Landfill operators must cover all disposed solid waste at the end of each day to control odors, vectors, fires, litter, and scavenging. Federal regulations require landfill operators to use six inches of earthen materials as daily cover; operators are also allowed to use alternative materials in lieu of earthen materials to cover waste at landfills. These materials are referred to as alternative daily cover (ADC).

Status of 2010 -2011 Projects

  1. Guidance Document (Working Group). An ADC working group, consisting of CalRecycle staff and two Enforcement Agency representatives, is currently developing an ADC demonstration project guidance document. This document will be used to evaluate newly proposed materials to be used as ADC and validate that existing materials continue to perform adequately. Staff provided an update on the draft Guidance for ADC Demonstration projects at a workshop in Sacramento on Feb. 8, 2010.
  2. Best Practices (Working Group). The ADC working group will also develop a guide on how to evaluate ADC use for compliance with regulatory specifications.
  3. Life Cycle Assessment (Research). These studies are currently under way and are being overseen by CalRecycle’s Materials Management and Local Assistance Program staff. The information obtained from these studies would assist in studying the economic impacts of green material ADC on the compost industry.
  4. Economic Impact Study (Research). Depending on funding availability, contract concepts and scopes of work for two separate contracts would be developed for approval. The concepts would be developed for the 2011-2012 fiscal year after the completion of the life cycle assessment. The first contract would be the development of a methodology (with stakeholder input) for determining how economic impacts of green material ADC to the compost industry could be evaluated. The second contract would be the application of the methodology.
  5. Auto Shredder Waste (Research). CalRecycle staff will continue to to monitor the Department of Toxic Substances Control's approach to regulating treated auto shredder waste.

Approach and History: Regulatory Review and Recommendations

Research and White Paper

To better understand ADC issues, during spring 2009 staff visited several landfills throughout the state, interviewed stakeholders, reviewed literature on research such as risk assessments, and contacted other states to identify their regulatory approaches to ADC. In June 2009, staff completed a draft white paper on ADC. The ADC white paper and a discussion and request for direction was presented to the Board's Strategic Policy Development Committee on Oct. 6, 2009, and as a consent item at the Board meeting on Oct. 14, 2009.

Stakeholder Workshops

Stakeholders were invited to provide input on the white paper at two Webinar workshops held in Sacramento on July 28, 2009, and Riverside on Aug. 13, 2009. The documents were posted before the workshops for public review. Comments were accepted until Aug. 19, 2009.


The Board approved the following staff recommendations, which will be implemented by CalRecycle staff over a 16-20 month time frame, depending on available resources and stakeholder assistance:

  1. Develop a standardized guidance document on how to evaluate the ability of ADC to control odors, vectors, litter, fire, and scavenging, as well as the effect on greenhouse gas emissions.
  2. Develop best practices for ADC regulatory inspection methodology.
  3. Continue monitoring the life cycle assessment of organic materials in landfills.
  4. Evaluate the economic impact of green material ADC on the composting industry.
  5. Continue to monitor the Department of Toxic Substances Control's approach to regulating treated auto shredder waste.
  6. Do not address the difference in green material definitions at this time.