Attachment 2
April 15, 2024
Krystal Acierto, Acting Director
Department of Resources Recycling and Recovery
1101 I Street
Sacramento, CA 95814
RE: …ensure payment of the most accurate commingled rate feasible Dear Krystal Acierto,
On behalf of the undersigned local governments, recycling service providers and environmental organizations, we urge the Division of Recycling to exercise its responsibility under Section 14549.5 of the Public Resources Code to “…ensure payment of the most accurate commingled rate feasible…” by updating the commingled rate on beverage container material collected at curbside since January 1, 2024, based on the division’s most recent curbside survey.
On January 1, 2024, SB 1013 (Atkins) and SB 353 (Dodd) expanded the scope of CRV-eligible containers covered by the program, adding a projected 1.2 billion containers to the program.
However, the division has thus far failed to update the curbside commingled rate and other critical program rates to reflect this expansion—despite the division’s own 2024 survey data showing the significant volume of these new CRV containers in curbside programs. All available data clearly demonstrates that the current commingled rate for curbside CRV glass is substantially inaccurate dating back to January 1. The continuation of the 35% commingled rate for glass is nearly 50 percentage points lower than the amount of CRV glass consistently identified by the division in their most recent surveys.
Failure to correct rates means publicly financed curbside programs are being underpaid as much as $200 per ton for glass alone.
The shortfall is costing publicly financed collection programs an estimated $4 million per month, exceeding $40 million in total under the Division’s timeline. Further inaction means that roughly 24 million newly eligible CRV containers are not being counted as ‘recycled’ every month, thereby distorting recycling rates and undermining perception of the program’s effectiveness.
We are calling on the Division of Recycling to exercise existing authority to:
1) Immediately establish an updated commingled rate based on the division’s most recent survey data; and
2) Recalculate CRV recycling rates and program payments on all material reported as collected at curbside since January 1, 2024.
Thank you for your attention to this pressing matter.
Attachment 2
Sincerely,
Mark Murray
Californians Against Waste
Veronica Pardo
Resource Recovery Coalition of
California
John Davis
Mojave Desert and Mountain
Recycling Authority
Brandi Massengill
Empire Steel
Jennifer Higgins
Tracy Solid Waste Management, Inc.
Christine Wolfe
Waste Management
Joe La Mariana
RethinkWaste
Catherine Howells
South Lake Tahoe Refuse &
Recycling
Charles Moine
Wilmington Recyclers
Dan Domonoske
Potential Industries, Inc.
Larisa Cespedes
California Waste Haulers Council
Jason Wu
Capitol City Recycling
Zoe Shoats
Monterey County Waste
Management District
Mike Caprio
Republic Waste Services
David Fahrion
CA Waste and Recycling
Association
Gary Clifford
Athens Services
Jeff Belchamber
Berkeley Recycling
Karla Estupinian
Leader Recycling
Mayor Larry Klein
City of Sunnyvale
Chris Hanson
Solid Waste Association of North
America (SW ANA)
Garen Kazanjian
Recology
Doug Button
S. San Francisco Scavenger
Co., Inc.
Shawn Guttersen
BLT Enterprises
Paul Molinewlli, Jr.
ACES Waste Services, Inc.
Patty Garbarino
Marin Sanitary Service
Robert James Rodriguez II
RJR Environmental Professional
Services, Inc.
Mark Figone
East Bay Sanitary Co., Inc.
Greg Kelley
Napa Recycling & Waste
Services, LLC
David Sikich
Atlas Disposal Industries
Christy Pestoni
Waste Connections, Inc.
Jeff Martin
Tule Trash Company
Alan Marchant
Turlock Scavenger Company
Gene Della Zoppa
Mill Valley Refuse Service
Ricky Ross
Intermountain Disposal, Inc.
Joe Kalpakoff
Mid Valley Disposal
John Snyder
EDCO
Cole Burr
Burrtec Waste Disposal
Bill Dobert
Specialty Solid Waste & Recycling
Chris Cunningham
Palm Springs Disposal Services
& Desert Valley Disposal
Joe Ragusa
Strategic Materials, Inc.
Melinda Andrade
Association of California Recycling
Industries
Timothy Burroughs
StopWaste
c.c. Governor Gavin Newsom
Members, California State Legislature
Attachment 2