Scope of Work

Under the Healthy Food, Healthy Soils (HFHS) scope of work, the HFHS team was tasked with reviewing the zoning and land use rules addressing composting and organic resource management of two San Diego County jurisdictions (one large city and one smaller in size), and providing recommendations for improving them. Local land use rules have not kept pace with myriad California legislation and initiatives designed to divert compostables from the landfill and facilitate more environmentally and economically beneficial processing methods, such as source reduction, food recovery and composting.

Zoning and land use rules fall short countywide, in all 19 jurisdictions, but Imperial Beach was selected partly because it’s one of eight in San Diego County eligible for the SNAP-Ed (Supplemental Nutrition Assistance Program, Education) funding that made this work possible, and partly due to the City’s ongoing revitalization efforts to shape itself as a vibrant, sustainable community whose many values align with those of a healthy and equitable food system including access, security, sustainability and economy. 


The HFHS team reviewed Imperial Beach’s municipal code and general plan, conducted interviews with staff, and compiled city data as well as that relevant to composting, community gardening, and other issues related to management of recoverable food and compostable materials. The city’s existing composting and resource management efforts were also reviewed. All data was analyzed and based on findings, the recommendations that follow in this study were formulated.

City Background

Imperial Beach, the "Most Southwesterly City in the Continental United States," is nestled between U.S. Naval Communication Station within the City of Coronado's jurisdiction and the shore of San Diego Bay to the north, on the east by the City of San Diego and on the south by the U.S./Mexican border. To the west lies the Pacific Ocean. Settlers arrived in the 1880s, with early subdivsions intended as a summer retreat for the residents of Imperial Valley (hence the name). It was during this time that labor workers congregated to construct the world’s largest resort at that time, the Hotel del Coronado. Many of the laborers stayed and remained in Imperial Beach, calling it their home.

Imperial Beach is 4.5 square miles, and almost entirely built out with a few vacant parcels. The projected population of 28,230 residents in 2020, compared to its 2014 population of 27,149, reveals that there really isn’t room to grow. Future development will primarily take place through upgrading and reuse of existing parcels and possible reuse of Ream Field. Nearly 40% of the city is housing, and another 40% is open space or public facilities. Residents of Imperial Beach typically work elsewhere in the County of San Diego. 

Income levels in Imperial Beach are disproportionately lower than others in the region, with 59% of household incomes low, very low, and extremely low. Forty percent of the city's households have incomes lower than $25,000.

Imperial Beach is currently undergoing an urban revival. Leadership is moving to revitalize the city into a vibrant coastal community that residents are proud to call home. The recent opening of its own grocery store, the planned opening of a microbrewery, and improvements along the SR-75/Palm Avenue corridor all stem from this shared vision. While land is limited within the city confines, the city strongly supports recreational, environmental and agricultural initiatives taking place in the adjacent Tijuana River Valley. 

Planning and Municipal Code

The existing General Plan generally discusses conservation, management of solid wastes, landscaping, water quality and watershed protection, yet the approaches outlined are relatively quiescent since this disadvantaged community’s push for redevelopment and environmental justice over the last ten years or so. The Tijuana River Valley, located south of the City, is infamously known for its slew of environmental problems including sewage spills, sediment and litter stemming from challenged infrastructure in Mexico as well as management decisions made on the US side of the border. Cross-border collaborations have been slow to both mitigate sources of pollution and clean up the valley. Consequently, contaminated flood waters enter the Pacific Ocean at Imperial Beach, resulting in unsafe beach conditions for beach goers and surfers. Imperial Beach suffers the most beach closures in all San Diego County. Compounding on its existing problems is the reality of climate change and how not only rising sea levels will impact this seaside community, but also changes in flood patterns in the river valley as weather events become more chaotic.

Sustainability, climate change, environmental and justice and equity, composting and soil health and healthy food access, among others, are all emerging topics of interest and importance as this community strives to find justice and establish means to thrive. The vision, policies, implementation strategies, as well as municipal code amendments, are all needed to support these opportunities. From a healthy food, healthy soils perspective, the language in the existing municipal code limits composting opportunities in and around the community. In essence, all composting other than backyard composting would require a permit, as demonstrated in the excerpts from Chapter 8.36. REFUSE, SOLID WASTE AND RECYCLABLE COLLECTION:

 8.36.030. Definitions.

 “Compostables” means yard waste, as defined herein, separated from single-family residential refuse for the purpose of composting or mulching at home, and landscaping waste from businesses or multifamily residences for the purpose of composting, mulching or preparation as biofuel at a permitted commercial composting or mulching facility. Food wastes from residential kitchens, excluding meat, dairy and oil products, are considered as compostables for home composting purposes only. Industrial, institutional, or retail food wastes are considered compostable in commercial composting operations only as permitted and properly regulated.

 8.36.240. Yard waste composting.

A. Any commercial business, landscape firm or other such entity establishing a compost pile, bin, holding area or other such composting system shall require a permit from the City. Any such operation shall be liable for all State, County and City regulations governing the establishment of such composting operations.

B. Any home composting pile, bin, holding area or system shall also require a permit from the City if the total areaused for composting is fifteen cubic yards or greater within the boundaries of the residence.

C. Any commercial or home composting pile, bin, holding area or system shall be maintained so as not to create a public nuisance through visual, odor, safety and/or other means. (Ord. 2005-1027 § 9, 2005; Ord. 846, 1992) 

Interestingly, the land use code is silent on facilities, uses and the permit process. The code could be amended, simplified and strengthened, but a profound culture shift amongst the residents and businesses of Imperial Beach would be critical to effective change. 

City staff expressed concerns about upcoming statewide mandates for composting. Space is already limited, yet generators will need to accommodate additional collection bins for organics. The streets are already too crowded, and suffer too much wear and tear to support additional collection vehicles. Depending on the collection program ultimately implemented, some businesses may be required to have collection for four streams of materials: source-separated food scraps, landscape trimmings, designated recyclables, and trash. Businesses, particularly those with limited space, are excluded from landscape bin collection requirements if they contract with a landscaper who hauls the landscape materials. What will be their diversion options when food scraps mandates are passed?  What options will be available for residents?

Opportunities for Model Programs

With such limited space and resources, the city would benefit from policies and programs that strengthen the community’s participation in diversion programs while reducing the burden on centralized hauling and infrastructure needs. Programs that offer the “biggest bang for the buck” will need to be carefully considered, and that are also reliable long term. The city would welcome partnerships with community groups willing to lead education and outreach efforts. Efforts could range from education and incentives on enhanced backyard and small onsite composting initiatives, linking life cycles through joint garden and composting programs at schools to empower the youth, development of urban agricultural incentives and community gardens, as well as supporting nearby agricultural and environmental initiatives underway in the Tijuana River Valley.  Even the largest of generators can implement the Food Recovery Hierarchy - prioritizing food for people and agriculture before committing this resource to another bin.  

The city has already started off on a good foot, recognizing decentralized green building infrastructure as a community asset, and such green facilities are permitted in commercial zones. This code can be expanded to catalyze decentralized approaches to composting and healthy soils. Recommended additions to existing text have been inserted below in bold.

19.04.382. Green building utilities.

“Green building utilities,” also referred to as small wind turbines, residential alternative power sources, or small alternative utilities, refers to the provision of sustainable essential services (such as water and electricity and resource management such as composting) in the form of small infrastructure that reuses water or generates electricity that is primarily used on-site and which support the principal development. Examples of green building utilities include small wind turbines, solar panels, onsite composting and barrels for grey water reuse. (Ord. 2012-1130 § 1)

A model zoning ordinance for Imperial Beach will recognize the lack of available space for a large-scale facility within city-limits and support smaller stand alone or accessory uses. Small to medium scale processing sites in connection with agriculture not only promotes community, it can provide meaningful employment currently not available to city residents. Composting as an accessory use will ensure it is allowed wherever agriculture is permitted, as well as onsite at businesses and commercial sites. The model ordinance will require best management practices be performed. Visual character is very important in this seaside community. The City’s model ordinance should include provisions for screening or other mechanisms to ensure composting areas are neat and tidy and fit in with the neighborhood.

In 2016, Imperial Beach sent a total of 16,720 tons of discarded materials to the landfill, of which:

  • 6,700 tons were compostables (based on California waste characterization data)
  • 2,600 tons of these compostables were food
  • An additional 2,450 tons of yard trimmings were collected and sent to the landfill for alternative daily cover (ADC).

Diversion of compostables from the landfill stands to benefit the city’s climate action goals, as it could yield upward of 3,000 MTCO2e* per year in greenhouse gas reduction benefits, which is equivalent to the carbon sequestered by more than 77,000 tree seedlings over ten years. The closer to home these organics are processed and the resulting compost used, the greater the benefits will be.

*Assumes 15% edible food recovery and 90% total organics diversion.

A profound influx of energy and foresight will be required to propel the paradigm shift towards sustainable management of compostable materials. Diversified approaches that empower and engage the community will yield success. This case study demonstrates opportunities to integrate healthy food, healthy soils into the city’s revitalization efforts while further benefiting the overall sustainability strategy. This resulting Healthy Food, Healthy Soils Toolkit was developed at an opportune moment for culture shift and policy development, as coincidentally, Imperial Beach was updating its General Plan at the time of this writing.