Questions and Answers: Recycled Fiber, Plastic, and Glass Grant Program (FY 2019-20)

General

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

   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 7 of the Application Guidelines and Instructions for the definition.

2. 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?

   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 CalRecycle 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.

3. We are going to build a factory using the grant but we do not currently own property. We are going to own or lease a property to build a factory if we are able to have a grant. Is it possible to apply for a grant without a property?

   The grant application must clearly state the applicant’s ownership or leasehold interests of the property or facility that the project will be located for the project purpose as described in the application. A copy of any agreement between the applicant and the private owner must be included with the application in order for the project to be eligible. Please refer to the Facilities on Non-Owned Properties section on page 8 of the Application Guidelines and Instructions.

4. Are applicants allowed to submit applications for the large tier and small tier?

   No, only one application per qualifying entity will be accepted.

Eligibility

1. 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.  Would only buying A grade bales 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.  Grant funds cannot be used to purchase feedstock of any kind.  Please see the Ineligible Costs on page 7 of the Procedures And Requirements.

2. Does California Redemption Value (CRV) bottles mixed with other PET plastic used to produce a finished product qualify as an eligible feedstock?

   California Redemption Value (CRV) bottles are not eligible for this grant program.  Eligible feedstock intended to be used for the Recycled Fiber, Plastic, and Glass Grant Program project must be California-generated material newly diverted from landfill disposal.  Projects using feedstock already expected to be recycled, such as CRV beverage containers, do not qualify; however, the non-CRV material, (i.e., non-CRV plastic or glass), is an eligible feedstock if the applicant demonstrates it is newly diverted from a landfill.

3. Do paper bales that can be used as an intermediate commodity to make recycled paper at a paper mill count as an intermediate commodity under this grant?

   Bales are an eligible feedstock, but are not considered an intermediate commodity for the purposes of the grant. “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.

4. Would recycling rice straw and sugarcane bagasse to make sustainable and biodegradable paper products be eligible for the California Climate Investments grant? Rice straw and sugarcane bagasse, normally would be discarded as waste but our company would utilize the material to make new products.

   Rice straw and sugarcane bagasse diverted from California landfill disposal are an ineligible Recycled Fiber, Plastic, and Glass Grant Program feedstock. To be considered “fiber,” the feedstock material must be paper, old corrugated cardboard, paper board, wood, or textiles. Please see the Eligible Projects/Products and Ineligible Projects section on pages 7 and 8, respectively in the Application Guidelines and Instructions.

5. My company works with plastics that are derived from plant sugars to make plastic bottles and other degradable plastic products. Would our organization fall within the scope/qualifications of your grant?

   Eligible projects must utilize California-generated postconsumer fiber (paper, old corrugated cardboard, paper board, wood, or textiles), plastic, or glass diverted from California landfills to manufacture an intermediate commodity or a finished product. Please see pages 6 through 8 of the Application Guidelines and Instructions for this and other requirements.

6. There needs to be a State recycling amendment passed requiring current ID as well as registered vehicle ID information in order to turn catalytic converters in for recycling. Most engine parts have ID numbers that have correlation to the exact vehicle. This program could be expanded to include the catalytic converters.Can this project be funded with the current Recycled Fiber, Plastic, and Glass Grant Program?

   No, catalytic converters or the identification of a catalytic converter are not eligible for funding through the Recycled Fiber, Plastic, and Glass (FPG4) Grant Program. Eligible FPG4 Grant Program projects include construction, renovation, or expansion of facilities to increase in-state infrastructure for production of an intermediate commodity or a finished product using fiber, plastic, or glass diverted from disposal at a California landfill. Eligible materials are only fiber, plastic, or glass; metal and ceramics are not covered.

7. Do all steps of the process need to take place in California? My recycled material comes from industrial carpets. Am I eligible?

   The grant-funded components of the project including manufacturing of an intermediate commodity and/or a final recycled content product must be located in California. Other processes not funded by the grant program do not need to be located in California. Carpet is not an eligible feedstock material for this grant cycle. Please see pages 6 through 8 of the Application Guidelines and Instructions for this and other requirements.

8. Why are pyrolysis and gasification ineligible components?

   Is a project that makes products from recycled plastics that have been treated in pyrolysis eligible? The pyrolysis would not be part of the project being funded: the funding would go towards making products from the output of plastics pyrolysis. If eligible material such as landfill diverted plastic is processed by pyrolysis, or the project involves a pyrolysis component somewhere within its operations, the project is considered ineligible. CalRecycle developed the eligibility criteria for this cycle of the Recycled Fiber, Plastic, and Glass grant program consistent with the statutory goals of the Greenhouse Gas (GHG) Reduction Fund. Projects must result in measurable reductions in GHG emissions through increased quantity (tons) of California-generated fiber, plastic, or glass diverted from landfill disposal by producing an intermediate commodity and/or manufacturing a finished product when compared to the existing practice of landfilling. Pyrolysis is identified in the California Public Resources Code section 40201 as one of the technologies that are considered “Transformation”, which is considered disposal in California, and as such is ineligible for this grant cycle.

Funding

1. Does the Design and Engineering costs and also the Combined costs for permitting, public education/outreach, indirect costs, and salaries not related to construction/installation both have a budget cap of five percent of the total amount requested for a maximum total of 10% of the requested grant amount?

   Yes.  There is also a separate budget cap for environmental justice consultant fees of $120,000.

Application

1. Is the applicant restricted to the number of rows set to in the application documents or can more rows be added?

   Applicants cannot add rows within the document(s).  Certain documents, such as the Budget, can be expanded by CalRecycle.  If you need more rows, please contact CalRecycle at Grant.Assistance@CalRecycle.ca.gov and a document with the additional rows will be provided.

2. In the applicant’s letter of commitment (LOC), can the signer of the LOC authorize him or herself as the Signature Authority, assuming that the signer is the person within the applicant’s company with the authority to commit the applicant’s organization to the project should it receive CalRecycle funding?

   Yes.

3. In Table 1.2 “Address a need” my census tract in the CalEnviroScreen shows that the area in which my facility is located is in the 84% for poverty and 86% for unemployment. Yet in section 1.3 “Show a benefit”, there is no sub-choice to discuss the benefits of adding jobs to the census tract, even though the application directly states:
   “Projects must meet at least one of the following benefit criteria focused on providing environmental improvements, economic benefits, or educational opportunities to priority populations.” Is the exclusion of economic benefits in the series of choices that follow an oversight, or is the inclusion of “economic benefits” not applicable? Can I proceed to section 1.3 even though there is no following reference to economic benefits in the A-F choices given?

   There are two sections in the Community Benefits Worksheet. The first section addresses waste diversion and utilization. This section will be completed if the project has any direct environmental or social benefits to priority populations in proximity to the project location.
   The second section addresses jobs and training targeting priority populations. This is focused on the project location in proximity to a priority populations, and the targeting strategy to benefit members of a priority population. Each section may be completed independently of the other.

4. My project is about processing a grade of material that is largely being landfilled. Because this material in question will be primarily coming from Materials Recovery Facilities (MRFs) who are outside of my census tract, will I be able to use this diversion for this section? I do not have access to the information of which MRF is sending materials to which landfill, nor do I believe I will be able to get it. Pulling material from MRFs that would otherwise be landfilled will benefit any populations near landfills. Would a statement saying as much suffice?

   The eligible feedstock may address a community benefit to a priority population if the majority of the waste utilized, recovered or processed by the project is diverted from landfills located in disadvantaged or low-income communities. Please refer to Step 3 Provide A Benefit on page 4 of the FPG4 Community Benefits worksheet. For the Waste Diversion and Utilization section of the Community Benefits Worksheet, the project location may be determined by the source of the majority of the waste (i.e. a California landfill). The landfill address must be provided to receive credit for claiming this benefit.
   A fiber, plastic, or glass material is eligible as project feedstock with a signed Feedstock Certification (CalRecycle 778 FPG4) or another officially signed document certifying that the material provided for the project will originate only from California-generated waste that would otherwise go to a landfill.

5. One of the project eligibility categories includes construction, renovation, or expansion of facilities to increase in-state infrastructure to manufacture a finished product using California-derived recycled fiber, plastic, or glass. Does this mean a project that proposes to make a product out of California-derived recycled fiber, plastic, or glass feedstock must actually make that finished product in California?

   No. A project located in California that manufactures an intermediate commodity is also eligible. Projects that sell the intermediate commodity to, or partner with, a manufacturer of a finished product located in California are eligible for a bonus point as outlined in the Scoring Criteria. Projects producing a finished product outside of California are not eligible for the bonus point.

6. If a manufacturing facility must be located in California and must use California-derived feedstock, does that mean that an eligible project that falls under this project category will automatically get the bonus point for a project that produces a finished product in California? If that is not the case, then how does an applicant qualify for that bonus point?

   Applicants will not automatically receive the bonus point for producing a finished product in California. If the project manufactures a finished product and is located in California, the application may be eligible for the bonus point as outlined in the Scoring Criteria. Applicants should provide an answer addressing all components of the bonus point question, to be eligible for the point. A blank answer will receive a 0.

7. The project facility will be developed in a leased space. Will a letter of intent to enter into a lease agreement with the property owner be accepted as part of the application in lieu of a lease agreement?

   No.

8. Are the Administrative and Equipment Maintenance Costs capped at 5 percent themselves or are they capped in combination with the other capped budget categories?

   The total costs for Administrative and Equipment Maintenance, together with Education and Outreach, Permitting and other indirect costs are capped at 5 percent of the total FPG4 grant funds requested in the application. Please refer to the Table 1 Budget Examples on page 17 in the Application Guidelines and Instructions and the Read Me tab of the Budget Template located in the Grant Management System (GMS).

9. Does installation/assembly of equipment get covered under the Construction/Application budget category or the Equipment budget category?

   Installation and assembly of equipment are itemized in the Equipment category in the Budget Template. Provide a detailed breakout of each equipment and installation/assembly costs associated with the grant project. For more information, please see the Equipment Costs section under the Read Me tab of the Budget Template located in the Grant Management System (GMS).

10. Where are contractor (non-employee) costs covered in the Budget?

    Contractor costs for construction, equipment assembly and installation, or grant administration are itemized in the Construction/Application, Equipment, and Admin categories respectively. Contractor costs not directly related to construction or equipment assembly and installation are itemized in the Admin category and are subject to the cap of 5 percent of the total FPG4 grant funds requested in the application.

11. Are grant management costs eligible for grant funding? If so, under which Budget category would they be covered?

    Grant Management costs are eligible and are itemized in the Admin category and are subject to the cap of 5 percent of the total FPG4 grant funds requested in the application. Unless, an employee managing the grant is also performing work that is directly related to the execution of the grant project, and wages are directly funded by FPG4 grant, then this position should be itemized in the Personnel category.

12. Under which Budget category is education and outreach personnel covered? Is there a difference if the person is an employee or a contractor?

    Employee and contractors costs for education and outreach are itemized in the Admin category and are subject to the cap of 5 percent of the total FPG4 grant funds requested in the application.
    If an employee is managing the grant or otherwise performing work that is directly related to the execution of the grant project, and wages are directly funded by FPG4 grant, this position should be itemized in the Personnel category.

13. Applicants must provide either a signed Feedstock Certification Form or a Commitment Letter for each feedstock supplier. The Application Instructions say applicants who are their own feedstock supplier are still subject this requirement. How must an applicant who is its own feedstock supplier comply with this requirement?

    Applicants who are their own feedstock supplier will self-certify through a Feedstock Certification (CalRecycle 778 FPG4). A Feedstock Commitment Letter may also be accepted.

14. The Application Instructions state in the event of a tie score among applications with the same overall score, funding order will be determined by comparing the score received in the first category listed in the scoring criteria. What is the first category listed in the scoring criteria?

    The first Scoring Criteria category is Project Description, Tons of Material Recycled, and GHG Emission Reductions. Please refer to the FPG4 Scoring Criteria Assessment located on the Summary tab in Grant Management System (GMS).

15. In the Incentives for Manufacturing in California and Producing a Recyclable Product section, one point may be awarded if a product meets the criteria for recyclability. What is the criteria for recyclability? If a product meets the criteria for recyclability but is not produced in California, may it still receive one point?

    The criteria for Recyclable Products in the Incentives for Manufacturing in California and Producing a Recyclable Product criteria section is listed in the FPG4 Narrative Proposal and include explaining and verifying the following:

    • The finished product is regularly collected at end of life and separated for recycling from consumers or communities where the item is sold.
    • Once collected, the finished product can be processed and reclaimed/recycled using commercial recycling processes.
    • Materials that are recovered through the recycling of the finished product have a market value.
    • There is no aspect (e.g. shape, size, or some other attribute such as food contamination through regular use) of the finished product that significantly limits the ability of the item to be accepted in recycling programs and be recycled.

    If the applicant manufactures an intermediate commodity that is sold or used by a partner to manufacture a finished product that is recyclable in California, the application may get one point for Producing a Recyclable Product. Products that are unable to be recycled in California (due to location or some other function) are not eligible for the bonus point.

16. Can project sites be added or changed during the grant term? If so, can these additional sites be included in the work plan even if their exact location is not yet determined?

    Due to the competitive nature of this grant program, project site locations may only be changed during the grant term due to extenuating circumstances and are not guaranteed. Project site locations are a required part of the grant application and contribute to the overall score of the application. Unapproved site changes may result in loss of grant funding.

17. Under the Applicant / Participant tab which and how many participants should we add? For example, add the communities that we are anticipating as locations to open our manufacturing facility?

    The Applicant/Participant tab will only list the participants that are submitting a joint application. The applicant is the Lead Participant that will receive any grant fund reimbursements for approved expenditure. Please refer to the Eligible Applicants and the Joint Application Requirements on page 5 and 6 of the Application Guidelines And Instructions.

18. Our grant project will include the construction of a facility. What is the timeline and process for filing permits?

    The process of filing and obtaining local permits is dependent on your local jurisdiction and governing authority. Please refer to CalRecycle’s Permit Toolbox to understand the general process and timelines for obtaining a solid waste facility permit and other permit related documentation. Businesses that process recyclable materials or produce products using recycled materials, that are not subject to CalRecycle’s authority, should be aware of possible circumstances, such as the “Three-Part Test”, that may trigger the need to obtain a solid waste facility permit Permitting will be evaluated and scored under the Experience, Project Readiness and Viability category. Permit scores will be based on obtaining any applicable permits needed to ensure that the project will be completed within the Grant Performance Period.

19. Our proposal involves the expansion of our business to California with an investment more than the $3,000,000 cap. Within our budget should we include both a breakout of the proposed $3,000,000 grant allocation as well as a breakout of the total investment on the project?

    Yes. The costs can be itemized and the budget amounts can be listed under the Local/State/Federal Funds/Other Funds heading in the FPG4 Budget Template located in the Grant Management System (GMS).

20. Our ability to provide an executable contract for our feedstock may be limited due to strategic / confidentiality considerations. What is considered an “agreement” for feedstock as to not preclude participation in the grant program? What happens if the feedstock partner does not live up to a contract and we need to change them out down the road?

    Agreement would include an MOU, contract, or similar document. Agreements containing confidential information may be submitted as confidential and will be handled in accordance with CalRecycle confidentiality rules specified in the Application Guidelines and Instructions. CalRecycle must be able to review, at a minimum, the sources, volumes, and types of all eligible feedstocks. If a feedstock partner does not “live up to a contract”, a grantee can change feedstock partners upon CalRecycle approval, but will need to include a feedstock agreement and/or submit a Feedstock Certification form. Material type(s) and quantity must be consistent with claims made in the application.

21. Do we need to submit the resolution letter with the application? If yes, who can prepare such a letter?

    A Resolution or Letter of Commitment is required with application submittal. Organizations with a Board may be required to submit a resolution. It is up to the organization to determine if a Resolution or Letter of Commitment is appropriate. Please see Resolution requirements on page 25 of the Application Guidelines and Instructions and see page 27 for Letter of Commitment Requirements.

22. With whom should we contact to know if we need these permit in our project?

    Different permits are administered by different state and local agencies and are dependent on the project and location. Please refer to the Permits application document in GMS, as well as CalRecycle’s Permit Toolbox for guidance.