HomeMy WebLinkAboutOIG No. 26-12 Royal Dumpsters, LLC. C&D Fee Revenues Audit
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TO: Honorable Mayor and Members of the City Commission FROM: Joseph M. Centorino, Inspector General DATE: July 14, 2026 PROJECT: Royal Dumpsters, LLC. C&D Fee Revenues Audit REPORT No.: OIG No.: 26-12
This report presents the findings of a Construction and Demolition (C&D) audit conducted by the City of Miami Beach Office of the Inspector General (OIG) regarding the compliance of Royal Dumpsters, LLC, with City Code Chapter 90, Solid Waste, provisions governing C&D contractors, during the audit period from August 1, 2022, to July 31, 2025.
BACKGROUND Chapter 90, Article IV, Private Waste Contractors, Subdivision II., of the City Code allows C&D haulers engaged in the business of removing or disposing of construction and demolition debris or large quantities of trash from any premises within the City limits to operate, after obtaining all required permits for such activities.
PERMIT REQUIREMENTS
City Code Section 90-276 requires C&D haulers to obtain a Business Tax Receipt (BTR). Failure to obtain a BTR will result in a penalty of $1,000 to $5,000 for repeat violations. An annual C&D Collection permit is required. Failure to obtain the annual C&D Collection permit will result in a
$5,000 penalty. A site-specific C&D Collection permit is required for each project involving the construction or demolition of an existing structure. Failure to obtain a site-specific permit will result in a $1,000.00 penalty.
ACCOUNT REPORTING REQUIREMENTS
City Code Section 90-278(4) requires that each C&D contractor provide the City Manager with a current list of account names and addresses when submitting an initial application. For permit renewal applications, contractors must also provide the service frequency, the permit number, the capacity of each container or dumpster for each account, and the address serviced by each container or dumpster. This list of accounts is typically furnished concurrently with the monthly report to the Finance Department. It serves as an essential document for verifying the accuracy of the contractor's filings during audits.
MONTHLY REPORTING AND FEE PAYMENT REQUIREMENTS
City Code Section 90-278(5) requires contractors to submit monthly reports to the City’s Finance Department, along with payment of any owed permit fees at the 20% City Commission approved rate. These reports are due by the end of the month following the month in which the gross receipts
were generated. Section 90-221 defines gross receipts as all contractors' fees collected, whether
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wholly or partially, for solid waste collection and disposal services provided within the city, excluding any taxes and gross receipts from servicing roll-off and portable containers. Under City
Code Section 90-225, those who fail to remit the fees timely are subject to a 10% original delinquency penalty of the delinquent fee and an additional 10% per month, up to a maximum of 50%. Additionally, the highest legal interest rate permitted by law will apply to all unpaid fee
amounts (excluding penalties) from the date the fee first became delinquent until paid.
ANNUAL REPORTING FOR GROSS RECEIPTS EXCEEDING $200,000
Per City Code Section 90-278(5), contractors with reported annual gross receipts exceeding $200,000 must submit a statement of annual gross receipts for the preceding fiscal year to the City Finance Department. This statement must be certified by an independent Certified Public Accountant and furnished within sixty days following the close of their fiscal year.
INSURANCE REQUIREMENTS
Finally, City Code Section 90-196 requires each waste contractor to maintain adequate insurance coverage throughout the entire effective period of its Business Tax Receipt.
PURPOSE
This audit assessed whether the contractor's filings were complete and accurate, and whether the corresponding payments were calculated correctly in accordance with the permit fee rate approved by the City Commission. Additionally, the audit aimed to ensure that the City Finance Department received and accurately recorded the filings and payments in a timely manner, and to assess the contractor's compliance with other relevant sections of the City Code.
OBJECTIVES 1. To determine whether the contractor has all the necessary permits to conduct the collection of C&D within the City pursuant to Section 90-276.
2. To determine whether the Contractor maintains the minimum insurance required by the city throughout the entire audit period, pursuant to Section 90-196. 3. To determine whether the contractor has collected and submitted 20% of its monthly gross receipts and has submitted the required monthly and annual reports, if applicable. If not, determine the penalties and interest charges following Section 90-278(7).
METHODOLOGY
1. Reviewed Energov records to confirm that the contractor obtained the required Business
Tax Receipt (BTR), Annual C&D Collection Permit, and Site-Specific C&D Collection
Permits before performing any collection or disposal activities during the audit period.
2. Review all Certificates of Insurance (COIs) to ensure that coverage meets the requirements outlined in the city code and that Risk Management reviews the policy prior to the renewal of the Business Tax Receipt.
3. Compare the monthly reports submitted to the city with the contractor’s records to confirm
that the 20% sanitation fee was accurately calculated and remitted and that the payments
were submitted timely.
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4. Review whether the annual report was submitted timely and certified by a CPA (if
applicable)
FINDINGS AND RESULTS/RECOMMENDATIONS
FINDING 1: Under-reported gross receipts of $8,901.70 resulting in an underpayment of
$3,765.04, consisting of $1,780.34 in sanitation fees, $890.17 in penalties, $250.00 in Late
fees, and $844.53 in interest.
Condition: The auditor reviewed all provided sales documents for the 36-month period and found that the contractor had underreported six months' gross receipts by $8,901.70 compared with the gross receipts reported to the City.
Criteria: Section 90-278 - C&D haulers and other persons engaged in the collection or disposal of
construction and demolition debris with or without a grapple service, with or without the use of
C&D containers, using dump trucks, trailers of any kind, or any other heavy equipment shall submit 20 percent of their gross monthly receipts to the city. Section 90-278(5) - Monthly report. Each C&D collection contractor shall deliver to the city's
Finance department a true and correct monthly report of gross receipts generated during the previous month (from accounts within the city) on or before the last day of each month, regardless
of whether any work was performed within the city during that period…Failure to timely submit the monthly report on or before the last day of each month will result in a penalty as set forth in
Appendix A. Cause:
The contractor failed to include all applicable revenue in their monthly filings and did not properly reconcile their internal records with the reports submitted to the city.
Effect: Underreporting of gross receipts resulted in a $3,765.04 shortfall in revenue collected by the City, including penalties and interest, reducing funds available for sanitation services and potentially undermining the City’s trust in the contractor’s compliance.
Recommendations to the Contractor
• The contractor should review and strengthen its internal revenue tracking and reporting procedures to ensure that all gross receipts subject to the 20% sanitation fee are accurately
captured and reported monthly.
• The contractor should submit future monthly reports and payments by the statutory deadline
to avoid accruing penalties and interest.
Contractor Responses:
Refer to Exhibit A at the end of this report for the Contractor's responses.
Recommendations to the Finance Department: The Finance Department should invoice the contractor for the $3,765.04 underpayment found in
the audit, including unpaid sanitation fees, penalties, and interest. Prompt billing helps recover
City revenue and reinforces compliance. In addition, Monthly reports, regardless of whether any
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work was performed within the City during that period, should be date-stamped upon receipt to
ensure timely submittal. If a report is received after the due date, the Finance Department should
bill late submittal penalty. Finally, all reports, including the zero balance, should be posted in
Munis for future audit review.
Finance Department Responses:
The Finance Department will issue an invoice to the contractor in the amount of $3,765.04 in accordance with the final findings of the Office of the Inspector General (OIG). Finance processes monthly filings within one to two business days in Munis. The date stamped envelope is retained
by finance as proof of receipt. Finance is implementing a monthly notification process to inform the Public Works team of any waste haulers that filed late or failed to submit a monthly return. Unfortunately, the Munis system does not support a zero billing. Filing received with a zero-amount collected is notated on a monthly log. Public Works is responsible for billing any applicable late fees and/or penalties in accordance with each contractor’s individual contract. FINDING #2: BTR was renewed without risk management reviewing the insurance policy. Condition: The auditor reviewed the Certificates of Insurance (COIs) submitted throughout the audit process and noted that the policies did not meet the insurance requirements outlined in Section 90-196,
and that the contractor had incorrectly listed the Office of the Inspector General as the certificate holder. As a result, the auditor then requested that Risk Management personnel review the contractor’s COIs to validate the auditor's findings. Risk Management validated via e-mail that the
policy lacked both automobile liability and workers’ compensation coverage, and that the City of Miami Beach should be named as a certificate holder. In the description of operations section, it must state, “The City of Miami Beach is listed as an additional insured with regard to general
liability”. In addition, the auditor did not find evidence showing that Risk Management reviewed the contractor’s COIs prior to the renewal of the Business Tax Receipt (BTR). A previous sanitation audit had already identified that COIs were not being reviewed or approved by Risk Management. In response, the OIG collaborated with Risk Management and Finance Customer Service to establish a verification procedure prior to BTR renewals. Although Risk Management, Finance, and Information Technology planned to implement an automated review process in July 2025,
Risk Management confirmed on April 29, 2026, that the process had not yet begun. Therefore, there is no evidence that COIs were reviewed by Risk Management prior to any BTR renewals during the audit period from August 1, 2022, through July 31, 2025. Refer to OIG No. 25-01. Criteria: Section 90-196 of the City Code, Insurance required.
(a) Each private waste contractor must maintain throughout the entire effective period and/or
term of its business tax receipt and/or franchise agreement, whichever term is longer, the following required insurance coverage:
(1) Commercial general liability, in the amount of $1,000,000.00 per occurrence for bodily
injury and property damage. This policy must include coverage for contractual liability and specifically re-state the indemnity agreement set forth in section 90-195. The city must be named
as an additional insured on this policy.
(2) Automobile liability, in the amount of $1,000,000,00 per occurrence for bodily injury and property damage, covering all vehicles owned, leased or used by the contractor within the limits
of the city. The city must be named as an additional insured on this policy. (3) Workers' compensation and employer's liability, as required by state law.
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(b) All companies providing insurance shall be authorized to do business in the state and rated B+:VI or better by Best's Key Rating Guide, latest edition.
(c) No change or cancellation of any insurance coverage shall be made without 30 days'
written notice to the city's risk manager. (d) All required policies of insurance are intended to be primary coverage to any insurance or
self-insurance of the city possesses that may be applied to a loss resulting from the work
performed by the contractors pursuant to this chapter. (e) All policies shall provide full coverage from the first dollar of exposure. No deductibles will
be allowed in any policies.
(f) As evidence of the above required coverage, the contractor must provide original certificates of insurance to the city's risk manager, which must be approved by the risk manager
prior to the issuance of a business tax receipt, or the commencement date of a franchise
agreement, as the case may be. The contractor must submit a new certificate evidencing continuing or replacement coverage prior to the expiration date of the insurance policies and must
submit annually certified copies of the liability policies required in subsections (a)(1), (2). (g) The city manager reserves the right to increase the kinds and amounts of insurance
coverage required in this section, including the right to make periodic adjustments to the amounts
of required coverage for inflation. (h) Operation of activities by the contractor without the required insurance shall be grounds
for revocation or suspension of the contractor's business tax receipt and/or franchise agreement. Cause:
The Finance Department renewed business tax receipts (BTRs) each year without verifying that Risk Management had reviewed and approved the contractor’s Certificate of Insurance (COI) beforehand. This lapse occurred because the renewal process lacked a compliance checkpoint for insurance. Effect:
Because the City Code requirements were not followed during the business tax receipt renewal process, the contractor’s insurance status was not verified for compliance. This oversight exposed the City to liability risks if a contractor’s coverage was inadequate or invalid, and could lead to increased financial burdens and operational disruptions in the event of an incident involving an uninsured contractor.
Recommendations to the Contractor
Contractors should be reminded of the City Code Insurance Requirements and their responsibility
to submit updated COIs well ahead of expiration and renewal deadlines to avoid processing delays and ensure compliance with City Code requirements.
Contractor Responses:
Refer to Exhibit A at the end of this report for the Contractor's responses.
Recommendations to the Finance Department:
• The City should implement a formal checkpoint within the BTR renewal process that requires documented approval of contractors’ Certificates of Insurance (COIs) by Risk Management before any renewal is finalized.
• The Finance Department and Risk Management should collaborate to establish clear communication protocols, ensuring that COIs are routed, reviewed, and approved in
advance of renewal deadlines.
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• Additionally, system-based controls—such as those available in Energov—should be configured to prevent BTR renewal until Risk Management approval is recorded. Refer to the report Insurance Compliance Controls in BTR Renewals OIG 25-01
Finance Department Responses:
The Finance Department implemented a formal checkpoint within the BTR renewal process that requires documented approval of contractors’ Certificates of Insurance (COIs) by Risk
Management before any renewal is finalized. The Department established a procedure to place a hold on all BTR renewals requiring insurance verification. The Customer Service Team mails and emails BTR renewals to BTR holders requiring insurance verification. These BTR holders are
notified to upload their current COI. Reviews (BLPLs) are created annually in EnerGov for the BTR renewals requiring insurance review by Risk Management. The EnerGov Licensing Module will hold any BTRs not approved by Risk Management.
This process will ensure that COIs are routed, reviewed, and approved in advance of renewal
deadlines, preventing a renewal of a BTR requiring insurance verification until Risk Management approval is recorded. FINDING #3: No site-specific permits were requested for any of the 23 projects conducted during the audit period, resulting in a $2,300 loss of revenue.
Condition: During the audit period, a review of all jobs performed within the city was conducted to confirm that site-specific permits were obtained before any work commenced. The auditor identified that the contractor completed 23 projects without securing the required site-specific permits.
Criteria:
According to Section 90-276(b) of the City Code, states All C&D haulers or persons providing
C&D removal services shall obtain a separate, site-specific C&D collection permit for each project
involving new construction or the demolition of an existing structure. Such permit shall be
prominently posted at the job site at the same location that other permits are maintained for
inspection for the duration of the project. The cost for such site-specific permit for new construction
and/or demolition projects shall be $100.00 to cover the city's annual administrative and
processing costs. The rate in appendix A pertaining to this subsection will be administratively
adjusted annually by the city manager, effective October 1 of each year, to reflect increases in
the Consumer Price Index for the Miami-Fort Lauderdale-West Palm Beach, Florida area,
pursuant to subsection 1-15(b) of the City Code. Each C&D hauler shall also pay the applicable
fees set forth in section 90-278 based on monthly gross receipts in respect of the project
concerned. Failure to obtain a site-specific permit for a project involving new construction or the
demolition of an existing structure will result in a penalty of $1,000.00.
Cause: The contractor's failure to comply with the City Code requirement to request and obtain site-
specific permits prior to commencing work. Effect: The absence of site-specific permits increases the risk of improper waste disposal and limits the City’s oversight of safety and environmental regulations. Additionally, the lack of required permits resulted in an estimated financial loss of approximately $2,300 (23 sites × $100 permit fee each).
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As per Section 90-276(b), the cost of such a site-specific permit for new construction and/or demolition projects shall be $100.00 to cover the city's annual administrative and processing
costs.
Recommendation to the Contractor:
The contractor should not engage in C&D collection without the appropriate site-specific permits.
Contractor Responses:
Refer to Exhibit A at the end of this report for the Contractor's responses.
Recommendations to Code Compliance: Code Enforcement should maintain ongoing monitoring of C&D activities to ensure proper permitting compliance across the city. Additionally, Code Enforcement should conduct C&D
collection inspections citywide, with recurring violations triggering escalated enforcement actions and immediate penalties for noncompliance.
Code Compliance Response:
The Code Compliance Department appreciates the opportunity to respond to Finding #3 regarding
the contractor’s failure to obtain required site-specific C&D collection permits. Under Chapter 162,
Florida Statutes, enforcement actions brought before the Special Magistrate must be based on
competent, substantial evidence supported by a personal investigation or independently verified
documentation. Because of these standards, Code Compliance may issue violations for missing
site-specific permits only when officers directly observe unpermitted activity or confirm it through
reliable evidence consistent with Chapter 162 procedures.
The audit found that Royal Dumpsters completed 23 projects without obtaining the required site-
specific permits, each of which carries a $1,000 penalty under Section 90-276(b) and represents
a $100 lost permit fee per job. While the Department acknowledges this finding, enforcement
cannot be applied retroactively when no officer witnessed the violation at the time of the activity.
Historical audit findings, by themselves, do not meet the evidentiary threshold required for a
Notice of Violation.
It is also important to note that in previous cases involving this same violation type, the Special
Magistrate has exercised discretion to waive or reduce fines, particularly when contractors later
demonstrated compliance or when the evidentiary burden was not fully satisfied. These outcomes
highlight the need for strong field documentation to ensure future cases can withstand Magistrate
review.
Moving forward, Code Compliance will continue strengthening monitoring of C&D activities by
expanding proactive inspections, improving coordination with other departments, such as Building
and Sanitation, to identify active job sites, and conducting recurring demolition permit compliance
sweeps. Consistent with Chapter 162, Notices of Violation will be issued immediately when
officers personally observe unpermitted C&D operations.
All written responses received by the OIG from affected persons or entities related to the
disbursed draft report were included in this final report, in accordance with Section 2-256(h) of
the City of Miami Beach Code. In its attached response, the contractor has accepted the findings
contained in this report and has indicated an intention to improve its compliance in the future. It
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has also requested that the City compromise on the interest and penalties assessed in this audit.
The OIG has no authority to do so. The City Finance Department may take the request under
consideration.
Respectfully submitted,
_________________________________________ ______________ Joseph M. Centorino, Inspector General Date _________________________________________ ______________ Norman Blaiotta, Chief Auditor Date cc: Eric Carpenter, City Manager David Martinez, Assistant City Manager John Norris, Public Works Department Director
Marla Alpizar, Human Resources Director Alvaro Rueda, Interim Sanitation Division Director Jason Greene, Chief Financial Officer
Hernan D. Cardeno, Esq., Code Compliance Department Director Jared Pilch, Manager, Royal Dumpsters, LLC.
OFFICE OF THE INSPECTOR GENERAL, City of Miami Beach 1130 Washington Avenue, 6th Floor, Miami Beach, FL 33139 Tel: 305.673.7020 • Hotline: 786.897.1111 Email: CityofMiamiBeachOIG@miamibeachfl.gov Website: www.mbinspectorgeneral.com
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Jared Pilch
Manager, Royal Dumpsters, LLC.
Exhibit A
Dear Inspector General Centorino and Mr. Blaiotta,
Thank you for the opportunity to respond to the Draft Audit Report dated June 15, 2026
regarding Royal Dumpsters, LLC.
We accept the findings and are prepared to pay the fees owed -the $1,780.34 in sanitation
fees. We will also promptly correct our Certificate of Insurance to meet Section 90-196 and
submit it to Risk Management for review. At this time we ask for your consideration to show
leniency by decreasing the amount requested or eliminating these penalties & interest charges
as a onetime offer so we can continue to work together in the City of Miami Beach, with
everything going on in the world every little penny we can save in cost really goes a long way to
help us operate during these difficult times.
The underreporting and missed permits were not intentional. We were unaware of the
requirements at the time, and as soon as we understood our obligations we obtained the
proper documents and now file our monthly reports accurately and on time.
As a small business acting in good faith, we respectfully ask the City to waive the penalties, late
fees, and interest ($1,984.71). We value our relationship with the City of Miami Beach and are
committed to full compliance going forward. We're·happy to discuss a resolution at your
convenience.
~R•~rJ
Jared Pilch
Manager, Royal Dumpsters, LLC.
Exhibit A
Dear Inspector General Centorino and Mr. Blaiotta,
Thank you for the opportunity to respond to the Draft Audit Report dated June 15, 2026
regarding Royal Dumpsters, LLC.
We accept the findings and are prepared to pay the fees owed -the $1,780.34 in sanitation
fees. We will also promptly correct our Certificate of Insurance to meet Section 90-196 and
submit it to Risk Management for review. At this time we ask for your consideration to show
leniency by decreasing the amount requested or eliminating these penalties & interest charges
as a onetime offer so we can continue to work together in the City of Miami Beach, with
everything going on in the world every little penny we can save in cost really goes a long way to
help us operate during these difficult times.
The underreporting and missed permits were not intentional. We were unaware of the
requirements at the time, and as soon as we understood our obligations we obtained the
proper documents and now file our monthly reports accurately and on time.
As a small business acting in good faith, we respectfully ask the City to waive the penalties, late
fees, and interest ($1,984.71). We value our relationship with the City of Miami Beach and are
committed to full compliance going forward. We're·happy to discuss a resolution at your
convenience.
~R•~rJ
Jared Pilch
Manager, Royal Dumpsters, LLC.
Exhibit A
Dear Inspector General Centorino and Mr. Blaiotta,
Thank you for the opportunity to respond to the Draft Audit Report dated June 15, 2026
regarding Royal Dumpsters, LLC.
We accept the findings and are prepared to pay the fees owed -the $1,780.34 in sanitation
fees. We will also promptly correct our Certificate of Insurance to meet Section 90-196 and
submit it to Risk Management for review. At this time we ask for your consideration to show
leniency by decreasing the amount requested or eliminating these penalties & interest charges
as a onetime offer so we can continue to work together in the City of Miami Beach, with
everything going on in the world every little penny we can save in cost really goes a long way to
help us operate during these difficult times.
The underreporting and missed permits were not intentional. We were unaware of the
requirements at the time, and as soon as we understood our obligations we obtained the
proper documents and now file our monthly reports accurately and on time.
As a small business acting in good faith, we respectfully ask the City to waive the penalties, late
fees, and interest ($1,984.71). We value our relationship with the City of Miami Beach and are
committed to full compliance going forward. We're·happy to discuss a resolution at your
convenience.
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