If my jurisdiction already offers recycling to commercial and multifamily customers at no additional charge and we monitor participation rates, are we in compliance?

If a jurisdiction already has a commercial recycling program that targets affected businesses and addresses the education, outreach, and monitoring components of the regulation, the jurisdiction would not be required to implement a new or expanded program. However, most jurisdictions will need to ensure that their program informs public entities and multifamily complexes about the state requirement to recycle under AB 341. In addition, depending on the program that the jurisdiction has for monitoring participation rates, the jurisdiction may need to add a component of informing those entities that are not recycling of the state requirement to recycle and how they can recycle in the jurisdiction.

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1. How will CalRecycle determine compliance with the Mandatory Commercial Recycling regulation?
2. If my jurisdiction already offers recycling to commercial and multifamily customers at no additional charge and we monitor participation rates, are we in compliance?
3. Will a generation study be required to demonstrate compliance with the regulation?
4. How will jurisdictions and CalRecycle be able to evaluate the effectiveness of a program without data?
5. How should jurisdictions collect information from businesses to determine compliance with the regulation?
6. Will CalRecycle issue a “Compliance Order” if my jurisdiction cannot demonstrate compliance with Mandatory Commercial Recycling requirements?
7. Is it the responsibility of the transfer station owner/operator to ensure compliance with the regulation, or does the jurisdiction need to establish an ordinance or landfill ban?
8. There is already a system where materials are separated from general garbage for recycling. Is that system alone sufficient to comply with the regulation?
9. Do we need to send commercial and/or multifamily waste to a mixed waste processing facility prior to landfilling to comply with the regulation?
10. Will CalRecycle consider availability of composting facilities and markets in its review?