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DRAFT June 15, 2021 | Page 7 2. Key Activities The City will need to amend certain sections of the Municipal Code to integrate the enforcement processes and penalties specified in SB 1383 for non-compliant generators, food recovery organizations, haulers, and other entities. The City will also need to develop protocols and policies for compliance reviews, route reviews, receipt and investigation of complaints, and documentation of its monitoring and enforcement efforts. If the City opts to use a third-party contractor or consultant to perform the monitoring and enforcement activities, it will need to enter into a contract for these services. In addition to the inspection procedures, the contract will need to include adequate record-keeping and reporting provisions associated with the contamination reviews to support the City in meeting SB 1383 reporting requirements and tracking program progress. Because StopWaste proposes to take leadership of the edible food recovery program, including inspections, StopWaste will be entering into a memorandum of understanding (MOU) with the County Environmental Health Department to confirm and outline requirements for the edible food recovery inspections. To comply with SB 1383, the City will need to use an information system for documenting and reporting monitoring and enforcement efforts. The City will be required to educate non-compliant entities no later than January 1, 2022, and at least until December 31, 2023. After this timeframe, SB 1383 will require the City to initiate a notice of violation (NOV) process and issue penalties. 3. Collaborators • StopWaste: Assist in desktop compliance review for commercial and multi- family generators. • County Environmental Health Department: Conduct inspections of commercial edible food generators and food recovery organizations and services. • City Staff and Consultants/Contractors: Assist in developing monitoring/enforcement procedures and conduct contamination monitoring route reviews. 4. Costs The City will have one-time costs for staff and consultants of approximately $30,000 to $53,000. On-going costs, prior to January 2024, will range from $81,000 to $248,000. Additional one-time costs of $8,000 to $16,000 and on-going costs of $194,000 to $459,000 will be required for enforcement activities commencing January 1, 2024.