Comments on StopWaste Guiding Principles and Recycling Plan

By David Krueger, NCRA President, 11/23/30

Thank you and StopWaste for the opportunity to provide input as you update your Guiding Principles and Recycling Plan. In general, your draft Principles and Plan align with NCRA’s mission to End Waste, our vision of a sustainable circular economy, and our goal to stop landfilling and incineration. NCRA appreciates the work that StopWaste has done in the past, and our primary comment for StopWaste is to “stay the course” and continue to implement and build upon your existing successful programs. Bringing about systemic change and transforming social norms is a slow, long-term process that requires consistent and repeated messaging and action.

Guiding Principles

NCRA is in alignment with StopWaste’s current (2018) guiding principles and the considerations for updating them that StopWaste presented at the October 15, 2020 NCRA Board Meeting: Systemic Change, Social and Racial Equity, Collaborative Partnerships, Regenerative Economy, Social Norms, Health Indicators. We strongly support your inclusion of Social and Racial Equity as a consideration. We encourage StopWaste to adopt guiding principles that look beyond a narrow “landfill diversion at any cost” framework and take into account the broader impacts of diversion efforts on communities, workers, health, climate change, and the protection of soil, water, and air quality.

Landfill Obsolescence

NCRA strongly supports StopWaste adopting a goal of landfill obsolescence by 2045. This is in complete alignment with NCRA’s mission and vision. It is a very clear and understandable goal. As noted above, this goal must be achieved in accordance with guiding principles that ensure that our efforts to achieve landfill obsolescence do not inadvertently negatively affect our communities, workers, climate, air, water, or soil.

We also recognize that this is a very audacious goal given that the previous goal of 75% diversion was not achieved. StopWaste needs to be prepared to answer questions from the public about how landfill obsolescence is achievable when 75% diversion was not. Other questions that StopWaste needs to address are: How much will it cost to achieve this goal, and how will StopWaste monitor progress towards this goal? NCRA would add that obsolete landfills can be “recycled” into locations for buy-back centers, re-use stores, resource recovery parks, composting facilities, recycling facilities, recycled content manufacturers, etc.

Stay the Course: Continue to Support Collection, Processing, and Public Education

NCRA is concerned that StopWaste may be planning to shift limited resources to new, desirable programs while prematurely discontinuing necessary existing programs that have not yet achieved their goals or full potential. One example is that StopWaste discontinued the program which provided no-cost indoor containers to businesses. That program was effective at encouraging businesses to source separate and will be even more needed as SB 1383 is implemented.

StopWaste’s draft Recycling Plan states, “both the data and the experiences of Alameda County jurisdictions and service providers suggest that the county is reaching the limits of an approach that relies on post-consumption collection and processing.” NCRA respectfully disagrees. While we wholeheartedly support waste prevention and “upstream solutions” and agree that they are preferable to “downstream” solutions, there is still much work to be done to optimize collection and processing.   Contamination of collected recyclables is still at 25% – 35%.   An estimated 50% of Alameda County residents don’t recycle their food scraps. Source separation is neither universally available nor understood. The public still doesn’t know how to sort properly. Significant public education, technical assistance, and enforcement efforts are still needed to ensure correct source separation and to bring about the needed change in social norms. StopWaste has successfully led these efforts in the past, and should continue to do so. Both “upstream” and “downstream” programs will be required to achieve landfill obsolescence, and StopWaste should not abandon the existing “downstream” solutions as it works to implement new “upstream” ones.

Promoting Reusables / Banning Disposables

One “upstream” solution that NCRA recommends StopWaste include in their Recycling Plan is promoting reusable foodware / banning disposable foodware. NCRA supports StopWaste creating a countywide ordinance which features funding for reusable foodware and support for enforcement. Similar to how StopWaste has successfully implemented and enforced other countywide ordinances and bans. While NCRA applauds the creativity and leadership of the individual jurisdictions who have implemented innovative, groundbreaking local resuable foodware ordinances, a unified countywide approach will be easier for the public and food vendors to understand and for hesitant jurisdictions to adopt.

SB 1383 Compliance

SB 1383 is the greatest challenge facing Alameda County jurisdictions since AB 939. StopWaste should continue and expand its efforts to support Member Agencies in achieving SB 1383 compliance. SB 1383 compliance should be a significant part of any Recycling Plan for 2021 and beyond. StopWaste has greater financial resources and staffing than most Member Agencies and is in a unique position to lead SB 1383 compliance efforts in the County. Many of the requirements of SB 1383 are most efficiently and effectively implemented on a countywide level. Examples of how StopWaste could lead SB 1383 compliance efforts include:

  • Inspection and Enforcement.
    StopWaste should expand its MRO inspection and enforcement activities to cover all related SB 1383 requirements.
  • Edible Food Recovery.
    Identifying edible food generators and food rescue organizations, connecting them to one another, and educating generators are all best done on a countywide basis. Food rescue organizations do not recognize jurisdictional boundaries.
  • Procurement
    StopWaste should coordinate the procurement of compost, mulch, renewable gas, biomass-derived electricity, and recycled content paper products by Member Agencies. StopWaste could consider organizing a purchasing co-op for some or all of these products.
  • Public Education.
    StopWaste should continue and expand its public education and technical assistance programs in support of SB 1383.
  • Regional Composting Capacity
    StopWaste should continue efforts to ensure sufficient composting/anaerobic digestion capacity for organics recovered in the County.

If there is insufficient funding for such efforts, StopWaste could consider asking Member Agencies if they would be willing to forgo a portion of their Measure D funding so that StopWaste could more cost-effectively implement these SB 1383 requirements on their behalf.

Thank you for soliciting and considering our comments. Please contact me if you would like to discuss them further.

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Help StopWaste Set Priorities


By NCRA Member Justin Lehrer, Operations Manager, StopWaste, 10/21/20
Every other year, StopWaste engages in priority setting to inform the Agency’s budget development, resource allocation, external fund-seeking efforts, and program selection and design for a two-year period. The agency is now engaged in the 2020 priority setting process, and will discuss a new draft set of two-year priorities at the November 2020 joint Waste Management Authority (WMA), Recycling Board, and Energy Council (EC) meeting.

A two-year priority setting process enables the Agency to be responsive to new challenges and opportunities. This ability to be nimble and adaptive has perhaps never been more important than now. The impacts of the COVID-19 pandemic on our communities and our work, the increasing urgency of the climate crisis, persistent social and racial disparities, new State-level requirements such as SB 1383, and the growing knowledge that we must take our work to the next level in order to achieve ambitious waste reduction and clean energy goals all point to the need for an updated set of priorities for the Agency. Updated priorities will guide the work of the Agency over the next two fiscal years, through June 2023.

StopWaste’s current priorities, presented as a set of guiding principles, have informed the Agency’s work in many important and tangible ways, including, such as:

      • FOOD WASTE PREVENTION: Increasingly high priority given to food waste prevention through projects such as the Stop Food Waste campaign, schools outreach, and assistance and tools developed to promote and enable edible food recovery and donation.
      • ORGANICS OUT OF LANDFILL: Ongoing efforts to divert organic materials from the landfill, such as through implementation of the Mandatory Recycling Ordinance.
      • CARBON FARMING: Coordination with member agencies to conduct training on compost application and to incorporate innovative carbon farming practices into city climate action plans.
      • SB 1383 IMPLEMENTATION INFRASTRUCTURE: Convening member agency staff to coordinate SB 1383 implementation efforts.
      • REUSEABLE FOOD WARE: Shift in focus from exploring mandatory food service ware policy to development of upstream pilot projects that build reusable food ware infrastructure.

At the October 15 NCRA Board meeting, StopWaste staff shared a set of considerations that are top of mind and serving as a framework for updating Agency priorities. These ideas have evolved, with input from staff and stakeholders, into the following aims:

      • SYSTEMIC CHANGE: Support member agencies and partners to make strategic policy and program interventions that create systemic change at scale
      • SOCIAL AND RACIAL EQUITY: Hold social and racial equity at the center of our work
      • COLLABORATIVE PARTNERSHIPS: Cultivate collaborative partnerships across issues and design programs that foster overall community and environmental well-being
      • REGENERATIVE ECONOMY: Focus resources on strategic interventions where we can support the shift towards a regenerative economy
      • SOCIAL NORMS: Change the social norms driving inefficient resource use and overconsumption
      • HEALTH INDICATORS: Evaluate success based on overall system health indicators

One important goal of the process is for the resulting priorities to reflect the full scope of the Agency’s work, including materials management efforts and the work of the Energy Council to advance clean energy solutions in Alameda County communities (previously the WMA/Recycling Board and EC have conducted separate priority setting processes).

Recycling Plan Update

The guiding principles adopted by the WMA Board are developed through a joint process with the Recycling Board. Measure D, the county charter amendment that established the Recycling Board, mandates that the Recycling Board implement a comprehensive source reduction and recycling program. This is further outlined in the Recycling Plan, which extends through 2020 and is currently being updated. While creating and updating this Plan is the legal obligation of the Recycling Board as a distinct entity, it is designed to be complementary to and consistent with the WMA’s goals, objectives and strategies and therefore it informs Agency priority-setting. The draft Recycling Plan can be found here and input may be given directly to staff by November 13, 2020, or at the December 12 Recycling Board meeting.

Between now and December, staff are facilitating a series of presentations and discussions with the WMA Board and its committees, Recycling Board, Energy Council, member agency staff, and other partners to gather input on the priorities that will guide Agency efforts for the next two years. Staff will request that the WMA Board and Energy Council consider adoption of a new set of two-year priorities at the December 16 Waste Management Authority/Energy Council meeting. NCRA members are invited to follow this process by sharing their input during the public comment period at any upcoming public Board meetings – schedules and agendas are posted online,  or via email to Justin Lehrer.

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Second Zero Waste Food Forum Fed Interest In Edible Food Waste Recovery

By Food Waste Reduction Subcommittee Members, Susan Miller Davis, Infinite Table and Susan Blachman, Blachman Consulting

Over 100 public sector, nonprofit and private sector professionals turned out for a program focused on successful statewide and regional policies and programs in food waste prevention and reduction and edible food re-purposing and recovery. The working forum provided opportunities throughout the day for attendees to break into smaller groups and delve more deeply into these subjects with presenters and colleagues.

NCRA hosted this second Zero Food Waste Forum on World Food Day – October 16, 2018, in Berkeley, in conjunction with the Solid Waste Association of North America (SWANA) Gold Rush Chapter and with support from the UC Berkeley Basic Needs Committee, Food, Equity, Entrepreneurship and Development (FEED), and the Ugly Fruit & Veg Campaign.

The purpose of the Forum was to provide an opportunity for local jurisdictions to better understand the direction and intentions of Senate Bill 1383 (2016), which requires that no less than 20 percent of edible food currently disposed of in California be recovered for human consumption by 2025.

Attendees enjoy food catered by FoodShift, a local non-profit that offers culinary job training, uses rescued food as a primary resource and sells and donates their products and coffee from 1951 Coffee, a non-profit specialty coffee organization providing job training and employment to refugees and asylmees. In the afternoon, Regrained offered attendees a snack of powerbars made from grains rescued from local breweries.

Setting the Stage
Martine Boswell of CalRecycle opened the day with an overview of SB1383’s requirements and notice of CalRecycle’s next round of Food Waste Prevention & Rescue Grants for which $5.7 million is allocated. NCRA will keep you posted regarding the grant cycle.

Justin Malan with Ecoconsult described the important work happening state-wide with environmental health inspectors, as AB1219 and related legislation now require them to inform food service businesses, about their right to donate food without fear of liability and about food donation options.

Melissa Romero of Californians Against Waste, gave an update on recent Food Waste Prevention, Recovery and Reuse Legislation and Regulations, including AB 954 (Chiu), the Uniform Food Date Labels bill which promotes the adoption of uniform date label phrasing to reduce consumer confusion, and SB 557 (Hernandez), which allows schools to donate food items that have been served and placed on share tables to food banks. Romero also reviewed the implementation deadlines of AB1826 which requires local jurisdictions across the state to implement an organic waste recycling program.

Innovative Programs
Barbara Hamilton, San Diego Food System Alliance, led off by describing a strategic county-wide food waste awareness partnership that leverages the national “Save The Food” public service campaign (a partnership with NRDC and the Ad Council) for community education, Re-Plate technology for food recovery, and LeanPath for food waste prevention. SDFSA is happy to share their material and strategies with other local jurisdictions.

Iesha Siler and Alyson Schill with the LA Food Policy Council, shared lessons learned from Los Angeles’ innovative public-private partnerships to promote food rescue. They described RecyLA’s new waste hauler contracts, requiring that haulers dedicate funding for the redistribution of edible food “before the bin,” in partnership with local non-profits. They also described some innovative approaches the City has taken to promote food waste prevention and organics recycling, including establishing composting hubs.

Robin Martin with Silicon Valley Food Rescue described the newly-launched pilot A La Carte program, which encompasses fleet of food trucks to rescue surplus food from institutions and deliver it directly to those in need, removing the intermediate steps of storage and redistribution. The pilot currently has one truck collecting food from Stanford University and delivering it to locations in Mountain View, Sunnyvale, East Palo Alto, and Palo Alto.

Annalisa Belliss with StopWaste presented an overview of the StopWaste Smart Kitchen Initiative, providing free access to LeanPath equipment and software for a year to large food service providers, caterers and commercial kitchens, to support their efforts to reduce pre-consumer food waste and identify donation opportunties. StopWaste has also launched a Smart Cafeteria Initiative, offering resources to staff and students in school districts throughout the state to prevent food waste and support food recovery and reuse.

Innovative Measurement Tools
Darby Hoover of the Natural Resources Defense Council (NRDC), described the challenges of measuring household food waste and the progress NRDC has made collecting food waste data in Nashville, Denver and New York City through kitchen diaries, bin digs and surveys. They found that 68% of discarded residential food was potentially edible. Based on their research, NRDC recommends that cities conduct city-wide baseline food waste and food rescue assessments in order to most effectively leverage city resources and tailor residential education programs.

Wendi Shafir, LEED, AP Sustainability, shared 3 ways to measure food waste for commercial generators, the pros and cons of each, resources about each, and how to use the data to inform policies and programs. The measurement options include wasted food sorts, wasted food audits, and wasted food tracking.

Nate Clark with Spoiler Alert explained how large food service businesses can use operational Key Performance Indicators (KPIs) and data-driven approaches to reduce food waste. KPIs include: Shrink Rate (product that a company doesn’t sell despite best wishes and intentions), Diversion Rate (product that is diverted from the landfill to a higher and better use) and Recovery Rate (product recovered for human consumption). By monitoring this data and the causes, a business can develop strategies to improve profitability.

Steven Finn of LeanPath described LeanPath’s automated waste prevention technology designed to measure food waste and help drive behavior change among commercial generators. After all, “you can’t manage what you don’t measure” – Drucker.

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America Recycles Day – November 15

The 22nd Annual “America Recycles Day” (ARD) as always will be on November 15, 2018. ARD is the only nationally recognized day dedicated to encouraging Americans to recycle and to buy recycled content products. Each year since inception in 1997, the ARD campaign has increased in awareness and has continued to evolve.

Since 1997, 2,762 events have been held nationwide. For 2018, there will be at least 97 additional ARD events, with five in California:

  • Nov. 13 – City of San Leandro, “Recycle Unusual Items” Collection. Marina Community Center, 9 am – 1 pm.
  • Nov. 15 – San Jose “Amazon Celebrates ARD” E-Waste (Electronics) Collection. Eastridge, 11 am – 7 pm.
  • Nov. 10 – Anaheim “Eco Challenge Day” Collections Event
  • Nov. 13-15 County of Ventura, ARD Display & “I Recycle” Pledge Drawing
  • Nov. 17 – City of Torrence “E-Waste & Shredding” Event

For 2019, the most promising target for encouraging participation of Bay Area ARD events should be among Bay schools and student organizations, at all levels, given their greater propensity and enthusiasm for sustainability, and willingness to take action. See the NCRA letter sent to the superintendents of Unified School Districts within Alameda County.

Since 1997, at least 76,240 Americans have taken the Pledge to increase their recycling habits at home and at work. NCRA supports America Recycles Day, and has taken the online Business Pledge. We encourage our members and friends to take Individual Pledges in solidarity at Encourage others to consider doing likewise.
For 18 consecutive years, from 1999 to 2016, each sitting U.S. President, W. Clinton, G. W. Bush and B. Obama, has issued a descriptive Proclamation “America Recycles Day”, on or about November 15. See them all at Unfortunately, the succession of annual US Presidential ARD Proclamations has ended, with President Donald Trump electing to not issue such a proclamation during 2017, and unlikely for this year.
Consider reading and sharing the last 2016 Proclamation by President Obama, for encouragement, to help transform the public from the garbage as usual paradigm, more towards a Zero Waste mentality. Keeping more and more valuable resources out of dwindling landfills, in part by raising citizens awareness and conscientiousness, remains a collective ongoing campaign vital to our common welfare. Thanks for doing your part.