolition Debris in the United States, U.S. EPA, June general economic conditions of the region, 1998, EPA530-R-98-010, page ES-3. weather, major disasters, special projects and local regulations. Following are some of the key steps that should be taken in the development of a C&D recycling Data Projections. Some of the best sources of plan. information to base future projections are zoning changes, community development plans, and building permits issued in a community. Building permits are the best barometers for identifying major projects that will impact a community in the coming year. Zoning and community development residential and non-residential debris plans may provide some insights into the potential approximately equaled the amount of demolition for future construction and demolition activities in debris estimated. A rough estimate of remodeling the area. debris could be obtained by using such a calculation. C&D recycling planners should contact their community development, redevelopment, and The combination of all these factors yielded a total building departments to obtain information about of 2.8 pounds per capita per day (pcd) for all C&D these anticipated changes and locate historical debris, not including roadway and bridge records. If historical records can be provided for construction/demolition or land clearing debris. the past two to three years, then some analysis can This could be used as a check on the numbers be made of that data to project what might be calculated above. expected, on average, for the next two to three Historical Analysis. A check and comparison of years. data projections are analyses of historical data in If hard data is available regarding the types and the area. Data may be obtained from existing nature of buildings that are expected to occur, then waste haulers, recyclers, landfill operators, and estimates of C&D debris expected from such regulators of those operations. Historical data activities can be calculated. In the U.S. should be compared to economic data for the Environmental Protection Agency (U.S. EPA) community to determine if the economy was landmark report “Characterization of Building- comparable during the past several years Related Construction and Demolition Debris in the compared to local economic projections for the United States,” Franklin Associates provides the future. following suggestions for such calculations: Once an estimate has been made of the amount of Residential Construction Debris. Types of C&D debris that is projected for the future, then houses, building practices, and regulations vary the plan can assess the need for additional widely. U.S. EPA used an average of 4.38 pounds collection and processing capabilities in the area. per square foot (ppsf) of floor space for their Step 2: Collection Analysis estimates. The second step is an evaluation of the collection Nonresidential Construction Debris. infrastructure. If a waste hauler collects C&D Nonresidential buildings vary even more widely debris on an exclusive basis, that hauler should than residential structures. U.S. EPA used an have much of the data needed to evaluate current average generation rate of 3.89 ppsf. operations and assess future needs. If multiple haulers collect C&D debris on an open Residential Demolition Debris. Assuming an competitive basis, a local government may need to average of 1,600 square feet for single-family contact each of the haulers to obtain the data houses and 1,000 square feet for multifamily desired, possibly on a confidential basis. houses, EPA used 61 ppsf for single-family and 115 ppsf for multifamily houses. Information should be obtained from C&D waste haulers on the equipment and services they have Nonresidential Demolition Debris. Assuming an available and the rates for those services. A survey average building size of 13,300 square feet for could be sent to haulers serving your area buildings built between 1920 and 1969, EPA used requesting the following information: 155 ppsf for nonresidential buildings.  Types of trucks available (for example, front Renovation/Remodeling Debris. EPA analyzed loaders, rolloffs). the amount of material produced by major remodeling projects and the number of those  Types of containers available (for example, 1- projects expected each year from the housing 2- and 3-cubic-yard bins and 10-, 20-, 30-, and stock. EPA found that 68 percent of renovations 40-cubic-yard debris boxes). were for improvements and 32 percent were for repairs. After extensive calculations, the total of  Rates for collection, based on size of container purpose (for example, lumber, doors, windows, and frequency. and plumbing fixtures). Conditions of rates (for example, whether there are Other businesses also are involved in salvaging or base tonnages assumed per box, and more weight reuse activities. Often these can be found by is done for a surcharge, or whether collection looking in the Yellow Pages. Deconstruction charges on a volume basis are separate from contractors usually advertise under “demolition disposal fees on a weight basis). contractors” and include references in advertisements to “hand wrecking,” “selective In addition, similar information should be obtained demolition” or “used building materials.” Some of from independent and franchised haulers serving these may also be found in reuse and recycling other cities within a 25 to 50-mile radius to guides prepared by other nearby local compare the costs of service and the structure and governments, particularly by the larger cities in the types of services available. The comparative area. analysis should provide sufficient information to gauge the full range of services needed or desired For reuse, recycling, and composting companies, in the area. questions should also include: Also, as part of the collection analysis, similar  Is there a fee for services provided? Is there a information should be obtained from reuse, payment for the sale of recycled materials? recycling, and composting businesses in the area.  Is there a minimum quantity of materials to be There are many types of businesses that reuse, collected? recycle, or compost source-separated or mixed C&D debris. Are there specifications for the amount of contamination allowed? What happens if there is Recyclers generally fall into the following more contamination? categories: A review of the types of mixed C&D recycling  General businesses available within a reasonable distance  Asphalt of your community is also important. This could determine which of the tools and strategies you  Concrete choose to ensure the maximum waste diversion  Brick from C&D wastes.  Appliances In addition to talking to service providers, it is helpful to contact a representative sample of  Flooring different types of C&D waste generators—  Wood including major businesses—contractors,  Drywall/Sheetrock developers, and public agencies involved in construction and demolition activities.  Metal A review of city contracts, ordinances, and permits  Paint related to C&D collection and processing activities  Plastic is also important to understanding the existing collection system.  Other Step 3: Evaluation of Tools and Strategies A statewide listing of C&D recyclers, processors, Once you obtain background information for your and receivers is included on the CIWMB Web site area, you should evaluate the tools and strategies at www.ciwmb.ca.gov/ConDemo/Recyclers/. In noted above. The full range of options noted above addition, in a few communities, there are other should be presented to key stakeholders and businesses that specialize in deconstructing decision-makers for their review and comments on buildings, taking them apart by hand to preserve the best approaches to implement in your area. materials to be used again for their original You may want to obtain more detailed background information from one or more of the sources Regardless of how the plan is adopted, many of referenced above, either by downloading the requirements of the plan will require one or information from the CIWMB Web site or by more ordinances to implement. Once adopted, contacting other communities directly to obtain local staff should inform all those who are affected their firsthand comments on what worked best for about the new program and offer training materials them. and presentations to ensure a good understanding of all facets of the program. The analysis of the most appropriate options is primarily based on your availability of staff resources, an understanding of local economic Case Study: Hawthorne C&D Waste conditions, and an assessment of local political Minimization Plan realities. The more involved the requirements, the The C&D waste minimization plan for the City of more staff time necessary to review, monitor, and Hawthorne was part of the city’s response to enforce those requirements. complying with the 50 percent waste diversion goals of the IWMA. Establishing the “threshold level” for your community depends on local economic conditions Project Approach and how much C&D material is created by The City of Hawthorne recognized that this plan different types of projects. High thresholds are needed to build on decisions that had been made appropriate if most of the C&D work anticipated is (for example, the structure of the existing from commercial, institutional, and industrial franchise and city ordinances) and existing projects. A lower threshold—but simpler—process operations in the area. Also, there were limitations is more appropriate if the majority of C&D debris on the amount of construction and demolition data anticipated will be from individual homeowners that could be obtained in the time allotted. This and small commercial business remodeling was particularly true because of the lack of projects. quantitative reporting on local disposal and recycling activities in the past. Finally, you may find it easiest to establish requirements on city projects only. Or you may The city’s consultants first obtained as much find that stakeholders and decision-makers don’t information as possible from the city and the city’s mind these extra requirements being imposed on franchised hauler, H&C Disposal. The city also them, if they understand the need for them and sought the perspective of other businesses in the know that they will be implemented fairly and city, including waste haulers, recyclers, with the minimum of red tape. contractors, waste generators, and developers. The city’s consultants contacted city departments to Step 4: Recommendations, Budget, and identify some businesses that may be impacted by Timeline the new franchise. The consultants made a Once you have identified which of the tools and presentation at the local Kiwanis club to solicit strategies will work best for your community, they additional input. The city prepared a flyer about should be drafted in a coherent, clear plan for the franchise requirements for distribution by city adoption by local decision-makers. The building and planning departments and sought recommended plan should be presented with a input from many other contacts in the area. budget and timeline for implementation. The budget should provide sufficient resources for The City of Hawthorne updated the Los Angeles education and training of involved city staff and C&D recycling directory for use by H&C and city all the stakeholders who were involved in the contractors and worked to evaluate any particular planning process. The timeline should outline constraints about operating within the City of particularly what will happen in the first year, Hawthorne, given the city ordinance and exclusive because during that time many details may need to franchise. The city also contacted many other be addressed for a smooth implementation. cities in the Los Angeles region to update information on their policies, practices, and rates The city council, board of supervisors, or the city and fees. Based on other successful programs, the manager/county executive could adopt the plan. city confirmed the best practices for C&D they exclusively collect, and to report to the city recycling, reporting, and monitoring. the amounts of C&D materials recycled and disposed. The city also reviewed city documents related to the terms of the city’s solid waste franchise and H&C had been the franchised hauler for contract agreement. Municipal code language residential and commercial wastes in Hawthorne related to solid waste and recycling activities for more than 40 years. On May 24, 1999, the City permitted in the city was also reviewed, as well as of Hawthorne approved an amendment to the current reporting practices and requirements for agreement for refuse collection services between H&C and other haulers and recyclers. the city and H&C to provide H&C an exclusive right to collect, transport, and dispose of the The terms of the franchise agreement with H&C following materials in Hawthorne: and the municipal code limit the city’s ability to require H&C to provide information on existing  Construction and demolition debris. solid waste costs, tonnages landfilled, and  Discarded appliances and furniture and other tonnages and types of material recycled. However, similar goods. H&C cooperated by providing information about their operations and by meeting with the city. Not included in this exclusive authority are the following exceptions: The City of Hawthorne tried to identify the amount of C&D activity in Hawthorne over the  C&D debris hauled by contractors in their own past year. Unfortunately, there was insufficient or leased vehicles from their own job sites data available in Hawthorne to properly determine when the hauling is an incidental rather than a how much material was collected, diverted, and primary part of the contractor’s services. disposed of over the past several years.  Carpeting, furniture, appliances, white goods, After local research was completed, the city or similar goods hauled by persons or entities evaluated C&D programs based on their delivering new goods, when the hauling is an practicality, cost effectiveness, and potential incidental part of the delivery of new goods. diversion impacts. The City of Hawthorne was  Scrap lumber incidentally included in yard particularly concerned with the cost impacts of waste hauled by gardeners or landscapers, recommendations, both short-term and long-term. when the hauling is an incidental part of the The city also wanted to protect itself against likely gardening or landscaping services. major cost increases from projected disposal cost increases.  Recyclable materials sold or donated to someone other than H&C Disposal, if the Since the primary impetus for the development of materials have been separated at the source the C&D plan was compliance with the 50 percent and the hauler was not paid by the waste diversion mandate, there was an overriding need to generator for collecting, processing, or maximize waste diversion and meet State transporting those materials, or a consulting reporting requirements. By building a sustainable fee for recycling services. infrastructure for policies, programs, and reporting on C&D debris recycling, the city was able to  Appliances and white goods hauled by utility understand and control future costs. Throughout companies as part of a rebate or buyback the plan, the City of Hawthorne adopted program. incremental steps to be taken to accomplish  C&D debris generated by any public project of individual tasks to reach the desired objectives. the City of Hawthorne. H&C Disposal Exclusive Franchise for C&D  Materials excepted by the city manager due to The city chose to award an exclusive right to special circumstances. collect and dispose of C&D debris to its franchised hauler, H&C Disposal. The city directed H&C to implement recycling programs for C&D debris H&C agreed to pay the city a 10 percent billing  Required all city departments and H&C fee and a 15 percent franchise fee for all C&D Disposal to implement a construction and wastes collected. demolition debris recycling program. The city council determined in its adoption of the  Required the city manager to complete and exclusive franchise for C&D debris for H&C begin to implement a comprehensive C&D disposal, that: waste minimization plan by October 1, 1999, that details activities by city departments, “CONTRACTOR represents and warrants to H&C Disposal, and all private sector C&D City that it has the experience and qualifications to projects in Hawthorne to increase the reuse, conduct recycling programs for the recovery of recycling, and composting of C&D materials. recyclables from construction and demolition debris, discarded appliances, discarded furniture  Required the chief of general services and and other similar goods, to provide City with public works to include a specification for information sufficient to meet the City’s reporting construction and demolition waste requirements under AB939 [the IWMA], to management in contract documents for all arrange to collect, transport and recycle or dispose public works construction, including: of these materials in a safe manner which will ○Guidelines and requirements for reuse, minimize the adverse effects of collection vehicles recycling, and/or composting of C&D on air quality and traffic.” materials from city construction and Based on these determinations, the C&D plan demolition projects. noted that it was incumbent upon H&C to detail its ○Submittal of a C&D waste management plan plans to provide C&D recycling services to the and quantitative reports for C&D materials satisfaction of the city in a comprehensive C&D generated by all contractors for City of operations plan (see below). Hawthorne construction and demolition City C&D Recycling Resolution: projects as a condition of approval of Requirements for C&D Recycling progress payments to be paid by the city. Reporting  Required all private construction or demolition The IWMA requires the City of Hawthorne to projects over 10,000 square feet in gross floor develop a diversion requirement and reporting area to divert the maximum feasible amount of system to document the amount of construction construction and demolition materials. and demolition waste diverted from landfills, along with the total amount disposed. The  Required all private developers, construction reporting systems outlined for C&D waste are and demolition contractors, waste haulers, and critically important for the city to more accurately others handling these materials to report the project the need for C&D services in the future. quantities diverted and disposed to the city The report data also serves as a guide to set rates upon completion of the project in a format that are fair to both ratepayers and the franchised approved by the city, either directly or through hauler and to provide incentives for recycling H&C Disposal. services. These can be evaluated on an ongoing  Established detailed measures for monitoring basis by city staff. and enforcing the reporting requirement on City staff recommended a council resolution that private construction, demolition, or land established a policy to require the reuse, recycling, clearing projects over 10,000 square feet in and/or composting of C&D waste and the gross floor area by: documentation of C&D waste recycling by all the ○Requiring submittal of quantitative reports key participants in Hawthorne. for C&D materials generated as a condition The resolution adopted by the city council on of issuance of building or demolition September 13, 1999: permits. ○Requiring a $250 deposit with building service options, technical assistance to permit fees from private contractors when contractors, and H&C subcontracting or joint they obtain building or demolition permits. venturing with recyclers. The deposit is to be returned at project 4. City staff is already implementing many completion if contractors demonstrate that recycling practices through their day-to-day they have supplied the C&D reports. functions, including imposing recycling and ○Requiring that satisfactorily completed C&D recycled-content requirements in contracts. reports are received by the city before However, these practices are not widely issuance of a certificate of occupancy for recognized. A more formal monitoring system new construction projects. and better reporting would help to document these activities.  Required H&C to submit quarterly reports to the city on the amount of C&D materials 5. City staff is in a position to help educate collected by material type, the destination to contractors about service options through the which each of those materials were taken, and distribution of literature at their service desks. the amount of diversion documented to have The staff can also collect data by requiring been achieved at each of those facilities. reporting with permit and EIR requirements Principal Findings of C&D Plan and by implementing clear enforcement of these requirements (for example, withholding The C&D plan was adopted by the city manager signoff or deposits). on October 1, 1999, as directed by the city council. The City of Hawthorne found that there were 6. H&C appears open to many different many opportunities to increase C&D diversion in strategies that would allow them to use Hawthorne. Key findings included: recycling facilities that are competitive in price with their current transfer station tip 1. Construction and demolition contractors in fees. Nearly all C&D rolloff materials are Hawthorne are already recycling some C&D delivered at transfer stations at this time. materials, particularly inert material and metal, but those activities have not been well 7. In addition to H&C, approximately 100 documented. Similarly, salvaging of reusable independent companies are currently able to material and selected recyclables is also taking provide reuse, recycling, and composting place, although harder to quantify. A services in Hawthorne for any materials considerable amount of inert material is donated or sold by waste generators. The crushed and processed on site for use in the materials must be kept separate for reuse, construction process, and this activity has also recycling, or composting. not been documented. Reporting requirements 8. The city prepared a construction and can capture this information. demolition debris recycling directory that 2. Many contractors already meet the definition provides detailed information on all those of “self-haul” and will continue to haul their companies, including contact information, own material. Reporting requirements for all types of materials accepted/processed, public and private projects can capture this specifications that need to be met for materials information. accepted, services offered, and end-products made. The Hawthorne directory is adapted 3. A large amount of recyclables from C&D from a directory developed over many years debris in Hawthorne is still going to disposal by the City of Los Angeles, modified for facilities. The city believes that contractors Hawthorne policies and programs. and haulers in Hawthorne can still recycle far more C&D material with minimal impacts on 9. Of particular note are the service providers costs or operating efficiencies. These could be that can accept loads of mixed C&D materials. stimulated through price incentives, city While these service providers may vary in policies and requirements, additional hauling their recycling processes, capacity, diversion rates, specifications, reporting, and collection companies showed a very broad range of services, they offer a starting point to help prices for disposal and recycling services. H&C supplement source separation practices There was considerable concern about costs and achieve high rates of diversion at prices increasing and less recycling occurring as a competitive with current transfer station fees. result of the additional city franchise and billing fees required as part of the C&D 10. Mixed C&D processing capacity in the region franchise. C&D practices vary, with some is expected to continue to increase contractors using H&C and others self- substantially in the coming 12 to 24 months. hauling. Many use other hauling and recycling At least one new facility will open before the companies, and some contractors and end of 1999. The State is currently in the final businesses using the services of small stages of adopting regulations that will companies that combine clean-out services monitor and oversee these new types of with recycling and hauling. recycling facilities. Currently, processors of mixed C&D materials are: C&D Plan Recommendations  American Waste Industries, Los H&C Disposal Angeles. The C&D plan recommended that H&C detail its  Bradley Landfill and Recycling plans to the satisfaction of the city to provide the Center, Sun Valley, Calif. services that are reasonably anticipated to be required to fulfill their exclusive franchise for  Community Recycling and Resource C&D. To this end, the city required H&C to: Recovery Transfer Station, Sun Valley, Calif. 1. Submit a C&D operations plan to the city.  Looney Bins, Sun Valley, Calif. 2. Report monthly to the city a summary of how many tons of material overall is being diverted Mixed C&D processors provide a particularly through the C&D program. H&C should important service as a clear alternative to report to the city monthly for the first year and disposing of C&D debris in landfills, even if quarterly thereafter, in a format approved by the C&D debris is mixed together. the city, on the amount of materials collected, 11. Rates to recycle C&D materials are now disposed, and diverted, the facilities to which competitive with local transfer station rates. those materials were taken, and types of Although there may be a small incremental materials which were recycled. cost in some cases to recycle mixed C&D at 3. H&C must make available for review backup reuse, recycling, or composting facilities by data at H&C that can be inspected by a city or H&C when compared to landfilling, that is CIWMB representative in order to verify the offset by the need to comply with State data included in the H&C monthly and recycling mandates. quarterly reports. The backup data was 12. Clear cost savings opportunities (for example, recommended to be consolidated in a form recycling concrete and scrap metal) combined that is designated by the city and that allows with incremental cost increases for mixed the city representatives to easily verify, on a C&D disposal should provide an aggregate monthly basis, the aggregate data in the H&C cost savings to H&C. With the risk of $10,000 reports to the city. per day fines under the IWMA considered by 4. Develop, print, and distribute promotional the city, it is also clearly in the city’s interest flyers in the city at all points of public contact, to maximize the amount of materials diverted and pay for advertisements in the local from C&D. Recommendations were made in newspaper regarding the types of C&D this C&D plan on how to accomplish that. recycling services that H&C offers. 13. Interviews with contractors, Hawthorne businesses, hauling companies, and recycling 5. Reuse, recycle, or compost all C&D materials an additional incentive to recycle those to the maximum extent possible. No greater materials. than 10 percent of C&D materials collected The C&D plan further recommended that the city under the exclusive franchise should be taken should conduct an annual survey of C&D rates in directly to a landfill by H&C, or by an the region for independent and franchised haulers intermediary, for disposal or use as alternative for all the major categories of services charged by daily cover in a landfill. Instead, to the fullest H&C. The City should not allow H&C to charge extent possible, all C&D materials collected C&D collection rates above the average found in under the exclusive franchise should be that survey for non-franchised independent haulers processed to recover all reusable, recyclable and recyclers. The city could make an exception if and compostable materials. In no event should additional financial justification provided by H&C less than 90 percent of C&D materials be warrants. taken to a facility for preprocessing for reuse, recycling, or composting. Processing residue Diversion of C&D from City Activities may be used as ADC, and as a last resort, 1. Separation and Consolidation of Materials landfilled. at Public Works Yard. The public works yard can be used for placement of bins for 6. Set a goal of achieving a 50 percent diversion source-separated material generated by city for all C&D materials for calendar year 2000. employees and some city contract activities After the first six months begin reviewing (for example, street sweepings, green waste, data. By the end of calendar year 2000, set concrete, asphalt) to be consolidated for goals for calendar year 2001 and beyond based subsequent removal and delivery to recycling on the first year’s experience and data on facilities. diversion rates, cost markets, and operational issues. 2. Continue and Expand Recycling Requirements in Public Works Contracts. 7. H&C should require all reuse, recycling, and Add formal reporting requirements so that the composting facilities they use to provide H&C city can quantify diversion. As highlighted in with weight tickets. The facilities should the C&D resolution, include a recycling maintain auditable records (weight tickets) of specification in city public works contract all C&D materials received and recycled from documents that require contractors to reuse, H&C and provide H&C with overall facility recycle, and/or compost C&D materials. The diversion reports quarterly. H&C should also contract should also require reports on the require all transfer and disposal facilities they amount diverted as a condition of approval of use for C&D materials to maintain weight contractor progress payments. slips documenting disposal and recycling. 3. Reporting As a Condition of Building 8. Pay the city franchise and billing fees only for Permits. Private contractors of projects over C&D materials collected under their exclusive 10,000 square feet should report the quantities franchise that are landfilled (from residue at of construction and demolition materials reuse, recycling, or composting facilities). diverted and disposed under the work of the Any C&D materials H&C collects on a project. Reporting would be a condition of source-separated basis for recycling without a obtaining a building or demolition permit and fee for service that are not considered part of a $250 deposit would be required with the the exclusive franchise should be exempt from permit fees (refundable when the contractor charges and payments of such city franchise submits C&D reports). C&D reports would be and billing fees. Any C&D materials that required to have been submitted before a H&C collects for recycling with a fee for project could obtain a certificate of occupancy service should be exempt from charges and from the city. payments required by the city billing fees as 4. EIR Requirements. Expansion of existing mitigation measures in environmental impact reports for major developments should variety of education, training, and technical consider including clear, quantifiable assistance tools be used to communicate the goals requirements for diversion of a broad range of of the plan. It also highlights ways everyone can materials with set diversion goals. These benefit by more carefully exploring their reuse, should be in addition to the reporting recycling, and composting options. Tools include, requirements in the C&D resolution. A waste but are not be limited to, the following: management and recycling plan that includes 1. The city can issue news releases and notices to detailed goals for maximizing diversion of the public and C&D contractors and C&D debris should be required for major developers to highlight the adoption of the projects. The planning and redevelopment C&D plan and C&D resolution. department should ensure the measurement and enforcement of such recycling plans. The 2. The city manager can issue a memorandum city should develop a written policy for the and guidelines to city staff outlining oversight of this solid waste mitigation recommendations of the C&D plan and measure. requirements of the C&D resolution. 5. Recycled-Content Building Products. The 3. Building/safety and planning and community city should create demand for recycled-content development departments can provide C&D materials through direct city purchases and recycling information and brochures about the contract requirements and document the city’s policies and programs and other results of these actions. A range of recycled- resources to C&D contractors and project content products is available on the market planners. This information will assist them in that can be included in specifications for city finding reuse, recycling, and composting buildings and private developments. There are businesses. City staff can include the City of many products that are fully tested, that meet Hawthorne Construction and Demolition building codes, that are available locally, and Debris Recycling Directory, a bibliography of that are cost-competitive. Starting from the resources, C&D recycled product guides, ground up, they include materials such as product samples, the State Green Building recycled road base, rubber-modified asphalt Guide (and similar documents), and model pavement, recycled plastic site furnishings, specifications at all city public counters and carpeting, wallboard, insulation, paint, and the library. ceiling tiles. 4. The city can organize internal training for The City of Hawthorne obtained a list of materials, code enforcement inspectors about the C&D specifications, and samples of products that can be plan and resolution and about how to help included in local projects so the city can be its own contractors handle materials correctly. best customer. In addition, the city obtained a list 5. City inspectors and public information counter of publications on recycled-content construction staff could attend quarterly training seminars products available throughout the United States regarding C&D during the first year to get and locally; private developers and contractors can them up to speed with what other communities obtain that. City staff makes those publications and haulers are doing and to connect with the available for public review at the counters in the network of public officials who are working planning and community development and on similar issues. building and safety departments. Budget and Timeline C&D Education, Training, and The city budgeted a total of $50,290 for Technical Assistance administration and program development for As with any recycling program, key to the C&D, tires, and wood waste programs. The city program’s success is the understanding and estimated that the costs that will be required to cooperation of all involved in generating the implement the recommendations of the C&D plan wastes. The C&D plan recommended that a wide will fall within that budgeted amount. A timeline with key milestones to implement the C&D plan Contacts was attached. Office of Local Assistance, CIWMB. (916) 341- 6199. References CIWMB Publications National Association of Home Builders (NAHB). (301) 249-4000, www.nahbrc.com/builders/green. Many CIWMB publications are available on the Board’s Web site at: www.ciwmb.ca.gov/ Bill Turley, Construction Materials Recycling Publications/. Journal. (630) 548-4510, [email protected]. To order hard copy publications, call 1-800-CA- Julie Rhodes, Reuse Development Organization. Waste (California only) or (916) 341-6306, or (317) 631-5395, [email protected], www.redo.org. write: Christine McCoy, National Recycling Coalition, California Integrated Waste Management Board 1727 King Street, Suite 105, Alexandria, VA Public Affairs Office, 22314-2720. [email protected], Publications Clearinghouse (MS-6) www.nrc-recycle.org. 1001 I Street J. Taylor, San Diego County, Local Enforcement P.O. Box 4025 (mailing address) Agency, 9335 Hazard Way, San Diego, CA Sacramento, CA 95812-4025 92129. (858) 694-3377. The CIWMB has published a series of fact sheets, Rick Anthony, Urban Conservation Corps, (re: case studies, and resource lists on construction and San Diego MRO), P.O. Box 84060, San Diego, demolition recycling. Publications of particular CA 92138. (619) 523-2828, Ext. 302, interest are: [email protected]. Construction and Demolition Recyclers— Laura Wright, City of Pittsburg, Waste Reduction Processors and Receivers Office, Public Services Department, 65 Civic (Publication #431-96-017). Avenue, Pittsburg, CA 94565. (925) 252-4114. Construction and Demolition Recycling Program Ken Wells, Director, Sonoma County Waste (Publication #431-97-030). Management Agency, 575 Administration Drive, Integrated Waste Management Disaster Plan Room 117A, Santa Rosa, CA 95403. (707) 565- (Publication #310-97-006). 3579, [email protected]. Military Base Closure Handbook: A Guide to John Zinner, Zinner Consultants (re: Playa Vista Construction and Demolition Materials Recovery Project), 824 Harvard Street, Santa Monica, CA (Publication #433-96-074). 90403. (310) 828-6051, [email protected]. Designing With Vision: A Technical Manual for Kelly Ingalls, KMI & Associates, (re: Playa Vista Material Choices in Sustainable Construction Project), 2418 Bywood Drive, Glendale, CA (Publication #431-99-009). 91206-4703. (818) 548-8996, [email protected]. Recycled-Content Building Construction Products (Publication #431-96-018). Sheila Davis, Materials for the Future Foundation Other Publications (re: Electronics Recycling), P.O. Box 29091 San Francisco, CA 94129-0091. (415) 561-6528, Residential Construction Waste Management: A [email protected]. Builder’s Field Guide, NAHB at www.nahbrc.com/builders/green/WASTEPUB. Ed Cooney, Town of Atherton, 91 Ashfield Road, Atherton, CA 94027. (650) 752-0525 or (650) Constraints and Opportunities: Expanding 375-7403, [email protected]. Recovery in the Demolition Industry, Community Environmental Council. (805) 963-0583, Stephen Bantillo, San Jose Solid Waste Program, [email protected]. 777 North First Street, San Jose, CA, 95111. (408) 277-5533, [email protected], Karen Swarbrick, Community Environmental www.sjrecycles.org. Council, Santa Barbara, Calif. (805) 963-0583, Ext. 155, [email protected]. Debra Kaufman, City of Berkeley, 1201 Second Street, Berkeley, CA 94710. (510) 644-6276, Ext. Stephen MacIntosh, Santa Barbara County, Calif., 224, [email protected]. Department of Public Works, Solid Waste & Utilities Division. (805) 882-3609, Kay Martin, Strategic Recycling, Darkhorse Press, [email protected]. 1996. (805) 654-2472, [email protected]. Wendy Sommer, Alameda County Waste Management Authority & Recycling Board, San Gary Liss and Associates, 4395 Gold Trail Way, Leandro, Calif. (510) 614-1699, Loomis, CA 95650. (916) 652-7850, [email protected]. [email protected]. John Moore, Law Offices of Stone and Moore, 4 Credits and Disclaimer Embarcadero Center, Suite 510, San Francisco, Gary Liss & Associates prepared this study CA 94111. (415) 956-3400, pursuant to contract IWM-C8028 ($198,633, [email protected] included other services) with the University of Joan Edwards, J. Edwards & Associates, 10840 California at Santa Cruz for a series of 24 studies Charnock Road, Los Angeles, CA 90034. (310) and summaries. 253-9790, [email protected]. The Board would like to acknowledge the following individuals who helped prepare this document: Stephen Bantillo, City of San Jose The statements and conclusions in this summary are those of the contractor and not necessarily Joan Edwards, J. Edwards & Associates those of the California Integrated Waste Kelly Ingalls, KMI Associates Management Board, its employees, or the State of Stephen MacIntosh, County of Santa Barbara California. In addition, the data in this report was provided by local sources but not independently Karin Swarbrick, Community Environmental verified. The State and its contractors make no Council warranty, express or implied, and assume no Wendy Sommer, Alameda County Waste liability for the information contained in this text. Management Authority & Recycling Board Any mention of commercial products, companies, or processes shall not be construed as an Relly Briones and Steve Austrheim-Smith, endorsement of such products or processes. CIWMB

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