Add-on Request to Existing Recycled Content Program in RSP

Description

REVISED - 12-2024:

NJ’s Recycled Content Law (N.J.S.A. 13:1E-99.135-157) required DEP to create an electronic registration process, which has been established and is currently operational with hundreds of manufacturers registered in 2023. However, the law also requires manufacturers to submit annual compliance reports beginning July 2025. In preparation for this deadline, the Division of Sustainable Waste Management wishes to establish a unified system within DEPOnline that will allow for the submission of these annual compliance reports with a manufacturer’s annual registration, which will be tied to each manufacturer’s unique PI number assigned in NJEMS. This project would be considered an extension of the registration process, developing a new build to be added onto the existing registration build.

In addition, the law requires DEP to create an online submission process for waiver applications. Program staff expect numerous waiver applications to be submitted. To date, about 50 waivers requests have been received in 2024. Similar to compliance certification, DSWM is seeking to build out from the existing recycled content manufacturer registration process in RSP to develop an official process to handle waiver requests. Handling waiver requests through RSP will allow program staff to store waiver, registration, and compliance details together in NJEMS and to collect the required waiver fee and provides the regulated community with a one-stop shop for registering, requesting waivers, and reporting compliance data. As is, we are handling waiver requests via email, which is time consuming, disorganized, and leaves room for human error. Furthermore, we have no means for collecting the $1,000 waiver fee required by law for such requests, making billing difficult to track and deploy. RSP allows staff to streamline the process, ensuring all manufacturer info is kept together in NJEMS and that fee payment is received.

Finally, given this project is an enhancement to an existing RSP, staff would also like to incorporate a revision process to give users the ability to submit revised registrations that could be migrated into NJEMS as the preferred data set. As is, when staff discover issues in a registration, updates must be manually uploaded to NJEMS. This reduces what staff can do with the updated data because it is not captured in the built-in fields within RSP which are migrated into NJEMS. Staff would like to incorporate a revision process to facilitate registration revisions submitted by manufacturers in RSP.

Problem Statement

This is an added build out from the existing recycled content manufacturer registration process in RSP. The Division of Sustainable Waste Management is seeking to develop an official process to handle waiver requests as required pursuant to New Jersey’s Recycled Content Law (N.J.S.A. 13:1E-99.135-157). Handling waiver requests through RSP allows program staff to store waivers and registration details together, collect the required waiver fee, and provides the regulated community with a one stop shop for registering, requesting waivers, and reporting compliance data. As is, we are handling waiver requests via email which is time consuming, disorganized, and leaves room for error. Furthermore, we have no means for collecting the $1,000 waiver fee required for such requests. RSP allows staff to streamline the process ensuring all manufacturer info is together and that fee payment is received.

Project Justification

The alternative for collecting, reviewing, and processing waiver requests is to accept and process requests via email. This approach is less preferred because it does not interact with registrations received in RSP which are stored in NJEMS. Staff have no means to update registrations with waiver determinations. Additionally, staff do not have the ability to invoice and collect the $1,000 waiver fee associated with waiver requests. This build would enable those possibilities allowing for a streamlined process that interacts with the existing registration service.

Estimated Transactions

We expect hundreds of manufacturers to register with us and a good percentage of that to request a waiver. That could mean hundreds of waiver requests submitted via email on top of what is already received.

Components

FSS (generic Facility Submittal Service)/DEP OnlineNJEMSRSP (customized service)/DEP Online

Target Rollout Date

1 January 2024

Target Rollout Date Reason

Proposed start date is as soon as possible, with priority prior to end of September 2023. Staff developed a temporary waiver process to begin accepting waiver requests. The longer it takes to start this project, the more waiver requests we may receive through the temporary process creating additional work for program staff to migrate waiver requests into the new service and bill for those requests. Additionally, the waiver process has been the most highly requested process from the regulated community, noting urgency as the recycled content standards take effect in January.

Attachments

Linked work items

Activity

Knute Jensen 18 December 2025, 19:15

We had JADs August 19 - 21 and received comments from the program based on the JADs which were then sent to CGI.  We received the Draft Design Document from CGI on September 15 of which the program provided comments.  The Final Design Document was delivered on October 17.  I believe CGI is working on a deployment package.  That’s the last I have.

  • Mike Kingkiner

james bridgewater 28 July 2025, 17:47

Work Plan 203 for JAD and Design being signed

james bridgewater 28 July 2025, 13:09

Draft CGI Work Plan 203 for JAD/Design of Recycled Content Waiver Request RSP Service being reviewed by DSWM and DOIT

Knute Jensen 20 May 2025, 19:00

5/8 Gerchman provided response to DOIT. Awaiting DOIT next steps.

james bridgewater 29 April 2025, 18:45

See attached email for DOIT initial notes on this IPTD, including the belief that this is actually multiple distinct projects needing their own IPTD Project Sheets. DOIT will be addressing these comments with AEMS in an upcoming meeting. 

Karen.Anselmo 25 March 2025, 14:45

DOIT initially needed to set up a meeting to get more info from the program. At the time, this IPTD was a lower priority item for AEMS. It just recently upgraded to AP-1 priority. 

With the focus on completing NJEMS Modernization and other priority projects from other program areas, DOIT has not had a chance to further discuss with Air. As noted in Jim B.'s comment, this will likely involve 2 or more separate and distinct RSP services, plus multiple changes to NJEMS (e.g., Assessments). Based on the outcome of further discussions, one or more of the services/requirements may be able to be handled with an internally configured FSS but additional info is needed to determine that.

DOIT also did not move on this for the more intricate service because it appeared that new NJEMS detail windows, etc. would need to be built and we didn’t want to pay to have the functionality built in both Legacy NJEMS and Pega NJEMS, with Pega NJEMS prod rollout so imminent.

DOIT will be better positioned to look at this in more detail with AEMS in a couple of weeks, after modernization is rolled out in late March to “Soft Rollout” status.

james bridgewater 20 March 2025, 18:44

This looks like it will involve at least 2 separate and distinct RSP services, as well as multiple changes to NJEMS and Assessments. May need to bifurcate this into 2 separate projects based on ultimate determination of scope

Nicole.Pellegrini 22 February 2024, 18:02

Need to set up a meeting - Seth and Nell.

We need to have the companies search for their PI/Site ID and upload the waiver application into the RSP.  We would then need to enable an invoicing process for the $1,000 fee.

 Yes, right now, we are able to bill the manufacturers by filling out a Fee Evaluation Form and submitting it to Lisa Offredo. Once the form is processed by Lisa, the bill will get generated by treasury and mailed out.  However, this is a temporary solution until the add-in is developed.

Per Jim B . -

  1. See if this is something Mike Kingkiner could build in-house;

  2. See if a Facility Submittal Service could be built for this, once the payment module is completely rolled out for the FSS module (could be problematic since Nita Mishra is out for several months)