Memorandum — Transportation and Environment Committee (t&e), September 11, 2023

Office of the City Auditor

Report to the City Council
City of San José

INTEGRATED WASTE

MANAGEMENT
ENFORCEMENT PROGRAM:

CLARIFYING GOALS AND

PERFORMANCE

EXPECTATIONS WOULD

IMPROVE ENFORCEMENT

COVERAGE
Report 23-03
September 2023
This page was intentionally left blank
200 E. Santa Clara Street, San José, CA 95113
Telephone: (408) 535-1250 Email: [email protected] Website: www.sanjoseca.gov/auditor/ Office of the City Auditor
Joe Rois, City Auditor
September 1, 2023
Honorable Mayor and Members
Of the City Council
200 East Santa Clara Street
San José, CA 95113
Integrated Waste Management Enforcement Program: Clarifying Goals and Performance Expectations Would Improve Enforcement Coverage
The Integrated Waste Management division (IWM) of the Environmental Services Department (ESD) oversees collection, processing, and disposal of solid waste and recycling in the City of San José. The IWM Enforcement team enforces Municipal Code and contractual requirements to resolve problems with solid waste management, including dangerous accumulation of solid waste, improper set outs of containers, illegal hauling, and other issues. The team has five positions to respond to complaints and initiate cases for problems they see in the field and conduct outreach with residents and businesses. The objective of this audit was to evaluate the IWM Enforcement team’s service delivery.

Finding 1: ESD Should Clarify the Mission and Workload Expectations of the IWM Enforcement Team. In recent years, the responsibilities of the IWM Enforcement team have changed.

This has contributed to a lower workload and a need to clarify the expectations for inspectors’ activities.

We found:
 New responsibilities, such as outreach or
enforcement related to new legislation or existing
ordinances, have been added to the team’s
responsibilities. Work in other areas has declined,
including shifting enforcement of illegal dumping to
Planning, Building and Code Enforcement.
 A decline in public complaints coming to this team has contributed to lower workload.
 In the first half of 2023, each inspector was conducting about 2.3 inspections per day, on average. The
expectation is for inspectors to complete four
inspections per day.
 The IWM Enforcement team should clarify procedures for reporting illegal dumping cases and handling properties with closed collection accounts or without collection service.

Finding 2: Proactive Cases Should Focus on Expanding Coverage Citywide. The Enforcement team’s approach for proactive cases could better augment the current complaint-driven system to expand coverage of solid waste enforcement citywide. We found:

RECOMMENDATIONS:

To focus the team’s work, ESD
should:
 Clarify the mission and create
success metrics for the team.
 Set performance expectations for
inspectors.
 Update procedures to clarify
expectations for inspector
activities.
4  IWM inspectors may only initiate proactive work if
they observe a solid waste violation while out of City
Hall for another reason.
 As a result, proactive cases largely follow the same
geographic trends as solid waste complaints. This
results in a risk of underreported issues, particularly for areas of the city with fewer cases than could be
expected given the density of multi-family and
commercial properties.
 Updated procedures would enable the team to better
reach communities, particularly those that may have
underreported violations, and tailor outreach
materials appropriately.

Finding 3: Streamlining Administrative Tasks Would Give Inspectors More Time in the Field. Administrative tasks related to cases such as data entry and identifying responsible parties can be made more efficient to free up inspectors’ time for additional inspections, outreach, or other activities.

We found:
 The software platform that the team uses is outdated
and was not designed for their needs, making data
entry complicated and time consuming. ESD is
working to replace the current system.
 Clarifying expectations for inspectors’ research for
responsible parties would also relieve frustration
among staff and maximize time spent in the field.

This report has seven recommendations. We plan to present this report at the September 11, 2023, meeting of the Transportation and Environment Committee of the City Council. We would like to thank the Environmental Services Department for their time and insight during the audit process. The Administration has reviewed the information in this report, and their response is shown on the yellow pages.

Respectfully submitted,
Joe Rois
City Auditor
Audit staff: Alison Pauly
Michael O’Connell Jr.

Maria Valle
cc: Jennifer Maguire Kerrie Romanow Nora Frimann
Kip Harkness Valerie Osmond Rosalia Tapia-Burgueño
Russell Joyce Jim Shannon Megha Prakash-Rao
Lee Wilcox Mariana Chavez-Vasquez
This report is also available online at www.sanjoseca.gov/audits RECOMMENDATIONS:

To better use proactive inspections to
augment complaint-driven cases, ESD
should:
 Update proactive case procedures
to target areas where there is a
risk of underreported issues,
particularly in areas with high
concentrations of multi-family and
commercial properties.

RECOMMENDATIONS:

To maximize the time that inspectors
can spend in the field, ESD should:
 Procure a new software solution.
 Update procedures for finding a
responsible party.

Table of Contents
Cover Letter ........................................................................................................... 3 Background ............................................................................................................. 7 Finding I
ESD Should Clarify the Mission and Workload Expectations of the IWM Enforcement Team .............................................................................................. 13 The Goals and Success Metrics for the IWM Enforcement Team Should be Clarified ................................................................................................................................. 13 Average Daily Inspections Remain Lower Than Expectations, Though Higher Than Recent Years ............................................................................................................. 17 The IWM Enforcement Team Should Update Procedures for Illegal Dumping and Service Interruption Work ..................................................................... 19 Finding 2
Proactive Cases Should Focus on Expanding Coverage Citywide .................. 23 The IWM Enforcement Team Should Target Proactive Inspections to Expand Solid Waste Enforcement Coverage ............................................................... 23 Finding 3
Streamlining Administrative Tasks Would
Give Inspectors More Time in the Field ............................................................ 27 Administrative Tasks Can Be Time Consuming, Taking Inspectors Out of the Field ................................................................................................................................ 27 Conclusion ............................................................................................................. 33 Appendix A
Audit Objective, Scope, and Methodology ...................................................... A-1 Appendix B
Map of Limited English Proficiency by Census Tract ...................................... B-1 Administration’s Response ................................................................. yellow pages Table of Exhibits
Exhibit 1: Example of Dangerous Waste Accumulation, a Common Case Type .................................................................................................................... 8 Exhibit 2: Cases by Complaint Type Reported (2022) ........................................... 8 Exhibit 3: IWM Enforcement Team Inspection Zones ........................................ 10 Exhibit 4: Flowchart of IWM Enforcement Inspection Process .......................... 11 Exhibit 5: Complaints and Caseload Have Changed Over Time ........................ 14 Exhibit 6: Daily Inspections by Inspector Have Varied Over Time .................... 18 Exhibit 7: Complaints and Proactive Cases by Zip Code .................................... 24 Exhibit 8: Commercial and Multi-Family Waste Collection Locations vs.

Proactive Inspections ............................................................................................... 25 Exhibit 9: Commercial and MFD Waste Collection Locations by Zip Code ..... 25 Exhibit 10: Inspection of a Sample Case Takes 2 Hours ...................................... 28 Exhibit 11: Data Entry Requires Multiple Steps in Two Software Platforms .... 29 7 Background
The Integrated Waste Management division (IWM) of the Environmental Services Department (ESD) oversees solid waste collection, processing, and disposal for residential, commercial, construction and demolition, and City facility operations in the City of San José. The mission of the division is to maximize diversion of solid waste from landfills and protect public health, safety, and the environment.

The division works with five contracted garbage, recycling, and green waste haulers to collect solid waste from over 300,000 residential, commercial, and industrial collection locations throughout the city.

To encourage efficient solid waste management and compliance with solid waste regulations, the IWM division relies on their Enforcement team to respond to complaints regarding private property solid waste management.

San José Municipal Code Enforcement
The IWM Enforcement team enforces portions of chapter 9.10, Solid Waste Management, of the San José Municipal Code. The chapter addresses topics related to waste management including responsibilities for residents and businesses, collection of solid waste by contracted haulers, and provisions for inspection and enforcement. Issues the IWM Enforcement team enforces include:
 Businesses or residences without solid waste hauling service;  Unauthorized hauling activities and self-hauling concerns;  Overflowing containers or improper accumulation of garbage, organics, or recyclables;
 Early set-out of garbage, organics, recyclables, or yard trimmings containers;
 Improper storage of garbage, organics, recyclables, or yard trimmings containers on private property;
 Leaking or broken solid waste containers;
 Complaints related to the City’s single-use carry-out bag ban;  Complaints related to the City’s polystyrene foam disposable food service ware ban;
 Complaints related to the Single-use Foodware Accessories and Condiments Law (AB 1276); and
 Complaints related to the Short-Lived Climate Pollutant Reduction Strategy (SB 1383 described later).

Audit of IWM Enforcement Program
8 Exhibit 1: Example of Dangerous Waste Accumulation, a Common Case Type Source: IWM Enforcement Team violation enforcement procedures.

In 2022, the team handled 840 cases across all categories. The most common complaint type was for dangerous accumulation, shown above. Following that, cases regarding the set-out of bins were the next most common category.

Exhibit 2: Cases by Complaint Type Reported (2022)
Source: Auditor analysis of IWM Enforcement team case data for calendar year 2022.

Note: Percentages do not add to 100 percent due to rounding.

SB 1383
In September 2016, the State of California passed Senate Bill 1383, establishing methane emissions reduction targets statewide to reduce emissions of short-lived Dangerous
Accumulation,
34%
Bin/cart/other, setout,
28%
Other, 14%
Unauthorized hauler,
11%
No collection service, 8%
Illegal dumping, 4%
Background
9 climate pollutants (SLCP). SB 1383 regulations require jurisdictions to conduct education and outreach on organics recycling to all residents, businesses, haulers, solid waste facilities, and local food banks and other food recovery organizations.

According to IWM management, SB 1383 is expected to increase the team’s work around organics disposal. This will particularly impact commercial facilities and require the use of an additional separated organics container. Management anticipates that enforcement of the new solid waste regulations will begin in January 2024, with education and outreach efforts having begun in February 2023.

Staffing and Budget
For fiscal year (FY) 2023-24, the Enforcement team has five budgeted positions:
four Environmental Inspectors and one Senior Environmental Inspector who acts as the supervisor. In recent years, the team has experienced turnover among Environmental Inspectors.

Prior to FY 2021-22, the Enforcement team had consisted of three Environmental Inspectors to cover the city. In FY 2021-22, the Enforcement team added two new positions:
 One Environmental Inspector II position to support the enforcement program.
 One Senior Environmental Inspector position to finalize the development and implementation of an enforcement program to ensure the City is compliant with new SB 1383 regulations.

These positions were added primarily in anticipation of increased workload to enforce new solid waste regulations, including SB 1383. According to ESD management, the Senior Environmental Inspector was added to also provide direct supervision and leadership to the Enforcement program and team.

Funding for the Enforcement team is provided through ratepayer fees for commercial and residential solid waste collection, which limits the scope of work that the Enforcement team can take on.

Enforcement Team Inspection Process
The IWM Enforcement program uses a primarily complaint-based system to identify and inspect issues with solid waste management. During the COVID-19 pandemic, complaints from the public for solid waste issues decreased and have yet to return to pre-pandemic levels.

To address issues relating to solid waste management, the Enforcement team has divided the city into four inspection zones. The zones are divided to have roughly similar numbers of cases. Each inspector is assigned to an inspection zone and a Audit of IWM Enforcement Program
10 secondary zone (to cover if another inspector is absent). The inspectors periodically rotate inspection zone assignments.

Exhibit 3: IWM Enforcement Team Inspection Zones
Source: Auditor analysis of IWM Enforcement team Inspection zones as of 2023.

Environmental Inspectors receive cases based on their assigned inspection zones.

IWM Enforcement cases can be complaint-based or self-initiated (proactive) by the inspector, though, as noted, the program is primarily complaint-based. From March 2020 through mid-2022, the team paused conducting proactive inspections and responding to non-collection reports from one of the City’s haulers.

The team receives complaints from:
 Emails to [email protected]. Per staff, this is the main route for submitting complaints and the preferred method.  Phone calls to ESD staff. ESD staff record the information in an email and send it to the email address listed above. Complaints may come in to ESD through other email addresses, which would be forwarded to the IWM team.
 Other City staff: If members of the public use the City’s Customer Contact Center, the SJ311 app, or other means of contacting the City, complaints would be forwarded to the IWM team.
 Reports from haulers. The Enforcement team receives monthly reports on commercial locations that have no service collection and issues of noncollection at multi-family dwellings.

Background
11  Complaints from haulers or IWM contract managers. Haulers may submit complaints to the Enforcement team or to staff who manage those contracts who then pass on the issue to the Enforcement team.

Exhibit 4: Flowchart of IWM Enforcement Inspection Process Source: Auditor analysis of IWM Enforcement team policy and procedure documents.

Note: if a complaint is received by the City through other means, such as to Code Enforcement or 311, staff forward those complaints on to the [email protected] email.

Inspectors also proactively address solid waste compliance issues they encounter while in the field through self-initiated cases. However, certain violations first require sending a letter in advance to provide the property owner notice and opportunity to address the violation. For more information about proactive cases, see Finding 2.

Escalation and Enforcement Process
If an inspector finds no violation while conducting an inspection for a solid waste complaint, they will issue an inspection report. This report contains information about remedial actions, so the property owner is aware that there was a complaint and how to avoid a complaint in the future.

When a violation is found during an inspection, the inspector will issue either a warning notice or an administrative citation.
 A warning notice includes remedial actions and gives the responsible party a time period (generally 10 business days) to correct the problem. After that time, an inspector will re-inspect to ensure the violation is corrected.

An inspector will issue a warning notice if the property has not had a violation within 12 months of the complaint.
 An administrative citation includes remedial actions and a fine, which varies based on the type of violation. An inspector will issue an Audit of IWM Enforcement Program
12 administrative citation if the violation is a repeat within 12 months or if a violation is not resolved upon re-inspection.

In 2022, the team issued 429 warning notices and 41 administrative citations (out of 840 total cases).
13 Finding I ESD Should Clarify the Mission and
Workload Expectations of the IWM
Enforcement Team
Summary
In recent years, some of the responsibilities of the IWM Enforcement team have changed. Enforcement activities around illegal dumping transferred to Code Enforcement and complaints declined. New responsibilities were assigned to the team, but the team has handled fewer cases overall. In the first half of 2023, each inspector was conducting about 2.3 inspections per day, on average. The expectation is for inspectors to complete four inspections per day. Per ESD management, the short tenure of inspectors has contributed to fewer cases being completed. To ensure that the team is working efficiently to respond to solid waste concerns, management should clarify the mission of the team and set an expectation for the amount of work staff should complete. To further clarify inspectors’ assignments, the team should update procedures for reporting illegal dumping cases and handling properties with closed accounts or without collection service.

The Goals and Success Metrics for the IWM Enforcement Team Should Be Clarified In recent years, the responsibilities assigned to the IWM Enforcement team have changed. Illegal dumping, a part of the team’s former workload, was reassigned.

Different duties have been assigned to the team, and more are being handed to them soon. Clarifying the goals of the team and developing success metrics would ensure staff are prioritizing the highest risk enforcement work.

Some of the IWM Enforcement Team’s Workload Has Changed Due to Lower Complaints and Shifting Assignments
Overall, the IWM Enforcement team has seen its caseload decline. In 2019, the IWM Enforcement team addressed over 1,500 cases. In 2022, the team only handled 840 cases. One case may involve several inspections if staff find violations and re-visit the site to check on compliance.

Audit of IWM Enforcement Program
14 Exhibit 5: Complaints and Caseload Have Changed Over Time Source: Auditor analysis of IWM Enforcement team data (August 2017 – June 2023) *Data for 2023 only includes January – June.

One factor in this decline is there has been a change in the type of work coming to the team.
 Illegal Dumping: The IWM Enforcement team was previously responsible for enforcement activities around illegal dumping. That responsibility was then transferred to Code Enforcement in 2020 when the funding of illegal dumping cleanup became entirely General Fund supported (the IWM Enforcement team is ratepayer funded).

Per IWM staff, illegal dumping enforcement involved sending letters to addresses when City staff alerted them to possible illegal dumping, investigating who was responsible for dumping, and issuing citations to violators when there was sufficient evidence. Illegal dumping made up about a quarter of the team’s total cases between 2017 and 2020.1  Complaints from the Public: Even accounting for the change in the team’s responsibilities, complaints from the public have decreased in recent years. The decrease began at the beginning of the COVID-19 pandemic, but complaints have not yet rebounded. In 2019, there were over 900 complaints from the public. Of these, nearly 600 were for issues other than illegal dumping. In 2022, there were around 300 complaints from the public—about 1/3 the total in 2019.
1 Some illegal dumping cases may have only involved sending a reminder letter. Of the total cases between 2017 and 2022, roughly 12 percent were for illegal dumping cases in which an inspector found a violation and identified a responsible party.
0 200
400
600
800
1000
1200
1400
1600
2018 2019 2020 2021 2022 2023*
Unauthorized hauler
Other
No collection service
Illegal dumping
Dangerous Accumulation
Container/other, setout
Finding 1
15 Meanwhile, different work has been added or will soon be added to the team’s responsibilities. This includes enforcement of some recently passed legislation and existing ordinances.
 SB 1383: Most notably, the team will be enforcing requirements relating to SB 1383 for commercial properties. Beginning in early 2023, the team started conducting outreach activities to educate businesses about SB 1383 requirements. Staff expect enforcement to begin January 2024.

Staff anticipate that this could involve a significant amount of work. As of April 2023, staff estimated that 6,000 of the 7,500 commercial properties in the city did not yet have the correct bins (or a waiver in place) to comply with the requirements. IWM Enforcement staff expect to begin issuing warning notices in January 2024 to businesses that have yet to comply with the requirements.
 Single-use food service ware ban: Effective 2022, San José enacted a request-only requirement for single-use food service ware accessories and condiments at food service establishments (per Assembly Bill 1276).

IWM staff report that the enforcement of this new law will be complaintbased, with education and outreach provided during normal inspections at food service establishments.
 Single-use carry-out bag ban: Effective 2013, San José enacted a ban on single-use carry-out bags at retail establishments (with some exceptions). The enforcement of this ban has been primarily complaintbased and has been handled by ESD’s Watershed Protection division.

The responsibility transferred to the IWM Enforcement team in July 2023.
 Polystyrene foam disposable food service ware ban: Effective 2014, San José banned all food vendors from providing food in polystyrene foam disposable containers. The enforcement of this ban has been primarily complaint-based and has been handled by the Watershed Protection division. The responsibility transferred to the IWM Enforcement team in July 2023.

During these changes, the IWM Enforcement team has enforced, and continues to enforce, requirements regarding non-authorized haulers, dangerous accumulation of waste, required collection service, and placement/storage of waste bins.

Clearer Goals and Success Metrics Would Help the Team Determine How to Prioritize and Focus Work
The IWM Enforcement team’s policies and procedures describe the purpose of the team as enforcing San José Municipal Code 9.10 regulations on solid waste management and hauler contract provisions.

Audit of IWM Enforcement Program
16 Integrated Waste Management Enforcement Program Purpose To ensure compliance with the San Jose Municipal Code and the various franchise agreements, 4 Environmental Inspectors are dedicated to enforcement related to solid waste management.  Integrated Waste Management (IWM) Enforcement
inspectors conduct complaint-based and proactive
investigations to identify and confirm non-compliance related to SJMC 9.10: Solid Waste Management.
 Inspectors educate property owners, business owners, and residents by providing educational material such as BMPs and recycling guidelines, informing them of solid waste
management requirements, and helping them with corrective action to remedy violations observed.
 Inspectors also ensure that exclusive and non-exclusive franchisees are collecting waste per the terms of their agreements and are meeting requirements for the quality of services to the customer.

Following recent changes to the team’s responsibilities, clear goals can help the IWM Enforcement staff understand how work should be prioritized. For example, staff have indicated that SB 1383 enforcement could involve a significant amount of work. To ensure that staff are responding to the most pressing solid waste management issues, goals and priorities should be established.

Broader goals about the purpose of the program should be coupled with clear metrics for success. Currently, the team has the target to schedule a first inspection within two business days and to provide a 10-day violation response time from the date of the first enforcement letter. As discussed later in this Finding, the team also has daily workload targets for inspectors.

When asked, management described quick response time and customer satisfaction as two measures of success, but the latter is not documented or tracked. Additionally, the response time metrics do not include metrics for timeliness of case closure, outreach activities, or resolution of repeat offenders.

All of these could provide insight into the success of the team’s enforcement activities.

Recommendation:
1: The Environmental Services Department should clarify the Integrated Waste Management Enforcement team’s mission, goals, and role in enforcing section 9.10 of the San José Municipal Code, including reassessing how to prioritize workload and developing success metrics for the team’s
activities.

Finding 1
17 Average Daily Inspections Remain Lower Than Expectations, Though Higher Than Recent Years
In recent years, the IWM Enforcement inspectors have conducted fewer inspections than management expects. The supervisor has communicated to staff a goal to complete four inspections per day. In 2022, inspectors completed less than two inspections per day on average; this increased to more than two per day in the first half of 2023. In addition to the decline in cases from illegal dumping and fewer complaints, IWM staff attribute the decrease in inspections to the short tenure of the inspectors. All the team’s inspectors were hired in the last two years.

Inspections Have Increased, But Remain Lower Than Peak and Lower Than Expectations
As noted previously, the number of cases coming to the team has declined. In 2022, the team received one-third as many complaints from the public as in 2019.

Additionally, staff self-initiated cases on a limited basis during the pandemic and focused on responding to complaints. Self-initiated cases have restarted, and the number of self-initiated cases has grown. Additionally, the team paused on responding to reports from haulers, but has restarted and expanded that work.

The overall result is that inspectors conducted fewer inspections each day. Each case results in one or more inspections: inspectors conduct one initial inspection for a case, and then re-inspect if they find violations.

In 2019, the inspectors each conducted about 3.1
inspections per workday, on average. In 2022, each
inspector conducted an average of 1.8 inspections
per workday. This increased in the first half of 2023
to 2.3 per day. Per ESD, the inspectors on staff in
2019 had more experience, which contributed to the
team handling a larger volume of work.

The IWM procedures state that inspectors should be completing three inspections per day. IWM management has stated that the goal to work towards is for inspectors to complete four inspections per day.

In recent years,
inspectors have
conducted about two
inspections per day.

Audit of IWM Enforcement Program
18 Exhibit 6: Daily Inspections by Inspector Have Varied Over Time
Year Total
Inspections
Average Inspections
per Workday (entire
team)
Average Daily
Inspections per
Inspector
2018 1,980 7.6 2.5
2019 2,170 8.4 3.1
2020 1,160 4.5 2.2
2021 700 2.7 1.5
2022 1,160 4.5 1.8
2023* 830 6.4 2.3
Source: Auditor analysis of IWM inspection records (January 2018 – June 2023). *2023 data is from January 1 – June 30.

Note: The average daily inspections per inspector was calculated based on the active inspectors during that year and uses partial FTE for inspectors that left or joined the team partway through the year.

The number of inspections that an inspector conducts during a given day varies.

Some days, an inspector may conduct only one inspection. On other days, inspectors conduct more than five inspections.

The team has other work beyond inspections that affects inspection workload.

As noted previously, starting in 2023, inspectors began conducting outreach activities for SB 1383. These activities involve field visits to educate business owners about the new bin requirements under state law and the Municipal Code.

Between February and June 2023, the team has conducted an average of about two outreach visits per inspector per week. In June 2023, the inspectors conducted more visits—about one per day, on average.

To understand how inspectors were spending time in the field, we reviewed telematics data to understand City vehicle usage. Based on this review, we referred a concern to the Office of Employee Relations to investigate alleged instances of personal use of a City vehicle and conducting personal business on City time.

Inspectors Respond to Complaints Quickly
Though there is some variation across the city and individual cases, inspectors can generally respond to complaints from the public quickly. In 2022, the median response time to a complaint from the public was the next day. For the same year, staff conducted second inspections for public complaints a median of 17 days after the first inspection. Staff give at least 10 days for a responsible party to resolve the violation. After that, staff schedule second inspections based on several factors, including collection service days.

IWM management reports that the Enforcement team does not usually have a backlog of inspections. In some cases, a batch of complaints comes in which Finding 1
19 needs to be triaged and coordinated among inspectors. For those situations, staff report that response may take longer.

Low Workload Results in Less Enforcement Citywide
Though the Enforcement team conducts fewer field inspections and receives fewer complaints, the need for solid waste enforcement persists. By conducting fewer inspections, whether complaint-based or proactive, the IWM Enforcement team is reaching hundreds fewer residents and businesses with education and corrective actions.

To address this, the IWM Enforcement team should formalize performance expectations. This will communicate to staff the level of service the team is trying to achieve. It also provides management with the opportunity to identify gaps in training or skills that affect good performance. These performance expectations could include the number of daily inspections in addition to other work. If inspectors have assigned outreach or proactive education, this could be incorporated.

Recommendation:
2: The Environmental Services Department should set formal performance expectations for the Integrated Waste
Management Environmental Inspectors’ daily activities, such as inspections, outreach, and other required tasks, and monitor performance in relation to those expectations.

The IWM Enforcement Team Should Update Procedures for Illegal Dumping and Service Interruption Work
As the IWM Enforcement team determines its mission and sets expectations for inspector activities, there are two specific areas that warrant reexamination. The first is reporting instances of illegal dumping. The procedures for reporting illegal dumping do not provide clear guidance, and do not match management expectations. The second area is inspections for businesses that do not have their waste regularly collected by the hauler, either because the account was closed or not paid. To use staff time more efficiently, the team should send reminder letters to businesses before sending staff into the field.

Procedures for Reporting Illegal Dumping Should Be Clarified The IWM Enforcement procedures provide guidance for how inspectors should report instances of illegal dumping to SJ311. However, these procedures do not match management expectations or how inspectors appear to work in the field.

Audit of IWM Enforcement Program
20 The IWM procedures has the section:

Illegal Dumping Referral
Refer complaints San Jose 311, [email protected].

Include a picture and description of information.

The procedures do not specify when an inspector should report instances of illegal dumping. The procedures for conducting proactive inspections list reporting illegal dumping to SJ311 as a Priority 2 task (prioritized lower than most other case types),2 but also do not include specific direction. As noted previously, enforcement related to illegal dumping is performed by Code Enforcement inspectors when possible.

Management and supervisory staff state that inspectors should report illegal dumping that is hazardous or poses a health and safety concern. For example, if the items are blocking the roadway, management expects that inspectors would report those instances to SJ311.

This expectation should be included in the team’s written procedures. It is not clear that inspectors understand what would constitute a hazardous situation and when reporting to SJ311 would be appropriate. In one instance observed by audit staff, an inspector drove past a site with significant illegal dumping and did not report the issue. Additionally, procedures should clarify whether some instances of illegal dumping—such as those with health or safety concerns—should be a higher priority.3
Inspection Procedures for Properties with Closed Accounts or Without Collection Service Should Be Revised
The IWM Enforcement team conducts inspections for commercial properties without garbage service to ensure that any solid waste is being removed and disposed of properly. However, these cases rarely led to other issues of solid waste management (such as dangerous accumulation of waste). To dedicate more staff time to higher priority cases, the team should first send a reminder letter to commercial properties with suspended service. If service is not reinstated, then staff should follow up with an inspection.

The Municipal Code mandates commercial properties have a collection service or be documented self-haulers. If an address does not have service, the City’s commercial garbage hauler sends a letter to the account holder of the suspended 2 Priority 1 case types include: unauthorized hauling, dangerous accumulation, no solid waste collection service, and single-family dwelling improper used oil set-out. Inspectors are instructed not to self-initiate cases for bin setout or storage.
3 Per the City Attorney’s Office, under state law, property related service rate revenue for residential garbage service may only be used for services that directly benefit the property. For this reason, additional actions around illegal dumping may require an increase in funding from the General Fund.

Finding 1
21 account. In addition, the hauler includes accounts without service for 90 days or more, or accounts that have closed completely, in monthly reports to IWM.

The IWM Enforcement team views inspections for service interruption cases as valuable because staff report that not having a collection service could lead to other issues. These could include dangerous accumulation of waste on the property, illegal dumping, or unauthorized use of other properties’ solid waste containers. The team may also find that a new business is operating at the property without weekly collection service.

Prior to 2023, the team visited commercial properties with closed accounts that were determined to be higher risk. Only a few cases of properties with closed accounts resulted in any violations. If the team doesn’t find a violation for a closed account, the business may have closed. In 2023, the team expanded the response to include properties with service interruption as a pilot program. About half of the cases resulted in a violation specifically for not having collection service.

However, only four of the 80 cases had a different type of violation (such as dangerous accumulation or unauthorized hauling). Staff note that in some cases, business owners may avoid issues of dangerous accumulation by improperly removing the waste from the premises.

To help the team focus on higher-risk violations, staff should deprioritize service interruption inspections. Sending a letter to the commercial property owner before sending out an inspector would save staff time. San Francisco's Department of Public Health takes this approach by sending a warning to the property owner that they must reinitiate service. Unlike in San José, staff can then initiate service after a seven-day grace period.4 In San José, commercial collection service is provided under a franchise agreement and is not required if a business is closed.

This approach is already in place for complaints regarding early set-out of bins or carts for single family homes. The team first sends a letter to the address with information about the City’s rules. An inspector is sent out only if another complaint is submitted for the address less than year from the first complaint.

Recommendations:
3: The Environmental Services Department should clarify procedures for when Integrated Waste Management
Environmental Inspectors should notify SJ311 staff of illegal dumping observed in the field, and train staff accordingly. 4 Per staff, residential service is required under the Municipal Code, and a lien could be placed on a property.

Audit of IWM Enforcement Program
22 4: To allow inspectors to focus on higher-risk inspections, the Environmental Services Department should update the
Integrated Waste Management Enforcement team procedures to send reminder notices to properties that have suspended garbage service or closed collection accounts and only conduct inspections if the problem is not resolved.
23 Finding 2 Proactive Cases Should Focus on
Expanding Coverage Citywide
Summary
The current proactive inspection approach can be improved to expand coverage of solid waste enforcement citywide. Per procedures, IWM inspectors may only initiate proactive work if they observe a solid waste violation while out of City Hall for another reason. As a result, proactive cases largely follow the same geographic trends as complaints. To better use proactive cases to augment complaint-based activities, the IWM Enforcement team should update proactive inspection standard operating procedures to target areas of the city with a greater concentration of commercial and multi-family waste collection locations. These procedures should take into consideration the unique characteristics of target neighborhoods to tailor outreach materials appropriately.

The IWM Enforcement Team Should Target Proactive Inspections to Expand Solid Waste Enforcement Coverage
The current proactive inspection program does not effectively expand coverage of solid waste enforcement through inspections and outreach. A proactive program that encourages inspectors to go out to areas that have fewer complaints based on factors such as multi-family housing and commercial density can improve enforcement efforts while creating opportunities for outreach and education.

Current IWM Proactive Inspections Align With Where Cases Are Already Being Reported
Proactive inspections can address concerns for unreported violations. Because of the current structure of the program, proactive coverage may be limited in some areas of the city compared to others. Currently, proactive inspections generally occur while staff is responding to complaints, and thus follow the same geographic trends as complaints received by the City.

Between August 2017 and April 2023, 39 percent of complaints were generated from five zip codes. During that same time, 46 percent of proactive cases took place in the same five zip codes. Although this may signify the need for enforcement in these zip codes, it also illustrates how current proactive enforcement activities may not be addressing the possibility of underreported violations that may occur in other parts of the city.

Audit of IWM Enforcement Program
24 Exhibit 7: Complaints and Proactive Cases by Zip Code Source: Auditor analysis of IWM Enforcement team case data (August 2017 - April 2023) Note: the five zip codes with the most complaints are labeled on each map.

As stated in the Enforcement team’s standard operating procedures for proactive inspections, inspectors may only initiate proactive work if they observe a solid waste violation while out of City Hall for another reason. Inspectors are also only expected to initiate a proactive inspection if they have time. Otherwise, responding to complaints received by the City takes priority. A proactive inspection program that targets areas with fewer inbound complaints for solid waste can improve the team’s coverage citywide while providing inspectors an opportunity to engage additional service recipients through outreach and education.

Multi-family Housing and Commercial Density Could Indicate Where Higher-Priority Solid Waste Violations May Be Occurring Since 2021, multi-family and commercial properties have accounted for 72 percent of cases other than those for bin set-out and storage or that only involved outreach. This indicates that higher-priority solid waste violations can be associated with multi-family and commercial properties. To understand where proactive coverage should be expanded, the IWM Enforcement team should review multi-family housing and commercial density.

Some areas of the city had fewer cases than could be expected given the density of multi-family and commercial properties. Conversely, there were some areas of the city which saw more proactive inspections when compared to the density of commercial and multi-family waste locations.

Finding 2
25 Exhibit 8: Commercial and Multi-Family Waste Collection Locations vs.

Proactive Inspections
Solid waste
collection
locations
Complaints Proactive
cases
North San José/Alviso (95134 and 95002) 580 37 0
Dove Hill/Brigadoon (95121) 77 196 37
Source: Auditor analysis of IWM Enforcement team inspection data (August 2017 – April 2023) Exhibit 9: Commercial and MFD Waste Collection Locations by Zip Code Source: Auditor analysis of IWM Enforcement team inspection data (August 2017 - April 2023) and IWM data on waste collection locations.

Note: The five zip codes with the most proactive cases are labeled on the Proactive Cases map.

IWM’s Proactive Enforcement Program Should Evaluate the Most Effective Ways to Reach Communities With Fewer Solid Waste Complaints The proactive enforcement program does not include guidelines for inspectors to conduct outreach and education, separate from a violation that may have been found in the field. As identified, there are some areas of the city that see fewer complaints for solid waste than expected given the density of commercial and multi-family waste collection locations. In some cases, these neighborhoods can be characterized as having large numbers of limited English proficient households (see Appendix B). This includes the North San José/Alviso neighborhoods as well as the Berryessa/Vinci South neighborhoods.

A more clearly defined proactive inspection program could address where proactive work should occur, and how to reach target audiences. A proactive inspection program engaged in outreach could prioritize education as well. This Audit of IWM Enforcement Program
26 would inform communities with lower complaints about solid waste compliance reporting.

Though complaints from the public have decreased over the past few years, proactive inspections have increased following a drop during the COVID-19 pandemic. However, program constraints limiting when and where inspectors can initiate proactive inspections undermine the goal of expanding coverage of solid waste enforcement.

By revising the proactive enforcement program procedures to include guidelines for inspectors’ routes, time in the field, and approach to education, the Enforcement team could expand its reach to residents and commercial businesses who otherwise may not be aware of their services. This approach could take into consideration the unique characteristics of the target neighborhoods to tailor proactive work accordingly.

Recommendation:
5: To identify potentially unreported violations, the
Environmental Services Department should update the
Integrated Waste Management Enforcement procedures for
proactive inspections to focus inspector attention on areas that have fewer complaints based on factors such as multi-family housing and commercial density, and tailor proactive work based on the needs of identified communities.

27 Finding 3 Streamlining Administrative Tasks
Would Give Inspectors More Time in
the Field
Summary
Administrative tasks related to cases such as data entry and finding a responsible party can be made more efficient to free up inspectors’ time for additional inspections or outreach. The software that the team uses is outdated and was not designed for their needs, making data entry complicated and time-consuming.

Additionally, all inspectors expressed frustration with the amount of time it may take to find a responsible party for violations. Lastly, the practice of reviewing all cases by multiple staff was duplicative and took inspectors from the field. To maximize the time inspectors can spend in the field, we recommend that the IWM Enforcement team procure a new software system and update procedures to streamline other administrative processes.

Administrative Tasks Can Be Time Consuming, Taking Inspectors Out of the Field Data entry and other administrative work relating to an inspection can take a significant portion of time. While this work is important to ensure documentation and follow-up on cases, updates to the IWM Enforcement team’s resources and procedures could make these tasks more efficient. Doing so would maximize the time that inspectors can be in the field responding to complaints, initiating cases, or conducting outreach.

Data Entry Is Inefficient Due to an Outdated Software System Not Designed for the Needs of This Team
Though inspection times can vary depending on the nature of a case, a typical inspection can take about two hours to complete. An inspector may spend less than 20 percent of the time (or just 10-20 minutes) in the field conducting the inspection. Inspectors might spend 50 percent (one hour) of the case on research, data entry, and other administrative tasks (such as corresponding with property owners or violators).

Based on available data and observation, a sample case can involve the following steps:
 Initial research: The process starts with some initial research and basic data entry for a complaint in the office, which can take about five to ten minutes.

Audit of IWM Enforcement Program
28  Drive time: Travel time to an inspection varies significantly based on the distance from City Hall but can take about 20 minutes.  Inspection: Once they arrive at the location, the inspector conducts a field inspection. For 2022 inspections with recorded data available, 73 percent took between 10-20 minutes. Exhibit 10 includes an estimate of 20 minutes for the onsite inspection time.
 Drive time: After the inspection, the inspector might do some data entry in the car, drive directly to their next inspection, or drive back to City Hall. Again, travel time varies, but can take about 20 minutes.  Research and data entry after inspection: When inspectors return to City Hall, they complete the research and data entry. This can take about 50 minutes per case.

Exhibit 10: Inspection of a Sample Case Takes 2 Hours
Source: Auditor estimation based on data
analysis, staff interviews, and observation of
processes.

Finding 2
29 Data Entry Requires Two Software Platforms and a Shared Folder System There are 11-12 steps in the data entry process. See Exhibit 11 for a simplified data entry workflow. The team uses two different software platforms along with a shared folder system.5 The two software platforms generate different letters for the team to send following inspections. The shared folder stores documents such as photos taken during the inspection, responsible party contact information verification, copies of letters sent, and documentation of supervisory approval of an Administrative Citation when applicable.

Exhibit 11: Data Entry Requires Multiple Steps in Two Software Platforms
Source: Auditor analysis of procedures and observation of inspector data entry.

Note: Each step indicates a data entry point (e.g., General Information) or specific action (e.g., Sync Software) in the process
5 The two systems are: iPACS and FAST. The iPACS database is a live, web-based system. This houses the team’s data.

There is a second component, called FAST (Field Assistance Service Tracking), that the inspectors use to enter information in the field that does not require an internet connection. Data entered in FAST is then synced back to iPACS.

Audit of IWM Enforcement Program
30 The process for data entry is cumbersome, requiring inspectors to navigate multiple tabs and fields in two software platforms. It also requires re-entering similar information in multiple places (e.g., steps 1, 4, 7, 9, and 12b in Exhibit 11).

In addition, the database, which was procured in 2012, is slow to sync. Lastly, according to staff, it is also prone to glitches that can lock out users, and which require support from the Information Technology Department to resolve.

It should be noted that the database was designed to serve the needs of ESD’s Watershed Protection program, not the IWM Enforcement team. The IWM Enforcement team does not use most of the features of the database and agree they need a streamlined and up-to-date database. Staff have identified features that they hope to incorporate into an upcoming Request for Proposal for a new database (shared with Watershed Protection).

Other jurisdictions such as San Diego and Long Beach reported using more updated systems to track their work. San Diego uses Salesforce which saves work orders, inspection reports, documents, and pictures. In Long Beach, staff report that the way data is stored by account holder makes data entry less time consuming.

Finding a Responsible Party Can Be a Frustrating and TimeConsuming Process for Inspectors For each case, an inspector attempts to locate the person or business responsible for creating the solid waste problem. The responsible party may or may not be the actual property owner. Locating the correct responsible party helps ensure the issue gets addressed but can take time.

All four inspectors expressed frustration with locating responsible parties, finding it challenging and time-consuming. Per the Senior Environmental Inspector, the expectation is that researching the contact information of a business owner and/or the responsible party should take five to ten minutes. However, in some cases, it takes inspectors longer. The current procedures recommend an internet search if information was not available in the commonly used databases. While such a search could be fast and effective, it could also be time-consuming and fruitless.

A revised procedure that clarifies the extent of research inspectors should undertake to search for the responsible party would make this task more straightforward. If an inspector cannot find a business owner or additional responsible party after a limited search, they should send letters to the property owner which should be easier to locate in the databases. Reminding inspectors of available databases and adding to the procedures clearer expectations for the process would balance the time in the field with time spent finding a responsible party.

Finding 2
31 The Peer Review/Quality Assurance Process Was a Duplicative Administrative Task That Took Inspectors Away From The Field At the end of 2022, a peer review/quality assurance process was put in place as a pilot program. It required all cases be reviewed by both a different inspector and the Senior Environmental Inspector. The intent of the peer reviews was to catch errors and promote consistency. However, having all cases reviewed by multiple inspectors was duplicative, and took inspectors’ time that could otherwise have been spent in the field.

During this audit, staff decided that the pilot program would not be continued.

Instead, the supervisor will review all cases to ensure violations are enforced correctly. The supervisor intends to debrief trends of reviews during team meetings as a continuous learning opportunity for inspectors. The supervisor also intends to discuss specific concerns with inspectors on an individual basis.

This accomplishes the goal of promoting accuracy and consistency in a more efficient way than multiple rounds of reviews.

Efficient Administrative Processes Can Save Inspectors Time for Additional Work in the Field
If inspectors reduced time on administrative duties, they would have additional time for other work in the field, such as responding to complaints or conducting proactive inspections or outreach. As an example, if data entry and research was limited to just 30-40 minutes (as opposed to an estimated 60), inspectors could have time to do one additional daily inspection. The cost of potential time savings if all four Environmental Inspectors had an extra hour per day because they were spending less time on data entry or other administrative work equates to about $77,000 per year. This helps the City maximize inspector resources.

Recommendations:
6: The Environmental Services Department should procure a new software solution for the Integrated Waste Management team that allows for streamlined data entry and management to free up time for inspectors to spend more time in the field. 7: To maximize the time that inspectors spend in the field, the Environmental Services Department should update the
Integrated Waste Management Enforcement procedures to
clarify the extent of research appropriate to find a responsible party, or when to contact a property owner if contact
information for a tenant or other responsible party is not readily accessible.

Audit of IWM Enforcement Program
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33 Conclusion
The IWM Enforcement team responds to complaints and initiates cases to enforce solid waste regulations. However, workload has been lower in recent years, leading to fewer enforcement activities. Clearer goals and success metrics, along with performance expectations for inspectors, would improve the team’s performance.

ESD should ensure that the team is spending time on the highest priority solid waste enforcement. This includes revisiting how the team prioritizes proactive work and reducing the amount of time on administrative tasks.

RECOMMENDATIONS
Finding 1: ESD Should Clarify the Mission and Workload Expectations of the IWM Enforcement Team
Recommendation #1: The Environmental Services Department should clarify the Integrated Waste Management Enforcement team’s mission, goals, and role in enforcing section 9.10 of the San José Municipal Code, including reassessing how to prioritize workload and developing success metrics for the team’s activities.

Recommendation #2: The Environmental Services Department should set formal performance expectations for the Integrated Waste Management Environmental Inspectors’ daily activities, such as inspections, outreach, and other required tasks, and monitor performance in relation to those expectations.

Recommendation #3: The Environmental Services Department should clarify procedures for when Integrated Waste Management Environmental Inspectors should notify SJ311 staff of illegal dumping observed in the field, and train staff accordingly.

Recommendation #4: To allow inspectors to focus on higher-risk inspections, the Environmental Services Department should update the Integrated Waste Management Enforcement team procedures to send reminder notices to properties that have suspended garbage service or closed collection accounts and only conduct inspections if the problem is not resolved.

Finding 2: Proactive Cases Should Focus on Expanding Coverage Citywide Recommendation #5: To identify potentially unreported violations, the Environmental Services Department should update the Integrated Waste Management Enforcement procedures for proactive inspections to focus inspector attention on areas that have fewer complaints based on factors such as multi-family housing and commercial density, and tailor proactive work based on the needs of identified communities.

Finding 3: Streamlining Administrative Tasks Would Give Inspectors More Time in the Field
Recommendation #6: The Environmental Services Department should procure a new software solution for the Integrated Waste Management team that allows for streamlined data entry and management to free up time for inspectors to spend more time in the field.

Audit of IWM Enforcement Program
34 Recommendation #7: To maximize the time that inspectors spend in the field, the Environmental Services Department should update the Integrated Waste Management Enforcement procedures to clarify the extent of research appropriate to find a responsible party, or when to contact a property owner if contact information for a tenant or other responsible party is not readily accessible.

APPENDIX A
Audit Objective, Scope, and Methodology
A-1
The mission of the City Auditor’s Office is to independently assess and report on City operations and services. The audit function is an essential element of San José’s public accountability, and our audits provide the City Council, City management, and the general public with independent and objective information regarding the economy, efficiency, effectiveness, and equity of City operations and services.

In accordance with the City Auditor’s Fiscal Year (FY) 2023-24 Audit Work Plan, we have completed an audit of the Integrated Waste Management (IWM) Enforcement Program’s service delivery. The objective of the audit was to evaluate the Integrated Waste Management (IWM) Enforcement Program’s service delivery.

We conducted this performance audit in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives.

We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.

To meet our audit objectives, we did the following:
 Reviewed Municipal Code section 9.10 and state regulations to understand solid waste regulations enforced by this team.
 Reviewed budget information to understand funding breakdown of this team.  Reviewed garbage and recycling hauler contracts to understand enforcement responsibilities.  Reviewed IWM Enforcement team policies and procedures to understand guidance provided to staff.
 Interviewed staff to understand the inspection process. This included staff from:
o IWM Enforcement team staff to understand how work is performed. o IWM Commercial and Residential contract management teams. o Planning, Building & Code Enforcement (PBCE) to understand the responsibilities of Code Enforcement team and how they coordinate work with IWM. o Parks, Recreation & Neighborhood Services RAPID team to understand illegal dumping work and coordination with other City teams.
o The City Attorney’s office regarding responsibilities based on Municipal Code and funding.  Accompanied inspectors on field visits and observed administrative duties to review the inspection process and required work.
 Created flowcharts to document procedures and steps to complete a case.  Reviewed inspection data dating back to 2017 to understand trend in inspections, including:
o Types of cases, including by violation, enforcement action taken, and complainant.

A-2
o Inspections completed by inspector.
o Geographic distribution of cases including by inspector zone, by zip code, and by type. o Timeliness to respond to complaints, including by violation type, complaint, and inspector.  Reviewed logs of incoming complaints and letters sent for early bin set-out.  Reviewed data relating to illegal dumping complaints to SJ311 and Code Enforcement cases and inspections.
 Reviewed the outreach materials this team distributes to learn about education provided.  Reviewed information on vehicle telematics/GPS tracking along with timecard and inspection data to determine how inspectors were spending time in the field.  Mapped cases geographically in ArcGIS to better understand the distribution of cases, and compared to other factors such as languages spoken, household income, and waste collection locations.
 Benchmarked other jurisdictions to understand how the City’s solid waste enforcement program compared to peers, including the cities of San Diego, Long Beach, Sacramento, and San Francisco, including interviewing staff and reviewing funding sources, and other jurisdictions’ municipal codes.

We would like to thank the Department of Environmental Services, along with the City Attorney’s Office and the City Manager’s Budget Office, and staff from Planning, Building & Code Enforcement and Parks, Recreation & Neighborhood Services for their time and insight during the audit process.

APPENDIX B
Map of Limited English Proficiency by Census Tract
B-1
Source: 2021 equity index scores for percent of population with limited English proficiency by census tract.

B-2
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TO: JOSEPH ROIS, FROM: Kerrie Romanow

CITY AUDITOR
SUBJECT: SEE BELOW DATE: August 22, 2023
Approved Date

INFORMATION
SUBJECT: RESPONSE TO THE CITY AUDITOR REPORT ON INTEGRATED WASTE MANAGEMENT ENFORCEMENT PROGRAM: CLARIFYING

GOALS AND PERFORMANCE EXPECTATIONS WOULD IMPROVE

ENFORCEMENT COVERAGE
The Administration has reviewed the report from the City Auditor entitled Integrated Waste Management Enforcement Program: Clarifying Goals and Performance Expectations Would Improve Enforcement Coverage, which contains 7 recommendations, described below. The Administration’s responses to each of the City Auditor’s recommendations are provided in this report.

Consistent with other priority-setting processes, the City Council adopted a new framework for the Administration’s response to Audit recommendations in May 2015. As with other priority processes, the green, yellow, and red, light system is utilized to convey the Administration’s operational readiness to undertake workload demands. Green administration responses represent items that are either in existing work plans or are part of work already underway. Yellow administration responses represent items that would take more than 40 hours including research and policy/ordinance development. The Administration’s response to each of the Audit’s recommendations is presented below employing the green, yellow, and red, light system consistent with City Council direction in May 2015.

BACKGROUND
The objective of the audit was to evaluate the Integrated Waste Management (IWM) Enforcement Program’s service delivery, in accordance with the City Auditor’s Fiscal Year (FY) 2023-24 Audit Work Plan.
08/22/23
JOE ROIS, CITY AUDITOR August 22, 2023
Subject: Response to the City Auditor Report on Integrated Waste Management Enforcement Program

Page 2 ends

RECOMMENDATIONS AND ADMINISTRATION’S RESPONSE
Finding I: ESD Should Clarify the Mission and Workload Expectations of the IWM Enforcement Team
Recommendation #1: The Environmental Services Department should clarify the Integrated Waste Management Enforcement team’s mission, goals, and role in enforcing section 9.10 of the San José Municipal Code, including reassessing how to prioritize workload and developing success metrics for the team’s activities.