Barriers to C&D Reuse & Recycling Survey Results & Findings

History

April 14, 2004, the Board directed staff to create a cross-divisional work group to identify C&D reuse and recycling barriers in California.

May 19, 2004 - 1st C&D work group meeting

October 2004 - Electronic Survey E-Mailed to 2,433 individuals - 2 week window of response.

Survey Process

1. Objective: Obtain stakeholder opinions on barriers

2. Identify target groups

3. Design survey

4. Obtain e-mail addresses of: all known C&D handlers, C&D recycling advocates, construction industry representatives, LEAs, solid waste industry representatives, C&D distribution list, and CIWMB Board and Committee agenda mailing list.

The Survey

Participants were asked to: Identify and rank the 5 most significant barriers

Participants could: select more detailed “sub-barrier” descriptions, or write in their own barrier, or write a general comment.

IMB staff compiled electronic data Work Group Staff grouped and analyzed data,

and summarized Key Findings

The 12 Survey Barrier Possibilities 1) Business Difficulty for Recycler/Processor 2) CIWMB and Legislative Issues 3) Facilities 4) Industry Education/Training 5) Local Enforcement Agency 6) Local Mandates 7) Local Ordinances, Plans, Policies, Programs &

Procedures 8) Lower-cost Options 9) Markets 10) Public Education 11) Recycled Content Product (RCP) Difficulties 12) Regulations for C&D Debris Processing

Primary Respondent Groups

Non-Regulatory Public Agencies (65) Private Solid Waste Industry (49) Regulatory Public Agencies – LEAs (21)

Total = 15% (135 responses out of 918 contacts)

Overall Survey Results

1. Facilities 2. Lower-Cost Options 3. a. Business Difficulty for Recycler/Processor

b. Local Ordinances, Plans, Policies, Programs & Procedures

Non-Regulatory Public Agencies Top 3 Barriers

1. Lower-Cost Options Cheap disposal – landfill rates may be lower than processing

fees Grinding materials for biomass or ADC Demolition is cheaper than deconstruction

2. Facilities Siting difficulties because of noise, dust, traffic, etc. Too few facilities to handle mixed C&D and dry wall, especially

in rural areas Too few “last chance, buy-back” facilities for salvaged C&D

material3. Business Difficulty High operational costs, Insufficient markets and unstable commodity prices for some

materials Unpredictable/unreliable C&D material flow

Private Solid Waste IndustryTop 3 Barriers

1. C&D Debris Processing Regulations Low permit tier placement thresholds Stigma of being a "Solid Waste Handler" The "no residual" restriction on "C&D-like" loads

2a. CIWMB Legislative Issues No C&D disposal ban Beneficial reuse competition at landfills Inconsistent, conflicting, and/or over-restrictive: CIWMB

regulations and/or CEQA2b. Local Ordinances, Plans, Policies, Programs and Procedures

Insufficient building permit diversion deposits Lack of implemented ordinances, long development process,

ordinances that don’t require reuse, and inadequate ordinance enforcement

Insufficient local economic incentives3. Markets

Inadequate markets for hard to market materials No mandate to use recycled base.

Regulatory Public AgenciesTop 3 Barriers

1a. C&D Debris Processing Regulations Low permit tier placement thresholds Stigma of being a "Solid Waste Handler" The "no residual" restriction on "C&D-like" loads

1b. Facilities Siting difficulties due to noise, traffic, dust, etc. Too few C&D material recyclers/processors, especially in rural areas2a. CIWMB Legislative Issues Beneficial reuse competition at landfills Inconsistent, conflicting, and/or over-restrictive: CIWMB regulations and/or

CEQA. 2b. Lower-Cost Options Cheap disposal Grinding materials for: biomass, or ADC Demolition is cheaper than deconstruction

3. Business Difficulty High operational costs Insufficient markets and unstable commodity prices for some materials Unpredictable/unreliable C&D material flow.

Findings

1) Cheaper Alternatives May Hinder Recycling/Processing

Demolition may be less costly than deconstruction because of: high deconstruction costs, insufficient markets, recycler/processors that accept

reclaimed/recyclable material at competitive prices, and

unpredictable/unreliable C&D material flow. Competitive LF disposal rates may hinder C&D

recycler/processors from removing C&D from the economic mainstream.

2) Lack of Ordinances or Insufficient Ordinance Implementation

Lack of ordinance implementation/enforcement may discourage an adequate infrastructure for the diversion of C&D material.

3) Lack of Local Economic Incentives

Some jurisdictions lack local economic incentives to support deconstruction and C&D diversion. For example:

low or nonexistent building permit diversion deposits

4) Regulatory Barriers

Respondents contend aspects of C&D processing regulations may result in higher operational costs and too few C&D material recyclers and processors. But analysis of existing sites doesn’t show

whether or not regs hinder new facilities CDI material may instead go through

transfer/processing stations and landfills Classifying a C&D debris processor as a “solid

waste handler” rather than “recycler” may create a negative public image reducing

material flow or causing siting problems.

5) Lack of Facilities

There are too few recycler/processors to handle mixed loads & hard-to-process C&D materials, e.g.,

asphalt roofing and wood shingles, discarded carpet, gypsum/wallboard material, organics/wood waste, painted lumber, soil, and stucco.

Reasons: competition with cheap disposal, high operational costs, insufficient markets and unstable commodity prices for some

C&D materials, restrictive State regulations for recycler/processors, severe material fragmentation by demolition, siting difficulties, and unpredictable/unreliable C&D material flow.

6) Lack of Markets

There are no industry-wide specifications to facilitate buying and selling recycled products from C&D materials. 

Some stakeholders contend that biomass diversion and ADC are cheaper alternatives that may undermine C&D diversion by: 1) encouraging demolition (severe material

fragmentation and mixing) over deconstruction; and 2) reducing the flow of C&D material to C&D

recycler/processors.

(This information is unsubstantiated by CIWMB data.)

ADC InformationC & D ADC Compared to Total ADC Used

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

4,000,000

Year

To

ns Total ADC

C & D

1998 1999 2000 2001 2002 2003

7) Miscellaneous

There is insufficient data on C&D reuse and recycling by local and State agencies.

Some stakeholders support: a statewide C&D disposal ban, a statewide mandate to use recycled road

base, and restrictions on demolition

C&D Handling Sites

7 Closed C&D Handling Sites

Site #1: Land Use Issues

Site #2: Land Use Issues

Site #3: Land Sold

Site #4: Business Bought Out

Site #5: Pilot Project Completed

Site #6: No Longer in Business – Site Clean-up

Site #7: No Land Owner Permission for Operations

29 Existing C&D Handling Sites (Prior to 8/9/03)

8 have or will receive small volume CDI debris processing operation EA notifications;

3 have or will receive medium volume CDI debris processing facility registration permits;

5 have or will use the CDI debris temporary registration permits for a full permit tier phase-in;

12 have or will be issued transfer/processing solid waste facility permits;

1 site changed operations to qualify as a CDI debris recycler.

12 New C&D Handling Sites (After 8/9/03)

6 have or will receive small volume CDI debris processing operation EA notifications;

3 received medium volume CDI debris processing facility registration permits;

1 planned site qualifies as a large volume CDI debris processing facility in the full permit tier;

1 site received a transfer/processing permit; and 1 site is a CDI debris recycler.