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Recycling Performance Grants Questions and Answers

Act 101 Section 904 Recycling Program Performance Grant
Questions and Answers
Pennsylvania Department of Environmental Protection
Bureau of Waste Management
Division of Waste Minimization and Planning
Oct. 20, 2000, Updated January 30, 2023

DEP conducted a series of workshops aimed at improving community recycling programs and reporting of recycling achievements through the Act 101 Section 904 recycling performance grant program. The following is a compilation of questions and answers provided at the workshops. In some cases, questions have been restated or combined, and answers have been elaborated upon for clarity. Persons seeking additional clarification may contact Mark Vottero at 717-787-7382, or

  1. If a municipality has commercial recycling but does not have a residential recycling program, can it still apply for a recycling performance grant?
    Yes. The municipality’s grant will be based on $10.00 per ton for each approved ton of commercial recycling reported.
  2. How can a grant applicant get recycling information from a commercial establishment handling recycling on its own?
    Most commercial establishments in Pennsylvania do not rely on their municipalities to provide recycling services. Nonetheless, materials recycled by these establishments can be included in a municipality’s recycling performance grant application because their achievements represent part of the total recycling in the municipality. You should get to know these businesses and the hauling companies that provide recycling services, and encourage them to support your grant application with their records as a community service. Some municipalities obtain this recycling information through licensing requirements for haulers, or recycling ordinance requirements for commercial, institutional and municipal establishments. The Department of Environmental Protection’s Municipal Waste Regulations, Section 272.351 permits recycling performance grant funds to be passed back to those responsible for recycling in a municipality.
  3. How can we use the sample Annual Commercial Recycling Report form provided on the department's web site?
    1. Provide the form to haulers performing recycling collection services in your municipality and have them submit the completed form to you in support of your grant application.
    2. Provide the form to businesses recycling in your community. They can record the amount of materials recycled each year and have their hauler or market sign the form to verify it. If a company provides a recycling report and is also included in a hauler’s recycling report, use only one of the reports when you calculate commercial tonnage for your grant application. Note: The Annual Commercial Recycling Report forms do not need to be submitted with the grant application, but must be retained to support the grant application during grant reviews or audits.
  4. Must we use the sample Annual Commercial Recycling Report form provided on the department's web site?
    No. Some haulers, markets, and applicants prefer to use their own forms.
  5. How important is it to get recycling information from every hauler providing recycling services in the municipality?
    Concentrate first on those haulers who will cooperate with you to support your grant application. Their cooperation may inspire others to assist you. More haulers providing recycling data in support of your grant application will increase your grant award.
  6. Do municipalities have the authority to require the licensing of waste haulers operating in their communities?
    According to Act 90 of 2002, existing county or municipal transportation or licensing programs in place prior to Aug. 29, 2002, may be continued at the county or municipality's discretion. Counties or municipalities are prohibited from implementing new transporter authorizations or licensing programs after Aug. 29, 2002.
  7. How do I determine which businesses to seek recycling information from?
    If you are just getting started, seek out the largest businesses, especially those that may be involved in the recycling of corrugated cardboard. Visit them, explain the provisions of your recycling ordinance if you have one. Explain how their participation in recycling and providing recycling data benefits the municipality and enhances their community image. You can provide the sample Annual Commercial Recycling Report form included in the grant application packet and explain how their hauler or market can help verify the amount of material recycled or marketed each year.
  8. Are there incentives for businesses to report their recycling figures to municipalities?
    Businesses should recognize that supporting a municipality’s recycling grant application should enhance their image in the community and contribute to the ability of the municipality to obtain recycling grant funds. In addition, Act 101 allows for the pass-through of recycling performance grant funds to organizations, businesses, institutions and haulers responsible for the recycling of materials claimed in the grant application as an incentive to recycle and report their achievements.
  9. Do weigh slips need to be signed?
    Yes, unless they are printed with the name of the recycling facility or market weighing the materials received or shipped. Monthly, quarterly or annual reports summarizing weigh slips must be signed by a representative of the company providing the summaries.
  10. Can partial tons be reported in the grant application?
    Yes, material weights should be stated to the nearest tenth of a ton, such as 14.3 tons of newsprint.
  11. Can a municipality that operates a recycling center sign the bills of lading to support its grant application?
    No. DEP will require a third party verification that is independent from the municipal applicant, such as a report, letter or receipt from the market receiving the materials processed by the facility.
  12. What is residue?
    Materials that are collected as recyclable but for whatever reason cannot be recycled and are subsequently disposed are considered to be residue. DEP will automatically deduct twenty percent of the total of the residential and commercial recyclables claimed in a performance grant application unless the applicant provides documentation that the amount of residue is less than twenty percent.
  13. A truck collects materials from commercial and residential sources, or from more than one municipality in a single trip. How can I break out the individual sources of recyclables?
    This is one of several cases where it is permissible to estimate recycling quantities. Use the known total weight of the truckload, and make a reasonable estimate of the quantities attributable to each source of the recyclable materials. The sum of the totals estimated cannot exceed the total known weight of the truckload.
  14. Can the amount of materials received from commercial and residential sources at a recycling drop-off facility be estimated?
    Yes, as long as a total combined weight of the materials is reported. You can estimate the split between the sources of the materials based on any reasonable means.
  15. Must shipments of shredded newspaper marketed to farmers as animal bedding be weighed?
    Yes, but rather than weigh all bales, a representative sample can be weighed. The average weight of the sampled bales can be multiplied by the total number of bales that are shipped.
  16. We have materials collected from a mixed use building, where the first two floors are commercial and the other floors are residential. How do we document the amount of commercial recyclables and the amount for residential?
    Make a reasonable estimate of the breakout of each type based on the known total combined weight of the recyclables collected and recycled or marketed.
  17. Can quantities of green and amber glass be listed as commingled materials on the grant form?
    Yes, if the materials were collected and weighed together. You can enter the total weight on the "commingled" line or on one of the glass reporting lines, and note that the total weight represents commingled glass. If the materials are collected and weighed separately, they should be listed separately.
  18. Why is used automotive oil not eligible to be claimed under recycling performance grants?
    Only "source separated recyclable materials" as defined by Act 101, Section 1501(C)(1)(i) are eligible for recycling performance grants. These include: clear glass; colored glass; aluminum, steel and bimetallic cans; high-grade office paper; newsprint; corrugated paper; and plastics. Further, the Department of Environmental Protection’s Municipal Waste Regulations, Section 272.352 specifically exclude leaf and yard waste from the grants. It is important for municipalities, however, to include used automotive oil, leaf waste and all other materials recycled within the municipality when completing the annual recycling report provided to counties each year. All materials diverted from municipal solid waste and recycled are factored into the municipality’s, county’s and state’s recycling rate.
  19. How do I list mixed quantities of newspaper, magazines, office paper or other mixed paper?
    The total combined weight can be reported under either "other marketable grades of paper," or "commingled materials." If reported as commingled, you should note which materials are included in the total.
  20. Can you explain the different types of plastics listed in the recycling performance grant application?
    PET plastic resin is the type used to produce soda bottles that may be marked or coded with the number 1. HDPE resins are typically used to produce milk and laundry product bottles, and may be marked or coded as number 2 plastics. For grant purposes, all other types of plastics diverted from municipal waste, including those marked or coded with the numbers 3 through 7 can be claimed under "other plastics."
  21. What is "tin?"
    "Tin can" is a common name for steel cans used for food and beverages that have a tin coating. The coating reduces corrosion from oxidation. Recycling totals for these materials and other steel containers, including empty aerosol and paint cans, should be reported as "Steel/Bi-metallic cans."
  22. Can you provide an example of a pre-consumer recycled material that is not eligible for the recycling performance grant?
    Scrap materials that are part of a manufacturing process are considered to be pre-consumer recycled materials. An example would be the trimmings or the ends from rolls of newsprint used in making newspaper. These scraps are residual waste materials, commonly and historically returned to be recycled in the paper-making process. Act 101 promotes the recycling of materials diverted from municipal waste, such as newspapers that are circulated to the public. Even if unsold, these are considered to be post-consumer recycled materials.
  23. Are old books recyclable?
    Yes, but not all areas of the state have markets readily available for books, magazines, "junk mail" and mixed grades of paper. You should check with the recycling centers serving your location. Books that are recycled may be claimed in the recycling performance grant application as "other marketable grades of paper."
  24. We collect litter from the roadsides, some of which we weigh and recycle. Can these materials be claimed in the grant application?
    Yes, if you can produce a weight slip from the hauler, recycling processor or market that accepts the materials for recycling.
  25. If a county submits a grant application on behalf of its municipalities, should it reduce its county population claimed by the population of any municipality submitting its own application?
    Yes, as long as the county knows that residents from other communities are not contributing materials toward the county recycling effort covered by the grant application. Otherwise, the entire county population should be listed in the grant application. It is also essential that the same recycled materials are not claimed in more than one grant application.
  26. Can a municipality apply on behalf of other municipalities?
    Yes, a lead municipality may apply on behalf of itself and others. But when the larger population of the group is factored into the grant formula, it could lower the award that a municipality could have received had it filed its own application.
  27. Can municipal authorities apply for recycling performance grants?
    Yes. Act 101 (as amended) defines eligible Performance Grant applicants as boroughs, cities, counties, towns, townships, home rule municipalities, councils of governments, consortiums, or similar entities established by two or more municipalities under 53 PA. C.S. Ch. 23 Subch. A (relating to intergovernmental cooperation).
  28. What would make a grant application ineligible for funding?
    Claims for materials not eligible for the grant, materials generated outside the municipal boundaries of the applicant, materials that are not supported by acceptable forms of documentation, materials marketed or recycled during a year not covered by the application, or an application submitted outside of the grant application period advertised in the Pennsylvania Bulletin.
  29. Does DEP notify grant applicants when a grant review will be conducted?
    Yes. While all recycling performance grants are reviewed, DEP conducts a more detailed desk or field review on a selected sample of applications each year. In these cases, DEP typically provides a minimum of 30 days notice.
  30. How does DEP select its sample of recycling performance grant applications for the detailed desk or field reviews?
    DEP selects a sample based on the total number of grant applications received, experience with applications from prior years, and in cases where materials claimed in grant applications exhibit marked increases or decreases, or appear to be ineligible for the grant.
  31. Does DEP perform grant reviews after a municipality receives its grant?
    In most cases, no. There are instances during the review of a current year application that supporting documentation from a prior year application is examined. It is also important to note the DEP Comptroller’s Office, the Office of the Treasurer and the Office of the Attorney General, or their agents, may perform an audit of a grant award any time up to fours years from the year the application was filed.
  32. Can a municipal solid waste (MSW) generation rate other than 0.80 tons/person/year be used for a recycling performance grant application?
    No, DEP uses this standard MSW generation rate to calculate the recycling diversion rate of the applicant. The population covered by the grant application is multiplied by 0.80 to determine the recycling diversion rate, which is a factor in determining the grant award. This is an average MSW rate for Pennsylvania that is also consistent with the Federal EPA MSW generation rate for the United States. It represents waste generation and not disposal only.
  33. How do you know if your municipality is mandated by Act 101 to require commercial recycling?
    All Pennsylvania municipalities with populations over 10,000 are required by Act 101 to have recycling ordinances that provide for residential, commercial, institutional and municipal recycling within its municipality. This same requirement applies to municipalities over 5,000 persons with 300 persons or more per square mile.
  34. A local waste hauler was observed mixing source separated recyclables with municipal waste in a packer truck. Would this impact the grant application?
    Yes. It is not likely that recyclables collected and mixed with garbage would be separated before transfer or disposal. Only materials that are recycled or marketed can be credited to the recycling performance grant application. Report questionable recycling collection practices to your municipality and your DEP Regional Office.
  35. Is the recycling performance grant application available on-line?
    The 904 Performance Grant application must be submitted through the Department of Community and Economic Development’s (DCED) Electronic Single Application website. Paper and faxed copies will not be accepted.