Questions and Answers: Recycled Fiber, Plastic, and Glass Grant Program (FY 2018–19)

General

1. Are there any incentives for projects that manufacture and/or produce a recyclable product in California?

Yes, the scoring criteria includes bonus points for projects manufacturing and/or producing recyclable products in California.

2. What does CalRecycle mean by making intermediate commodities used in a finished product eligible?

For this cycle, CalRecycle has broadened the scope of eligible projects to include production of intermediate commodities. An intermediate commodity is defined as a material that is interchangeable with equivalent post-industrial or virgin commodities and is sold to a manufacturer or converter to use as feedstock to produce a finished product. Sorted and baled recyclable material are not considered an intermediate commodity for the purposes of this Grant. Please refer to page 6 of the Application Guidelines and Instructions.

3. Our material is LDPE and the GHG calculator is for HDPE. Can we use the .8 factor for HDPE or is there a different factor for LDPE?

Yes, the recycling emissions reduction factor for HDPE may be used for LDPE. However, applicants without a specific recycling emission reduction factor for their material may request to use an alternative methodology by February 12, 2019. Please see the Alternative Methodology Request and Process section on page 15 of the Application Guidelines and Instructions for more information.

4. Is there a PowerPoint or webinar about the program?

No, there is no PowerPoint or webinar about the program.

5. We have developed a process for recycling large amounts of glass into finished building products such as blocks and pavers as well as larger structures like slabs and walls. Our cement itself is made up primarily of steel dust, which is another non-toxic waste material. We are ready to scale up to the level required by this grant project but need a partner that can supply the crushed glass and provide a site for the recycling operation. Can you suggest a company, recycling center, municipality or other organization? 

CalRecycle cannot suggest a company, recycling center, municipality or other organization for partnering purposes.

6. The application states clearly that an agreement with a landlord must be provided. If our entity is currently looking for a larger workspace in CA, are there any scenarios where a lease agreement and subsequent permits can be signed and provided after the application/award process.

A signed lease agreement or a legally binding long-term commitment is required at time of application submission. A copy of any agreement between the applicant and private owner must be uploaded in the Documents tab of the application. Please see the Lease Agreement for Facilities on Non-Owned Property section on page 20 of the Application Guidelines and Instructions.

7. In the Q&A section, it was clarified that “Applicants must provide an agreement/contract with a California entity that will supply the feedstock, which could include entities such as MRFs, direct collection from waste generators, and/or self-haul”.  Our business would be picking up waste throughout the year from an industry comprising of 70-80 small companies producing currently unrecycled plastic.  We do not have an agreement for an agreed volume of feedstock, and wanted to check if a simple contract between our business and a regulating body that explains our role (IE waste collectors) and estimates annual volume would be sufficient for this requirement? 

Applicants that collect eligible feedstock material from the original solid waste generator should include substantiation of any applicable waste collection agreements, and should complete the Feedstock Certification form (CalRecycle 778-FPG) estimating the amount of material that will be collected and guaranteeing that the potential feedstock is only California generated material. The Feedstock Certification (CalRecycle 778-FPG) form is a required application document that must be submitted at the time of application  Please see the instructions on the back of the CalRecycle 778 FPG form.

8. The calculator applied to the FPG3 grant application seems to allow for GHG reductions via the landfill diversion of the source materials only. Our application will show benefits in further GHG reductions for both transportation and for offset electrical power reductions. We intend to submit additional calculations using the GHG reduction spreadsheet with supporting data to further illustrate benefits delivered. Will this additional GHG reduction data be used in our evaluation from a “scoring” perspective? 

The deadline to submit an alternative quantification methodology request was February 12, 2019, and as such projects that do not fall within the ARB approved Quantification Methodology are ineligible. However, minor project-specific differences such as transportation distance and/or process efficiencies do not warrant an alternative quantification methodology. Further, electricity is not an eligible intermediate commodity or finished product for the purposes of this cycle, and as such cannot be taken into account for the purposes of GHG quantification. Please see the Alternative Methodology Request and Process section on page 15 of the Application Guidelines and Instructions for more information.

9. We possess detailed quotations for all aspects of our project, but how do we ensure confidentiality of our proprietary information? Can sensitive information on the quotes we upload as a part of our grant application be redacted and still provide the information the committee requires? The application asks for both the Feedstock Certification and agreement/contracts from the feedstock source-are both necessary? If you have the Feedstock Certification from the feedstock source is that sufficient?

Title 14 of the California Code of Regulations (14 CCR), sections 17041-17046, states that confidential or proprietary information shall include information of a proprietary or confidential business nature provided by persons in applications, reports, returns, certification or other documents submitted to the Board which if released would result in harmful effects on the person’s competitive position.
Documents containing information an applicant feel is confidential should be clearly labeled as such. The labeling of a document as confidential will not necessarily preclude its release under a Public Records Act request, as CalRecycle will make a determination as to whether the document falls under the exceptions to release provided in the above referenced sections of Title 14.

Please refer to Confidentiality on page 10 of the Application Guidelines and Instructions for further information regarding the handling of proprietary information submitted in applications and how it relates to the Public Records Act.

A contract or agreement with an entity that will supply the feedstock and the Feedstock Certification are required application documents. The Feedstock Certification is signed by the feedstock supplier ensuring the material provided to the applicant will originate only from California-generated waste that was otherwise going to a landfill.

10. We request that we be able to add, to the landfill diversion GHG calculations via your spreadsheet, the additional transportation and electrical power generation GHG offsets that the realization of this grant enables. The set of materials to be used, which include a Department of Energy endorsed set of analyses, and sets of analyses endorsed by the US Environmental Protection Agency and the Department of Transportation, are already loaded into the response package for this purpose.

The deadline to submit an alternative quantification methodology request was February 12, 2019, and as such projects that do not fall within the ARB approved Quantification Methodology are ineligible. However, minor project-specific differences such as transportation distance and/or process efficiencies do not warrant an alternative quantification methodology. Further, electricity is not an eligible intermediate commodity or finished product for the purposes of this cycle, and as such cannot be taken into account for the purposes of GHG quantification. Please see the Alternative Methodology Request and Process section on page 15 of the Application Guidelines and Instructions for more information.

11. What is the change process if the original submitted permit plan must be modified because the manufacturing location changes prior to the completion of the work?

A change of the original manufacturing location during the grant term would constitute a scope change and would make the project ineligible.

Eligibility

1. Would the purchase of expanded recycling infrastructure (sorting, baling, handling and associated structure) at a landfill facility be eligible for this grant funding for the materials targeted? (Fiber, Plastic, Glass)

Expanded recycling infrastructure upgrades would only be eligible expense if the upgrades were a component of a project that manufactures an Intermediate Commodity or Finished Product as defined in the Guidelines and Instructions, p.6:

• “Finished product” is defined as a good or package in a form which requires no further processing or forming before it is offered for sale to an end-user.
• “Intermediate commodity” is defined as a material that is interchangeable with equivalent post-industrial or virgin commodities (such as plastic pellets, flake, paper rolls, or glass cullet) and is sold to a manufacturer or converter to use as feedstock to produce a finished product

Please see the Eligible projects/products section on page 6 of the Application Guidelines and Instructions.

2. In the project requirements, it says that the project must result in an increase of tons of material diverted from landfills. Does that mean the only viable projects source from Material Recovery Facilitates (MRFs)? It is well known that MRF bales are filled with trash and require a much more expensive set up that I do not possess. Would only buying A grade bales from Plastic Recycling Corporation of California disqualify me?

Applicants must provide an agreement/contract with a California entity that will supply the feedstock, which could include entities such as MRFs, direct collection from waste generators, and/or self-haul. While there is no explicit restriction on the grade of bales utilized as feedstock, eligible projects must result in an increase in tons of material diverted from landfills, and grant funds cannot be used to purchase feedstock of any kind. Please see the Ineligible costs of the Application Guidelines and Instructions.

3. Our organization has collected and distributed gently used baby clothes. We collect unwanted clothes from consignment stores and sales when they do not want the items anymore. One hundred percent of the clothes are then boxed up and distributed free to the homeless. Our grant would be to divert essential garment from landfills, resulting in textiles diverted from landfill. Would this be eligible under your grant program?

Textile reuse is not an eligible standalone project type for this program. Eligible projects must manufacture an intermediate commodity or finished product using California derived fiber, plastic, or glass. However, this scenario may qualify as a textile reuse component that can be part of a cooperative application with a recycled fiber, plastic, or glass project. Please see the Textile Reuse requirements under the Eligible Projects/Products section on page 6 of the Application Guidelines and Instructions.

4. We process used materials for reuse and the rest of the items that don’t make the cut end up in a trip to the landfill as a last resort. Things that are reusable but don’t get placement in a store are auctioned off in bulk daily–which still leaves literally tons of leftovers. The leftover extra clothing is baled and sold to recyclers throughout California and from all around the world as rags. The same goes for metals, cardboard, e-waste and accessories. 

Please advise if our recycling program would be eligible for consideration for the project area of construction, renovation, or expansion of facilities to increase in-state infrastructure for production of a fiber, plastic or glass intermediate commodity that will be supplied to a domestic manufacturing facility for the production of a finished product.

Eligible projects must manufacture an intermediate commodity or finished product using California derived fiber, plastic, or glass. Bales of sorted recyclable materials are not considered an intermediate commodity for the purposes of this Grant.  However, this scenario may qualify as a textile reuse component that can be part of a cooperative application with a recycled fiber, plastic, or glass project. Please see the Textile Reuse requirements under the Eligible Projects/Products section on page 6 of the Application Guidelines and Instructions.

5. Are carpet and mattresses eligible as feedstock?

No, carpet and mattress are no longer eligible as feedstock.

6. Would MRF upgrades be an eligible project if they increased recycling of FPG?

MRF upgrades would only be eligible expense if the upgrades were a component of a project that manufactures an Intermediate Commodity or Finished Product as defined in the Guidelines and Instructions, p.6:

• “Finished product” is defined as a good or package in a form which requires no further processing or forming before it is offered for sale to an end-user.
• “Intermediate commodity” is defined as a material that is interchangeable with equivalent post-industrial or virgin commodities (such as plastic pellets, flake, paper rolls, or glass cullet) and is sold to a manufacturer or converter to use as feedstock to produce a finished product.

7. With recent restrictions on international trade, feedstock has become more expensive. Can I use grant funds to offset the increased cost of feedstock?

No, collection/delivery/purchase of fiber, plastic, and glass feedstock is not an eligible cost. Please refer to the Ineligible Costs section on page 8 of the Application Guidelines and Instructions.

8. Is a project centered around using recycled polypropylene (PP) acceptable? We notice in the FPG calculator does not include PP (only HDPE and PET for plastics).

Polypropylene (PP) is an eligible feedstock material. By February 12, 2019, the applicant should request to use an alternative methodology for quantifying the emission reductions associated with using recycled polypropylene (PP). Please see the Alternative Methodology Request and Process section on page 15 of the  Application Guidelines and Instructions for more information.

9. Although our project will “result in an increase in tons of material diverted from landfills”, the nature of our innovation is such that we do not fulfill the other requirements listed. Our device – both hardware & software – will reduce the contamination levels of recycled plastics collected at curbside. Please understand that we are a very early stage business. The grant would enable us to continue our research & development by building and testing prototypes and then commercial production when appropriate. Do you believe that we qualify for the subject grant?

No. Projects must meet all of the requirements as listed under Eligible Projects/Products section on page 6 of the Application Guidelines and Instructions to be eligible.

10. Would a coal substitute be considered a fuel product?

If the coal substitute is used to produce fuel, electricity, or heat, it is considered a fuel product and therefore is an ineligible finished product. See ineligible Projects section on page 6 of the Application Guidelines and Instructions. .

11. Can we use grant funds to purchase of new trucks, trailers, and loaders to collect and provide plastic feedstock for our proposed processing facility expansion project?

Equipment for the collection or delivery of feedstock is an ineligible cost. Please refer to page 8 of the Application Guidelines and Instructions..

12. If a parent company of an applicant that is not located in CA is selling the processing equipment to CA applicant, and CA applicant has not yet entered into formal contract to purchase the equipment, can this qualify for Grant eligibility? (if formal contract to purchase equipment was signed AFTER grant approval)?

Grant funded equipment listed in the applicant’s budget and work plan must be used for activities associated with the approved grant project. Approved expenditures do not need a contract prior to grant execution but no expenditures/funds may be transferred before the notice to proceed date, and equipment needs a detailed description in the budget of its function and purpose in the grant project. That being said, all expenditures for which reimbursement pursuant to the grant is sought shall be the result of arm’s-length transactions and not the result of, or motivated by, self-dealing on the part of the grantee or any employee or agent of the grantee. Seeking reimbursement for equipment purchased from a parent company would not be considered an arm’s-length transaction, and the state would not be able to reimburse those costs.

13. Does diversion of biomass waste have any benefit for this Request for Proposal (RFP) (e.g., use of agricultural waste products used as filler in recycled plastics)?

Biomass is not an eligible feedstock material for this grant program.

14. What was the reasoning that carpet and mattresses were excluded from eligibility?

CalRecycle has excluded carpet and mattresses as eligible feedstocks due to the limited amount of California Climate Investment funding allocated to the Department, the acute need for development of recycling infrastructure in California due to international policies such as National Sword, and the availability of other funding sources for the development of recycling infrastructure for carpet and mattresses. In addition, California consumers are charged an assessment at point of sale on carpet and mattresses, which flows to stewardship organizations that are responsible for developing and implementing programs to recycle those materials. Both the Carpet America Recovery Effort and the Mattress Recycling Council, the respective stewardship organizations for carpet and mattresses, currently have surplus funds and the ability to develop and administer grant programs, if needed, to achieve their recycling goals.

15. Can a project spend money from this grant on thermal processing of biomass materials that will be used in the product (e.g. heat treatment of biomass fillers for plastic composites)? We notice pg. 8 of the Application Guidelines and Instructions says “Costs associated with projects that use pyrolysis, gasification, or other thermal processes to produce fuel, electricity, or heat.” are ineligible.

Biomass is not an eligible feedstock material for this grant program, and projects must use diverted California-generated fiber, plastic, or glass to produce an intermediate commodity and/or manufacture a finished product.

16. Is purchase of equipment allowable or just construction?

Yes, the purchase of equipment is allowable if its function is associated with the approved grant project. However, the costs associated with the purchase of equipment and supplies that will not be under the direct control of a grantee is not an eligible expense. Please see the Eligible Costs/Ineligible costs section on pages 7 and 8 of the Application Guidelines and Instructions.

17. Would the recycling of chopped wire and/or fiber from waste tires be of interest? If this material alone is not of primary interest, would it be seen as beneficial if it is combined as a minor component in the recycling of much larger amounts of glass?

The requirements of the grant program are to divert California-generated fiber, plastic, or glass from landfill disposal and to use the material to produce an intermediate commodity and/or manufacture a finished product. Chopped tire wire is not an eligible material for this grant program. Tire threading made of fiber or nylon is an eligible material, but must be used to produce either an intermediate commodity or a finished product. Please refer to the Project Requirements section on pages 5 and 6 of the Application Guidelines and Instructions.

18. We have a Materials Recovery Facility (MRF) and are considering applying for this grant to recover fiber material by adding specific pieces of equipment to our system. This would result in feedstock that we send to a different company to recycle. It would cost us money to recycle this material; however, it keeps it from going to landfill. Would that qualify as an eligible project under page 6 of the application? 

Recycling infrastructure upgrades at your MRF by adding specific pieces of equipment to your system would only be an eligible project if the improvements were a component of a project that manufactures an Intermediate Commodity or Finished Product as defined on page 6 of the Application Guidelines and Instructions:

• “Finished product” is defined as a good or package in a form, which requires no further processing, or forming before it is offered for sale to an end-user.
• “Intermediate commodity” is defined as a material that is interchangeable with equivalent post-industrial or virgin commodities (such as plastic pellets, flake, paper rolls, or glass cullet) and is sold to a manufacturer or converter to use as feedstock to produce a finished product.

Please see the Eligible projects/products section on page 6 of the Application Guidelines and Instructions.

19. Are Federal agencies eligible to apply for this grant?

No

Funding

1. Is there any way to know the amount of available grant for plastic recycling?

$3,000,000 is the maximum available for individual grant awards for this cycle. A total of $9,000,000 is available for this cycle. Of the total available funds, all eligible material types are competing together (i.e. there is no subset of funds for plastic alone). Please see the Available Funds section on page 7 of the A Application Guidelines and Instructions.

2. There are two Grant Term End, Final Report, and final Payment Request due dates – April 2021 and 2022. Which one is used?

Utilize the grant term end date of April 1, 2022 for all application documents.

3. Since the maximum is $3,000,000 per individual grant awards, will there be a maximum of three winners regardless of the total or will it be as many applications that qualify not to exceed 9 million dollars?

A total of $9,000,000 is available for this grant cycle. $3,000,000 is the maximum available for individual grant awards. Depending on the number of applications awarded, it would be as many applications that qualify, in rank order according to the score, not to exceed the $9,000,000 available for this grant cycle.

Application

1. Can Letters of Support for the project be uploaded?

Yes. Letters of Support are not required but are encouraged and may be uploaded in the Grant Management System.

2. If a project wants to have salaries funded as part of the budget, how can the project leaders document that this project is a direct charge, rather than an indirect charge? What employee positions qualify as a “direct charge” salary that won’t be included in the 5% indirect charge limit?

Direct charge for personnel must be for work associated with the construction, installation of equipment, operation, execution, or supervision of the grant project. These activities must be clearly supported by appropriate documentation. Please refer to the Indirect Cost section on page 7 of the Application Guidelines and Instructions.

3. For one of the worksheets, Net Tons of Diverted Material Used in Manufacturing or Textile Use, it starts with Q3 2019. Will this be something that needs to be filled out if the grant is awarded? Or does this refer to projects?

The Net Tons of Diverted Material Used in Manufacturing or Textile Reuse is a required application document used to provide the anticipated annual tons of material(s) expected to be diverted from landfill and toward manufacturing or textile reuse once the project is up and running. Please see the CalRecycle documents section on page 15-19 of the Application Guidelines and Instructions.

4. Regarding confidential information, as we know markets are scarce for certain commodities. The application does state that the information will be available to the public. If awarded, is there a way for us to outline information that gives our Company a competitive advantage?

Title 14 of the California Code of Regulations (14 CCR), sections 17041-17046, states that confidential or proprietary information shall include information of a proprietary or confidential business nature provided by persons in applications, reports, returns, certification or other documents submitted to the Board which if released would result in harmful effects on the person’s competitive position.

Documents containing information an applicant feels is confidential should be clearly labeled as such. The labeling of a document as confidential will not necessarily preclude its release under a Public Records Act request, as CalRecycle will make a determination as to whether the document falls under the exceptions to release provided in the above referenced sections of Title 14.

Please refer to Confidentiality on page 10 of the Application Guidelines and Instructions for further information regarding the handling of proprietary information submitted in applications and how it relates to the Public Records Act.

5. Question #3 of the FPG3 Narrative Proposal states, “Describe the type of collection program(s) (e.g. source separated, dual stream, mixed recyclables, etc.), the geographic location(s) and type of generator(s) served, and the source and duration of funding for the collection and processing programs.” Do you mean how long and from what source we have funded our current collection and processing program historically or how long and from what other sources it will be funded during and after the 3-year grant term? 

Please describe material flow (fiber, plastic, or glass) from point of generation in California to the grant project facility or facilities as proposed in your application during and after the 3-year grant term. Include if any state or local laws, or programs, mandate or support the collection programs and if there is any funding associated. For example, the local area may have single stream mixed recyclables that the project intends to use as feedstock. If there are no “other” sources, or the project is self-hauled, then current and historical funding would be appropriate.

6. Question #4 of the FPG3 Narrative Proposal states, “Provide a signed contract, letter of intent, or other documentation from the MRF(s) or other supplier(s) of diverted feedstock that describes the quantity, grades, and specifications, of the feedstock.” If we provide a Feedstock Certification (CalRecycle form 778-required with the application) from each supplier, do we have to provide an additional letter of intent or contract from them as well?

Yes. The applicant must provide an agreement or contract with a California entity that will supply the feedstock proposed in your application. Please see the CalRecycle documents section on page 6 of the Application Guidelines and Instructions.

7. Step 1, Option A of the COMMUNITY BENEFITS-NARRATIVE PROPOSAL AND WORKSHEET states, “Project Location. The majority of the project must be located in a disadvantaged or low-income community census tract. For projects that divert waste from landfills, the project location may be determined by the source of the majority of the waste.” Our recycling processing facility, which our project proposes to expand, is located in both a disadvantaged and low-income community. In our assessment, that is where the majority of the project is located. We do, however, source all of our feedstock from a multitude of CA plastic generators whom would otherwise landfill the plastic. Some of these generators are in low-income communities, some of which are disadvantage, and others are in both. How then should we determine our project location? 

Please provide the locations and census tracts for project location(s) and if applicable the verified landfill that the waste will be diverted from. The location and census tracts of solid waste generators is not an eligible input for this section.