The stakes · 3 minutes
The records support counting 18.5%–24.1% of LA’s commercial waste as diverted.
Why does that matter? Because diversion is already required: state law and the RecycLA franchise both assume this material can be kept out of landfills. The target is not arbitrary: the city’s own inventory says landfilled-waste emissions come mostly from paper, cardboard, and organics — the materials the blue and green bins are supposed to capture. And when those tons are not diverted, they do not disappear. They go to landfills with neighbors, complaints, violations, and enforcement records.
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Required · already law, already contract
This is not a new policy demand. SB 1383: state law mandates organics diversion, enacted on methane and health grounds; LASAN “implemented the Organics Recycling Program in January 2023” on the residential side in response. The franchise contract defines Zero Waste as “90% or higher Diversion of SOLID RESOURCES from CLASS III LANDFILLS”. The franchise promises a 90% standard; this audit found only 18.5–24.1% supportable from the records reviewed. And the 90% has no official scoreboard: the City’s last published citywide diversion rate is 76.4% — computed in 2011, under an everything-not-landfilled accounting the state retired in 2007 — and no successor figure has been published since.
And failure already has a price. First measurement period: a required disposal reduction of 606,000 tons; haulers achieved 403,000; the city issued $12.2M in liquidated damages to five service providers (all appealed) — and the city’s own report concedes the 1-million-ton goal “most likely will not” be achieved.
And the state has noticed: CalRecycle has placed the City of Los Angeles on a formal SB 1383 corrective-action pathway — described as “in noncompliance,” subject to potential fines, none levied so far. That is a city-wide finding under state law, not a finding about any hauler. The obligation already exists. What follows is why it exists — and where the waste goes when it isn’t met.
Targeted · the city’s own table
Paper and organics are the two materials every blue and green bin exists to capture, and the city’s own inventory — not our analysis — says they cause 90% of its landfilled-waste emissions.
“Paper and cardboard constitute 23% of the City’s waste but are the largest contributor of the City’s landfilled waste emissions at 53%. Organic waste is the largest waste component at 26% and is the second largest emissions contributor at 37%. Together, these two categories account for 90% of the City’s total landfilled waste emissions.”— City of LA 2020 Community GHG Inventory (LASAN, April 2022) · fetched 2026-07-05
One caveat belongs in the open: those shares describe the citywide waste stream, not the audited commercial stream — the city has published no comparable breakdown for the RecycLA stream, so the inventory does not prove the audited tons have the same composition. What it does show is why the city’s own climate logic points at exactly the materials the blue and green bins are designed to capture.
The honest context
In the city’s own accounting, waste is about 6% of community-wide emissions — small next to buildings and cars. But within the waste sector, landfill emissions are concentrated in exactly the materials diversion is supposed to address.
“Solid waste disposal at landfills accounts for over 95% of this sector’s emissions.”— City of LA 2020 Community GHG Inventory (LASAN, April 2022) · fetched 2026-07-05
Scope: the inventory line is citywide — all waste, residential included. The audit covers only the commercial franchise stream within it.
Why organics · methane
Organics diversion matters because landfilled organic waste produces methane, and SB 1383 was built to reduce that near-term climate harm. That is the whole point; the arithmetic is below for readers who want it.
Averaged over 100 years, a ton of landfill (biogenic) methane traps about 27.0× the heat of a ton of CO2; over the 20 years current climate policy actually targets, about 79.7×. LA’s inventory uses an older 100-year value (AR4 GWP = 25) for consistency with the state’s. And the official numbers are likely conservative: EPA guidance assumes gas-collection efficiency of about 75 percent, while national aircraft surveys (2016–2022) found point-source plumes at 52% of surveyed U.S. landfills and emission rates about 1.4× what facilities report. Those surveys are national; none of this measures any specific landfill.
Local · where it lands
So where do the undiverted tons go? Over the three audited years (Jan 2022 – Dec 2024, 4,828,942 tons), the commercial stream’s single largest destination was Chiquita Canyon Landfill in Castaic: 795,780 tons — about 796,000, one in six tons of everything the records track (16.48%).
Close behind: Simi Valley Landfill (777,259 t), Sunshine Canyon Landfill (769,638 t), Frank R. Bowerman (354,554 t). Of the full stream, 892,206 t is counted as diverted; the remaining 3,936,736 t (81.52%) is landfilled or unconfirmed. Within that, 1,114,692 t (23.08%) reaches a transfer or processing endpoint, endpoint unconfirmed; 5,079 t (0.11%) stays unknown.
Chiquita Canyon closed to new waste on January 1, 2025. The regulator record there shows what landfill dependence can mean locally.
The regulator record · Chiquita Canyon
Chiquita Canyon was the audited stream’s largest destination during the years regulators there documented odors, leachate problems, violations, an EPA order, and finally closure. LA’s commercial waste did not cause that crisis, and this audit does not claim it did — the connection is only that this is where the tons went.
“…a subterranean chemical reaction causing elevated temperatures beneath the surface of the landfill is increasing odors in an older closed section of the landfill.”— California Air Resources Board, facility investigation page · fetched 2026-07-05
Regulators locate the reaction in an older, closed section of the landfill — not the active cells where incoming waste went. Nothing in the record ties the city’s commercial waste to the event’s cause. The record simply shows where the tons were going while the reaction continued underground.
Complaint tallies diverge by author: SCAQMD counted over 2,100 complaints (~60 NOVs) by September 2023 and more than 5,700 (~100 NOVs) by November 17; EPA’s own 2023 tally was “almost 6,800 odor complaints.”
| Date | Agency | Fact (as stated by the agency) |
|---|---|---|
| ~May 2022 | EPA | Subsurface Elevated Temperature (SET) event begins; ~30–35 acres, northwestern portion |
| 2022→2023 | EPA | Leachate ~150,000 → 1,000,000+ gal/week |
| Apr 2023 | CARB / SCAQMD | Odor complaints surge; odors traced to the landfill; reaction later located in an older closed section |
| Sep 6–7, 2023 | SCAQMD | Hearing Board stipulated Order for Abatement; >2,100 complaints, ~60 NOVs so far in 2023 |
| Nov 17, 2023 | SCAQMD | >5,700 complaints, ~100 NOVs (Rule 402 / H&SC §41700); leachate-system NOVs |
| 2023 tally | EPA | “almost 6,800 odor complaints in 2023” (EPA’s count) |
| Feb 21, 2024 | EPA | RCRA §7003 order — “imminent and substantial endangerment”; benzene renders leachate RCRA hazardous waste |
| Jan 1, 2025 | Operator | “closed for the acceptance of waste” (chiquitacanyon.com) |
| May 30, 2025 | SCAQMD | Five post-closure NOVs; >29,000 complaints since Jan 2023; ~340 nuisance NOVs to date |
| Jan 26, 2026 | DTSC | Non-compliance determination: Chiquita Canyon LLC and parent Waste Connections |
~796,000 audited tons went to this landfill during 2022–2024 — 89% of the audit window overlaps the event from its ~May-2022 onset; 58% from the April-2023 complaint surge.
Not just one landfill
Chiquita is the extreme case, not the only one. Sunshine Canyon — the audited stream’s third-largest destination, 769,638 tons — drew 653 odor complaints in 2022, 1,721 in 2023, and 2,187 in 2024 — more than triple two years earlier, with 65 public-nuisance NOVs in 2024 alone (SCAQMD complaint & NOV summary; complaints rose again in 2025).
In April 2024 the LA County Board of Supervisors ordered an audit of the site. The claim here is the narrow one: landfill dependence concentrates impacts at facilities with documented community and regulatory problems.
The close
State law and the RecycLA franchise require diversion. The city’s own inventory points to paper, cardboard, and organics as the core landfill-emissions target — 90% of the landfilled-waste emissions. The audit shows that much of the commercial stream still ends up landfilled or unverified. And the undiverted tons go to specific landfills — the two largest destinations both carry active regulator complaint and enforcement records.
So the issue is not whether diversion matters. The city and the state already decided that it does. The issue is whether LA’s records can prove that required diversion is actually happening — and, when it is not, which communities receive the tons instead.
California made organics diversion mandatory, but the dedicated CalRecycle diversion lines — SB 1383 Local Assistance, $240M, and Waste Diversion, $210M — total about $450M of the $32.9 billion appropriated through California Climate Investments: about 1.4%. The mandate is statewide; the dedicated funding is small. The arithmetic: ($240M + $210M) ÷ $32.9B.
For scale, the largest cumulative CCI lines: high-speed rail $7,474M, ZEV incentives $3,693M, transit operations $1,400M. What diversion costs depends on how you count: CalRecycle’s own SB 1383 analysis projects $20.9B in gross costs against $17B in offsetting benefits — a net cost of $3.9B. Across its projected ~58.2M tons of CO2e reduction, that is roughly $67 per ton net, or $359 per ton gross (CalRecycle Appendix A, Table 14).
The findings piece shows what the records say. The methods piece shows what the records would need to collect for the diversion rate to be answerable without an audit.
The companion methods piece shows how these numbers were made — and the minimum reporting standard that would make the diversion rate answerable from records instead of reconstructed by audit.