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DRAFT June 15, 2021 | Page 24 THE CITY OF PLEASANTON SB 1383 ACTION PLAN 2021 ─ 2025 3.2 Monitoring and Enforcement parties is necessary. The Action Plan cost analysis includes an estimated cost for the software; however, the actual cost may vary significantly. 3.2.6 Education and Outreach The City will be required to educate non-compliant customers no later than January 1, 2022 and at least until December 31, 2023. After this timeframe, the City will be required to additionally initiate an NOVs process and issue penalties. It is recommended that the City continue to provide education with the NOVs. It is recommended that the City collaborate with PGS and StopWaste on education messaging and distribution. 3.2.7 Budgetary and Staffing Implications The City has three primary options for staffing the contamination monitoring program required by SB 1383; the City may choose to staff the program with City Code Enforcement staff, PGS staff, or another third-party contractor. Based on conversations between the City and PGS, as well as the analysis conducted for this Action Plan, it is recommended that the City engage a third-party contractor to support the monitoring and enforcement process. While there will be direct costs for contractor time, this option is the most feasible based on City staffing constraints. In addition to contamination monitoring, the City will be required to perform a desktop review of all commercial garbage accounts generating two cubic yards of solid waste or more and all multi-family garbage accounts with five or more units. StopWaste has proposed to conduct these desktop compliance reviews on behalf of the City, at no additional cost. It is recommended that the City delegate this responsibility to StopWaste, which will greatly reduce the impacts to City budget and staffing. See Section 4 for the anticipated costs and staffing estimates needed for these activities, based on the recommended delegation options. It is important to note that the range in costs and staffing related to NOVs is limited by assumptions about consumer behavior and their willingness to participate in programs. The City will gain a better sense of NOV and penalties costs and staffing as programs roll out. Additionally, it is anticipated that an effective education and outreach campaign will help reduce overall NOVs and penalty processes. As a result, these cost assumptions are subject to change over time. 3.2.8 Recordkeeping and Reporting The City will need to develop protocols and policies for compliance reviews, route reviews, receipt and investigation of complaints, and documentation of its monitoring and enforcement efforts. The City will need to track a number of metrics related to the monitoring and enforcement program. First, the City will need to track the number of generators complying with collection service, self-hauling registration, and receiving generator waivers. Additionally, the City must report monthly the number of compliance reviews, route reviews, NOVs issued, penalties assessed, repeat NOVs and penalties, follow-up inspections completed, educational material provided to noncompliant customers, and other metrics required by SB 1383. Much of this information may be obtained through reports submitted by collaborating parties such as PGS, StopWaste, and any third-party contractors. Consequently, strong reporting provisions in contracts and process design meetings will be critical to ensure the efficacy of such reports.