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DRAFT – June 15, 2021 | Page 23 THE CITY OF PLEASANTON SB 1383 ACTION PLAN 2021 ─ 2025 3.2 Monitoring and Enforcement (with the exception of generator violations of container contamination provisions, for which a penalty is optional) (§18995.4; §18997.2). • Conduct a sufficient number of route reviews, inspections, and compliance reviews to determine compliance, and generate an electronic or written record for each inspection or review (§18995.1). • Provide a procedure for the receipt and investigation of complaints, including the method for notifying the complainant of the result of the complaint; investigate complaints received; and, maintain a record of all complaints and responses (§18995.3). • Pay penalties assessed by CalRecycle for the jurisdiction’s failure to comply, if any, which includes many possible violations, ranging from minor, moderate, or major, and with associated penalties ranging from $500 per violation to $10,000 per violation per day (§18997.3). 3.2.3 Ordinance and Policy Needs The City will need to amend certain sections of the Municipal Code to integrate the enforcement processes and penalties specified by SB 1383 for non-compliant generators, food recovery organizations, haulers, and other entities. 3.2.4 Contract Implications Delegating portions of the monitoring and enforcement programs will minimize the impacts on the City’s budget and staffing requirements. While delegation to PGS is not recommended at this time, the City will need to ensure that the amended Franchise Agreement provides for communication between PGS and the City’s inspection process, particularly as it relates to logistics such as routing and scheduling for container inspections and providing information the City will need to manage these monitoring and enforcement processes. If the City opts to use a third-party contractor or consultant to perform monitoring and enforcement activities, it will need to enter into a contract for these services. In addition to the inspection requirements, 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. For contracts related to edible food recovery inspections, StopWaste will be entering into an MOU with the County Environmental Health Department to confirm and outline requirements for the edible food recovery inspections. 3.2.5 Infrastructure Needs To comply with SB 1383, the City will need to develop an information system for documenting and reporting monitoring and enforcement efforts. The City can create an internal system and/or use a software platform to support with record keeping and reporting related to monitoring and enforcement. The City currently uses Green Halo for some solid waste program reporting, and PGS uses a system called Tower. Neither Green Halo nor Tower are equipped for a full SB 1383 program. The City is discussing options with StopWaste, including evaluating the regional use of web-based software platforms such as Recyclist. It is recommended that the City use the software system selected by StopWaste, if in alignment with the City’s specific needs... The City will have multiple entities involved in enforcement (e.g., City staff, StopWaste, County, PGS, and/or third-party contractors), and a software system that supports the integration of records from multiple