The overall intent of the pilot is definitely impactful in helping to shift the market to more strict verification processes; however, there could me more alternative compliance pathways embedded into the credit that recognize the already existing entities, like the CALGREEN Building Code / CalRecycle, that already employ a very stringent set of requirements and regulations for applicable facilities. 

Additionally, the credit language is unclear when stating that "Recycling rates applied to a project's waste generation must be the weighted average for the facility over the time in which the project sent materials to the facility." It is not clear how this average is "weighted."