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AB 2346 • AB 2902

Waste Characterization Studies

How & When a Jurisdiction Can Reduce Its

Recovered Organics Waste Procurement Target

Presented by: Judi Gregory & Madeleine Tully, Go2Zero Strategies

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Background & Legal Framework

SB 1383 Mandate

California's SB 1383 requires jurisdictions to:

Reduce organic waste disposal 75% by 2025
Rescue 20% of currently disposed edible food by 2025
Procure a minimum annual quantity of recovered organic waste products (e.g., compost, mulch, biomethane)

Procurement targets are based on each jurisdiction's population and service area.

AB 2346 & AB 2902

The procurement target formula does not account for differences in organic disposal on a jurisdiction-by-jurisdiction basis.

These bills created targeted relief mechanisms:

AB 2346: Allows jurisdictions to use a CalRecycle-approved waste characterization study to demonstrate that organic waste generation is lower than the default calculation.

AB 2902: Provides additional pathways for adjusted procurement targets, including small jurisdiction relief and study-based reductions.

How the ROWP Target is Calculated

Procurement targets are based on each jurisdiction's population and service area.

Statewide Organic Disposal	25,043,272 Tons
X 13% Share Government GDP	3,255,625 Tons
/ 42,066,880 Population	=.08 tons Per Person Per year
X Jurisdiction Population	?

As a bit of background, SB 1383 is state mandated legislation which aims to reduce organic waste disposal as well as reduce disposable edible food.
As part of this legislation, there is one section which requires jurisdictions to procure recovered organic waste product per a specified target.
The initial legislation has a limited number of recovered organic waste products eligible, including compost, mulch, biomass…
For those interested in understanding how the .08 tons per person was calculated, here is the formula.
Two key elements about this formula, First, it is based on organic disposal, not generation…we will keep this in mind for the rest of the study presentation
Second, is that it does not take into account variations in organic disposal across jurisdictions, regions, or area. It is a blanket formula that can result in some jurisdictions being disproportionately targeted for procurement.
Therefore, AB 2346 and AB 2902 were passed to help (explain that waste studies can be used as one method to adjust ROWP target)

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How the Study Reduces the Procurement Target

Default Target

CalRecycle assigns targets using:

Population-based formula
State-average waste generation rates
Assumes typical organic content

→

Waste Study

Jurisdiction conducts study showing:

Lower actual organic disposal
Different waste composition than state average
Study meets CalRecycle methodology

→

Reduced Target

CalRecycle recalculates using:

Study-derived organic disposal fraction
Allows 75% statewide diversion goal adjustment
Lower, achievable target

Key Principle: The procurement target is proportional to the quantity of organic waste disposed. A study proving less organic waste in the fraction of residuals being disposed lowers the minimum procurement obligation.

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When to Use a Waste Characterization Study

Procurement Target Feels Disproportionate

The default CalRecycle target appears higher than what local generation rates warrant, due to unique land use, demographics, or commercial mix.

Low Organic Waste Generation Area

Jurisdictions with arid climates, industrial zones, or dense commercial areas may generate far less organic material than state averages assume.

Before Target Compliance Deadlines

Studies should be initiated early in a compliance cycle — ideally 6–18 months before the reporting year — to allow time for CalRecycle review and approval.

Multi-Year Value

A jurisdiction falling short on procurement can use the study results for up to five years.

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What Is a ROWP Waste Characterization Study?

Definition

A systematic field study that physically sorts and weighs samples of a jurisdiction's solid waste to determine what organics are disposed and in what quantities.

What It Measures

The study quantifies the composition of the waste stream, solely organic materials (food scraps, yard trimmings, wood, paper…) being disposed.

CalRecycle Approved

Studies must follow CalRecycle's prescribed methodology and sampling protocols to be accepted as the basis for a reduced procurement target.

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Study Requirements & CalRecycle Standards

Methodology Requirements

Sampling Protocol

Must follow CalRecycle's approved waste characterization methodology (based on ASTM D5231 or equivalent)

Sample Size

Statistically significant number of samples — typically 12 or more per residential/commercial/self-haul stream

Study Approach

The study should target all disposal streams. This includes landfill direct loads as well as post processing residuals.

Seasonal Coverage

Samples collected across multiple seasons to capture temporal variation in organic content

Material Categories

Must separately quantify food waste, yard trimmings, lumber/wood, paper, and other organic fractions

Submission & Approval

Required Documentation

Raw sort data, field notes, laboratory results, chain of custody, qualified analyst credentials

Qualified Personnel

Study should be conducted or overseen by a professional firm, waste characterization specialist, or other firm familiar with proper waste study procedures

Review Timeline

CalRecycle typically takes 30-60 days; submit well in advance of compliance reporting deadlines

Study Validity

Approved studies are typically valid for up to five years; re-study may be required if the waste stream changes significantly

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What Get’s Measured

Step-by-Step Process

Organics being disposed from:

Transfer/disposal only or post-processed single-stream
Post-processed recyclables
Post-processed organics
Construction debris & self-haul

Stream disposal rates MUST be normalized

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Recalculate ROWP Target

Cost-Benefit Consideration: Waste characterization studies may cost $30,000–$150,000+. A jurisdiction should first estimate its default procurement target cost and compare it to the study investment before proceeding.

Another Benefit

An additional benefit of the ROWP adjustment target calculation is that it allows the 75% statewide diversion goal.

Calculate Cost Savings

Before undertaking a study, compare estimated cost savings to the cost of conducting a study, over five-years.

Statewide Organic Disposal	25,043,272 Tons
X 13% Share Government GDP	3,255,625 Tons
/ 42,066,880 Population	=.08 tons Per Person Per year
X 75% Diversion Goal	=.06 tons Per Person Per year
X Jurisdiction Population	?

Current Annual ROWP Cost	Adjusted Annual ROWP Cost
Estimate 5000 TPY @ $15/Ton	50% reduction = 2500 TPY @ $15/Ton
$75,000/YR	$37,500/YR
	5 YR Annualized Cost of Study = $10,000
$75,000 / YR	$47,500/YR
Saving over 5 Years	$137,500

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Step-by-Step Process

Determine Eligibility: Confirm the jurisdiction qualifies under AB 2346/AB 2902 and review CalRecycle's guidance on approved study types.

Design the Study: Engage a qualified contractor and follow CalRecycle's prescribed sampling methodology — sufficient sample size, seasonal windows, and proper categorization.

Conduct Field Sampling: Physically sort and weigh representative waste samples. Document organic fractions (food, yard, wood, paper) separately from non-organics.

Submit to CalRecycle: File the completed study with all raw data, methodology documentation, chain of custody records, and professional certifications.

Receive Adjusted Target: Upon CalRecycle approval, the procurement target is recalculated using the study-derived organic waste generation rate.