JOSEPH M FERGUSON INSPECTOR GENERAL
CITY OF CHICAGO OFFICE OF INSPECTOR GENERAL 740 NORTH SEDGWICK STREET, SUITE 200 CHICAGO, ILLINOIS 60654 TELEPHONE (773) 478-7799 FAX (773) 478-3949
DECEMBER 2, 2020
TO THE MAYOR, CITY COUNCIL, CITY CLERK, CITY TREASURER, AND RESIDENTS OF THE CITY OF CHICAGO:
The City of Chicago Office of Inspector General (OIG) has completed an audit ofthe Department of Streets and Sanitation's (DSS) enforcement of recycling requirements for commercial and high-density residential buildings (i.e., those with five or more units). The objective of the audit was to determine if DSS ensures that building owners are providing collection services required by the Chicago Recycling Ordinance. In addition, the audit evaluated DSS' enforcement of reporting requirements for the City's licensed private haulers—companies engaged in hauling refuse and recyclables from commercial and high-density residential buildings. The required annual reports identify a hauler's customers, catalog the total amounts and types of materials hauled, and specify which facilities received them.
Based on the audit results, OIG concluded that DSS does not ensure that commercial and high-density residential building owners provide recycling services. In addition, DSS does not ensure that private haulers submit complete, accurate, and timely reports detailing the buildings they served, and the amount and type of materials hauled. This data would be useful to the City for establishing recycling goals, monitoring progress towards these goals, and determining waste diversion rates. While recent changes in the global marketplace for recyclable materials have presented challenges for municipal programs, other cities are adapting rather than abandoning recycling altogether.
In response, DSS stated that it agrees with the recommendations and will begin to implement corrective actions. The Department is awaiting the results of a comprehensive waste study before moving forward with some of the recommendations.
We thank DSS staff and management for their cooperation.
Joseph M Ferguson Inspector General
ir.CHICAGO ORG | OIG TIPLINE (866) 448-4754 | TTY (773) 478-2066
Respectfully,
OIG File #19-0942
DSS Commercial and High-Density Residential Recycling Enforcement Audit December 2, 2020
TABLE OF CONTENTS
EXECUTIVE SUMMARY|910|A CONCLUSION 3
B FINDINGS 3
C. RECOMMENDATIONS|910|D DSS RESPONSE|910|BACKGROUND|910|
RECYCLING IN CHICAGO ' ... .6|109|The Blue Bag and Blue Cart Programs|910|The Chicago Recycling Ordinance|910|Additional Options to Encourage Recycling|910|RECYCLING KEEPS WASTE OUT OF LANDFILLS 9
CHANGES IN THE GLOBAL MARKETPLACE HAVE SIGNIFICANTLY AFFECTED
U S. RECYCLING 10
1. Impact of Chinese Policy Changes on United States Recycling 10|109|Proactive Municipal Strategies 10
III FINDINGS AND RECOMMENDATIONS 12
FINDING 1: DSS DOES NOT ENSURE THAT COMMERCIAL AND HIGH-DENSITY
RESIDENTIAL BUILDING OWNERS PROVIDE RECYCLING SERVICES 12
FINDING 2: DSS DOES NOT ENSURE THAT PRIVATE HAULERS SUBMIT COMPLETE, ACCURATE, AND TIMELY ANNUAL REPORTS DETAILING THE BUILDINGS THEY SERVED, AND THE AMOUNT AND TYPE OF MATERIALS HAULED. DSS ALSO CANNOT DETERMINE PROGRAM OUTCOMES AND DIVERSION
RATES 15
IV. OBJECTIVES, SCOPE, AND METHODOLOGY 18
A. OBJECTIVE 18
B SCOPE 18
C. METHODOLOGY 18
D STANDARDS 19
E. AUTHORITY AND ROLE 19
APPENDIX A: CHICAGO RECYCLING ORDINANCE 20
APPENDIX B: MINIMUM CAPACI TY REQUIREMENTS 22
APPENDIX C: VOLUME-BASED WASTE FEE 23
APPENDIX D: RECYCLING HAULER/CENTER REPORT 27
ACRONYMS
AIS Department of Assets, Information and Services
BACP Department of Business Affairs and Consumer Protection
DOE Department of Environment
DSS Department of Streets and Sanitation
MCC Municipal Code of Chicago
MET Mobile E-Ticket
MRF Materials Recovery Facility
OIG Office of Inspector General
VBWF Volume-Based Waste Fee
OIG File? #"19-0942
DSS Commercial and High-Density Residential Recycling Enforcement Audit
CITY OF CHICAGO OFFICE OF INSPECTOR GENERAL
OIG File #19-0942
DSS Commercial and High-Density Residential Recycling Enforcement Audit
EXECUTIVE SUMMARY
The Office of Inspector General (OIG) conducted an audit ofthe Department of Streets and Sanitation's (DSS) enforcement of recycling requirements for commercial and high-density residential buildings. Our objective was to determine if DSS ensures that building owners provide collection services required by the Chicago Recycling Ordinance.
The Chicago Recycling Ordinance (the Ordinance) states that owners or occupants of such buildings "shall contract with a private hauler, or cause a contract to be entered into with a private hauler, for the provision of source-separated recycling services [...]." The City is required to provide buildings found in violation of this requirement 30 days to come into compliance. Continued noncompliance can result in fines ranging between $500 and $5,000 per day. The Ordinance also requires private haulers to submit annual reports detailing the source, type, and amount of recyclables collected. This information would assist DSS in calculating waste diversion rates, setting goals, and monitoring progress toward those goals.
CONCLUSION
OIG concluded that DSS does not ensure commercial and high-density residential building owners provide the required recycling services. In addition, DSS does not ensure private haulers submit complete, accurate, and timely reports detailing the buildings they served, and the amount and type of materials hauled.
FINDINGS
DSS does not thoroughly enforce the Chicago Recycling Ordinance requiring commercial and high-density residential building owners to provide recycling services. In fact, the Department's Mobile E-Ticket (MET) citation system does not even allow users to issue citations for Ordinance violations. This creates-a significant barrier to enforcement. Notably, when the former Department of Environment (DOE) was responsible for enforcing the Ordinance it was capable of issuing citations. The City disbanded DOE in 2011, however, and transferred responsibility for enforcement to DSS. The Department acknowledged that it has not met this responsibility, and has focused instead on operating the City's blue cart recycling program for residential buildings with one to four units
Although DSS does not maintain a list of high-density residential buildings, data from the Census Bureau's 2013 American Community Survey shows that nearly 500,000
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DSS Commercial and High-Density Residential Recycling Enforcement Audit December 2, 2020
Chicago households, about 41%, are in buildings with five or more units.' In addition, there are approximately 60,000 licensed businesses in Chicago that are required to procure private refuse and recycling hauling services.-' Without enforcement of the Ordinance, many of these households and businesses may not be recycling.
OIG also found that DSS does not ensure private haulers submit complete, accurate, and timely annual reports detailing the buildings they served, and the amount and type of materials hauled. The Ordinance requires haulers to provide these reports by February 28lh each year or risk fines. Furthermore, the Ordinance requires the DSS commissioner to "review and approve the adequacy" of each annual report submitted by a private hauler. In addition to citing haulers for submitting late or incomplete reports, the ordinance allows DSS to refer them to the Department of Business Affairs and Consumer Protection (BACP), which is authorized to withhold renewal ofthe hauler's business license until the hauler files a complete report.
In 2018, there were 15 licensed private waste haulers subject to the Ordinance's reporting requirements. Ofthe 15 required reports,3 DSS,
possessed nine, three of which were submitted after the February 28, 2019 deadline;
obtained four upon OIG's October 2019 request; and
did not possess or obtain two.
In addition, private haulers did not fully complete 5 ofthe 13 reports, thereby preventing DSS from calculating their waste diversion rates and including them in a citywide waste diversion rate/' Finally, DSS did not review the adequacy ofthe hauler reports or cite haulers for failure to submit timely and complete reports. The data in these reports could help DSS calculate diversion rates, set goals, and monitor progress toward those goals.
1 Chicago Metropolitan Agency for Planning, "Community Data Snapshot Chicago, Municipality June
2019 Release," June 2020, accessed August 6, 2020,
https //www cmap Illinois Qov/documents/10180/10288'l/Chicaqo pelf
;: City of Chicago, Department of Business Affairs and Consumer Protection, "Statement from BACP Commissioner Rose Escareno," 2020 Budget Proposal to the City Council Committee on Budget and Government Operations, November 5, 2019, 3, accessed August 6, 2020, h tti.is //www Chicago nov/cQiUei'u/riom/city/dtMJtsfo^ PO pen i net S tn re me n 1 od f
7 Appendix I j contains an example of a hai.Jer report
' ihe waste diversion rate— the percentage of waste generated that is diverted from iandf lis by recycling, reuse, composting, and oilier diversion means—is a key performance indicator in any recycling program
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RECOMMENDATIONS
OIG recommends that DSS, working with the Department of Law (DOL) and the Department of Assets, Information and Services (AIS), if necessary, configure the MET system to allow users to issue citations for violations of the Ordinance. DSS should consistently record-and monitor the outcomes of recycling inspections to determine, for example, whether building owners received 30-day notices and ultimately came into compliance or were issued citations. In coordination with the City's new chief sustainabihty officer, DSS should develop a program to enforce the Ordinance proactively, in addition to responding to complaints.
DSS should also ensure that haulers submit complete, accurate, and timely reports. As required by the Ordinance, DSS should review each annual report and notify BACP of noncompliant haulers. DSS should review the design of the annual reports to ensure it supports the City's recycling goals. The Department should also develop procedures to incorporate private haulers' diversion data into a citywide waste diversion rate. Finally, DSS should ensure that private haulers report all customers who decline recycling services and should consider requiring each hauler to submit a list of buildings it serves.
DSS RESPONSE
In response to our audit findings and recommendations, DSS stated that it agrees and will implement corrective actions. DSS has begun working with DOL and AIS to revise citation processes and add the ordinance to the MET system. The City has engaged a consultant to conduct a comprehensive waste study, and DSS will await the results before developing a proactive enforcement strategy. The waste study will also inform any changes to the design, collection, and usage of private hauler reports.
The specific recommendations related to each finding, and DSS' response, are described in the "Findings and Recommendations" section of this report.
OIG File #19-0942
DSS Commercial and High-Density Residential Recycling Enforcement Audit
II. BACKGROUND
A. RECYCLING IN CHICAGO
Chicago began administering recycling programs in the mid-1990s. Although the Municipal Code of Chicago (MCC) does not require the provision of garbage collection service to low-density residential buildings (four units or less), the City nevertheless performs this role. The City also collects recycling from such buildings, in keeping with MCC requirements.5 In contrast, the MCC imposes both recycling and garbage collection requirements on commercial and high-density residential buildings, but the City does not provide those services.
The Blue Bag and. Blue Cart Programs
The City has implemented a variety of programs for low-density residential building recycling. In 1995, the City rolled out its blue bag recycling initiative—a voluntary program where residents put their recyclables into blue bags that were placed in their garbage carts and later separated at City waste stations. However, the City struggled with low rates of participation in the program. In addition, the blue bags reportedly tore open and spilled in DSS trucks, and the process of separating them from garbage at waste stations was considered expensive and ineffective. The City discontinued the blue bag program in 2008.
The City initiated the blue cart program in seven communities in 2007 and expanded it citywide in 2013. This program, which is still in effect, relies on residents placing recyclable materials into separate blue containers and discarding other waste in black containers. The blue cart program is divided into six geographic zones. DSS services the blue carts in two zones and contractors service the remaining four.6
The Chicago Recycling Ordinance
The City's original legislation on this subject, the Workplace and Residential Recycling Ordinance, effective January 1,1995, required all building owners and property managers of commercial and high-density residential buildings to establish recycling programs and procure private hauling services. However, according to DSS, that ordinance lacked clarity and required stronger enforcement provisions. Effective January 1, 2017, it was replaced by the Chicago Recycling Ordinance,7 which was intended to remedy these problems and designates DSS as the enforcing department.
: MCC i" 11-4-1860
'¦¦ City of Chicago Department of Streets and Sanitation. "Blue Cart Schedule and Maps,' accessed August "17, 2020, htl.os/A^wvvChicago gov/citvAj; ./doots/str;;eis/st. : si;nio/iecvchnoi/bh,e_cai ;._scneciul-?s.r id maps html 7 MCC §11-5-010
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The Ordinance requires commercial and high-density residential building owners to contract with private waste haulers for the provision of source-separated recycling services.13 DSS is required to give noncompliant building owners 30-day notice to come into compliance, after which violators may be fined,
between $500 and $1,000 per day for a first violation;
between $1,000 and $2,500 per day for a second violation within one year; and
between $2,500 and $5,000 per day for a third, and any subsequent, violation within one year ofthe most recent offense.9
Building owners are also required to furnish common areas with recycling containers "in an amount sufficient to enable persons occupying, using, visiting, or lawfully upon such premises to engage in source-separated recycling"10 and to implement an ongoing education program to educate occupants about the recycling requirement.11
The Ordinance requires private haulers to, among other things,
offer recycling services to their garbage collection customers and notify DSS within ten days of any customers who decline the offer;
keep accurate and comprehensive records detailing the amount of recyclable materials collected annually and the facilities to which they delivered the materials;
submit an annual report to DSS by February 28"' every year, and including the following information on a form provided by DSS, with a certification that the information is complete and accurate:
o the percentage of their customers that are residential, commercial, industrial, or institutional;
o the type and tonnage of all recyclable material collected within the city during the reporting period and facilities to which it was delivered (by percentage);
8 MCC § 11-5-030 Source-separated lecycling is "a process that (1) separates recyclable material from waste, before the point of collection of such material, by requiring that recyclable material be placed in designated recycling containers, and (2) keeps recyclable material separate from waste until the recyclable material can be returned to the economic mainstream as new, used or reconstituted products" MCC § 11-5-020 Single stream recycling, a type of source-separated recycling where all recyclable materials are placed in the same container for collection, is permitted under MCC § 11-5-050 2 MCC §11-5-095 '° MCC 9 11-5-120
'' MICC § 11-5-140 Appendix A provides more information on the ordinance requirements for building owners, private haulers, arid DSS
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o the same information as above for construction and demolition debris, and other waste, if applicable; and
• any other information the DSS commissioner requires.r
Private haulers that violate the Ordinance are subject to the same fine schedule as building owners.1'
The DSS commissioner is required to review and approve each annual report submitted by a private hauler. Ifthe commissioner notifies BACP of a late or incomplete report, the MCC provides that BACP shall not renew the hauler's business license until the DSS commissioner confirms that the hauler has filed a complete report.^
3. Additional Options to Encourage Recycling
At the outset of this audit, DSS and the Mayor's Office expressed interest in learning about other cities' attempts to increase recycling through minimum capacity requirements for recycling containers and volume-based waste fees. OIG researched these practices. The results of our research are provided in Appendices B and C, and summarized below.
Minimum Capacity Requirements
The Ordinance does not require specific minimum container capacities or frequency of collection. For example, a high-rise building owner could technically comply with the Ordinance by providing tenants with a single 96-gallon blue cart—the size typically used for a single-family dwelling—emptied once every two weeks. Guidelines collected from various recycling organizations advise, however, that receptacles should allow 64 to 96 gallons for every five units within a building, assuming weekly pickup. We provide examples of multi-dwelling residential minimums in Appendix B.
Volume-Based Waste Fee
Volume-based waste fee (VBWF) programs—also referred to as "pay as you throw"— require customers to pay for the amount of waste they discard rather paying than a flat fee, thus providing an incentive to recycle. This approach is akin to customers paying for the amount of electricity or natural gas they use. Flundreds of municipalities across the U S. and throughout the world have implemented VBWF programs. We provide further information regarding VBFW programs in Appendix C
¦¦' MCC § 11-5-220 Anyone who Knowingly suomits false material statements n this report is si ibject to prosecution under the City's False Statement Ordinance
MCC 511-5-250
MCC §TI-5-220(e)
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DSS Commercial and hligh-Density Residential Recycling Enforcement Audit
B. RECYCLING KEEPS WASTE OUT OF LANDFILLS
The Illinois Environmental Protection Agency (IEPA) reported that, as of January 1, 2019, landfills in the Chicago metropolitan area had the capacity to receive trash for approximately 10 more years.1-'As shown in Figure 1, this is the shortest landfill life expectancy of lEPA's seven Illinois regions.
FIGURE 1: THE CHICAGO METROPOLITAN REGION LANDFILLS ARE PROJECTED TO FILL BEFORE ALL OTHER ILLINOIS REGION LANDFILLS
Region Number Geographic Area Number of Landfills Life Expectancy as of January 1, 2019 (Years) |109|Northwestern Illinois|99|19.8 |109|Chicago Metropolitan|99|10.2 |109|Peoria/Quad Cities|99|29.7 |109|East Central Illinois|99|27.3 |109|West Central Illinois|99|14.8 |109|St. Louis Metro East|99|22.7 |109|Southern Illinois|99|48.5
Total 38 Average of 214
Source IEPA, Illinois Landfill Disposal Capacity Report, September 2019
Recycling reduces the amount of trash sent to landfills, thereby increasing their life expectancies. Recycling also reduces municipalities' dependence on landfills, thereby reducing the greenhouse gases that landfills emit.15 Landfills are the third largest source of human-generated methane gas in the United States.17 According to the Intergovernmental Panel on Climate Change, in conjunction with other potent greenhouse gases, human-generated methane harms our natural habitats and human health systems. The harm includes, but is not limited to,
disruption of rural and urban economies;
food and water scarcity;
the increased spread of water and foodborne disease; and
greater risk of injury and death associated with intensifying flooding, heat waves, and fires.
13 Illinois Environmental Protection Agency. "Illinois Landfil Disposal Capacity Report,'' September 2019, 3. accessed August 6, 2020, htt&s //Vvvvw2 Illinois nov/epaAopiCs/vvasie-mcii lagemeni/land 111 Is/land till cai:;acn v/Docijrneiiis/lancil"ill-caijacitv iooo; t-2019 pdf
16 City ol Chicago, "Recycling 101 An Introduction to Recycling," 2013, accessed August 6, 2020.
httr«//www Chicago ciov/ciam/citv/depis/doe/aeneral/R^
eel Recy:-. In iqlOl pdf
17 United States Environmental Protection Agency, "FJasic Information about Landfill Gas." 2020. accessed
August 6, 2020, hups //¦¦.vvvw eoa r:ov/liroo/basic- nformation-acouL ianciii-f ria-;
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DSS Commercial and High-Density Residential Recycling Enforcement Audit December 2, 2020
These harms are felt most acutely by underprivileged communities, regardless of their country's level of development.18 Although recycling alone will not stop the harmful effects of climate change, it is an essential component of any climate change mitigation strategy.
C. CHANGES IN THE GLOBAL MARKETPLACE HAVE SIGNIFICANTLY AFFECTED U.S. RECYCLING
On January 1, 2018, China instituted the National Sword policy, effectively banning the import of all recyclable mixed plastic and mixed paper.19 Soon thereafter, on March 1, 2018, China reduced the amount of impurities allowed within recyclable materials (the contamination level) to 0.5%. Later in 2018, China began enforcing tariffs on numerous recyclables, such as cardboard, plastics, and metals.
1. Impact of Chinese Policy Changes on United States Recycling
China's policy changes have significantly reduced the international market for recyclable materials, and the United States has struggled to adapt.20 Materials recovery facilities (MRFs) that sort and prepare recyclables for the market have raised processing prices. Some MRFs have gone out of business. The rise in fees has increased costs for municipal curbside recycling programs, resulting in some programs being suspended or discontinued altogether.21 Much ofthe United States' waste and recyclables have been diverted to other countries with less stringent regulations, such as Malaysia, Thailand, and Indonesia. However, these countries lack the capacity to process the amount of imported recycling previously processed in China, and they have also implemented restrictions on the import of foreign waste. Overall, the value of recyclables processed by MRFs in the U.S. declined by 48%, or $431 million dollars, between February 2017 and February 2019.22
2. Proactive Municipal Strategies
Although changes to the recycling market have created difficulties for municipalities, adaptive strategies are emerging For example, MRFs have enhanced their processing
18 Intergovernmental Panel on Climate Change, "Climate Change 2014 Synthesis Report," 2015, 64, accessed August 6, 2020, https//www incc ch/sii.e/assets/iiploacls/20ia/Q2/SYR AR5 FINAL full pdf 15 Solid Waste Association of North America Applied Research Foundation, "Resetting Curbside Recycling Programs in the Wake of China," September 2019, 7
20 Alex Truelove and Carrie Katan, "~rhe State of Recycling In Illinois." U S PIPC Education Fund, November 14, 2019, 6, accessed August 6, 2020. https//'illinoispirciedtjnd orq/sites/p;rg/jl;es/repcrts/The%20S;atevi: ;K)of%20Recvclina9f2Qin%20llhi-x)is%20%?SririaBC29 pdf
x Cole Rcsengren. Max Witynski, Rina Li. FA Crunden. Cody Boteler and Katie l:'yzy-<, "How recycl.ng has
changed in all 50 states," Wastedive com. November 15, 2019, accessed August 6, 2020,
hi.Ios //www wasi ogive coi-i/i lews/what-chn ~ese i;; iooi : policies - mean foi --all-50-si a\ os/5"0751/
Solid Waste Association of North America Applied Research Fo. ir.dation, "Resetting Curbside Recyclu -.
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procedures to match China's contamination standards, and cities have adjusted recycling fees to reflect the costs of hauling and processing. While this requires additional time and increases labor costs, recyclables retain a higher market value. According to a report by the National League of Cities, domestic recycling markets are beginning to expand; cities can facilitate this growth by employing such tactics as tax breaks for businesses utilizing recycled materials and municipal procurement practices that require purchasing recycled materials.-"
Another strategy for responding to the new recycling market is modifying municipal contracts so that risk is shared more equitably between cities, haulers, and processers. In Palm Beach County, Florida, waste authorities reached a 12-month sales agreement with a paper mill that guarantees price minimums and maximums for the city's mixed paper. Similarly, San Antonio, Texas, entered into a contract with an MRF that charges more for accepting the city's materials than in the past but provides the city with a greater share of the revenue generated.
To increase recycling participation and reduce contamination, it is critical for municipalities to educate the public on these issues. Between 2016 and 2018, Elgin, Illinois, reduced its contamination rate from 40% to 16% with assistance from Waste Management's Recycle Often, Recycle Right educational toolkit. In Florida, the Rethink. Reset. Recycle, initiative provides educational resources for residents, public officials, and recycling advocates across the state. Other cities have used strategies such as utility bill inserts, social media outreach, and municipal websites to educate people on how to reduce contamination and maximize recycling.-1'''
21 Connne Rico and Cooper Martin, "Rethinking Recycling l-low Cities Can Adapt. To Evolving Markets," 2018, 22-28, accessed August 6, 2020. hli.i)s//wy-/w nlc oiQ/sites/delauli/files/2018-09/CSAP Recvchno-MAG pdf
2~ Connne Rico and Cooper Martin. "Rethinking Reeve mg Flow Cities Can Adopt To Evolving Mar kets," 2018,16, accessed August 6, 2020. https //ww.y oro/sites/de'ault/filer.^;)'^: C9/CSAP Pocvchrn-MAC cdf
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FINDINGS AND RECOMMENDATIONS
FINDING 1: DSS DOES NOT ENSURE THAT-COMMERCIAL AND HIGH-DENSITY *[y : RESIDENTIAL-BUILblNG.OWNERSPROViDE RECYCLING SERVICES.'
DSS does not actively enforce the Chicago Recycling Ordinance, requiring commercial and high-density residential building owners to provide recycling services. Notably, the Department's citation software does not allow users to issue citations for Ordinance violations. DSS acknowledged that it has not enforced the Ordinance, focusing instead on operating the City's blue cart recycling program.
DSS makes no attempt to identify noncompliant commercial or high-density residential buildings. However, it responds to public complaints about such buildings by sending ward superintendents to inspect them. OIG identified 97 complaint-based inspections conducted between January 1, 2017, and December 30, 2019. Of those, DSS issued 3 citations, 1 of which resulted in a fine of $290. But it is impossible to determine the significance of these numbers, because,
DSS does not maintain a list of buildings subject to the Ordinance or a list of customers served by private haulers (see Finding 2). Comparing these two lists could reveal buildings that do not provide recycling services
DSS does not consistently record the outcomes of inspections. It is not clear from the records if, for example, the ward superintendent found a building was in compliance, or delivered a notice to comply within 30 days and found it in compliance upon re-inspection, or closed a complaint for other reasons (such as an inability to contact the building owner).
The Mobile E-Ticket (MET) system ward superintendents use to issue citations does not include MCC § 11-5-030—the requirement to contract with a private hauler for recycling services—as a citable code section. Therefore, a ward superintendent seeking to cite a building owner for failure to provide recycling service must write the citation under a different provision. Each of the three citations OIG identified were cited under MCC § 7-28-220 ("Duty to provide refuse containers and service").-'
¦:- Based on the substance of the complaints that piomptecl the inspections, wc are reasonably ceitain the citations were actually for failure to provide recycling services
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The inability to issue a citation for failure to provide recycling services is a significant barrier to enforcement ofthe Ordinance. Notably, options for citing violations were available when the former DOE was responsible for enforcement. DOE was disbanded in 2011, however, and the responsibility was transferred to DSS.
Although DSS does not maintain a list of high-density residential buildings, data from the Census' 2018 American Community Survey shows that nearly 500,000 of Chicago households, about 41% ofthe total, are in buildings with five or more units.26 Additionally, there are approximately 60,000 licensed businesses in the city that are required to procure private refuse and recycling hauling services.27 Without enforcement ofthe Ordinance, many of these households and businesses may not be recycling.
RECOMMENDATIONS
DSS, working with the Department of Law and the Department of Assets, Information and Services if necessary, should configure the MET system to allow users to issue citations for violations of the Ordinance.
DSS should consistently record and monitor the outcomes of recycling inspections to determine, for example, whether building owners received 30-day notices and ultimately came into compliance or were issued citations.
In coordination with the City's new chief sustainability officer, DSS should develop a proactive approach to enforcing the Ordinance, in addition to responding to complaints. An effective approach will likely require DSS to,
create and maintain a complete and accurate list of buildings subject to the ordinance, as well as their compliance status. This may require the assistance of other City departments (e.g., Law, Buildings, and Planning and Development);
set goals for number and frequency of inspections and measure the Department's performance against those goals;
develop a random or risk-based method of selecting which buildings to inspect; and
20 Chicago Metropolitan Agency for Planning, "Community Data Snapshot Chicago, Municipality June
2019 Release," June 2020. accessed August: 6, 2020,
hi 1 os //www cmap illi nois oov/docurriei u?/IO'lftO/10?031/Chica( io odf
27 City of Chicago. Department of Business Allans and Consumer Protection, "Statement from BACP Commissioner Rose Fscareno," 2020 Budget Proposal to the City Council Committee on Budget and Government Operations. November 5. 2019, 3. accessed August 6. 2020.
hitos //www Chicago gov/content/oaiWcily/oeois/olvMTi/su^^ peninqStatemenls/BAC
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(cl) define a standardized inspection process for determining compliance with all provisions of the Ordinance, including an owner's duty to implement an education program informing occupants about their building's recycling service.28
MANAGEMENT RESPONSE
"We hove begun the discussion with the Deportment of Low (DOL) ond AIS obout revising the process for proper citing ofthe violation, including odding the ordinance to the MET system."
"DSS currently tracks all complaints/inspection requests and tracks the outcomes in the CSR/Salesforce system. In March 2020, DSS began discussions with DOL to update our inspection, compliance, and outcome tracking process."
"DSS worked with the Mayor's Office Policy and Sustainability group to engage a consultant to conduct a comprehensive waste study, which includes issues of private waste & recycling collection. As part of this study, a full' assessment ofthe City's private waste regulation is being conducted. This study will inform the direction and goals that need to be set in order to improve the-waste diversion for the City and region.
Specifically, the scope ofthe study will include a review ofthe waste & recycling policies, contracts, data, and infrastructure. And, develop and prioritize strategies for waste reduction, recycling and reuse. The information and recommendations from the study will inform the development of a proactive approach to enforcement ofthe Ordinance and to achieving the underlying goals ofthe Ordinance. The recommendations provided in the OIC's report will be taken into consideration together with the waste study findings to form a comprehensive strategy going forward."
* bee Appendix A for a summary of other provisions of ihe Ordinance
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.FIN DI NG 2:: DSS DOES -NOT Ertl^RETHA^ V : " 1 •PRIVATE HAULERS S;UBMIT-cdWi^ETE.S ;;*;„ ;;t iACCURATE,AND.T)MELY/^NL^ f D ETA I LI NG T HE B U I lib IN G S TH iV S E R V E D*'A N D> THE AMOUNT AND. TYPE OF MATERIALS:. : HAULED. DSS ALSO CANNOT DETERMINE -~ PROG RAM OUTCOM ES AN D DIVERSION. RATES."
DSS does not ensure that private haulers submit complete, accurate, and timely annual reports detailing the buildings they served, and the amount and type of materials hauled. The Ordinance requires haulers to provide these reports by February 28th of each year or risk a fine. Furthermore, MCC § ll-5-220(e) requires the DSS commissioner to "review and approve the adequacy" of each report submitted by a private hauler. In addition to citing haulers for submitting late or incomplete reports, the Ordinance allows DSS to refer them to BACP, which is required to withhold renewal of the hauler's business license.until they file a complete report.
In 2018, there were 15 licensed private waste haulers subject to the reporting requirements. Ofthe 15 required reports,29 DSS,
possessed nine, three of which were submitted after the February 28, 2019 deadline;
obtained four upon- OIG's October 2019 request; and
did not possess or obtain two.
In addition, private haulers did not fully complete 5 of the 13 reports, thereby preventing DSS from calculating their waste diversion rates and including them in a citywide waste diversion rate.3,0 Finally, DSS did not review the adequacy ofthe hauler reports or cite haulers for failure to submit timely and complete reports. The data in these reports could help DSS calculate diversion rates, set goals, and monitor progress toward those goals.31
~- See Appendix D for an example of a hauler i epoi t
x The waste diversion rate— the percentage of waste generated that is diverted from landfills by recycling, reuse, composting, and other diversion means—is a key performance indicator in any recycling program
7'' DSS last reported diversion rates in July 2018 Those tales, however, were based sc'elv on '.he Blue Cart Recycling Program City of Chicago Department ol Streets and Sanitation. 'About Blue Can: Recycling
OIG File #19-0942
DSS Commercial and High-Density Residential Recycling Enfoicement Audit
The Ordinance also requires private haulers to offer services to their garbage collection customers and to notify DSS of any customers who decline the offer. Private haulers have not reported such customers to DSS, though this information would help DSS enforce compliance. While not required by the Ordinance, private haulers could also provide a list of buildings served to further inform DSS efforts to ensure compliance.
RECOMMENDATIONS
DSS should ensure that private haulers submit complete, accurate, and timely annual reports. As required by the Ordinance, DSS should review each report and notify BACP of noncompliant haulers.
DSS should review the design ofthe annual reports to ensure it supports the City's recycling goals. Such review efforts would include,
determining data collection goals and conclusions to be drawn from the reports; and
ensuring the reports are designed to accurately capture the data necessary to evaluate the goals and make conclusions.
DSS should develop procedures to incorporate elements of private haulers' diversion rates into a citywide waste diversion rate.
DSS should ensure that private haulers report customers who decline recycling services and consider requiring each private hauler to submit a list of buildings served.
MANAGEMENT RESPONSE
"DSS understands the importance of these reports and the obligation to continue to collect the information under the MCC. DSS will utilize BACP's two-year renewal process to ensure the hauler reports ore submitted as required by the MCC BACP may withhold the issuance or renewal of a license to haulers that fail to submit a report. The reporting process and other regulatory measures for private waste haulers are being assessed as part of our waste study."
"These reports are being assessed as part of our waste study & review process and may be re-designed based on specific recommendations ofthe waste study."
2018 Results,' accessed September 17 2020 h; tos ¦V--v---/-.-v ch icq-tip co ¦.'/¦¦:: tv/eivoepisA; i eets/SL.po info /iecvciiriol/aboi.it..l:li.ie_.cari;._.recvchru-i html
OiG File #19-0942
DSS Commercial and High-Density Residential Recycling Enforcement Audit
"This is a part of the comprehensive waste study, and a course of action will be developed taking into consideration the recommendations in the OIG's report upon receipt ofthe study."
"This is a part ofthe comprehensive waste study, and a course of action will be developed taking into consideration the recommendations in the OIG's report upon receipt of the study."
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DSS Commercial and High-Density Residential Recycling Enforcement. Audit
IV. OBJECTIVES, SCOPE, AND METHODOLOGY
OBJECTIVE
The objective ofthe audit was to determine if DSS ensures commercial and high-density residential building owners provide recycling services, as required by the Chicago Recycling Ordinance.
SCOPE
This audit focused on DSS' current enforcement processes, or lack thereof, related to recycling at commercial and high-density residential buildings. The Ordinance defines high-density residential buildings as those having five or more dwelling units. Regarding DSS' complaint-based enforcement, OIG considered service requests from June 2, 2018 to November 26, 2019.
METHODOLOGY
To gain an understanding of DSS' current enforcement activities and internal controls, OIG interviewed DSS management and ward superintendents. We learned that DSS did not thoroughly enforce the Ordinance, but relied solely on complaint-based inspections conducted by ward supervisors. We assessed control environment, control activities, information and communication, and monitoring activities with the understanding that there is no active enforcement ofthe Ordinance, based on interviews with DSS management.
To determine the effectiveness of DSS' complaint-based inspection process, OIG reviewed Salesforce32 service request data. Because there is no request specific to recycling at commercial or high-density residential buildings, we reviewed all requests related to recycling and attempted to decipher from the content whether the request was related to our objective. Specifically, we generated a report of service requests that identified buildings with five dwelling units or more. Finally, we compared these requests to City citation data, including citations under MCC § 7-28-220, which ward superintendents stated they used as a proxy for violations ofthe Ordinance.
To determine if DSS collected private hauler reports, OIG requested the 15 reports from 2018 as required by MCC § 11-5-220. We evaluated the available reports for the timeliness of their submission, completeness, and utility of their data.
¦:; Salesforce -s the software that captures ¦den:ifying chaiaciensucs of ~j'P se'Vice ieg jests
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DSS Commercial and High-Density Residential Recycling Enforcement Audit
STANDARDS
We conducted this audit in accordance with generally accepted Government Auditing Standards issued by the Comptroller General of the United States. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives.
AUTHORITY AND ROLE
The authority to perform this audit is established in the City of Chicago Municipal Code § 2-56-030 which states that OIG has the power and duty to review the programs of City government in order to identify any inefficiencies, waste, and potential for misconduct, and to promote economy, efficiency, effectiveness, and integrity in the administration of City programs and operations.
The role of OIG is to review City operations and make recommendations for improvement.
City management is responsible for establishing and maintaining processes to ensure that City programs operate economically, efficiently, effectively, and with integrity.
PAG I 19
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DSS Commercial and High Density Residential Recycling Enforcement Audit
APPENDIX A: CHICAGO RECYCLING ORDINANCE
The following tables summarize the major responsibilities of building owners, private haulers, and DSS under the Chicago Recycling Ordinance, MCC Chapter 11-5.
contract with private wasteshatalers for the provisionjof source-separated recycling .
services" in addition to garbage collection;" '• '' _ ¦" -¦¦ '_ . • ¦";'
"in an amount sufficient to enable
furnish common areas with recycling containers persons occupying, using, visiting, or lawfully upon such premises to engage in source-separated recycling;" the containers must,
o . "(1) be ^iiealf^^
(2) display a written and/or pictorial deposited into such a container;
o-"- (3Lbc emptied on aJregular basis so that'cofWirvIS^
.^X:separatear,ec the-pAeng:ise„svana
o (4) be maintained free from odor;"'1
ji: Reeyding,Qjdinan
post permanent, legible signs in maintenance areas listing all materials required to be source-separated and how those materials are collected,
types of materials that must be recycled
o
o "types of materials that ma^not^fee^lace^Jn!a.reGycling•.^•contalnero how to properly prepare items for recycling ,o
,.4taejii|!ter:ior|and.exterior locations oftijeeyjling containers
o the collection schedule vo .the name andxontact information of the private ha'iiilerf.ancL' provide written notice to occupants of any change to the recycling service within ten days of the change.
inform their customers in writing:offer to provide recycling services to their garbage collection customers, and notify DSS
within ten days of any customers who decline the offer,
provide their customers with IcgaUy accessible recycling:contaiher:s!that are:
o a shade of blue that is clearly distinguishable from the garbage containers, and clearly marked as recycling containers, !.
35 MCC §11 5-030 Source-separated recycling is "a process that (1) separates recyclable material from waste, before the point of collection of such material, by requiring that recyclable material be placed in designated recycling containers, and (2) keeps recyc able material separate from waste until the recyclable material can be returned to the economic mainstream as new, used oi reconstituted products" MCC §11-5-020 Single stream recycling, a type of souice-separated recycling wheie all recyclable materials are placed in the sa'~ne coniainei foi collection, is permit ten unciei MCC '} 11-5-050 MCC §11-5-120
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DSS Commercial and High-Density Residential Recycling Enforcement Audit
o made of leak- and rodent-proofing id.matonal'wrt^^^
o d:splay a list or illustration of recyclable materials that may be deposited in the container,
o display tr^e _name%hd:contact information of the private hauler, and the address or business nam^o4the customer;-provide their customers with written instruction manuals that include. :-: o "(1) the definition pfgp.urce^separatcd recycling; o (2) why it is important to recycle;
o (3) the^hstbtimaterial aece^ prohlbited-for^ o (4) how to prepare recyclable material for handling by the hauler;
o (5) hoyvip prevent coB^^f^^^^y^c^cla^e^ax^^^^T r- ~- ••• •
o (6) the address of the Department's City of Chicago website, where this ordinance shall be posted and where additional information about disposal, reuse and recycling options can be obtained :keep aieuraleiand-'cfem
from custoj^iBrs^anpua1l-y_and the faciiit-iesfto^hich they;,de1jyer*th,e materials^-'"' . ; retain those records for at least three years and make them available upon request by the City
by-FeBruafy 28th every year! submit an anhTjalTepoJt-tb'bsS includihglth^etfol lowing
information, on a form provided by DSS. - .'-o percentage of customers that are residential, commercial, industrial, or institutional;
o type and'tonhage cSaMei^iab1ermatcrial collectedwifhinfthe/cifylduri^g tBe -reporting period, and:faGr]i|ics;t'6iwhi'eh it'wastdeliyereqr.^ylpercontage';- -4# o the same information as above for construction and demolition debris, and other waste, if applicable, . o :;;anyotherjnf;oj;ro.atipn^0_ejp certify that the information in the annual report is complete and accurate.30
j:give noncprripliant.buildingiiow:ners 30;:days; notice to come into compl'unco; •
"review and approve the adequacy" of each annual report submitted by private haulers; if the DSS commissioner notifies the Department of Business Affairs and Consumer Protection (BACP) of any late or incomplete reoorts, BACP must not renew the hauler's business license until the commissioner confirms that the hauler has filed a complete report
fine violators, . _ _\JS, ¦...'. "'_ _L- .,
o between $500 and $1,000 for a first violation, . " o ¦¦ \^t^^\^%x6^&^\0^^^'ioiKB second'^Siafib'n'.With'iri'oriey^ir„andT'
o between $2,500 and $5,000 for a third, and any subsequent, violation within one year ofthe most recent offense3'
- MCC §'l'l-5-240(a)
'e Anyone who knowingly submits false matenal statements is subject to prosecution under the City's False Statement Ordinance. MCC Chapter 1-21 MCC § 11-5-220 (c)
These fines apply to building owners and to private haulers The ordinance also specifies thai "each day a violation continues shall constitute a separate and distinct offense" MCC §§TI 5-050 and -250
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APPENDIX B: MINIMUM CAPACITY REQUIREMENTS
OIG identified organizational guidelines for determining the appropriate volume and number of recycling containers relative to the number of occupants or residential units. The organizations include StopWaste, Recycling Partnership, and Zero Waste Design, as shown in Figure 2. Additionally, OIG identified guidelines determined by certain municipalities across the U.S. and Canada, as shown in Figure 3.
FIGURE 2: ORGANIZATIONAL GUIDELINES
Source Volume Per Unit/Person Frequency
StopWaste-* 50 gallons Every 3 People Weekly
Recycling Partnership^ 96 gallons Every 5 Units Weekly
Zero Waste Design Guidelines/,° 64 gallons Every 5 Units Weekly
FIGURE 3: MUNICIPAL GUIDELINES
Municipality Volume ' Per Unit/Porson Frequency
Chula Vista, CA 34-40 gallons 1 unit Weekly
Columbus, OH 64 gallons 1 unit Bi-weekly
Half Moon Bay, CA 1 cubic yard (200 gal) 16 units N/A
Louisville, KY 25 gallons 1 unit/3 people Weekly
Seattle, WA 1.5 cubic yards (302 gal) 10 units Weekly
Sunnyvale, CA 192 gallons 10 units Weekly
Toronto, CAN 8 cubic yards (1,536 gal) 100 units Weekly
Stopwasto, "Space Guidelines for Recycling, Organics, and Refuse Services lo-" Designers of Multifamily and Commercial Buildings," 2020, accessed August 6, 2020, IU'p//'A'wvy siopwaste ofo/sites/default/hies/EkiilclMic-CL;idelinc,s--Fii)ai-Api3 odf 95 The Recycling Partnership, "A Guide To Implementing A Cait-Baseci Recychng Program; 2015, accessed August 6, 2020, hitos/Zrecychnnoartneishio oro/vvD coruent/LiDloads/201B/05/impleme;ii irm-
-' Zero Waste Design Guidelines, "Waste Calculator,' 2020, accessed August 6, 2020, httos//'¦¦'¦/¦¦/¦.¦•¦¦¦'¦; jier^-A-asiepes'on orn/wasr.o calculator/
PAG f 22
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DSS Commercial and High-Density Residential Recycling Enforcement Audit
APPENDIX C: VOLUME-BASED WASTE FEE
Volume-based waste fee (VBWF) programs offer a more equitable distribution of costs to those who use refuse collection and disposal services the most They provide financial incentives to reduce waste generation, as well as a greater awareness of an individual's responsibility to reduce waste and increase recycling. These programs may not necessarily cause people to generate less waste, but may incentivize people to divert more of their waste. There is also potential to financially burden low-income residents or large families, which may then create an incentive to illegally dump waste. Administering VBWF programs in multi-unit buildings can be more challenging than doing so in single family homes, and depending on the type of VBWF program enacted, there may be substantial start-up costs."1
FIGURE 4: VBWF PROGRAM TYPES'*2
Program Type Description
Bag Programs Customers purchase bags imprinted with special logos ahead of time, and waste must be put in the appropriate bag (yard waste, recyclables, garbage, etc.). The price ofthe bag incorporates the cost of collection, transport, and disposal ofthe waste. In some communities however, the cost ofthe bag only reflects a portion of the cost.
Hybrid Programs Adds an incentive-based system to fixed fee systems by reducing service under existing fixed fee system and if a customer needs to dispose of additional waste, there is an additional charge such as a fee per bag or additional container
One-Can Customers Some communities have introduced mini-can (13-20 gallons) or micro-can (10 gallons) garbage service levels to provide incentives for aggressive recyclers.
Tag and Sticker Programs Identical to bag programs, except instead of using a special bag, customers affix an appropriate sticker or tag that identifies the type of waste they are disposing.
Variable Can or Subscribed Can Customers select the appropriate number or size of containers for their standard weekly garbage disposal amount Higher rates correspond with increases in the number or size of carts selected.
Weight-Based Programs Waste trucks weigh garbage containers and charge customers based on the actual weight of garbage set out for disposal. On-
"Advancing Sustainable Materials Management. 2017 Fact Sheet.," United States Environmental Protection Agency, November 2019 hups /'www eon ooy/sites/oroduci io* i/!les^20'!9TI/docuiTrents /2C"7 factsand.figuresfact .sheecfnai pdf
"Recycling in Michigan Successful Recycling Programs, Best Practices, and Diversion Potential,' Noitheast Michigan Council of Governments, January 2016
hi' os //www mic! i,oan aov/documents/dea.'-vr:0?"yj- !/> iMlI-'COCJ'-lNAl JT C'-'CIJt .C. :":;;TPOP '" V
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DSS Commercial and l-ligh-Density Residential Recycling Enforcement Audit December 2, 2020
board computers record weights by household and customers are billed on this basis
Other Variations Waste drop-off programs that use customer tracking systems.
FIGURE 5: EXAMPLES OF VBWF PROGRAMS ACROSS THE U.S.
Municipality Program Type Program Description
Austin, TX*3 Variable Can or Subscribed Can, Tag and Sticker Program Residents are charged a base fee of $14 70 per month plus a per gallon fee that is dependent on the size cart they choose Total costs for collection of refuse, recycling, bulk, brush, and yard trimmings are included. • $0.16 per gallon for 64-gallon or smaller carts • $0.30 per gallon for 96-gallon carts Austin also offers collection of extra bags of trash that do not fit in a resident's cart Extra bags must be tagged with an extra trash sticker which cost $4 plus tax each
Fort Worth, TX4i Variable Can or Subscribed Can, Bag Program Residents are charged monthly for refuse based on the size cart they choose Each cart size has a garbage collection weight limit as well. Recycling is provided at no additional charge • $12 05 per month for 32-gallon cart (150 lb limit) • $17 05 per month for 64-gallon cart (200 lb limit) $22.75 per month for 96-gallon cart (250 lb limit) If residents exceed their limit, residents can purchase bags that can be set aside their carts for collection Those are $15 for a set of five
Grand Rapids, Ml-* Variable Can or Subscribed Can Residents are charged for waste per tip,'"3 and the fee per tip varies depending on the size cart they choose Recycling is provided at no additional charge • $3 05 per tip for 32-gallon cart • $510 per tip for 64-gallon cart • $715 per tip for 96-gallon cart Grand Rapids equips refuse and recycling carts with radio frequency identification tags and collection vehicles are equipped with onboard reader systems The carts are linked to each residents' address allowing for refuse and recycling data collection and the transfer of operational data back to the office using tne onboard systems
Minneapolis, MN" Variable Can or Residents are charged a monthly refuse fee of $25 08 (per dwelling unit) They are then charged an additional fee per month based on the
'¦- "Residential service rates and fees," austintexas gov, 2020 hup //www aust.: n texas gov/depart ment/ residen t la I services- ra tes-a nd-fees
¦'-' "Garbage Collection Fees," fortworthtexasgov, 2020 httus//fort.wot thtexas qoy/soiidwas'e/fees/ ¦'¦'"¦ "Waste Service Payments," City of Grand Rapids, 2020 ht.tps //www granclrapidsmi cioy/i~>avments/ Waste-Service-Payments
*f' A "tip" refers to the act of emptying one container—in this case "tipping" the container ir:o a truck to remove its contents
"2016 Minneapolis Residential Solid Waste Composition Analysis And Recycling Program Evaluation Final Report,' Hennepin County, 2016 httos//www hennepin usA/media/honneniiius/your -oove- nment /;':roiect~-ii'iit:a;iyes/docucni- nts/henneoin-coun tv-y/aste-soi t-stuoy-20 !6 ixif'- la -en&hash-7C299f"8l-C'/CI0B9BLjS9l3349.5A9B7l4C06A702Cf I
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Subscribed Can size container they choose Recycling is provided at no additional charge. • $2 00 per month for 32-gallon size • S5 00 per month for 96-gallon size There is no additional fee for recycling carts
Sacramento, CA"'- Variable Can or Subscribed Can Residents are charged for both waste, recycling and yard waste pickup based on the size and number of carts they choose for each service Waste Collection • $1435 per month for 32-gallon cart, any additional cart of this size is $14 20 per month • $1890 per month for 64-gallon cart, any additional cart of this size is $16 44 per month • $23.00 per month for 96-gallon cart, any additional cart of this size is $19 43 per month Recycling • $5 90 per month for 64-gallon cart or 96-gallon cart, any additional cart of any size is S2 03 per month Yard Waste • $10 75 per month for 96-gallon cart, any additional cart is $3 49 per month
San Jose, CA'-9 Variable Can or Subscribed Can, Tag and Sticker Program Residents are charged for garbage collection based on the size cart they choose These fees include recycling service • $35 89 per month for 32-gallon cart • $71 78 per month for 64-gallon cart $107 67 per month for 96-gallon cart If any additional waste collection is needed, residents can purchase extra bag stickers San Jose also explicitly outlines a VBWF program for high-density buildings. The city offers 1, 1 5, 2, 3, 4, 5, 6, and 8 cubic yard size containers and offers up to 5 collections per week Prices are dependent on the size container and the number of collections per week requested
Seattle, WA50 Variable Can or Subscribed Can, Bag Program Residents are charged for waste collection based on the size container they choose and where the container is located (curb or alley vs backyard) There is no additional cost for recycling services • 12-gallon cart $24 25 per month for curb or alley pickup, backyard pickup N/A • 20-gallon cart $29 70 per month for curb oi alley pickup, backyard pickup N/A • 32-gallon cart $38 65 per month for curb or alley pickup, $5400 per month for backyard pickup • 64 gallon cart $77 25 per month for curb or alley pickup. $108 20 per month for backyard pickup
"Cur bs de Collection Services,' City ol Sacramento, 2020 h:.' os //www cnvpr'saci m rio o; o.-Pi iNic-Wo; ks/RSW/Co I lection-Services
''"' "Recycle Plus Service S Rates." sanjoseca gov, 2020 hti ps //wwwsa'iioseca ciov^horne/shovvr'loci inon;? idl~4Q:')68_
"Garbage Can Pares." Seattle gov 2020 huns //¦¦¦vwvv s^a: to pov/i.:H • r's/se:v;ccs/iates/:-;aroaoe ruei
PACE 25
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DSS Commercial and High-Density Residential Recycling Enforcement Audit December 2, 2020
• 96-gallon cart $115 90 per month for curb or alley pickup, $162 25 per month for backyard pickup • Extra waste pickup is also available at a fee of $12 00 per bundle
PAGE 26
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DSS Commercial and High-Density Residential Recycling Enforcement Audit
APPENDIX D: RECYCLING HAULER/CENTER REPORT
The following is 1 of the 13 reports submitted to DSS with identifying information redacted.
RECYCLING HAULER/CENTER REPORT DEPARTMENT OF STREETS AND SANITATION
AS REQUIRED UNDER THE PROVISIONS OF THE CHICAGO RESIDENTIAL AND COMMERCIAL RECYCLING ORDINANCE (MCC 11-5-210 and 11-5-220): Privnte haulers shall maintain complete and accurate records containing the following information: (1) the total tonnage of recyclable material collected by the private hauler from the totality of the private hauler's refuse collection customers within the city during each calendar year; (2) the name and address of each facility to which the private hauler delivered any percentage of such collected recyclable material during each calendar year, (3) the percentage of recyclable material delivered each calendar year by the private hauler to each facility identified pursuant to item (2) above; and (4) any other information that the Commissioner may require in duly promulgated rules. The records required under MCC 11-5-210 and 11-5-220 shall be kept on file by the private hauler for a period of three years.
Any recycling hauler operating within the boundaries of tbe City of Chicago shall submit an annual Recycling Hauler Report to the Department of Streets and Sanitation. This report must be completed and submitted Id Its entirety. If further space is required, please include, as needed, additional sheets as attachments to this Form.
Hauler/Center Name: J
Hauler/Center Address: JBaa^LssssssBaa^HLisssssssssssssssssssssistssss
Name of Contact Pcnon(s) Responsible for responding to Departmental Inquiries ("Responsible Contact Person"):.
Responsible Contact Person(s) Telephone Number: Responsible Contact Person(s) E-mail Address: Percentage of Private Hauler's Customers that arc:
^•C Residential (jtf) Commercial "SQlndustrial | Institutional H Establishments Reporting Period: January 1 - December 31 (Due Feb 28) ~9~0\ 5 Year
Materials Collected bv Category
Recyclables (Not including materials listed below)
Yard Waste
Food Scraps
Electronics
White Goods
Construction and Demolition Debris
Other
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DSS Commercial and High-Density Residential Recycling Enforcement Audit December 2, 2020
Percentage of Recyclable Materials Collected per Facility
|lSaJegqiy}2;: Category,;*
Approximate Percentage of Construction and Demolition Debris Collected and the Receiving Facility
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Approximate Percentage of Waste delivered to Each Facility
FOBercentage'?!
i.
2.
3.
4.
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6.
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OIG File #19-0942
DSS Commercial and High-Density Residential Recycling Enforcement Audit
Certification
As an authorized representative ("Representative") of the company named below, I hereby certify that I have personally examined and am familiar with the information submitted in this Report; and that, based on my inquiry of those individuals immediately responsible for obtaining that information, I believe, to the best of my knowledge, that all of the information submitted herein is true, accurate and complete.
Representative's Name;
Representative's Title:
Company Name:_
Representative's Mailing Address: Representative's Phone Number: Representative's Fax Number: _
Representative's E-mail Address Representative's Signature Submit this Form by mail OR electronically by e-mail to:
City of Chicago Department of Streets and Sanitation 121 N. LaSalle/ Room 1107 Chicago, IL 60602
Or
Email: DSSRecyclinK(5jcityofchica go.org
For further questions and information, please contact: Recycling Office
Department of Streets and Sanitation
Recycling Office: 312.744.2413
Email: DSSRecycling(5),citvofchicaEo.org
MISSION
The City of Chicago Office of Inspector General (OIG) is an independent, nonpartisan oversight agency whose mission is to promote economy, efficiency, effectiveness, and integrity in the administration of programs and operations of City government. OIG achieves this mission through,
• administrative and criminal investigations by its Investigations Section;
performance audits of City programs and operations by its Audit and Program Review Section;
inspections, evaluations and reviews of City police and police accountability programs, operations, and policies by its Public Safety Section; and
compliance audit and monitoring of City hiring and human resources activities and issues of equity, inclusion and diversity by its Diversity, Equity, Inclusion, and Compliance Section.
From these activities, OIG issues reports of findings and disciplinary and other recommendations,
to assure that City officials, employees, and vendors are held accountable for violations of laws and policies;
to improve the efficiency and cost-effectiveness of government operations; and
to prevent, detect, identify, expose, and eliminate waste, inefficiency, misconduct, fraud, corruption, and abuse of public authority and resources.
AUTHORITY
OIG's authority to produce reports of its findings and recommendations is established in the City of Chicago Municipal Code §§ 2-56-030(d), -035(c), -110. -230, and 240.
Cover image courtesy of OIG
- , . AUDIT TEAM , . ,,
...'.''.'.".„. JUSTIN GUTIERREZ, PERFORMANCE ANALYST'. .'"
•'--'•'''-,• •• •' ¦ SAM DIAZ^PERFORMANCE ANALYST- '": /'^ - ' .
; 'ABIGAIL SULLIVAN, SENIOR PERFORMANCE ANALYST;. ."• ,
." '' ' DARWYN JONESfCHIEF PERFORMANCE ANALYST'' ¦' .'-''"-
USE VALENTINE, DEpUTYJNSPECTOR GENERAL •• •.
. ;¦ . PUBLIC INQUIRIES: "'" - . . ". ' . " " "";" :
'.-J-'/-.': ¦ '¦ . NATALIE'A. KURIATA: 1773) 478-8417'! NKURIATA(cDIGCHICAGO.ORG-' , . v
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r.v^-' ';:,,^'.*V> '" •t->GALLOIG'ST.OLL-FREE-TIP'LINE:'(866) 448-4754ATTY: (773) 478-2066*<.Hv'-\:;y-v ,¦ y
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