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<br /> <br /> <br /> <br /> <br /> <br /> Conclusion <br /> Fundamental to any meaningful assessment of the County's recycling and diversion efforts is the basic <br /> ability to accurately measure waste flows by type and track costs related to their specific modes of <br /> diversion. DEM managers indicate that they feel implementing adequate controls would make the <br /> programs too costly, therefore they have been willing to accept the risks of fraud and/or abuse related to <br /> inadequate controls in order to gain the benefits of diverting solid waste commodities from our landfills. <br /> While the Auditor agrees that there are significant environmental, social, and operational benefits to <br /> diverting these commodities from the County's waste stream, County government is not relieved of its <br /> responsibility to provide public programs and services in a fiscally prudent and accountable manner. <br /> The Auditor recommends that the County perform cost-benefit analyses to assess whether it would be <br /> more cost-effective to conduct hauling from transfer stations and possibly subsequent diversion or <br /> recycling activities with County personnel, thereby reducing verification and control requirements <br /> associated with private contractors. Should the County decide to continue outsourcing components of its <br /> recycling and diversion programs, it should implement proper controls to reduce the risk of abuse and/or <br /> fraud or the perception of impropriety by requiring proper disclosure of contractor relationships and <br /> independent third-party verification of contractor tonnage claims. The County should also pursue alternate <br /> State and Federal funding and directly administer its recycling and diversion programs whenever possible <br /> to minimize excessive loss of funds to multiple layers of contractors and subcontractors for administrative <br /> rather than program activities. <br /> The Mayor and his cabinet can assist DEM and other County departments by providing information <br /> management systems that can efficiently gather data and report outcomes, so they may better exercise <br /> managerial and fiscal controls and improve their delivery of services to the public. The Finance <br /> Department and Corporation Counsel can assist by developing and implementing standardized policies <br /> and procedures to ensure that all contracts clearly delineate contractor performance expectations as well <br /> as remedies for failure to deliver goods and services, and by providing training on contract formulation <br /> and documentation of contractor performance. The Council can assist DEM by participating in the Update <br /> to the County's Integrated Solid Waste Management Plan and committing to its adoption and funding of <br /> its implementation, and by requiring regular detailed reports on program status and operational activities <br /> to provide greater accountability and transparency to the public. <br /> Most importantly, the "Tone at the Top" set by the Administration and the Council needs to communicate <br /> that the County's commitment to source reduction, recycling, and diversion of its waste stream is <br /> balanced with the County's commitment to monitor and deliver cost effectiveness and expense <br /> reconciliation. Only through the implementation of internal controls, performance measures, reliable data <br /> systems, and regular public reporting by newly elected officials and new managers at the Department of <br /> Environmental Management can their governmental responsibilities for public accountability and <br /> transparency be achieved. <br /> Colleen Schrandt <br /> Legislative Auditor <br /> March 2009 <br /> 1 <br /> I~ <br />