California Department of Resources Recycling and Recovery (CalRecycle) 

Diversion Study Guide, Appendix K

Jurisdiction Checklist for Base-Year Proposals

CalRecycle has continually affirmed that compliance with AB 939 involves both achievement of the diversion mandates and implementation of diversion programs. CalRecycle is committed to ensuring that local governments are implementing the programs described in their Source Reduction and Recycling Elements and their Household Hazardous Waste Elements. In upholding the intent of AB 939, CalRecycle also is expecting jurisdictions to demonstrate real disposal reduction and not to simply quantify preexisting diversion activities to reach the 50 percent diversion mandate.

The checklist is a guidance tool for jurisdictions submitting a base-year study to CalRecycle. The base-year proposal should contain good documentation, solid calculations, strong methodology, and clear summaries.

Prior to submitting a final proposal to CalRecycle, submit a draft to your local assistance staff contact, so they can review the proposal and provide feedback.

(This is not an on-line form.  Please print the checklist out and fill it in manually.)


If extrapolation was used, check to make sure that the methodology is clearly documented and that all of the necessary information has been provided to clearly document how the method was performed, including: type of sampling method; source for identifying population; total population and sample size; survey data collection tool(s) and approach; confidence level and margin of error; explanation of outliers.  Note: diversion tonnages from extremely large businesses, or those with atypical diversion practices, should not be extrapolated to the entire population.

If jurisdictions are doing a study jointly; e.g., a county and associated cities, then they should use population for residential programs and taxable sales combined with employment for commercial programs when allocating diversion from regional facilities. For example, the jurisdictions would use taxable sales and employment for allocating landfill salvage tonnage from a regional facility to the various jurisdictions.
All conversion factors that are used should be referenced in the proposal. Check the factors to make sure they are consistent with the Diversion Study Guide. If they are different, explain why they are different in the proposal and provide sources. The conversion factors provided may not be representative of every jurisdiction within the state and should be used only if they accurately reflect the weight of items and materials submitted in the jurisdiction’s diversion study.
Make sure that there is no double-counting of diversion data. For example, check that the non-residential sector data is not also captured in the reports from the haulers, MRF operators, and/or composters.


The diversion should be well documented. Documentation provided should demonstrate that the jurisdiction is actually sending materials to a diversion facility.  Note: If a jurisdiction claims diversion, for example, and yet there is no information from the business stating that the jurisdiction’s residents send materials to their facility, then the diversion shouldn’t be counted.
Make sure the types of diversion activities are described. The new base-year request should contain a good explanation of what type of program generated the diversion (material types and diversion tons should correspond)
Compare waste prevention, recycling, and composting categories to see if one seems abnormally high. This is an indicator. If one is extremely high, then an explanation should be provided in the proposal.
If any particular diversion activity is extraordinarily high when compared to the other diversion activities, provide an explanation. For example, if landfill salvage is high compared to the other recycling tonnage, provide an explanation that justifies the diversion. Check curbside recycling tonnage against total residential diversion and see if it is high; e.g., 18 percent or higher. If it is high, explain why you are getting such a high diversion rate; e.g., the jurisdiction has a high participation rate, automated program, 96-gallon recycling containers, includes greenwaste, etc.
For quantifying source reduction, a disposal-based quantification method should be used. The tonnage for source reduction should be counted as the incremental difference of a material being diverted versus looking at it in perpetuity. For example, when quantifying the reuse of wood pallets you should determine the normal life expectancy of the pallet; e.g., wood pallets are not typically bought and disposed of after one use. Thus, if a business uses 1,000 pallets and the life expectancy is 25 uses per pallet, diversion would be quantified as 1,000 pallets being diverted, not 25,000 pallets diverted.
If sludge is being counted, be sure to refer to the "What Counts" section in the Diversion Study Guide (DSG) and also PRC  41781.1 and 14 CCR section 18775.2. Sludge certification is required for the material to be counted as diversion.
If using an inerts landfill (Nuway, Peck Rd.) confirm that the material being claimed for diversion was actually beneficial use and not “filling the hole.” An explanation should be included for the diversion from an inerts landfill.
If inerts, scrap metal, white goods, or agricultural waste is being counted, check to see if the restricted waste criteria applies. The proposal should specifically address restricted waste (see the "What Counts" section in the Diversion Study Guide for additional information).

If businesses were surveyed for the purposes of extrapolation, make sure a large enough sample was obtained. Provide the sampling methodology in the base-year request certification sheet that is submitted to CalRecycle.  (See Appendix J for recommended sample sizes.)  Note: Do not extrapolate diversion tonnages from extremely large businesses, or those with atypical diversion practices.  Add the actual diversion tonnages from all very large businesses to the diversion tonnage extrapolated from the randomly selected businesses.

The diversion data should be for the same year. If multiple years are used, there should be a strong explanation that is logical.

If biomass or transformation is listed as a diversion activity in the base-year proposal, it can only be counted as diversion in the year 2000. If the proposed base year is prior to the year 2000, the jurisdiction cannot count that diversion.

If tires are being counted as diversion, the jurisdiction should explain how the tires are being diverted. For tire diversion to count, the jurisdiction should address that the tires were reused or recycled. In many tire-burning facilities, metals and other materials are separated from the tire before they are burned, and this material could also be counted as diversion. The jurisdiction which hosts the facility would receive diversion credit for any materials which are diverted after the tires have been burned such as metals or ash that is diverted. NOTE: Since transformation could not be counted until the reporting year 2000, tires that were burned cannot count prior to 2000.
If the pounds/person/day (generation) is high, you will need to provide an explanation.


Double check that the disposal data is accurate according to the Disposal Reporting System.
If the disposal tonnage went up significantly from the previous year and yet the base year change is a high rate, you should provide an explanation.

Please contact your local assistance staff representative for additional assistance.

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Last updated: March 19, 2000
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Local Assistance & Market Development: (916) 341-6199