FINAL REPORT
City of Stockton
SOLID WASTE VENDOR MANAGEMENT FOLLOW- UP REVIEW
October 5, 2023
Moss Adams LLP
999 Third Avenue, Suite 2800
Seattle, WA 98104
(206) 302-6500
Attachment A
Solid Waste Vendor Management Follow-Up Review
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Table of Contents
Executive Summary 1
Scope and Methodology 3
A. Background 3
B. Scope and Methodology 3
Commendations 5
Follow-Up Results 6
A. City Observations 6
B. Contract Compliance 9
C. Hauler Coordination 14
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EXECUTIVE SUMMARY
The City of Stockton (the City) engaged its internal auditor, Moss Adams LLP (Moss Adams) , to conduct a follow-up review of the Solid Waste Vendor Management Review conducted by Moss Adams in 2021. The prior review evaluated the performance of the City’s solid waste haulers (the Haulers) in comparison to contract terms and industry best practices, including operational efficiency and effectiveness, compliance with contract terms, communication and reporting, and collaboration with the City, vendors, customers, and other stakeholders. We also assessed the City’s structure and operations for oversight of the franchise agreements for efficiency, effectiveness, and alignment with best practices.
Overall, we found the City has made progress in almost all areas of the prior report. We found that one prior recommendation was implemented, six were partially implemented and one was not implemented. Most of the prior observations were not fully implemented due to staffing and capacity challenges at the City. Below is a summary of the implementation status of the recommendations from the previous review. This follow-up review was conducted between May 2023 and October 2023.
SUBCATEGORY PRIOR RECOMMENDATION S
CURRENT
STATUS
City Contract Management Observations
Contract
Management
Staffing Levels
Prioritize hiring for currently vacant positions to support adequate staff resources dedicated to contract management.
As vacancies are filled, Waste and Recycling should ensure roles, responsibilities, and authority are clear to support appropriate delegation and strong contract management practices.
Partially
Implemented
Contract
Management
Training and
Resources
Develop formal contract management policies and procedures and incorporate financial and nonfinancial components into ongoing management practices.
Provide employees with contract management responsibility the commensurate training to support success in this role.
Partially
Implemented
Contract Compliance Observations
Reporting
Requirements
Update the report templates with the requirements set forth in the franchise agreements that went into effect on January 1, 2020.
Leverage the newly hired Administrative Analyst to oversee reporting to ensure compliance and proactive performance monitoring.
Partially
Implemented
Performance
Reporting
Framework
In coordination with the Haulers, define key terms and establish a plan for reporting and discussing performance measures.
Partially
Implemented
Attachment A
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SUBCATEGORY PRIOR RECOMMENDATION S
CURRENT
STATUS
Composition
Study
The Haulers should conduct a composition study as soon as possible to define baseline levels of contamination for ongoing evaluation.
The City should establish a schedule for future waste composition studies to support compliance with performance measures established in the franchise agreements and SB 1383
requirements.
Not
Implemented
Billing
Transition
Establish clear policies, procedures, and expectations for ongoing billing practices between all parties to support a consistent experience for all Stockton residents.
Implemented
Hauler Coordination Observations
Overage and
Contamination
The City and the Haulers should jointly develop an SB 1383 implementation plan for overage and contamination processes and fees that provides consistent and equitable outcomes for residents across the City.
Partially
Implemented
Public
Education and
Outreach
The City and the Haulers should coordinate to improve annual public education and outreach planning and support a consistent experience across the community.
Additionally, Stockton residents would benefit from a coordinated media campaign to support a common understanding of SB 1383 requirements, and how it applies to their specific Hauler.
Implemented
While the purpose of this engagement was to follow-up on past recommendations, we identified the following additional recommendations to support continued improvement of the City’s management over its franchise agreements with the Haulers. All prior recommendations that have not been fully implemented still apply.
• To better align with industry practices and improve the City’s ability to monitor the accuracy of franchise fee remittances from the Haulers, the City should require the Haulers to complete an annual financial statement audit specific to their agreements with the City. • To further improve the City’s ability to monitor the accuracy of franchise fee remittances , Waste and Recycling should perform due diligence on Hauler billing practices, including reviewing monthly transaction billing reports for accuracy, performing spot checks of invoices to verify customers are billed correctly, and conducting trend analysis to identify potential concerns or anomalies.
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SCOPE AND METHODOLOGY
The City of Stockton (the City) contracts with Republic Services and Waste Management (the Haulers) to provide solid waste services to the City. The City executed new 10- year contracts (franchise agreements) with the Haulers, effective January 1, 2020, that are identical to one another.
These franchise agreements were designed, in part, to address compliance with state law, including the Short-Lived Climate Pollutants Act of 2016 (SB 1383). SB 1383 is a regulation intended to reduce emissions of short-lived climate pollutants by reducing organic waste disposal in landfills and diverting organic material, such as food scraps and paper products, to composting or recycling facilities.
The Haulers each serve a designated residential area and commercial customers are able to select their preferred provider. The City’s Waste and Recycling Division (the Division) within the Public Works Department is responsible for overseeing both franchise agreements.
The City engaged its internal auditor, Moss Adams LLP (Moss Adams), to conduct a follow-up review on the Solid Waste Vendor Management Review conducted by Moss Adams in 2021. The prior review included an assessment of the City’s franchise agreements with the Haulers to evaluate their performance compared to contract terms and industry best practices, including:
• Operational efficiency and effectiveness
• Compliance with contract terms and relevant laws and regulations • Internal controls
• Policies and procedures
• Communications and reporting
• Collaboration between the City, vendors, customers, and other stakeholders The original review also assessed the City’s structure and operations for oversight of the franchise agreement for efficiency, effectiveness, and alignment with best practices.
This follow-up review was informed by interviews with City and Hauler staff, a review of documents, billing testing, and research into industry best practices. The review was conducted from May 2023 to October 2023, and consisted of four phases:
1. Project Initiation and Management: This phase concentrated on comprehensive project planning and project management, including scope setting, identifying staff to interview and documents to review, communicating the project plan, and establishing a strategy for execution.
2. Fact Finding: This phase included staff interviews, document review, billing testing, and research into industry standards. We worked with City and Hauler staff to obtain the most current information and insights.
○ Interviews: We conducted interviews with City staff within Waste and Recycling and the Administrative Services Department, as well as Waste Management and Republic Services Attachment A
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staff, to gain insights into the current operational environment and the status of prior recommendations.
○ Document Review: We reviewed a variety of documents, data, and information provided by the City and the Haulers, including planning materials, organizational charts, franchise agreements, quarterly reports from the Haulers, education and outreach materials, and policies and procedures.
○ Testing: We conducted testing on each of the Haulers cash receipts transaction details to ensure the Haulers remitted accurate franchise fee amounts to the City for Q4 2022.
3. Analysis: This phase served as the assessment portion of the project. Based on the information gathered, we evaluated the importance, impact, and scope of our observations in order to document progress in achieving prior recommendations.
4. Reporting: This phase concluded the project. We reviewed draft observations and recommendations with City leadership to validate facts and confirm the practicality of recommendations. We provided a finalized report and presentation to the City’s Audit Committee.
Attachment A
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COMMENDATIONS
The purpose of this section is to highlight the hard work and continued efforts of C ity staff in promoting effective, high-quality waste and recycling services. The following is a list of commendations that the Moss Adams team would like to note:
• City staff have made progress on prior recommendations. Despite capacity challenges, one recommendation has been fully implemented and six have been partially implemented. • The City continues to maintain strong relationships with the two Haulers and the Haulers reported effective collaboration. This contributed to a successful transition of billing from the City to the Haulers.
• The City has made continued progress in achieving compliance with SB 1383 through increased community education and outreach.
We would like to commend the City and the Haulers for their willingness to assist us in this follow -up review process.
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FOLLOW-UP RESULTS
1. Prior Observation Due to several vacant positions, staffing levels for solid waste contract m
anagement are low in comparison to peer cities; existing staff who support the contract lack capacity to fully address all elements of the contract, such as reporting and performance monitoring.
Prior
Recommendation
A. P rioritize hiring for currently vacant positions to support adequate staff resources dedicated to contract management.
B. As vacancies are filled, ensure roles, responsibilities, and authority are clear to support appropriate delegation and strong contract management practices.
Implementation
Status
Partially Implemented
In our last review we found Waste and Recycling lacked capacity to fully address all elements of the franchise agreements with the Haulers such as reporting and performance monitoring. As noted in our last review, this lack of capacity was due to low staffing levels in solid waste contract management in comparison to peer cities and several vacant positions in the Division. We recommended the City prioritize hiring for vacant positions within the Division to support adequate staff resources dedicated to overseeing the franchise agreements with the Haulers. We also recommended Waste and Recycling ensure there were clear roles, responsibilities, and authority detailed for any new positions that were filled.
Currently, Waste and Recycling still has several vacancies and continues to struggle with having enough capacity to effectively oversee the franchise agreements with the Haulers. T here are currently six vacancies in the Division, with one position posted as of September 2023. Given these staffing challenges, many positions continue to be stretched thin with high workloads. Management reported Waste and Recycling has faced challenges in keeping positions filled due to promotional opportunities in other departments. For example, the Division has hired two different projec t managers and an administrative analyst who have since left due to promotional opportunities elsewhere. Public Works also has competing staffing priorities in other areas of the Department, limiting the ability to prioritize hiring for Waste and Recycling given other pressing departmental needs.
Staffing challenges continue to impact Waste and Recycling’s ability to effectively manage oversight of the City’s franchise agreements with its Haulers, which is important to ensure the Haulers are meeting performance expectations. The Solid Waste Manager, who is primarily responsible for the contracts between Waste Management and Republic Services, works hard to manage the contracts but does not have the capacity to fully complete all contract oversight responsibilities given the high Attachment A
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workload of this role, which is exacerbated by vacancies throughout the Division. Additionally, limited capacity across staff has made it difficult to train staff on oversight responsibilities or to delegate these tasks. This not only limits the City’s ability to effectively monitor Hauler performance, but it also creates risks in continuity of operations and succession planning. Staff reported capacity challenges have also impacted the City’s ability to review Hauler marketing materials timely, which can create challenges if materials are not approved in time for their planned outreach activities.
Due to these challenges, the City has been limited in its ability to make progress in implementing our prior recommendations. We continue to recommend the City prioritize the hiring of vacant positions to support adequate staff resources dedicated to management of the franchise agreements. As vacancies are filled, Waste and Recycling should ensure roles, responsibilities, and authority are clear to support appropriate delegation and strong contract management practices.
2. Prior Observation The City lacks contract management policies and procedures as well as t
raining for staff who manage large multi-faceted contracts.
Prior
Recommendation
A. D evelop formal contract management policies and procedures and incorporate financial and nonfinancial components into ongoing management practices.
B. Provide employees with contract management responsibility the commensurate training to support success in this role.
Implementation
Status
Partially Implemented
In the prior review we found the City lacked contract management policies and procedures as well as training for staff who manage large multi-faceted contracts. We recommended the City develop formal contract management policies and procedures and incorporate financial and nonfinancial components into ongoing contract management practices. We also recommended the City provide employees with contract management responsibility the commensurate training to support success in their roles.
Since the prior review, the City has made progress on but has not finalized contract management policies and procedures. Additionally, the City has not provided contract management training to staff.
The City should have Citywide contract management policies and procedures that apply to all departments and divisions, while departments and divisions should have additional procedures as needed to clarify roles, responsibilities, and required activities specific to their unique contract management needs. While not finalized, the City has documented draft contract management policies and procedures which are incorporated into the Procurement Operations Procedure Manual that is expected to be finalized by the end of 2023. The draft policies and procedures include general guidance on how to monitor contract performance throughout the City and will support departments in their contract oversight responsibilities.
Waste and Recycling does not yet have formalized procedures specific to monitoring its franchise agreements with the Haulers. These procedures would be helpful to clarify roles and responsibilities Attachment A
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across the Division as it relates to the franchise agreements and support a clear and consistent understanding of the steps that should be taken. While the Division would like to develop formalized procedures for managing the franchise agreements, the Division’s challenges with staffing vacancies have limited the Division’s capacity to do so. Documented policies and procedures will help aid in delegation as well as operational continuity given current the reliance on the Solid Waste Manager.
In addition to the City prioritizing finalization of the Procurement Operations Manual, we continue to recommend Waste and Recycling develop and finalize procedures for overseeing the Hauler franchise agreements to accompany the Citywide contract management policies and procedures. To meet the needs of the Division and in alignment with best practices from the National Institute of Governmental Purchasing (NIGP)
1, these procedures should clearly define responsibilities and activities in at least the following areas:
• Overseeing the franchise agreement
• Reviewing quarterly and annual Hauler reports for completion • Monitoring Hauler performance and compliance on a regular basis, including verif ying performance targets and timelines are met and ensuring compliance • Coordinating with the Haulers and City Procurement on any identified issues • Complying with the City’s contract management policies and procedures • Reviewing the Hauler franchise fee remittances for accuracy • Organizing and documenting related files, including reports and communications between the City and the Haulers
• Handling dispute resolution practices with the Haulers, including escalations The City should also provide contract management training to those involved with contract administration and oversight, including staff in Waste and Recycling. Since our last review , there has been no additional contract management training provided to staff. Training is important in developing skilled, knowledgeable staff who can be experts in the field and enhance performance. Waste and Recycling should also continue to provide training to its staff as needed to support success in their roles overseeing the franchise agreements, such as training on specific performance requirements, SB 1383 compliance, and financial reviews.
1 National Institute of Governmental Purchasing, Global Best Practice, Contract Administration (pdf) Attachment A
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3. Prior Observation The City has not u pdated its reporting template with the information required as part of the updated franchise agreements; therefore, the reporting provided by the Haulers does not fully align with contractual requirements.
Prior
Recommendation
A. U pdate the report template s with the requirements set forth in the franchise agreements that went into effect on January 1, 2020.
B. Leverage the newly hired Administrative Analyst to oversee reporting to ensure compliance and proactive performance monitoring.
Implementation
Status
Partially Implemented
In the prior review we found the City had not updated its quarterly reporting templates to align with the franchise agreements and the Haulers were not reporting in compliance with the contractual requirements. We recommended the City update the reporting template with the requirements set forth in the franchise agreements. We also recommended the City leverage the newly hired Administrative Analyst to oversee reporting to ensure the Haulers were reporting timely and in compliance with the franchise agreement.
The City has partially implemented these recommendations. After the prior review, the City contracted with a consultant knowledgeable in SB 1383 to help the City update the Hauler reporting template.
The consultant created a detailed template in coordination with the City and its Haulers that was rolled out at the end of November 2022.
The updated template includes the required reporting elements from the franchise agreements.
However, we reviewed both Haulers’ calendar year Q4 2022 and Q1 2023 reports and found the Haulers did not consistently complete the reporting template. Examples of sections that were unreported are included in the following table. The Division is aware of this issue and has been working with the Haulers to support more thorough completion of the templates moving forward.
REPORTING TAB REPUBLIC SERVICES WASTE MANAGEMENT
Service Exemptions Not reported Not reported
Outreach Activities Reported Not reported
O&E Budget Partially reported Not reported
Planned Technical Assistance Not reported Not reported
Summary Assessments of the Program Not reported Not reported Attachment A
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Waste and Recycling also made efforts to leverage the Administrative Analyst for reporting. The Solid Waste Manager is primarily responsible for monitoring all Hauler reporting and has begun to involve the Administrative Analyst to help oversee reporting. However, neither the Solid Waste Manager nor the Administrative Analyst have the capacity to fully monitor report compliance, given the ongoing staffing challenges and vacancies in the Division previously noted. Since the reporting template is designed to capture information related to the Hauler’s compliance with the franchise agreements and SB 1383, not effectively monitoring its completion creates compliance and performance risks.
As recommended in the section on Contract Management Staffing Levels, to support Hauler report monitoring, the City—specifically Public Works and Human Resources—should prioritize hiring for currently vacant positions to support adequate staff resources dedicated to contract management.
Without staff to review and monitor the Haulers performance and compliance, the City is at risk of noncompliance or poor performance from its Haulers.
In the meantime, Waste and Recycling should continue training and leveraging the Administrative A
nalyst to take on more contract management responsibilities. This should include reviewing the quarterly reports for completeness and performing trend analysis by reviewing the changes in each reporting section over the year to analyze performance over time. If notable variances or issues appear in a particular month, staff should communicate with the Haulers to understand changes and improve performance.
4. Prior Observation Although there are performance standards included in the franchise ag
reements, there are no reporting requirements directly linked to these measures and staff report that many of the definitions are ambiguous.
Prior
Recommendation
In coordination with the Haulers, define key terms and establish a plan f
or reporting and discussing performance measures.
Implementation
Status
Partially Implemented
In the previous review, we observed that although there were performance standards included in Exhibit F of the franchise agreements, there were no reporting requirements directly linked to the measures and staff reported that many of the definitions were ambiguous or difficult to measure. We recommended the City, in coordination with the Haulers, define key terms and establish a plan for reporting and discussing performance measures.
As noted in the section on Reporting Requirements, the new reporting template was rolled out at the end of November 2022. The reporting template includes reporting for some of the performance standards listed in Exhibit F such as those related to missed collections and outreach activities but does not include reporting for most of the performance standards listed in the Exhibit. This includes performance standards related to resolving complaints, answering phones, and maintaining vehicles and equipment. Performance standards that are not reported on and monitored are not useful and do not provide opportunities for improvement. The performance standards in the franchise agreements Attachment A
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are intended to ensure community members receive a specified level of service and if they are not effectively monitored, there is no way to hold the Haulers accountable for their service provision.
In interviews with the Haulers, they did not note any performance metrics that were confusing or ambiguous; however, the City reported that the performance standards in the agreements are presented in a way that makes it difficult for the City to hold the Haulers accountable for some performance metrics. For example, one performance metric enables the Haulers to miss 84 weeks of collections before needing to report missed services to the City.
As previously recommended, the City should coordinate with the Haulers to establish a plan for monitoring, reporting on, and discussing performance measures included in the franchise agreements. Monitoring processes will vary depending on the specific performance measures, but might include processes for regularly reviewing complaints, conducting regular inspections of Hauler records or equipment, and interviewing residents. Additionally, the City should continue to work with the Haulers to ensure performance measures are clear and well understood across all parties and to revise performance measures as needed to ensure they are meaningful.
5. Prior Observation Section 5.12 of the franchise agreements require the Haulers to complete a composition study to define the baseline level of contamination used to evaluate diversion over time; however, these studies have not been completed.
Prior
Recommendation
A. T he Haulers should conduct a composition study as soon as possible to define baseline levels of Contamination for ongoing evaluation.
B. The City should establish a schedule for future waste composition studies to support compliance with performance measures established in the franchise agreements and SB 1383 requirements.
Implementation
Status
Not Implemented
In the previous review, we found the Haulers had not completed a composition study required by the franchise agreements. We recommended the Haulers conduct a composition study to define baseline levels of Contamination for ongoing evaluation. We also recommended the City establi sh a schedule for future waste composition studies to support compliance with performance measures.
Neither of these recommendations had been implemented. Neither Hauler has completed a composition study and the City has also not enforced this requirement due to other State compliance priorities. These priorities, as included in the franchise agreements, include efforts to gain organic bin compliance for commercial customers related to SB 1383 and public education and outreach in the community.
Attachment A
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We continue to recommend the City require the Haulers complete a composition study this year as required by the franchise agreements; the results of the study can be used as a basis for future performance metrics. According to the franchise agreements, the City can require up to five additional Solid Waste composition studies during the agreement term (Exhibit E. 1.C.). These composition studies are intended to establish the baseline contamination rates to help monitor performance with SB 1383 and may be used to help determine appropriate performance metric standards in future agreements. According to the City, they are internally discussing enforcing this requirement in 2024.
6. Prior Observation The billing transition has lacked a comprehensive plan for the transition and subsequent management of billing practices to support a seamless transition for the City, the Haulers, and, ultimately, Stockton residents.
Prior
Recommendation
Establish clear policies, procedures, and expectations for ongoing b
illing practices between all parties to support a consistent experience for all Stockton residents.
Implementation
Status
Implemented
Additional
Recommendations
A. T he City should require the Haulers to complete an annual financial statement audit specific to their agreements with the City.
B. Waste and Recycling should perform due diligence on Hauler billing practices, including reviewing monthly transaction billing reports for accuracy, performing spot checks of invoices to verify customers are billed correctly, and conducting trend analysis to identify potential concerns or anomalies.
In the prior review we observed that the billing transition lacked a comprehensive plan for the transition and subsequent management of billing practices to support a seamless transition for all involved parties including Stockton residents. We recommended the City establish clear policies, procedures, and expectations for ongoing billing practices between all parties to support a consistent experience for all Stockton residents.
This recommendation was implemented and the billing transition was completed in July 2022. All parties indicated that collaboration and coordination was strong throughout the process and there continues to be strong communication as issues or questions arise. Staff reported part of this success was due to coordinated efforts between the City and its Haulers on public education and outreach regarding the billing transition. This reportedly reduced the number of upset customers and misaligned accounts.
While the billing transition was successfully implemented, the City has not established an effective or consistent process for monitoring the Haulers’ franchise fee remittances now that the Haulers are managing customer billing. Both of the City’s Haulers are required to remit a franchise fee equal to
23.5% of gross receipts for all services performed. While the Haulers have remitted fees, Waste and Attachment A
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Recycling has not consistently analyzed the Haulers’ billing details or done spot checks on customer invoices to ensure the City is receiving the correct franchise fees. Additionally, the City does not currently require the Haulers to complete an annual financial statement audit specific to its agreement with Stockton, though the franchise agreements state the City may conduct up to three detailed financial audits during the agreement term. An annual financial statement audit is standard practice in the industry and will provide greater assurance to the City that the Haulers are remitting accurate fee amounts to the City.
We conducted testing on both Haulers’ franchise fee remittance amounts for Quarter 4, 2022 to confirm the detailed transaction listings of gross receipts collected for the period agree to the 23.5% fee the City received for the period. We found Republic Services accurately remitted the franchise fee amount to the City for Quarter 4, 2022. In reviewing the detailed gross receipts reports for Waste Management, we found a small variance between the franchise fee amount reported by Waste Management from Stockton’s posted franchise fee amount for the period. Waste Management reported this difference was due to adjustments to customer accounts made after the fees were remitted to the City.
To better align with industry practices and improve the City’s ability to monitor the accuracy of franchise fee remittances, the City should require the Haulers to complete an annual financial statement audit specific to Stockton’s franchise. Waste and Recycling should also perform additional due diligence on Hauler billing practices, including:
• Reviewing the Hauler’s monthly transaction billing reports to confirm the amount of revenue remitted to the City each month is accurate.
• Performing spot checks of vendor invoices against Haulers’ transaction listings to ensure the Haulers are billing customers correctly and remitting the customer amount to the City in accordance with the franchise agreements. These spot checks may be done with view access to the Haulers’ finance systems. The City should also work with Waste Management to gain view access to billing information, since this is currently not available. • Performing trend analysis to better identify if or when billing may look off from month to month.
Performing these due diligence requirements will help the Division ensure the Haulers are performing all billing related practices accurately and in accordance with the franchise agreements.
Attachment A
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7. Prior Observation Different approaches to overage and c ontamination monitoring between the Haulers, which ultimately support compliance with SB 1383, have resulted in inequitable experiences and outcomes for residents across the City.
Prior
Recommendation
The City and the Haulers should jointly develop an SB 1383 implementation plan for overage and contamination processes and fees that provides consistent and equitable outcomes for residents across the City.
Implementation
Status
Partially Implemented
In the prior review, we found the Haulers had two different approaches to monitoring overage and contamination, a compliance objective related to SB 1383. Waste Management used Smart Trucks SM equipped with video cameras to automatically capture, record, and report contamination and overages, while Republic Services’ vehicles did not have this capacity and performed spot checks manually to determine whether customers had overage or contamination issues. As a result, Waste Management was able to monitor 100% of customers, while Republic Services was only able to monitor about 10% of customers. Since overage and contamination issues result in fees for customers, this led to divergent experiences for customers and created the perception of inequitable treatment among Stockton neighborhoods. We recommended the City and Haulers jointly develop a SB 1383 implementation plan for overage and contamination processes and fees that provide consistent and equitable outcomes for residents across the City.
The City reported that the Haulers are following franchise agreements and coordinating to promote equitable outcomes for residents. However, the City and Haulers have not yet developed a detailed SB 1383 implementation plan for overage and contamination. To avoid inequities, the City halted Waste Management’s use of Smart Truck
SM technology for residential customers because Republic Services does not yet have updated equipment to monitor all residential customers for overage and contamination. Republic Services is working on getting updated equipment but estimates this will not be done for several years.
In the meantime, the City has requested, as part of their agreement, that the Haulers update all residential carts with chips as a foundation for the use of technology enhanced trucks in the future.
These chips should help track carts for more accurate reporting of overage and contamination. The Haulers are currently working on updating all residential carts with a planned roll -out date in mid to late 2024.
We continue to recommend the City develop a detailed plan, in coordination with the Haulers, on how to best and most equitably monitor overage and contamination for residents given the current differences in technology between the Haulers. The plans should include potential timelines, check in Attachment A
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points, and an agreement from both Haulers on set expectations for a consistent and equitable process to monitor overage and contamination.
8. Prior Observation There are inconsistencies in public education and outreach planning b
etween the Haulers as well as opportunities to increase coordination with the City and deliver consistent messaging throughout the Stockton community.
Prior
Recommendation
A. The City and the Haulers should coordinate to improve annual public education and outreach planning and support a consistent experience across the community.
B. Stockton residents would benefit from a coordinated media campaign to support a common understanding of SB 1383
requirements, and how they apply to their specific Hauler.
Implementation
Status
Implemented
In the prior review, we found there were inconsistencies in public education and outreach planning between the Haulers. We also found there were opportunities to increase coordination with the City to better deliver consistent messaging throughout the Stockton community. We recommended the City and Haulers coordinate to improve annual public education and outreach planning and support a consistent experience across the community. We also recommended the Haulers coordinate a media campaign to support a common understanding of SB 1383 requirements and how they apply to their specific Hauler.
These recommendations have been partially implemented. City and Hauler staff reported they have improved coordination on public education and outreach for a more consistent experience across the City. For example, staff reported they worked collaboratively to educate the public on the billing transition and have improved coordination on SB 1383 outreach and education.
Further, we found the Haulers have consistent messaging in their marketing materials. Based on a review of the commercial and residential 2023 Summer Newsletters from both Haulers, we found the content to be aligned with SB 1383 and the information on household hazardous waste, clean sweep directions, and examples of what items can and cannot go into different waste bins was consistent between the Haulers. This may be in part because the City requires the Haulers to submit marketing materials for approval by City staff, which allows staff to verify materials and ensure consistent messaging.
We reviewed outreach plans for 2023 from both Haulers and found they use the detailed outreach plan put together by City staff. Both plans align in terms of estimated timing, planning, and content required on outreach materials. The outreach plans satisfy most requirements of the franchise agreements, except the requirement for an itemized description of how the Hauler’s annual public education budget will be spent (Exhibit C 1. A). The reporting template includes a section to report Attachment A
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outreach and education activities incurred for the quarter but is a retroactive review of marketing spend, rather than a planned budget for future spending. Without the inclusion of a marketing budget in the Haulers’ outreach plans, the City may not approve of certain marketing activities the Haulers plan to incur for the year. The City should ensure the Haulers include this requirement in their outreach plans for extra assurance all items in the budget are accounted for and the budget appears to be allocated in accordance with the agreement and consistently across Haulers.
Attachment A
Attachment A