Rigid Plastic Packaging Container(RPPC) Recycling Rates Board Meeting April 13, 2004 Cal/EPA California Integrated Waste Management Board Waste Prevention & Market Development Plastic Recycling Technologies Contact: Sue Ingle or

ALL of the following: made entirely of plastic; relatively inflexible, capable of maintaining its shape; Between eight ounces and five gallons Definition of an RPPC

Rigid Plastic Packaging Containers Regulated:Non-Regulated: - soap, detergent- soda, beer, water - clamshell packaging- food, drugs, (non-food) cosmetics -oil, gas additives- hazardous materials, pesticides, floral

RPPC Compliance Methods 1. 25% All Container Recycling Rate 2. 55% PET Container Recycling Rate 3. 25% Post Consumer Resins (PCR) used in manufacture of container 4. 10% Source Reduction (SR) of resins in manufacture of container 5. Container meets criteria for Reuse or Refill [Title 14 CCR (3)]

Use of Existing Methodology No Longer Feasible Data Adjustment Issues: – Data sources now include Canada and Mexico – Differences in use of RPPCs by region Data not published in format or timeframe: – Can not accurately disaggregate for RPPCs – No import data – Not published in time to meet commitment to provide advance notice

Board Directed Workshop February 5, 2004 Workshop! Objectives: 1. Understand Methodology limitations 2. Forum for discussing solutions 3. Obtain stakeholder feedback

Methodology Criteria: Methodology Criteria:  Based on independent sources of California specific data,  Accurate, precise and independently verifiable,  Measure effectiveness of the law,  Cost effective

Stakeholder Feedback Stakeholder Feedback 1.Remove Recycling Rates: – Support: 5 (Recyclers/Environmental Groups) – Oppose: 7 (Industry, Manufacturing Lobbyist) 2.Oregon’s Methodology – Support: 10 (Industry, Manufacturing Lobbyist) – Oppose: 5 (Recyclers/Environmental Groups) 3.Other Recommendations: 1. Disposal-Base Calculation 2. All-Plastic Recycling Rate 3. Landfill Ban

Rating by Methodology Criteria: Criteria Rating: Option 1Option 2 Option 3Option 4 CA Specific Data N/AYes Accurate, Precise N/AYes No Measures Law N/ANoYesNo Cost Effective YesNo Statutory Change YesNoYes Certifications YesMaybeYesMaybe

Option 1: Eliminate the All-container and PET recycling rates as com- pliance options and pursue statutory changes to existing RPPC law. Pros: Cost and resource effective Supports intent RPPC law Streamlines implementation of RPPC law Doesn’t depend on data collection Supported by recycling community Cons: Requires statutory change Eliminates recycling rates as compliance options Not supported by industry (annual certifications)

Option 2: Adopt “Oregon’s” Methodology for calculating Recycling Rates. Pros: No statutory change needed California specific, accurate and precise rates Supported by industry Maintains historical recycling measurement Cons: Very costly Staff intensive Doesn’t measure effectiveness of RPPC law Opposed by recycling community

Option 3: Adopt “Oregon’s” Methodology for calculating the All- container and PET recycling rates for Regulated containers Pros: Effectively measures RPPC law California specific, accurate and precise rates Maintains historical recycling measurement Cons: Very costly Staff intensive Requires Statutory Changes Opposed by recycling community

Option 4: Adopt Methodology using a disposal based methodology, similar to calculation as used by local jurisdictions for AB 939 diversion Pros: Uses Ca. data Cons: Very costly & staff intensive Requires statutory Changesc Requires a base year to measure disposal changes Not precise nor accurate Doesn’t measure effectiveness of RPPC law

Costs and Task Analysis: Annual CostsOption 1Option 2Option 3Option 4 Add. Staff$0 $100,000 $50,000 PR Survey$0 $40,000 $0 RC Study$0 $100,000 $0 WC Study$0 $150,000 TOTAL $0 $290,000$400,000 $ 200,000

CONCLUSION CONCLUSION Staff can not calculate accurate and timely rates under the current methodology. – Data problem has been ongoing Based on Criteria- staff recommends the Board Adopt Option 1, and support current legislation to eliminate the “all container” and PET recycling rates from the RPPC law.

Recycling Rates