Cities Index.
Attachment 2 - Exhibit A

City Council / Housing Authority
February 7, 2022

Document
Attachment 2 - Exhibit A
Meeting
February 7, 2022
Body
City Council / Housing Authority
Original file
837 KB
Text extracted from the city's file for reading and search. Open the original on pomona.legistar1.com. That file is the official record.

Notification of Intent to Comply
CalRecycle is providing this optional form as a convenience to assist jurisdictions (counties, cities, a county and city, or special districts providing solid waste collection services) for purposes of submitting a notification of intent to comply to CalRecycle [see Public Resources Code (PRC) section 42652.5(c)].

A jurisdiction may submit a notification of intent to comply if it is facing continuing violations of the Short-lived Climate Pollutants: Organic Waste Reductions requirements in Title 14 California Code of Regulations (14 CCR). The written notification of intent to comply, adopted by resolution of the jurisdiction’s governing body, shall be sent to CalRecycle no later than March 1, 2022, to [email protected].

A jurisdiction shall, at minimum, include the following in its notification:

1. A description, with specificity, of the continuing violations.

2. A detailed explanation of the reasons, supported by documentation, why the local jurisdiction is unable to comply.

3. A description of the impacts of the COVID-19 pandemic on compliance.

4. A description of the proposed actions the local jurisdiction will take to remedy the violations within the timelines established in 14 CCR section 18996.2 with a proposed schedule for doing so. The proposed actions shall be tailored to remedy the violations in a timely manner.

Upon approval by CalRecycle of a jurisdiction’s notification and implementation of the intent to comply, a jurisdiction may be eligible for both of the following:

1. Administrative civil penalty relief for the 2022 calendar year pursuant to PRC section 42652.5(d).

2. A corrective action plan pursuant to 14 CCR section 18996.2. a. CalRecycle may address through a corrective action plan any violations disclosed in a jurisdiction’s notification that will take more than 180 days to correct. In this situation, the proposed actions and schedule in the jurisdiction’s approved notification will be in effect until a corrective action plan is issued.

CalRecycle will respond in writing to a jurisdiction within 45 business days of receiving its notification with an approval, disapproval, request for additional information, or timeline for a decision on approval or disapproval. CalRecycle will include details about why a jurisdiction did not meet the requirements for a Notification of Intent to Comply when disapproving the jurisdiction’s notification.

EXHIBIT A ATTACHMENT NO. 2
Please clearly print or type responses. Attach additional pages as necessary.

Jurisdiction Name: City of Pomona County:Los Angeles Count Person Completing the Form:Shandy Dittman
First Name: Shandy Last Name: Dittman
Title: Public Works Fiscal and Project Manager
Mailing Address: 505 S. Garey Ave.

City: Pomona Zip Code: 91766
Email Address: [email protected]
Phone Number: 909.620.3797

1. Select using the check boxes below or write in the continuing violations for each applicable regulatory section. For each selection, please describe the specific violations related to the regulatory section.

Example:
☒ (B) 14 CCR section 18984.1 Three-Container Organic Waste Collection Services i. Not implementing mandatory residential foodwaste collection for all residents. Note:

City already provides mandatory greenwaste collection to all residents ii. Not implementing mandatory commercial organics collection for all businesses under 2 cubic yards. Note: City already provides mandatory commercial organics collection to all businesses 2 cubic yard or more.

Disclaimer: The list of possible continuing violations below is not inclusive of all potential violations of the regulations.

(A) 14 CCR section 18984 Combined Organic Waste Collection Services. This requirement is not included since the requirements are further specified in sections 18984.1-18984.11. (B) 14 CCR section 18984.1 Three-Container Organic Waste Collection Services (C) 14 CCR section 18984.2 Two-Container Organic Waste Collection Services (D) 14 CCR section 18984.3 Unsegregated Single Container Collection Services (E) 14 CCR section 18984.4 Recordkeeping Requirements for Compliance with Organic Waste Collection Services
(F) 14 CCR section 18984.5 Container Contamination Minimization (G) 14 CCR section 18984.6 Recordkeeping Requirements for Container Contamination Minimization
(H) 14 CCR section 18984.7 Container Color Requirements (I) 14 CCR section 18984.8 Container Labeling Requirements (J) 14 CCR section 18984.11 Waivers Granted by a Jurisdiction (K) 14 CCR section 18985.1. Organic Waste Recovery Education and Outreach. (L) 14 CCR section 18985.2. Edible Food Recovery Education and Outreach (M) 14 CCR section 18985.3. Recordkeeping Requirements for a Jurisdiction’s Compliance with Education and Outreach Requirements
(N) 14 CCR section 18988.1. Jurisdiction Approval of Haulers and Self-Haulers (O) 14 CCR section 18988.3. Self-haulers of Organic Waste (P) 14 CCR section 18988.4. Recordkeeping Requirements for Compliance with Jurisdiction Hauler Program
(Q) 14 CCR section 18989.1. CALGreen Building Codes
(R) 14 CCR section 18989.2 Model Water Efficient Landscape Ordinance (S) 14 CCR section 18991.1. Jurisdiction Edible Food Recovery Program (T) 14 CCR section 18991.2. Recordkeeping Requirements for Jurisdiction Edible Food Recovery Program
(U) 14 CCR section 18992.1. Organic Waste Recycling Capacity Planning (V) 14 CCR section 18992.2. Edible Food Recovery Capacity (W) 14 CCR section 18993.1. Recovered Organic Waste Product Procurement Target (X) 14 CCR section 18993.2. Recordkeeping Requirements for Recovered Organic Waste Procurement Target
(Y) 14 CCR section 18993.3. Recycled Content Paper Procurement Requirements (Z) 14 CCR section 18993.4. Recordkeeping Requirements for Recycled Content Paper Procurement
(AA) 14 CCR section 18994.2. Jurisdiction Annual Reporting Note: This requirement is not included since jurisdictions are still expected to report to CalRecycle.
(BB) 14 CCR section 18995.1. Jurisdiction Inspection Requirements Note: Section 18995.1(a)(1) should not be included because a jurisdiction should already be completing this action due to the requirements of PRC Chapter 12.9 (commencing with Section 42649.8)
(CC) 14 CCR section 18995.2. Implementation Record and Recordkeeping Requirements (DD) 14 CCR section 18995.3. Jurisdiction Investigation of Complaints of Alleged Violations Note: This requirement is not included since jurisdictions are still expected to investigate complaints.
(EE) 14 CCR section 18995.4. Enforcement by a Jurisdiction

Use the check box(es) below to write in the continuing violations for any regulatory section(s) not reflected above and describe the specific violations related to the regulatory section.

Example:
☒ (1) (Type regulatory section number) (Type regulatory section title) i. Describe the specific violations related to the regulatory section (1)
(2)
(3)
(4)
(5) See Attached

2. A detailed explanation of the reasons why the jurisdiction is unable to comply, supported by documentation, if applicable.

See Attached

3. A description of the impacts of the COVID-19 pandemic on compliance.

See Attached

4. Provide a description of the proposed actions the jurisdiction will take to remedy the violations with a proposed schedule for completing each action. The proposed actions shall be tailored to remedy the violations in a timely manner. See optional format below.

See Attached

City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules

3. Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Per Capita Program.

Date to Be Completed:

Feb 1, 2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Begin July 1, 2022 for 2
years. Additional
funding for this position
will come from hauler
fees. As proposed in
the RFP, haulers will
need to pay the City
$250k per year for SB Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through the CalRecycle Per Capita funding and franchise hauler revenues paid to the City through their franchise agreement and through fees paid by enforcement of SB 1383 regulations.

Begin July 1, 2022 and
ongoing
Regulatory Requirement: (B.i) 14 CCR section 18984.4 Recordkeeping Requirements for Compliance with Organic Waste Collection Services.

Description:

A jurisdiction shall include all relevant documents supporting its compliance with this article in the Implementation Record required by Article 14 of this chapter.

1. The City of Pomona currently fulfills the necessary recordkeeping requirements for organics collection with the exception of SB 1383. The City operates its solid waste program on an extremely limited budget. Prior to SB 1383, the program was underwater, and with the new costs associated with SB 1383, the City is unable to implement all of the required elements immediately. The City hired a consultant to determine the exact cost that SB 1383 will impose on the City. The City began this process in November 2019, but due to Covid, the study was delayed and work on this did not commence until late summer 2020. During this time, our consultant, R3, conducted an exhaustive study of rates and analyzed the impact SB 1383 would have on our operation. It was determined that the City would need an immediate rate increase of 35 percent in order to implement SB 1383. Because a large contingent of the population of the City is economically disadvantaged, the City asked R3 to look at the impact of outsourcing our Solid Waste program. In November 2021, it was determined that this may be the most feasible strategy in order to effectively address SB 1383 and maintain affordable rates. The City issued an RFP in December 2021 and should know by next summer whether it will outsource or immediately raise rates in order to afford compliance with SB 1383.

2. The main way that Covid has delayed compliance is that the City engaged R3 for a study to determine the effects of SB 1383 and to determine the extent of a rate increase. The study was delayed due to Covid. The study should have begun February/March 2020, but the City shut down due to Covid and, at the same time, was dealing with the emergency that Covid presented. During this time, although the City shut down, staff was still working and having to dramatically cut all budgets, including our solid waste budget, while not laying off staff. This shutdown and budget cuts delayed the study until late summer/fall 2020. The study took several months, and at the end, with the determination that rates would need to be increased significantly (35 percent) on a predominately economically disadvantaged community that was also dealing with the economic impacts of Covid, it was determined that we needed to adjust the study to look at how outsourcing our residential and commercial solid waste might better serve the Community. After this was prepared, Council needed to be educated on the economic impacts of SB 1383 to better understand why it may be necessary to outsource both residential and commercial. This process has taken time, and we were finally able to release the RFP in December 2021.
1 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: The City has an active RFP to identify a single hauler for both commercial and residential trash services. After reviewing the bids provided by prospective haulders, the City Council will award an exculsive franchise agreement with one hauler.

Award in Fall 2022.

Services begin 1-1-2023
TASK 2: The City will hire one or more staff to audit trash cans. Funding for this will be paid from fees outlined in the Franchise agreement to be paid by the Exclusive Franchise Hauler to the City when one is selected.
1/1/2023
TASK 3: The City provides residential trash services to residents through the end of the year. There is an inspection process where drivers tag trash cans when there are contaminants in the trash. An inspection of the trash is also done at the facility where the trash is processed before going to the landfill. This audit occurs when the City is charged by ton for the waste left at the facility. We are also implementing education, outreach, and new trash can labeling that provides direction on the proper disposal of organic waste. Education and outreach to residents will be the full-time responsibility of new permanent staff hired this calendar year.

Ongoing
Regulatory Requirement: (B.ii) 14 CCR section 18984.5 Container Contamination Minimization.

Description: A jurisdiction shall monitor the containers provided to generators using a three-container or two- container organic waste collection service pursuant to Section 18984.1 or 18984.2 to minimize prohibited container contaminants in a manner that complies with either the provisions of Subdivision (b) or the provisions of Subdivision (c) of this section.

1. The City currently tags containers when they determine that a container is contaminated at the time of pickup. The City is not yet ready to hire the staffing required to do the random can audits as described in this section of the law due to limited funding. As described above, the City has been evaluating the extent to which SB 1383 imposes significant costs and how much of this would have to be passed to the ratepayer and determined, as described above, after an extensive study, that rates would need to increase by 35 percent.

This prompted the City to issue an RFP, and once the City either outsources its solid waste enterprise or raises rates (to be determined based on the bids), the City will be able to hire the staffing needed to audit cans.

2. Please see first response above to the question of the impacts of Covid-19 pandemic on compliance 2 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Begin July 1, 2022 for 2
years. Additional
funding for this position
will come from hauler
fees. As proposed in
the RFP, haulers will
need to pay the City
$250k per year for SB
1383 compliance.

Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Begin August 31, 2022
and ongoing
Regulatory Requirement: (B.iii) 14 CCR section 18984.6 Recordkeeping Requirements for Container Contamination Minimization.

Description: A jurisdiction shall include all relevant documents supporting its compliance with Section 18984.5, in the Implementation Record required by Section 18995.2 of this chapter.

1. When a container is determined to be contaminated, the container is tagged and a record of this tagging is logged with the department. Regarding the additional requirements associated with the sections identified above, the City will be able to fulfill this with the new position it plans to hire funded with the SB 1383 Per Capita funding. The City operates its solid waste program on an extremely limited budget. Prior to SB 1383, the program was underwater, and with the new costs associated with SB 1383, the City is unable to implement all of the required elements immediately. The City hired a consultant to determine the exact cost that SB 1383 will impose on the City. The City began this process in November 2019, but due to Covid, the study was delayed and work on this did not commence until late summer 2020. During this time, our consultant, R3, conducted an exhaustive study of rates and analyzed the impact SB 1383 would have on our operation. It was determined that the City would need an immediate rate increase of 35 percent in order to implement SB 1383.

Because a large contingent of the population of the City is economically disadvantaged, the City asked R3 to look at the impact of outsourcing our Solid Waste program. In November 2021, it was determined that this may be the most feasible strategy in order to effectively address SB 1383 and maintain affordable rates. The City issued an RFP in December 2021 and should know by next summer whether it will outsource or immediately raise rates in order to afford compliance with SB 1383.

2. Please see first response above to the question of the impacts of Covid-19 pandemic on compliance. 3 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: The City has an active RFP to identify a single hauler for both commercial and residential trash services. After reviewing the bids provided by prospective haulders, the City Council will award an exculsive franchise agreement with one hauler or increase rates. It is anticipated that the City will receive significant revenues from outsourcing that will allow it to be able to comply fully with SB 1383.

Award in Fall 2022.

Services begin 1-1-2023
TASK 2: While the RFP process is ongoing, work with current container vendor to acquire containers with signage, or develop signage and send to residents via City staff.

Ongoing process
Regulatory Requirement: (B.iv) 14 CCR section 18984.8 Container Labeling Requirements.

Description: Commencing January 1, 2022, a jurisdiction shall place a label on each new container or lid provided to generators consistent with the applicable container collection requirements and limitations of this article specifying what materials are allowed to be placed in each container.

1. The City will be implementing this with future containers that are ordered. The City will work with the vendor or develop the applicable container signage moving forward. As explained above, the City's solid waste program is already underwater and SB 1383 is already imposing significant additional costs. As described above, the City has a plan to move forward with either a rate increase or outsource it's residential and commercial in order to generate enough money to afford all of the additional costs, such as replacement containers with signage.

2. Please see first response above to the question of the impacts of Covid-19 pandemic on compliance. In addition, the City has experienced severe economic impacts on its solid waste fund with increased dumping when people were predominately working from home or out of work due to Covid. This has made it very difficult to afford additional costs associated with SB 1383, such as container replacements with signage. 4 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Begin July 1, 2022 for 2
years. Additional
funding for this position
will come from hauler
fees. As proposed in
the RFP, haulers will Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Begin August 31, 2022
and ongoing
Task 4: The City is currently working with the San Gabriel Valley COG in a regional effort to link Tier 1 and Tier 2 food generators to Food Recovery Organizations and to enter into contracts between these entities. The City can utilize the data gathered for this task and also provide information to residents about food recovery organizations.

Begin August 31, 2022
and ongoing
Regulatory Requirement: (B.v) 14 CCR section 18985.1 Organic Waste Recovery Education and Outreach.

Description: Prior to February 1, 2022, and annually thereafter, a jurisdiction shall provide the following to organic waste generators that are provided an organic waste collection service pursuant to Article 3 of this chapter.

1. The City has provided educational materials via mail, website, and social media to let residential generators know how to properly dispose of organic waste. It has also provided information on methane reduction. The City is still working on an edible food recovery program. The City will also be providing a video that demonstrates how to separate organic waste.

2. See above for explanation about how Covid has affected both timing and funding for our activities. 5 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: Work with San Gabriel Valley COG and consultant on identification of food recovery organizations both local and regionally. Update website with list and provide information on food recovery organizations.

Date to Be Completed:

List February 2022.

Outreach and
information to be
ongoing.

TASK 2: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 3: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Begin August 31, 2022
for 2 years. Additional
funding for this position
will come from hauler
fees. As proposed in
the RFP, haulers will
need to pay the City
$250k per year for SB
1383 compliance.

Regulatory Requirement: (B.vi) 14 CCR section 18985.2 Edible Food Recovery Education and Outreach.

Description: Prior to February 1, 2022, and annually thereafter, a jurisdiction shall develop a list of food recovery organizations operating within the jurisdiction and maintain the list on the jurisdiction’s website. The jurisdiction must provide education and outreach on the need to reduce food waste and information about local food recovery organizations.

1. The City is in the process of developing the list of food recovery organizations. We are currently working with the San Gabriel Valley COG on regionally linking food recovery organizations to Tier 1 and Tier 2 food generators. When this is complete, the City will be able to publish the list on the website and provide information and outreach.

2. See above for explanation about how Covid has affected both timing and funding for our activities. 6 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022
Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022
Regulatory Requirement: (B.viii) 14 CCR section 18988.4 Recordkeeping Requirements for a Jurisdiction Hauler Program
Description: A jurisdiction shall include all relevant documents supporting its compliance with this article in the Implementation Record required by Article 14 of this chapter.

1. The City will be able to fulfill the recordkeeping requirements associated with SB 1383 when it is able to hire additional staffing.

2. See above for explanation about how Covid has affected both timing and funding for our activities.

1. The City will be able to fulfill the recordkeeping requirements associated with SB 1383 when it is able to hire additional staffing.

2. See above for explanation about how Covid has affected both timing and funding for our activities.

Regulatory Requirement: (B.vii) 14 CCR section 18985.3 Recordkeeping Requirements for a Jurisdiction's Compliance with Education & Outreach Requirements
Description: A jurisdiction shall include all relevant documents supporting its compliance with this article in the Implementation Record required by Section 18995.2 of this chapter. 7 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022
Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022
Description: A jurisdiction shall implement an edible food recovery program that shall include education of commercial food generators, compliance monitoring, and analysis to assess capacity planning and increasing commercial food generators access to edible food recovery organizations.

Regulatory Requirement: (B.x) 14 CCR section 18991.2 Recordkeeping Requirements for Jurisdiction Edible Food Recovery Program
Description: A jurisdiction shall include all documents supporting its compliance with Section 18991.1 in the Implementation Record required by Section 18995.2.

Regulatory Requirement: (B.ix) 14 CCR section 18991.1 Jurisdiction Edible Food Recovery Program

1. The City will be able to fulfill the this requirement when it is able to hire additional staffing. The City is working towards the first steps of compliance by working with the San Gabriel Valley COG to identify commercial food generators and facilitate contracts between generators and food recovery organizations.

2. See above for explanation about how Covid has affected both timing and funding for our activities.

1. The City will be able to fulfill the this requirement when it is able to hire additional staffing. The City is working towards the first steps of compliance by working with the San Gabriel Valley COG to identify commercial food generators and facilitate contracts between generators and food recovery organizations.

2. See above for explanation about how Covid has affected both timing and funding for our activities. 8 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022
Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with managig the procurement of organic materials. City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022

1. The City has updated its Purchasing Ordinance to be compliant with SB 1383. The City regularly purchases compost for City giveaways and utilizes composted materials throughout the City in medians and parks.

However, the amount of this has not yet been determined and the City will need additional resources in order to determine whether it is meeting its goal.

2. See above for explanation about how Covid has affected both timing and funding for our activities.

Regulatory Requirement: (B.xi) 14 CCR section 18993.1 Recovered Organic Waste Product Procurement Target Description: A jurisdiction, as defined in 18993.1(a), shall include all documents supporting its compliance with this article in the implementation record required by Section 18995.1 of this chapter.

1. The City will be able to fulfill the this requirement when it is able to hire additional staffing. The City is working towards the first steps of compliance by working with the San Gabriel Valley COG to identify commercial food generators and facilitate contracts between generators and food recovery organizations.

2. See above for explanation about how Covid has affected both timing and funding for our activities.

Regulatory Requirement: (B.xi) 14 CCR section 18993.2 Recovered Waste Procurement Target 9 of 10
City of Pomona
Notice of Intent to Comply Proposed Actions and Schedules Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022
Action Proposed Schedule
TASK 1: Obtain funding to pay for permanent staff member to assist with implementing an organics recycling program, compliance, and enforcement policies.

City Staff will apply for CalRecycle SB 1383 Local Grant Assistance Program.

Date to Be Completed:

Application submitted
2/1/2022. New staff
hired 8/31/2022
TASK 2: The permanent staff position would be funded for two years and enable the City to develop the necessary infrastructure to conduct education and outreach on SB 1383, enforce regulations, track and report compliance, and coodinate with franchise hauler and edible food recovery ogranizations to ensure success of these programs.

Date to Be Completed:

Begin 8/31/2022 and
ongoing
Task 3: As the City organics recycling program is developed over the next two years, the staff position will be fully paid for through both franchise hauler revenues paid to the City through agreements and through fees paid by enforcement of SB 1383 regulations.

Ongoing beginning
8/31/2022
Regulatory Requirement: (B.xiii) 14 CCR section 18993.4 Recordkeeping Requirements for Recycled Content Description: A jurisdiction shall include all documents supporting its compliance with this article in 3 the implementation record required by Section 18995.2 of this chapter.

2. See above for explanation about how Covid has affected both timing and funding for our activities.

1. The City will be able to fulfill the recordkeeping requirements associated with SB 1383 when it is able to hire additional staffing.

2. See above for explanation about how Covid has affected both timing and funding for our activities.

1. The City will be able to fulfill any recordkeeping requirements associated with the this section when it is able to hire additional staffing. The City has updated its purchasing ordinance, however, to be compliant with SB 1383 and will procure items consistent with these requirements.

Regulatory Requirement: (B.xii) 14 CCR section 18993.3 Recordkeeping Requirements for Recovered Organic Waste Procurement Target
Description: A jurisdiction shall procure paper products, and printing and writing paper, consistent with the requirements of Sections 22150-22154 of the Public Contract Code. 10 of 10

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