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88 Page 48 Transfer Truck Pavload The Evaluation Committee recognizes that Community Recycling (an SBR partner) has substantial experience in the handling and transportation waste materials, but the Evaluation Committee has had concerns regarding SBR's aggressive material transportation payload projections. The Evaluation Committee has discussed these concerns with the company and to support their position, SBR has offered a detailed volume-to-weight conversion calculation for the different material types at the SRDC and SBR has stated that their large-volume, specially fabricated, lightweight tractor/trailer combination, will accomplish their projected payloads. Upon review of the company's rationale, the Evaluation Committee can accept the plausibility of SBR's payloads except for the C&D/self-haul materials. Without the implementation of size- reduction technology and/or mechanical compaction, the Evaluation Committee believes it is unlikely that SBR will achieve their projected payloads for the C&D/self-haulloads. Note the Evaluation Committee believes that SBR will require an additional 120 loads per year to transport these bulky materials (at SaR's proposed haul rate, the company could have transportation cost overruns of about $34,000 per year). SBR's original proposal assumed the use of spread-axle trailers to attain the higher payloads. As currently configured, the transfer station tunnel scales cannot accommodate spread-axle trailers. SaR was instructed to submit revised cost forms to reflect the restriction. Note: after an economic benefit analysis, SBWMA may opt to install tunnel-scales to accommodate spread- axle trailers. Community Recycling - Permits & Compliance Issues Community Recycling Inc. has received numerous regulatory citations regarding the operation of its Sun Valley operation. The Evaluation Committee further investigated the permit and regulatory violations received by the company. Community Recycling (the managing partner of South Bay Recycling, LLC) is one of the early recycling pioneers in the State of California and has been recycling in Los Angeles area since the mid-1970's. As such, the company's C&D and green waste processing operations were in full operation for almost two decades before laws were adopted by the California Integrated Waste Management Board (CIWMB) to regulate these activities. As regulation for the company's recycling activities were implemented, Community Recycling applied for the required permits (applied in 2002, the same year that the law requiring the new permits went into effect), however the company received numerous violations and a Cease and Desist Order from the Local Enforcement Agency during the time that has taken for this permit to be issued by the CIWMB. More detailed information regarding these actions follows: Permits: Community's transfer station is covered by a permit issued by the City of Los Angeles, Department of Environmental Affairs, Local Enforcement Agency (LEA) Permit # 19~AR-0303. This permit is for the for the operation of the company's MSW transfer station and MRF that operates 24-hours per day and receives 1,700 tons per day of incoming refuse. The company has a separate permit for organics and C&D processing at the site. These materials processing operations are covered under an Interim Operating Agreement (lOA) that was issued by the City of Los Angeles LEA, under authority from the Independent Hearing Panel. This lOA is an agreement to allow the processing of these materials to continue during the interim time period that the company completes a CEQA process and receives a final permit that incorporates all operations into one master permit for the facility. SBWMA - EC Report Page 24 1/15/2009